MeCCSA response to OfS Consultation on regulating quality and standards in higher education

MeCCSA prepared and submitted a response to the consultation from the Office for Students (Ofstud) on ‘regulating quality and standards in higher education’.  The response questioned the emphasis in the consultation paper on using salary levels and managerial and professional employment figures as proxy indicators of the value of HE programmes, and pointed out the irrelevance of such data for many of the fields of interest to our students, in that their entry was often some time after graduation, and, more fundamentally, this was based on a very limited and ‘skills training for employment’ conception of higher education which was both intellectually shallow and counter to the aspirations of both students and staff. It also took little or no account of the rapidly changing nature of technology and skill sets in many fields. 

Full response below.

Questions relating to proposal 1  

Question 1a: Do you agree or disagree with the proposed definitions of “quality” and “standards” set out in Table 1 of Annex A and that this should be used to express minimum baseline requirements for quality and standards in revised B conditions 
We are wholly opposed to the approach to quality and standards suggested here. A great deal of thought and discussion went into this when the QAA Subject Benchmark Statement for our field was developed (published as recently as December 2019 these describe the nature and content of study and the academic standards expected of graduates in specific subject areas. They show what graduates might reasonably be expected to know, do and understand at the end of their studies, and set out detailed standards for what are termed threshold and typical levels (

We also find the emphasis on the use of outcomes as measured by such indicators as salaries and employment in professional and managerial positions utterly misguided. This misunderstands the purpose of much of higher education as expected by providers, students, and indeed employers. That purpose is to impart understanding and knowledge that can be applied and adapted. There are thus two radical and objectionable misunderstandings. Firstly, higher education is not a form of skills training. It may well, and indeed should, deliver skills and knowledge but of a generic kind that may be applied in a variety of settings. Secondly, in fields such as those taught by our members and studied by our students, practice and knowledge are changing rapidly. What is applicable and valued today may well be redundant in a couple of years, and certainly is likely to be in time. 
Question 1b: Do you have any comments about how the proposed definitions of quality and standards set out in Table 1 of Annex A should be assessed for individual providers? 
See comments above. The definitions of quality and standards make no mention of those developed in the QAA Subject Benchmark standards, and assessment of them is calibrated in terms of inappropriate outcomes rather than intrinsic values. 
Question 1c: Do you agree or disagree with the proposal in paragraphs 41 to 43 to express initial requirements differently from the equivalent ongoing requirement for providers seeking registration? 
See above

Questions relating to proposal 2  

Question 2a: Do you agree or disagree with the proposed approach to assessing student outcomes set out in Annex B? 
In addition to the general points above we would also note
1. Many of our students move into employment in a variety of fields where some time elapses before they acquire ‘managerial and professional’ posts or salaries. Agcas and similar data shows very high employment rates in early periods after graduation but not always in what later become career paths. This would make the data intended for use here both difficult to obtain, but also misleading.
2. Students in the fields we teach enter a very wide variety of occupations where their skills and knowledge of media, communications, and culture serve to make them valuable contributors whether very specifically related to their studies or not.
Question 2b: Are there any other quantitative measures of student outcomes that we should consider in addition to continuation, completion and progression (see Annex B paragraph 18)? 
We are puzzled by the lack of reference in the consultation document to the many other relevant materials arising from the QAA, REF, TEF and so on. 
Question 2c: Do you agree or disagree with the proposals for the levels of study at which indicators should be constructed? Should any additional indicators be considered (see Annex B paragraph 25)? 
Neither agree nor disagree 
Question 2e: Do you agree or disagree with the demographic characteristics we propose to use (see Annex B paragraph 36)? Are there further demographic characteristics which we should consider including in the list of “split indicators”? 
Neither agree nor disagree 
Question 2f: Do you agree or disagree that the longitudinal educational outcomes dataset should be used to provide further indicators in relation to graduate outcomes (see Annex B paragraph 46)? 
Neither agree nor disagree 

Questions relating to proposal 3  

Question 3: Do you agree or disagree with the proposals in Annex C for monitoring ongoing compliance with regulatory requirements for quality and standards? 
Neither agree nor disagree 

Questions relating to proposal 4  

Question 4: Do you agree or disagree with the proposals in paragraphs 86 to 101 for our approach to intervention and gathering further information about concerns about quality and standards? 
We are concerned that nothing is mentioned about the obligation of institutions to provide resources, or for said resources to be of a high enough standard to maintain provision. There is a term often used in HE, wherein “resources follow recruitment”. It should be an explicit requirement for institutions to deliver core resources once they enter into the recruitment cycle. This often has an impact on retention and low rates of continuation.  
The various implications of widening participation have also had an impact on the sector with regards to support mechanisms and student retention. In recent months of course, this has been even more noticeable, yet, even over the last five years, students have become increasingly reliant on HEI’s for both pastoral support and for wider student services such as counselling and mental health. 

Questions relating to all proposals  

Question 5: Do you have any comments about any unintended consequences of these proposals, for example for particular types of provider or course or for any particular types of student? 
For creative programmes this is a problematic set of proposals. While generic outcomes such as understanding the political, economic, cultural, or social contexts of a given artefact are relatively timeless – fast-moving fields (such as computer games, vfx, online communications) tend to age rather quickly. While there are numerous underpinning principles, to focus unduly on specifics would open providers up to criticism where employers and individuals should be committed to lifelong learning and CPD as well. 
Question 7: Do you have any comments about where regulatory burden could be reduced? 
We share a concern about improvement in and support for the recruitment and retention of under-represented groups. However, there seems to be an emphasis here on this being the sole concern of HE providers. How will compulsory and tertiary providers prepare candidates from underrepresented groups for Higher Education? Similarly, the notion of disproportionate levels of progression either towards work or within employment indicates that employers should also share the responsibility for providing access to equal opportunities. On the one hand, historically there has been disproportionate representation of race and gender within the creative sector – both in terms of pay and employment. If we are looking at progression to managerial or senior posts, that could also take up to ten years from graduation and entry-level roles. So how are these metrics gathered, by whom, and based on what evidence? The regulatory and resource implications for all sectors, not only HE, need to be considered here. 
Question 8: Do you have any other comments? 
A major concern relates to para 56c which says “Low rates of progression into employment and higher level study destinations commensurate with the qualification they have completed may suggest that a course has not equipped students with knowledge and skills appropriate to their intended learning aims, or that students were not effectively supported to transition into the workplace.” This fundamentally conflicts with appropriate measures of student intentions, not least the notion of “destinations commensurate with the qualification they have completed” – qualifications obtained in HE are not, in the main, narrowly skills based nor should they be. 

Para 70 suggests the proposals are needed to ensure public confidence in the efficacy of public funding. However, we regard this justification as itself rooted in a presumption that HE outcomes must only be defined inn line with employment., and a rather specific set of employment indicators at that. 

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