Amid all the talk of a ‘Teaching Excellence Framework’ (TEF), a consultation on Quality Assessment (QA) launched by the Higher Education Funding Council for England (HEFCE) on behalf of all UK funding councils has received considerably less attention. But academics, students and others should be paying close attention because HEFCE’s proposals are clearly intended both to soften up the sector for the TEF and – more importantly – spur its hitherto partial marketisation.

I have written a response to the consultation, with very useful input from Meera and from John Holmwood, cofounder of the Campaign for the Public University. You can read the full thing here (it is signed by 50+ other academics). There is still a little time to associate yourself with the document if you wish (email me directly by 18 September). Below I highlight the core points, and in a follow-up post I also provide an open letter that colleagues can sign to oppose the worst aspects of these plans, which are also likely to be reflected in the proposals for a TEF, expected later this autumn.

QA is the process by which higher education institutions (HEIs) guarantee the quality of their teaching and qualifications. As I’ve said elsewhere, UK HE combines the worst aspects of the market with the worst aspects of Soviet-style bureaucracy. Reflecting this, QA is presently heavily regulated, imposing massive burdens and costing the sector over £1.1bn annually, 8.8% of the total teaching budget. QA is currently undertaken by vast bureaucracies internal to HEIs, with the associated policies, routines, meetings and dreaded ‘periodic reviews’ of departments and programmes, coupled with heavy inspections from the Quality Assurance Agency (QAA) every six years.

HEFCE proposes quite a radical shake-up of these arrangements. Its proposals are very complex, but here are the main ideas:

• The funding bodies will shift from assessing quality directly to merely certifying HEIs’ own internal QA processes as meeting a ‘baseline quality’ threshold. This is described as a ‘light touch’ approach that would supposedly reduce the regulatory burden. The proposals are open-minded about whether any routine checks would ever be conducted once HEIs are certified with a proposed ‘kite mark’. HEIs’ governing bodies, which would assume overall responsibility for quality, would merely certify their ongoing compliance in annual reports. The QAA is apparently to be scrapped. But funders would ‘intervene’ rapidly if there is suspicion of a collapse in standards.
• Internal QA would be guided by data on ‘student outcomes’, presented in an easy-to-follow format (though the proposals, for now, eschew ‘star ratings’ – that’s probably for the TEF). The proposed goal is ‘constant improvement’. This is presented alongside contradictory goals like curbing grade inflation. This is perhaps the most problematic aspect of the proposals, as discussed further below.
• The system of external examiners would be ‘professionalised’ (which assumes we are not already professionals). Externals would be trained and accredited by some additional body. While this is not quite an ‘OFSTED’ for HE, the tendency of the bureaucracy to expand to meet the growing needs of the bureaucracy means it could well evolve into an external inspectorate. At the very least it means external examiners are likely to become progressively divorced from the activities they are meant to be judging.
• To help curb grade inflation, there are also calls for internal and external examiners to form (inter-)disciplinary groups to develop shared assessments of work – a sort of nationwide moderation process. The idea is to help police the pass/fail and 2(i)/2(ii) borderlines. Anyone who has ever marked assessments (i.e. virtually no one at HEFCE) will know that even expert judgements within a single department can vary substantially, but the notion here is that hundreds of academics working within very different traditions and environments with very different learning objectives can somehow agree definitively what constitutes a ‘59’ and what constitutes a ‘60’. At the very least, coupled with ‘professionalised’ external examination, this is likely to create pressures for curriculum standardisation.

Readers will already appreciate some of the many things that are wrong with these proposals. These are described at length in the response to the consultation. In brief, it is obvious that this is not a ‘light touch’ regime at all. The amount of overt regulation and inspection that occurs between the funding bodies and HEIs will obviously be diminished. But the proposals would merely displace regulatory activity from this space into HEIs themselves and into new regulative spaces such as the external examiner accreditation and macro-moderation bodies (which, of course, HEFCE does not wish even to fund). The proposals acknowledge that there is massive over-compliance with existing regulations, with extensive costs for HE, but basically blames risk-averse ‘compliance professionals’ and hopes the new regime would reduce costs. It does not acknowledge that self-regulation in an era of markets always fuels over-compliance because of its inherent vagueness and because the reputational costs of non-compliance are potentially disastrous – as London Met’s brush with the immigration regime amply demonstrates. The reality is that the proposed new QA regime would only increase the already enormous regulatory burden.

But perhaps what is not immediately apparent is the way that these proposals seek to extend the marketisation of UK HE. In adopting the recommendations of the Browne Review, the former LibDem/Tory coalition government sought to create a market in HE by establishing various ‘signals’ for consumers to follow. Although the cap on fees was lifted to £9k, universities were expected to compete on price, driving ‘efficiency’. The provision of ‘Key Information Sets’ including earnings data for degree programmes would enable ‘consumers’ to make the ‘right’ choices about how to ‘invest’ in their ‘human capital’. The assumption was that students would only be willing to pay high prices for a high ‘return’ on their ‘investment’. Universities would accordingly be pressured into maximising the employability of graduates. Degree programmes that failed to generate a ‘return’ – whether low-quality courses at weak institutions, or the less remunerative arts and humanities degrees – would become less popular than higher-yielding (STEM) subjects, driving down their ‘price’. Through the magic of the market, higher quality and more ‘worthwhile’ institutions and subjects would expand (and possibly even get higher fees), while lower-quality universities and ‘irrelevant’ subjects would contract.

