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In defence of bureaucracy

  • 11 September 2020
  • By Rachel Hewitt

I have been concerned what plans to reduce bureaucracy will entail, since the restructuring regime was published in July, accompanied by a sentence ‘For our part, we are actively considering how to reduce the burden of bureaucracy imposed by Government and regulators’. I appreciate many in the sector may not share my view, but I think talks of reducing bureaucracy in higher education can be cause for concern.

The newly published guidance on plans to ‘reduce bureaucratic burden’ has done nothing to assuage my concerns. The plans are far-reaching and include:

  • cutting Office for Students (OfS) registration costs;
  • reconsidering the scope of the Data Futures project (which was meant to bring more timely data on students);
  • reviewing TRAC (transparent approach to costing); and,
  • efficiency savings at the OfS, Higher Education Statistics Agency (HESA) and Quality Assurance Agency (QAA).

However, the most substantial element is a ‘radical, root and branch review’ of the National Student Survey (NSS).

The accompanying text on the National Student Survey (NSS) is damning. It describes concerns that ‘good scores can more easily be achieved through dumbing down and spoon-feeding students, rather than pursuing high standards and embedding the subject knowledge and intellectual skills needed to succeed in the modern workplace’ and that the ‘extensive use of the NSS in league tables may cause some students to choose courses that are easy and entertaining, rather than robust and rigorous’. One of the aims of the review is set as ensuring the survey ‘provides reliable data on the student perspective at an appropriate level, without depending on a universal annual sample’, implying that the survey should no longer be based on a survey of all final year students but a smaller sample.

There will be many in the sector who cheer the news of the role of The National Student Survey being limited. Indeed there is fair reason to criticise the survey, which has been found to be biased against female lecturers for example. The sector’s own criticism of the NSS is referenced in the Government’s guidance ‘Academics have also criticised the cost and bureaucracy the NSS creates, arguing that the level of activity it generates can be a distraction from more important teaching and research activities.’ However, my concerns are that the reduction of the NSS will only lead to a reduction in the student voice in policymaking and decisions being based more on political will (which does not currently seem favourable to universities), than on a solid evidence base. What is not clear, is what would replace the substantial role of the NSS to provide Government with information on student satisfaction and inform student choice.

We are still yet to see what will come from the review of the Teaching Excellence Framework (TEF), due to be announced alongside a spending review which may be postponed until next year. It may be that the review of the NSS, which is due to conclude by the end of the year, may report before the review of TEF. But again, while many would cheer the downfall of the Teaching Excellence Framework, at least the exercise uses a basket of metrics alongside contextual information to make judgements. If the TEF were to be lost or reduced, Government may rely on single measures, such as graduate salaries to make judgements about the ‘value’ of universities.

As I learnt during my years at HESA, good quality data is bureaucratic. There are whole teams of staff in universities across the country whose jobs are to ensure we have robust data about students, graduates, staff, university finances and others. It is entirely fair to critically assess the data Government are using to form judgements about higher education. However, if we want our policy making to be based on evidence, my takeaway from these changes is that we need to engage with what data we do want Government to be working on, rather than only criticising the existing metrics.


  1. Andrew Fisher says:

    It isn’t true that the NSS is biased against female teachers is it? That bias exists in individual module- or teacher-level surveys, but the NSS asks students to assess their whole study experience.

    I agree with your broader point though. Reducing bureaucracy by increasing chaos does not in fact make anyone’s life easier.

  2. Andy says:

    The government is right that the NSS doesn’t measure quality. I think the solution is to acknowledge what it does measure – satsifaction with experience – and use it accordingly. It makes for poor targets (e.g. ‘we must be 7 better’, as a University SMT might ocassionally request), but it isn’t a bad tool for identifying potentially concerns – if your students are really unhappy with their feedback (and you can benchmark this by subject etc, to give a decent sense of how your student satisfaction compares to the satisfaction of similar students), that is something worth investigating.

    There’s more than one set of alarm bells rung in the DfE statement. Abolishing the NSS (as it is now) is no blow against managerialism and neo-liberalism (as I’ve seen a few people celebrating it) if its place is taken (as outlined) by greater emphasis on graduate outcomes, continuation rates and grade inflation; NSS is not a measure of quality, but it is highly misleading to suggest that continuation and graduate outcomes (measures which owe a lot to a student’s background) are instead, and they reduce the purpose of a University education to a purely (and short-term) economic exercise. A new NSS asking more tailored questions (aligned to DfE priorities – so value-for-money and the alleged suppression of conservative viewpoints?) is an opportunity to hammer the sector much more directly; placing significant emphasis on graduate outcomes seems a good way of enabling the government to close courses it perceives to be of limited (economic) value, and therefore better direct University teaching (circumventing the protections on institutional autonomy otherwise enshrined in law). Bringing Grade Inflation to the fore might help with a floated shift towards norm (rather than criterion) referencing, so presumably the sector can look forward to something more like the recent A-level debacle happening in HE. I also enjoyed seeing debateable (‘since 2005 … NSS .. downward pressure on standards’) and incorrect (you can’t use NSS to take action at a modular level, as NSS does not provide information at the modular level) statements presented as fact (which doesn’t necessarily reassure me that this is a particualrly evidenced-basd piece). It’s also bizarre to see *this* government complain about universities using analysists to review data – that is surely a good thing.

    This is all dressed up as a reduction on Bureaucracy – a helpfully crowd-pleasing and populist aim – but, while I’d welcome a reduction in the onerous (and increasing) requirements which the OfS has put in place, I don’t think these proposals will be good for the sector, and they certainly don’t look good for the kind of University – with high NSS, a WP-focus but comparatively (if understandable) lower rates of retention and graduate-level jobs – which the current government doesn’t seem to like.

  3. Perplexed says:

    The NSS will be shelved.
    The TEF will be shelved.
    Eventually, the REF will be shelved.

    The government will reintroduce discretionary, direct funding for universities. Both of them.

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