Written evidence submitted by Coventry University


  1. Coventry University Group submission


1.1. This submission is written evidence from the Coventry University Group. Coventry University Group is one of the country’s leading 'modern universities', with approaching 40000 students and a robust academic presence in the West Midlands, multiple locations in London, Scarborough and internationally. Our teaching was rated Gold in the latest TEF, confirming the excellence of the undergraduate teaching carried out at Coventry. Our teaching, staff, facilities, and student experience have all been recognised as being among the finest in the sector and our future is looking bright as a modern university with a flourishing global reputation. The recommendations in this submission come from a place of ambition within the sector, striving for excellence and driving our national and global impact.


1.2. The OfS found in its yearly report (2021) that currently the HE sector in England has “generally reasonable financial resilience, despite the many operational and financial challenges arising from the coronavirus pandemic. However, there continues to be significant variation in the financial performance and strength of individual higher education providers. Looking ahead, the environment remains challenging, and providers will need to continue to adapt to uncertainties and financial risks to protect their longer-term sustainability[1].” Coventry University Group agrees with the regulators findings and in this submission, we put forward proposals to improve sector resilience considering the national finances and impact of the pandemic.

  1. Whether DFE has set a clear purpose and scope for the oversight regime.

2.1. The long-term financial sustainability of the HE sector in the UK is currently imperilled by short term political decision making which has failed to consider the significant contributions of the sector to the economy both through training the national workforce, driving innovation within the UK, and as an internationally valued exporter of educational products.


2.2. In their recent response to the Augar review of post 18 education, the Government has been clear that HE providers must drive further savings in their existing budgets. Within this response the Government outlines their belief that the HE sectors response to the pandemic has demonstrated that HE providers can provide innovative provision with reductions in funding. We would recommend to the Government that this is not a sustainable position to take and will hamper the ability of the sector to protect students from further economic shocks the UK may face.


2.3. The sector received almost no additional support from the Treasury during the pandemic aside from accessing the Job Retention Scheme. The survival of the sector in the face of the pandemic is now used as justification for the reforms.  The Government believe that there is still “unnecessary bureaucracy, including administrative tasks and requirements placed on academics that do not demonstrably add value: our primary goal must be to maintain delivery of our world-class, high-quality teaching, and ground-breaking research[2].” The sector has consistently worked with Government on reducing regulatory burden and streamlining operations and universities are committed to delivering a high-quality experience for all their students, whatever their background, course, or ​place of study.


2.4. However, the Government’s system of oversight is contributing significantly to the bureaucracy they are attempting to cut. For example, in the sector responses to the quality and standards consultations (OfS B3), it was highlighted that significant resources could be saved by universities with teaching partnerships and those delivering vocational and technical education can avoid unnecessary burden where dealing with multiple regulatory bodies[3]. This is illustrated well by the current regulatory ecosystem for apprenticeships, which are the backbone of the Government’s levelling up agenda. Currently, checking the quality of apprenticeships delivered by UK FE and HE is overseen by 6 different regulatory bodies[4]:



2.5. Each regulatory body has its own system of compliance – which is a significant burden on HE providers resources. We would recommend that streamlining these regulatory ecosystems would make significant savings for the both the taxpayer and for HE providers.


2.6. Compared with previous years, the OfS’s proposed strategy for the 2022-2025 strategy has provided significant clarity on how they intend to apply regulatory oversight, especially in terms of quality and standards. However, the OfS’s ability to provide strategic direction with regards to funding priorities is stifled by the approach of yearly allocation and direction from the Minister for Universities. Coventry University Group agrees with the spirit and goals of the OfS’s strategy for 2022-25. However, there is a lack of detail on how its aims will be achieved practically with funding. Greater detail is needed on the framework for linking regulatory activity to the Government’s strategic goals. For example, the consultation with the sector on the OfS’s strategy for 2022 -25 was published in advance of the ministerial advice that the access and participation agenda should be completely refreshed. Consequently, there was no opportunity for the sector to comment on how this major workstream will interact with the priorities outlined in the strategy.  The OfS should outline how its regulatory work will withstand political shifts in national priorities to give the sector clarity and stability for the future.