Of course, what has happened bears little relation to the market-makers’ neoliberal dreams. Universities overwhelmingly declined to compete on price, with virtually all HEIs charging at or near the maximum £9,000 (unsurprisingly, as this barely covers the costs of teaching students). Meanwhile, students have steadfastly declined to ‘maximise their human capital’ by undertaking more remunerative degrees, with the arts and social sciences continuing to thrive. Even when the cap on student numbers was lifted, most HEIs declined to expand at the expense of their ‘competitors’. Facing massive uncertainty and instability, they have typically played it safe, hoarding cash and expanding cautiously, if at all.

Reading between the lines, it is clear that HEFCE’s QA proposals are an effort to disrupt this status quo by lowering barriers to ‘market entry’ for private providers and thereby trigger the price competition that has so far largely failed to materialise. HEFCE seeks to do this in two ways.

First, by relativising the notion of ‘quality’. HEFCE states that because there is growing ‘diversity of providers, provision, and students’, we should abandon a ‘one size fits all’ approach to quality. It suggests that ‘there are “student experiences” – and therefore different conceptions of “quality” – that could and should be determined by the mission of the provider, the type of provision, and the needs of the student.’ This is the logic of assessing HEIs only against a minimum ‘baseline’: once this is met, it is up to HEIs to determine what ‘quality’ actually means.

The second measure is to make it easier for ‘new providers’ to attain and retain their accredited status. Rather than being exposed to ongoing inspections by the QAA, all they would need to do is demonstrate compliance with a low baseline and then self-certify thereafter (with or without a ‘probationary’ period included in the proposals). This would make it easier for ‘new providers’ to acquire degree-awarding powers and not be dependent on established universities to accredit their qualifications.

The obvious rationale of all this is to deflate the notion of what constitutes ‘quality’ higher education in order to allow private providers who cannot meet current standards to enter the market. An example of what is presumably envisaged is Coventry University College Ltd (CUCL), a subsidiary of Coventry University. CUCL offers part-time degrees in vocational areas like law and accountancy. Its staff teach 40+ weeks per year and consequently are not engaged in research; most are not ‘academics’ but merely ‘deliver’ teaching. It students are denied access to facilities afforded to Coventry University students, like library borrowing rights or participation in the student union – justified explicitly on the grounds that such things are ‘added extras’ and not all students want the same ‘student experience’. As a result of shaving its provision and costs to the bone, CUCL charges fees below £6,000 per year.

Obviously, HEIs like CUCL, or its longer-established private counterpart, the University of Law, could potentially multiply rapidly if the existing quality threshold was lowered, because the costs of provision – and associated QA processes – could (in theory) be cut substantially. ‘New providers’ would be enabled to undercut existing ones on price, triggering the price war that David Willetts always hoped to unleash.

The problems with this are obvious, but let’s rehearse a couple. There is no reason to believe that price competition will benefit students or have any beneficial impact on quality. The whole logic of these proposals is to destroy an existing notion of ‘quality’ HE, defined by tough regulation and the historic culture of British universities, and introduce a variety of possible definitions of ‘quality’, some lower than the current definition. What is called a set of proposals on ‘quality assessment’ actually seeks to reduce average quality. This is a deliberate attempt to usher in a multiple-tier HE system with HEIs having ‘different missions’ and ‘different students’. It is already widely understood that UK HE is already at the very least two-tier, with many students from non-traditional backgrounds funnelled into weaker institutions. HEFCE’s proposals seek to legitimise and exacerbate this division. Their implication is clearly that it should be acceptable for some students to opt for cut-price, low-quality HE if it meets a low baseline standard, and the low expectations of their particular ‘consumers’.

This has been the norm in the US for many years, resulting in many students from underprivileged backgrounds receiving cut-price, low-quality HE that does not even qualify them for their chosen field of employment. Despite increasing numbers of lawsuits from disgruntled students, these ‘sub-prime’ HEIs do not care because they have already received fee income from federally-backed student loans – repayment of which occurs through the sequestering of wages and cannot be annulled even by bankruptcy. The situation resembles a gigantic Ponzi scheme and has been condemned by the US Senate.

Quite apart from the impact on students, these proposals could easily destabilise many existing HEIs. In the National Health Service under Tony Blair, General Practitioners were required to offer patients requiring hospital treatment a choice of venue, including at least one private provider. This was a deliberate attempt to transfer market share to the private healthcare industry. Private providers have specialised in providing operations with the maximum difference between cost and ‘tariff’ (the price paid to them by the NHS), like ear, nose and throat operations. They eschew complex, costly operations like heart bypasses, leaving these – and the often very expensive costs of post-operative care – to NHS providers. This cherry-picking has drained remunerative work out of the NHS while leaving it with costly burdens, undermining the financial sustainability of many hospitals. The same could happen in HE, with private providers specialising in cheap-to-provide vocational courses that are attractive to students seeking remunerative post-graduation employment. This will drain established HEIs of income that they currently use to cross-subsidise more expensive subjects. Outside of Oxbridge it is generally accepted that humanities and social science subjects cost less than £9,000 per year to teach, but many science subjects cost substantially more, with costs not being covered by the remaining government subsidies for STEM subject teaching (which have in any case been cut this year by HEFCE). If universities are forced to compete on price, or lose market share, this cross-subsidy may become impossible and render many departments financially unviable. Moreover, it goes without saying that this price competition could only be pursued by worsening the wages and conditions of staff.

A final highly problematic element of the proposals is the use of data on ‘student outcomes’ as a proxy measure for teaching quality. The reasons why this is wrong are outlined in the open letter in the next post, which all academic colleagues are invited to sign.