A week is a long time in politics – a day in higher education can seem even longer

• This blog was kindly authored for HEPI by Professor Amanda Broderick, Vice-Chancellor & President at the University of East London.

On 12 September, the Office for Students (OfS) published its first set of findings from assessment visits focused on the quality of Business and Management courses. In conjunction with the announcements, HEPI ran a blog by Professor David Phoenix, Vice-Chancellor of London South Bank University (one of the institutions visited by the OfS), reflecting on the ‘lack of transparency and the additional burden’ of the process from the University’s perspective. The piece raised important questions about the ways in which the regulator currently uses its wide-reaching powers, and ‘the broad basis upon which the OfS has powers to initiate an assessment of any provider.’

It was only one day after this, that the House of Lords’ Industry and Regulators Committee released its report into the OfS – ‘Must do better: the Office for Students and the looming crisis facing higher education‘. In summary it found, as a direct consequence of the OfS’ own approach and Government pressure, that it is neither trusted by nor has the confidence of many of the providers it regulates, and neither has it acted in the real interests of students. Committee Chair Lord Hollick highlighted that one particular area of concern was the OfS’ approach to assessing the quality of courses, linking this to the QAA’s de-designation from the Designated Quality Body role.

Today, I want to add my voice to these calls for a rethink of our regulator’s approach towards quality assessment, and to reflect on where there is room for improvement in this important process and the role it plays in the national and international reputation of Higher Education.

The University of East London (UEL) business and management provision is one of the first eight universities that the OfS visited between December 2022 and February 2023 in line with its B regulatory conditions and as a precursor to subsequent assessments undertaken through B3.

At UEL, we believe that external oversight is crucial in ensuring accountability and improvement. We are a university that has undergone a radical transformation over the last 5 years through Vision 2028, and as part of this continuous drive for development, we welcome the opportunity to learn and grow from national quality evaluations. Indeed, a diverse range of external evaluation and validation plays an important role in assuring and promoting the quality of our courses and other institutional activity not only nationally but also internationally.

Thus, I am pleased to highlight that UEL have yielded 100% positive results from the OfS evaluation with no concerns identified regarding our Business and Management provision. The investigating team commendations included, for example, ‘the university’s effective support for staff in curriculum design and implementation of business and management courses’; ‘…. an organisational culture that encourages pedagogical excellence, and provides mechanisms to support that ambition’; ‘the validity and reliability of assessments, which were deemed effective and aligned with the requirements’; and, ‘….. student support effectively tailored to the student demographic, and has successfully scaled their support mechanisms’.

This finding can be cross-referenced with the improved rating of an overall Silver Award in the 2023 Teaching Excellence Framework 2023 and in the 2023 National Student Survey where our graduating students are among the most positive nationally (published post-OfS assessment). Particularly noteworthy is our top 10% Progression increase reflecting an astonishing 800% increase in employer partnerships over five years, bringing top employers to communities that were traditionally underserved and boldly challenging conventional proxies of talent, working in partnership with employers to better identify diverse talent, innovation and creativity for the future. As one of the most socially inclusive UK universities with the highest number and percentage of care-experienced students in our community, also being ranked 1^st for Completion nationally (vs. benchmark) should not be taken lightly.

One of the peculiarities of the OfS quality assessment process was that we were not informed of what the OfS’ concerns had been at any point during the review. There has never been clarification as to the exact criteria, data used or threshold for the assessment, nor how the OfS decided on the shortlist of universities that were to be assessed. On receipt of the ‘no concerns’ OfS report in September, we privately challenged the generic response, which said that ‘The OfS will now consider whether any regulatory action is appropriate’. As a result, the OfS changed its communication to state that ‘The OfS will now consider the content of the report’, removing the reference to regulatory action – despite having over 7 months in which to make that consideration.

It is notable that each of the institutions targeted has a high percentage of students from widening participation backgrounds, and social mobility or inclusion as an explicit institutional mission. Far from suggesting that this is the result of explicit discrimination, I believe it is worth considering if the current definitions, interpretations, and measurements of quality, can have an unintended implicit bias towards certain students, regions and institutions. Either way, it is critical that we challenge any suggestion that socially inclusive HEIs are low-quality, and actively correct any false assumptions about the students who attend our institutions, the challenges they may face and the full value of successful outcomes. Whilst talent is evenly distributed through society, opportunity is not and it is those HEIs doing the majority of work, in partnership, to dismantle structural inequity that may be disadvantaged by simplistic measures. The government’s recent suggestion that OfS might consider ‘earnings potential’ in their measures of a degree course’s value is certainly not the answer here, only threatening to further penalise universities that make it their mission to build the public sector workforce and to understand inter-sectional challenges. For example, London graduates have one of the largest ethnicity pay gaps in the UK – 23.8% compared with 1.4% in Wales.

The danger of the OfS approach to quality assessment lies in forgetting that the invaluable diversity of students, regions and institutions have a critical role to play in driving social mobility and unlocking the growth, productivity and competitiveness of UK Plc. I fear that some of the discourse surrounding the announcements of OfS quality assessments gives the false impression that universities are not all that interested in students. Indeed, the government’s response to the HE reform consultation back in July was framed as evidence of a ‘crackdown’ on ‘rip-off’ degrees, and low-quality courses even got a mention in the Prime Minister’s speech at the 2023 Conservative Party conference. Given that the forthcoming ‘crackdown’ gives no new powers to the sector regulator, one might wonder why these proposals form the centre of so many government announcements relating to universities. As HEIs collectively we must and will do more to assure the public that these assessments, though important, are not a corrective to a sector with a common purpose to transform lives through education. A focus on continual improvement should strengthen rather than detract from the reality of our vibrant and diverse sector occupying global pre-eminence reputationally. Certainly, UEL is resolute in its mission to tackle the 5.0 skills gap by increasing the diversity of the talent pipeline, advancing a socially just education and equipping students from all backgrounds to play their part in solving society’s biggest challenges.