- This HEPI blog was kindly authored by Fabrizio Trifiro, Head of International Quality Reviews and Stakeholder Engagement at Ecctis.
On Tuesday, 16 May 2023, HEPI – in conjunction with Universities UK and Kaplan – will be launching new modelling from London Economics on the economic contribution of international students to the UK. For more details, including how to book a free place, see here.
UK transnational education (TNE) is set to grow in the coming years in response to an increasing demand for quality international education from students unable or unwilling to travel to the UK, and the need of UK higher education (HE) providers to diversify their internationalisation strategies. At the same time TNE has been identified as a key area of growth in the UK Government International Education Strategy. It appears highly in the international engagement agenda of the International Education Champion Sir. Steve Smith, and the Department for Business and Trade is working with the HE sectors and internationally to identify opportunities for growth and resolve regulatory barriers.
Consequently, we can expect increased international attention and scrutiny on how the quality and standards of UK TNE provision are safeguarded.
The UK regulatory and quality assurance landscape for TNE has changed significantly over the past few years. To fully understand the current state of play it is helpful to take an historical perspective, which can help us reflect on likely future directions and developments.
This blog provides a short historical overview focusing on the key features and dynamics pertaining to the UK system for overseeing the quality of outbound TNE, as it evolved over time, concluding with a quick glimpse at the future.
To start appreciating some of the key challenges and dynamics that have characterised the quality assurance of UK TNE, it can be helpful to reflect on the very rationale for undertaking quality assurance in the first place.
Three main motivations have underpinned the development of the external quality assurance system in the UK:
- Accountability for public funding
- Protecting the student experience
- Safeguarding the reputation of national education systems
If we look at the early days of the external quality assurance system in the UK, the Quality Assurance Agency (QAA) was established in 1997 through the merger of the quality assurance divisions of the HE funding bodies of the four nations of the UK, and the quality assurance body, the Higher Education Quality Council. The Higher Education Quality Council had been set up by universities themselves to reassure the public about the quality and standards of their provision. Hence, we have at the start a combination of accountability for public funding and reassurance to the public about the standards of learning and the student experience taking place at UK HE providers, as well as a combination of external regulation and self-regulation.
When it comes to TNE, however, accountability for public funding, and the associated external regulatory attention, has traditionally been missing, since UK HE providers have never been allowed to use public funding to support their TNE activities. For this reason, for a long time, there has been a lack of explicit remit for the external review of the quality of UK TNE. As TNE was not publicly funded provision, it sat outside of the scope of the HE funding bodies holding the statutory responsibility for quality and standards.
It is of course of paramount importance that all students receive the best possible experience and that they can expect to achieve the same standards of learning, regardless of how and where they are studying. This can be regarded as the golden rule of quality assurance of TNE, and it is a key consideration underpinning international reputation and confidence in TNE.
Safeguarding the international reputation of UK TNE was the main rationale behind QAA’s initial TNE monitoring activity. Possibly the first high profile TNE review (or ‘audit’ as it used to be referred to those days) was of TNE operations in Israel in 1999 where bogus degrees of a UK degree awarding body were sold without their knowledge through franchised agreements gone wrong.
QAA’s TNE reviews over the years occurred through an in-country review of a sample of TNE operations in the country selected. This is typically one country per year. These in-country TNE reviews were not explicitly part of the contractual agreement through which the four national HE funding councils delegated to the QAA their statutory responsibility for the quality and standards of HE across the UK. TNE activity could also be looked by the QAA at as part of the different cyclical institutional review or audit processes in place in the four UK nations, although these had variable focus on TNE.
QAA’s TNE monitoring activity continued pretty much unchanged in its lack of explicit remit, and allocated budget, until 2016 when the Higher Education Funding Council for England (HEFCE), together with the national funding bodies for Wales (HEFCW), Scotland (Scottish Funding Council) and Northern Ireland (Department for the Economy), decided for the first time to publicly tender the review of UK TNE and broader international activity. QAA was eventually contracted to deliver in-country TNE reviews (a contract I managed back then for the QAA), for the first time with a dedicated budget and a clear mandate.
