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The value of independents and independence

  • 11 January 2023
  • By Rob Stroud

This blog was kindly contributed by Rob Stroud, Director of Quality Assessment, England at the Quality Assurance Agency for Higher Education.

In their recent HEPI blog, Professor Sir Malcolm Grant and Mary Curnock Cook rightly highlight some of the challenges that independent challenger institutions have faced entering the higher education sector in England – despite the opportunities envisaged by the White Paper Success as a Knowledge Economy and the subsequent passage of the Higher Education and Research Act (HERA) – and offer what I take to be some well-meaning critique of the regulatory and quality assurance regime.

Over the last decade, I’ve spent a lot of time working with independent providers, at the Higher Education Funding Council for England (HEFCE) leading a joint unit with the Department for Education (DfE), then the Office for Students (OfS), and now at the Quality Assurance Agency (QAA). I have seen and heard first-hand the numerous policy and practical challenges they face. After the difficulties in the early part of the last decade, much effort and resource was put in place by government and other public and sector bodies to support and engage with independent providers. HERA’s implementation finally brought them into a single consistent regulatory regime.

Independent providers are incredibly diverse, and very rarely look like the stereotypical multi-faculty institution that the words ‘higher education’ typically bring to mind. They are often focussed closely on one or two specialisms, and have a sharp eye on developing future talent for their respective industries. So Grant and Curnock Cook’s premise that quality assurance approaches need to be fit for purpose for such providers is spot on. It is worth emphasising at this point that processes undertaken by the Designated Quality Body (DQB) are shaped by the regulatory framework, not by the DQB itself. Nonetheless it’s dispiriting to hear that independent providers are advised to try to look like established universities, especially after all the effort put in prior to the beginning of the OfS era to allow providers to be themselves, while ensuring protection for students through robust and appropriate oversight by suitably qualified bodies.  

Good quality assurance practice has to balance rigour with burden, and it may be that the current regulatory framework doesn’t always get it right. Grant and Curnock Cook highlight the difficulties in following advice to look like an established university when seeking New Degree Awarding Powers (NDAPs). I am confident that the sector would not want to see providers registered or awarded their own degree-awarding powers without having passed stringent checks. The Regulatory Framework is clear on this when it says:

the criteria for the authorisation for DAPs are designed to ensure that a provider with DAPs has demonstrated a firm guardianship of academic standards, a firm and systematic approach to the assurance of quality of the higher education that it provides, and the capacity to contribute to the continued good standing of English higher education.

Clearly it is not easy for a provider that may not yet have students or have delivered a module let alone a degree, to be able to demonstrate this. The regulatory requirement for those providers to demonstrate – criterion by criterion – that they meet all of the DAPs criteria in full at the end of a probationary period for NDAPs is where a large proportion the burden will come from. What providers will find is that QAA has the expertise to examine all of the criteria in detail, gathered through our many years of looking at HE in the UK and abroad. 

Where I disagree with Grant and Curnock Cook is in their suggestion that QAA is not attuned to risk-based evaluation or the promotion of innovation. With over 25 years of experience working with all types of providers, domestically and internationally, QAA has the skills and expertise in just these things. We facilitate innovative approaches to quality in England through our voluntary membership offering: publishing and promoting a wide range of tools that members can find and use, bringing together practitioners and experts from across all parts of the sector (we run networks for both independent and college providers) and also through funding a range of Collaborative Enhancement Projects among other activities. This is all part of our contribution to the sector as a quality body independent from both government and the providers in the sector and is something that providers tell us they highly value.

However because we are still currently the English DQB, we are currently unable to operate in a way that more directly supports individual providers in England, as this could clearly represent a conflict of interest. When a provider is reviewed as an individual entity with our statutory DQB hat on, we look through the lens of the regulatory framework and the criteria that it (not we) specifies. 

There has been much speculation regarding what QAA’s role will be in England now that we are stepping away from the role as the DQB early next year. We believe that there is an opportunity for QAA to contribute to exactly what is being called for – working with providers across the sector to support their growth through both promoting innovative approaches to enhancement, and also helping them address problems with quality when they arise. This is an offering that QAA is perfectly positioned to make.

When our service as DQB ends, we will offer our expertise across the whole of the English sector through a deeply collaborative approach, forging new and different types of relationships with providers. We will be able to better support providers with existing resources for enhancement and engage with them utilising our significant pool of subject experts. This will give providers the feedback for quality enhancement that is called for by Grant and Curnock Cook. This is simply not a feature of the current review processes, as it is not a feature of the criteria that the regulatory regime considers at the baseline. 

QAA is, and works hard to remain, an internationally recognised and acknowledged expert quality body, and we want to offer the providers the opportunity to be able to tap into that expertise and credibility. The quality of higher education in England is at the heart of the sector’s international success, and we think working more closely with individual providers in England will allow independent providers to be a greater part of that too, alongside establishing other activities for all English providers. 

We’ll say more about this later this year, including through an updated QAA strategy. The future offers greater chances to promote quality and greater choice for students, and QAA, as an independent body, will play our part in that. 

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