Are we counting everything that counts? Data, judgement, and the TEF

This blog was kindly authored by Emily Pollinger, Education Policy and Programmes Manager, University of Bath  and Jen McBride, Senior Lecturer and Academic Lead for Teaching Excellence & Quality, University of Manchester

The Office for Students (OfS) has recently consulted on its future approach to quality regulation, and its proposals will have a significant impact on future iterations of the Teaching Excellence Framework (TEF). These proposals include mention of potential incentives and interventions linked to TEF ratings, with Gold and Silver institutions potentially becoming eligible for specific funding in future.  

A central feature of the proposals is an increased weighting for quantitative data (‘indicators’) relative to the previous iteration of the TEF. In the 2023 TEF exercise, the OfS stated that ‘For each aspect, the [data] indicators will contribute no more than half of the evidence of excellence’. Provider and student submissions, therefore, played a substantial role in determining TEF ratings.  

Under the new proposals however, this would change significantly. The Student Experience aspect would continue to be assessed through a combination of quantitative indicators and qualitative submissions, but the Student Outcomes aspect would be assessed almost entirely on quantitative data. As a result, while the 2023 TEF involved an approximate 50:50 balance between quantitative data and qualitative evidence, future TEF ratings may be around 75 per cent driven by quantitative measures. When combined with the proposal that the lowest aspect rating should determine the overall award, this shift would mean that institutions performing more strongly in Student Experience than in Student Outcomes could find their overall rating almost entirely dictated by quantitative indicators.  

We are concerned about this direction of travel. Assessing the quality of education through a relatively small number of quantitative proxy measures for excellence risks unnecessarily limiting how student success – and the value of higher education – are defined, measured, and understood. At a time when transferable skills, critical thinking, confidence, and personal development are increasingly valued by students, employers, and policymakers, we believe there is a strong case for greater use of qualitative evidence and academic judgement than these proposals will allow. 

Alongside this increased emphasis on quantitative indicators, the proposals propose removing providers’ accounts of students’ Educational Gain as a mandatory element of assessment. Instead, they would become an optional, contextual component within the Student Experience aspect of submissions. This is a significant and regrettable change. Work on Educational Gain has prompted institutions to articulate how students grow academically, personally, and professionally during their studies. It has encouraged reflection on teaching, support, and curriculum design, and has helped to capture dimensions of learning that cannot be reduced to numerical outcomes. Removing Educational Gain from the core assessment framework risks narrowing the TEF’s understanding of educational excellence. It reinforces an over-reliance on indicators that, while useful, cannot capture the full richness of students’ experience and development. It also diminishes the role of peer review, academic expertise, and institutional self-evaluation as we strive for excellence. 

We recognise the OfS’ concern with the burden and complexity of assessment, particularly in a system where regulatory and financial consequences may follow TEF judgements. However, higher education is founded on principles of academic judgement and peer review. A credible and future-facing quality framework should therefore combine robust quantitative indicators with structured qualitative submissions assessed by expert panels. In practice, this means maintaining a clear minimum weighting for qualitative evidence across all aspects, retaining Educational Gain as a core component, and ensuring panels are empowered to exercise professional judgement where contextual factors are significant. Such an approach would preserve transparency and comparability while recognising that excellence in teaching and student development cannot be fully captured through metrics alone, and provide a quality framework that reflects everything that counts in higher education (rather than only that which can be easily counted).