The mandate was explicitly predicated on the need to provide public assurance, protect student interests and the collective reputation of UK TNE, and it included strategic engagement with international quality assurance bodies and networks. Cross-border cooperation by then had gained increasing importance in devising solutions for the quality assurance of TNE. The contract also included the production of country reports providing strategic information about key TNE host locations’ operating environments.
End of in-country reviews, and their continuation under a different mandate
The contract with the HE funding councils to undertake international activities, including TNE reviews, came to an end in 2018 following the closure of HEFCE and the establishment of the Office for Students (OfS) in England. That opened an uncertain period for the quality assurance of UK TNE, at a time in which the quality assurance of English HE (in fact ‘quality assessment’ as per the OfS regulatory framework) had changed significantly.
The QAA’s traditional cyclical institutional peer-reviews had come to an end in England. These were replaced by the OfS’ annual monitoring of providers listed in the OfS register of English HE providers through a risk-based, principle-based and data-led approach focusing on student outcomes. A limited number of functions were contracted by the OfS to the Designated Quality Body, but these did not cover TNE. These limited functions covered:
- reviews of providers wishing to enter into the OfS register against threshold standards;
- reviews of providers in connection with the grant, variation or revocation of providers’ degree awarding powers;
- focused reviews of concerns the OfS might have had about specific providers on the register based on their regular monitoring of outcomes related data;
The QAA was designated to deliver these functions until its decision not to continue in this role after March 2023. From April 2023 the assessment activities are carried out by the OfS itself.
As for TNE, the establishment of the OfS, and the end of the HE funding bodies’ contract with the QAA for international activities, meant two things:
1. The OfS became responsible for regulating registered English higher education providers offering TNE through its risk-based data-led and outcomes focused approach. The OfS’s 2018 Regulatory Framework stated from the beginning in reference to English providers’ overseas activity, that:
The OfS will regulate such overseas activity on the basis that the obligations of the registered provider extend to students for whom it is the awarding body wherever and however they study (paragraph 88)
2. The QAA no longer had a mandate to review English TNE, and there was no longer a dedicated process in place to look at Scottish, Wales, and Northern Irish TNE – other than variable monitoring through the different national cyclical institutional reviews, which by then had stopped to run also in Northern Ireland.
It was at this time that consideration started to be given to developing a voluntary scheme that could allow the continuation of a dedicated UK wide in-country TNE review scheme.
As part of the initial proposal, the voluntary in-country TNE review scheme would look at three host locations per year, looking at a sample of TNE operations operating in the selected locations, to allow cover over a five-year period much of UK TNE in established and new delivery locations. The low coverage of the traditional approach had in fact always been a limit of the traditional in-country review approach.
A group of experts was set up to discuss a draft proposal for a future voluntary scheme. The group of experts eventually turned into the TNE advisory group managed by UUKi and GuildHE that developed the consultation on the future QA arrangements for UK TNE. This eventually informed the QAA quality enhancement TNE scheme commissioned by UUK and GuildHE in 2021.
Importantly, whilst for Welsh and Scottish providers there is currently an expectation by the respective national funding bodies to sign up to the QE-TNE scheme, it is entirely voluntary for English TNE providers. In particular, the scheme does not play a role in the OfS regulatory and quality assurance framework for England.
Thus, as far as English TNE is concerned, we seem to have come full circle and gone back to something akin the pre-1997 two-tracks system, one managed by the statutory/regulatory body, the OfS, through its risk-based and data-led and outcome-focused approach to quality assessment, and the other, voluntary in nature, and enhancement-oriented, commissioned to the QAA by the bodies representing universities and colleges themselves.
The Office for Students’ approach
If Scottish and Welsh TNE can be regarded as covered as per the old framework through the QE-TNE in-country review scheme and cyclical institutional reviews – which QAA still undertake on behalf of the Scottish Funding Council and the Higher Education Funding Council for Wales – what about England and the OfS’ approach to TNE? How has the OfS been progressing on its original intention to extend its regulatory framework to English overseas activity?
