Ashley Wheaton (@UCEM_Principal) is Principal of the University College of Estate Management. He has previously held senior roles as Director of Global Learning Services for Microsoft, and Chief Executive Officer of InfoBasis Ltd, a global talent management software company.
The issue of regulatory burden is never far from the surface of debate in higher education and the Office for Students (OfS) have recently published their key performance measure on this topic, which declares that they are ‘making progress in minimising regulatory burden.’ While this focus on regulatory burden from the higher education regulator is welcome, the experience on the ground where HE and skills meet paints a very different picture.
The over-burdensome requirement to continually and repeatedly show the OfS evidence of compliance with the conditions of registration appears to do very little to enhance the student experience. Being subjected to a regime which by design is aimed at the lowest common denominator in higher education stifles the work which should be going into innovation and further enhancement of the student experience, particularly for smaller institutions, where resources are inevitably spread more thinly. Intelligent and useful regulation requires a tangible understanding of the nature and impact of the burden it imposes on providers and, in my opinion, the OfS needs to develop this substantially more by engaging with institutions and learning directly from their experiences, rather than through the endless process of formal consultations (which in themselves are arduous).
The decision to appoint Ofsted as the monitoring body for Degree Apprenticeships now means that universities which are supporting industry and the Government’s agenda for more technical and vocational skills are subjected to an inspection model which does not feel like a particularly good fit for higher education’s purposes (even if it ever was for the rest of the education sector?). Applying the existing tactics of 48 hours’ notice to the provider (and therefore also its in-work apprentices and employers) seems anathema in higher education where students are typically on programme for five years when undertaking an undergraduate degree apprenticeship, and therefore a full assessment of the quality of provision cannot be easily understood or evaluated with such scant pre-visit preparation, or the ability to view more than a simple snapshot in time. We are very comfortable that our apprenticeship provision should be inspected, but I would argue that an opportunity was missed to more comprehensively overhaul the Inspection Framework through a clearer directive from the Department for Education to ensure it was adapted and made properly fit for purpose for higher education providers.
Most notably, I believe a considerable amount of pre-inspection work could be carried out through a desk-based approach, using the already available data returns and monitoring returns submitted by each provider. This could very easily be supplemented with results from surveys issued directly by Ofsted ahead of the inspection visit, all of which could both enhance and focus the inspection on appropriate areas, ensuring that it looked adequately and appropriately at the right aspects of the provision, while also lessening the operational burden of a four-day inspection visit at short notice. Given the amount of information being provided by registered providers to the OfS, I would advocate more of the work being undertaken progressively using existing information, culminating perhaps in a shorter visit to corroborate what is already known.
There is also an apparent absence of coordination or integration between the different agencies and their approaches to monitoring, and the result is that providers can all too easily be in the grip of monitoring activities from several appointed bodies concurrently. This week for example, in addition to the ongoing OfS reporting requirements, UCEM has been simultaneously hosting and providing evidence, documentation and further information to three – Ofsted, the ESFA (Education and Skills Funding Agency) and the QAA (a significant additional burden on our limited resources). You can likely imagine how challenging this is for a small institution. I would hope that this can be better appreciated and looked into, in order that a model is agreed between the agencies to talk with each other, and ensure any individual provider is not unduly burdened by such an unwelcome coincidence.
Finally, and perhaps most importantly, there appears to be a limited understanding of, and empathy for, the current fatigue levels of staff who have been working tirelessly and non-stop for the last 19 months during the pandemic to support students, under extremely challenging circumstances and despite their own often personally challenging situations. Perhaps we have forgotten how to be human in our race to reinstate the quality monitoring and inspection regimes, but if nothing else, perhaps the Department for Education could help its appointed bodies to adjust their approach somewhat, and be appropriately sensitive to the burden which has fallen on university staff and their institutions during the COVID-19 crisis and learn to adapt in the same way the sector has had to.
We all welcome the understandable focus on assuring standards in higher education. However, in my view this focus needs to be both fair and appropriate in its interventions, with the aim of balancing better the risk and rewards of such a system. Let’s please not lose sight of the fact that by far and away the vast majority of academics and institutions were and remain fully focused on providing a fabulous student experience, without the need to repeatedly provide the evidence of it.