2.7. Recommendation: We would recommend that to provide greater certainty to the sector, that guidance should be given to the OfS for the lifetime of the spending review cycle – so that the funding priorities and allocations can be fixed – to allow universities certainty when investing in major capital and teaching projects which benefit national priorities such as training 50, 000 new nurses to meet the Government’s ambitious target[5].

  1. Whether DfE and OfS have responded appropriately to new financial risks, for example arising from COVID and EU exit.

3.1. Neither the OfS or the DfE have yet fully realised the legacy of withdrawal from the EU in terms of their financial guidance and support to the sector, which continues to be restrictive in scope and application, hindering longer term planning. Brexit has had an extremely chilling effect on student recruitment. Brexit meant new EU students no longer have access to home fees from 2021 and are no longer eligible for tuition fee loans, meaning they must have the tuition and maintenance costs upfront. Applications from EU students fell by 40% in 2021 as this disparity in support from what EU students had previously enjoyed has made the UK much less attractive to EU students[6]. Replacing the income from these students is a priority for universities nationally, who have faced significant shortfalls against their forecasted income. Research prepared on behalf of DfE estimates the loss to the UK economy of the reduction in EU student numbers to be approximately £66.5 million per year. This figure is estimated from tuition fees alone, the figure with loss of EU student contribution to the UK economy would be much higher[7].


3.2. Recommendation: The Government should consider costing the impact of negotiating and offering reciprocal tuition fee status with EU students (as used to happen within EU membership, where students from the EU and EEA were treated as Home Students for the purpose of charging tuitions fees). We understand that this may need to be negotiated with individual EU member states, and may represent a significant negotiation, however, we feel that the dramatic drop in EU student numbers must be addressed. 


3.3. On 6 February 2021 the Government launched an updated International Education Strategy – which reaffirmed its aims to recruit 600,000 international higher education students annually and increase education exports to £35 billion a year by 2030. The Government has introduced a two-year Graduate Route post study work visa and a three-year visa for PhD graduates[8]. We firmly believe that the Government can be more ambitious in its plans to attract the worlds brightest and best students to the UK. Making the immigration system user friendly with clear guidance and processes are crucial to the enabling the recruitment of international students and the financial stability of the HE sector.  We welcome the Government’s new graduate visa route – our own recruitment shows it is attractive to students. However, it will be a challenge for the UK to remain competitive in the international HE market at the same level now when the USA, Canada and Australia have reopened their borders.


3.4. Recommendation: Mirroring or improving on the offer of the Canadian post graduate visa would ensure the UK remains an attractive destination to international students when the travel corridors are fully reopened as the travel routes return to normal post pandemic. Canada currently offers an automatic three-year visa post-graduation as opposed to the UK’s current offer of two.

March 2022


[1] https://www.officeforstudents.org.uk/media/19efb6a1-2c54-4643-a8d4-1616cdd0bdff/financial-sustainability-of-higher-education-providers-in-england-2021.pdf

[2] https://www.gov.uk/government/speeches/higher-and-further-education-minister-michelle-donelan-speech-on-the-augar-review

[3] https://www.universitiesuk.ac.uk/what-we-do/policy-and-research/publications/our-response-changes-quality-and

[4] https://www.officeforstudents.org.uk/advice-and-guidance/skills-and-employment/degree-apprenticeships/degree-apprenticeships-for-providers/checking-the-quality-of-apprenticeships/

[5] https://www.gov.uk/government/news/government-over-halfway-to-delivering-50000-more-nurses-by-2024

[6] https://commonslibrary.parliament.uk/research-briefings/cbp-7857/


[8] https://commonslibrary.parliament.uk/research-briefings/cbp-7976/