So far, the OfS has based its monitoring of TNE on three activities:
- Reportable events, that is significant events that registered providers should notify the OfS such as establishing new TNE operations or closing TNE operations for example.
- Notifications from students, staff and third parties about any issues or concerns about specific TNE operations.
- The Higher Education Statistic Agency (HESA) aggregate offshore record, with enhanced data covering continuation and completion of studies.
Significantly in the summer 2021 the OfS announced two important developments related to TNE:
- A review of the HESA data, with a view to obtaining better data about TNE, and TNE students in particular, to be able to better apply its data-led and outcomes-based approach to TNE.
- The intention to engage internationally with key stakeholders as part of their regulation and monitoring of English TNE, with a view to both improving international understanding of the OfS’ regulatory role and providing assurance about their regulation of English TNE
As for the former, the OfS is currently working with HESA (now merged with JISC) to move towards an individualised TNE student record, with more detailed data about students’ outcomes. Due consideration of context will also be an important aspect when considering and analysing TNE students’ outcomes, given the great variety of locations in which English TNE providers operate.
As for international engagement, this work has been progressing steadily. The OfS is now proactively engaging and building partnerships with international quality assurance bodies and regulatory agencies in key countries for English TNE. This engagement activity is of paramount importance, contributing to improving international understanding of how English TNE is regulated, the work of the OfS in general, and its commitment to ensure that students studying on TNE offered by OfS registered providers benefit from the same regulatory protections enjoyed by students studying in England.
This international engagement work will crucially help to underpin international confidence in English TNE and its regulation. It will also allow the OfS to strengthen cooperation with key bodies in TNE host locations to cover information, data, and intelligence sharing and eventual cooperation in monitoring activity – thus helping to inform the OfS’ risk-based approach and its commitment to lessen regulatory burden, avoiding unnecessary regulatory overlap.
Focus on recognition and the international landscape
Going back to the question we started with, about the underlying motivations for external quality assurance, there is a further vital aspect which was not listed, although it has been indirectly touched upon at different points, an aspect that has to do with securing international confidence – it is that of securing international recognition for TNE qualifications.
TNE, as other non-traditional modes of delivery, such as online learning, has been a challenging area for qualification recognition. Although there are number of international conventions with the aim of providing a common framework and approach to the recognition of different types of qualifications, such as the UNESCO / Council of Europe Convention on the Recognition of Qualifications concerning Higher Education in the European Region (Lisbon Recognition Convention), which includes a specific Code of Good Practice in the provision of Transnational Education, and now the UNESCO Global Convention on the Recognition of Qualifications concerning Higher Education (Global Recognition Convention), there are still different national approaches to qualification recognition and to the implementation of the conventions. These differences ultimately rest on different views of what quality provision and quality assurance should look like.
Not all countries recognise or easily recognise all TNE qualifications. Certain types of TNE qualifications face more challenges than others, such as those obtained through online learning or through collaborative partnerships with partners without local degree awarding power. Whether TNE provision is demonstrably quality assured by either the sending country or the host country can also be an important factor informing recognition decisions by part of international recognition authorities and credential evaluators.
Generally, these recognition challenges relate to a lack of trust towards qualifications obtained through TNE operations whose nature and quality might be difficult to understand and assess for international regulators and credential evaluators. Especially in the absence of a shared international framework for the quality assurance of TNE and a shared understanding about what quality education should look like. Not all countries regulate or quality assure outbound or inbound TNE, and those that do do so in very different ways, resulting in widespread quality assurance gaps, and at times overlaps.
Learning outcomes vs. learning experience
Possibly one the of the main challenges to the recognition of TNE qualification rests in a lack of clear distinction, and sometimes conflation, between ‘learning outcomes’ and ‘learning experience’ when thinking about the golden rule of quality assuring TNE, that is that TNE provision should be comparable or equivalent to provision offered by the TNE awarding institution at its home campus.
There is no doubt that this comparability or equivalency principle should be considered as an uncompromisable expectation in relation to learning outcomes, in the sense that TNE students should be expected to achieve the same level of preparedness in their studies as students who are studying at the home campus of the TNE awarding institution. However, when it comes to the learning experience, strict comparability or equivalency between TNE and home campus provision might not always be possible or even desirable.
Students studying on TNE operations in different countries or through different modalities will be necessarily exposed to different learning environments. This might be because of different cultures of teaching and learning, or different learning modalities when studying online or blended format, or through intensive block-teaching mode, or different types of resourcing at the TNE delivery site – considering that it is not a realistic expectation for TNE providers to reproduce across their TNE operations the same level of support services that they have at their home campus. But these differences in learning environments available to TNE students should not necessarily be regarded as undermining trust in the quality and standards of TNE provision.
As long as TNE students receive the required support to allow them to achieve the expected learning outcomes for their studies, any difference in learning environment can be regarded as a matter of student expectations. That is, a matter of making sure that students are clearly communicated from the start what type of learning environment, resources and support they should expect from their TNE studies.
By failing to distinguish between learning outcomes and learning experience, and therefore extending the comparability or equivalency requirement from learning outcomes to the learning experience, it is easy to be led to believe that TNE qualifications are inherently at risk of being of lower quality than similar qualifications offered at the home campus. The failure to draw this distinction, and embracing outcomes oriented approaches to quality assurance and recognition, is often behind decisions to not recognise TNE qualifications or certain types of TNE qualifications.
Ecctis’ TNE Quality Benchmark Scheme
It is against the backdrop of this fragmented international regulatory context and ongoing recognition challenges, and in the context of the recent adoption of the Global Recognition Convention, that Ecctis (formerly UK NARIC), the agency managing the qualification recognition function on behalf of the UK Government, has developed a TNE Quality Benchmarking (TNE QB) scheme intended to help improving international understanding of and trust in TNE qualifications of demonstrable quality and standards.
The scheme offers international TNE providers, regardless of country of origin, a means through which they can demonstrate in an independent way that their TNE operations, regardless of country of delivery, meet international standards of good practice developed in alignment with existing international reference points such as the UNESCO/OECD Guidelines for Quality Provision in Cross-border Higher Education and the UNESCO/Council of Europe Code of Good practice in the Provision of Transnational Education.
This is expressly to respond to the Global Recognition Convention’ emphasis on the importance of quality and quality assurance for providing the ‘foundation upon which trust can be built’ and recognition granted to qualifications, as well as the intention for the Convention to ‘provide platforms for national authorities to collaborate across borders and regions to develop better tools and practicesfor the recognition of HE qualifications.’
Summing up and looking ahead
To conclude with a look at the possible future directions of regulation and quality assurance, for UK TNE, and international TNE more broadly, we can expect that:
- In England, the OfS data-led, outcomes-focused, and risk-based approach will be refined with more comprehensive data for students on English TNE, combined with strengthened international cooperation in monitoring activity with host countries’ regulatory authorities.
- Outcomes and impact of TNE will gain increasing importance, not only in England under the regulatory drive of the OfS, but across the UK (and internationally) in response to increasingly clear expectations that TNE contribute to meeting the needs of TNE students and local communities – it will therefore be important for TNE providers to start collecting relevant data about the impact of their TNE provision, including student and other stakeholders satisfaction and progression after graduation.
- With regulation and quality assurance across the four nations of the UK taking different directions, UK TNE providers might increasingly rely on their own brand, and we might see the emergence of national brands, as exemplified by the launch of the Global Wales programmes and the Scotland’s Universities Welcome the World campaign.
- The recognition agenda will acquire increasing importance internationally with the coming into force of the Global Recognition Convention, and an expanding, diversifying, and competitive TNE landscape – with growing international attention on how TNE quality and standards are maintained, and quality assured externally.
- We might see growing international recognition of the progressive potential of TNE as a mean to widen international access to quality international education, paving the way for broader acceptance of a multiplicity of modes of learning and achieving learning outcomes, supported by strengthened international cooperation in the quality assurance and recognition of TNE.