Written evidence from the University of Kent (WOS0013)

The University of Kent is a semi-collegiate public research university with campuses at Canterbury and Medway.  It is a strong regional university, with strengths in both research and education and takes very seriously its responsibilities as an anchor institution for Kent and Medway. This submission sets out why the current regulatory, funding and governance arrangements for Higher Education do not work for us.

Who we are and what we do

We supply around 5,500 career-ready graduates each year. A high proportion of our students come from the region (Kent, London and the South East); and many remain here after graduating, where they provide the crucial skills to support public, private and third sector businesses and organisations. We have recently opened, with Canterbury Christ Church University, the first medical school in Kent. We are expanding our non-traditional offer to include higher and degree apprenticeships, online programmes, more short courses and more continuing professional development. We are looking forward to engaging with proposals for the Lifelong Learning Entitlement.  We are one of the largest employers in the region.

We carry out cutting-edge international research which both advances knowledge and understanding and contributes to the wider research ecosystem in the UK. In the recent Research Excellence Framework, eight of our subjects were in the top ten for research quality. Our applied research can be linked to local needs - at the same time providing regional enterprises with access to our national and international networks.

We do much more than education and research. We have energetic programmes designed to help schools and colleges in the Kent and Medway region widen participation to Higher Education, through both our sponsorship under the University of Kent Academies Trust, and through the progressive and sustained work with our 22 Partner Schools and 3 FE Partner College groups. We provide a convening role for business and wider civil society, such as an annual Kent and Medway Business Summit. We are engaging with urban renewal. We provide local communities with access to our campuses, including our theatre, cinema and concert hall. We provide Kent and Medway with its own Ofcom-licensed TV channel. Pre-pandemic, the regional economic impact of the university was estimated at nearly £1bn GVA a year.

The University of Kent is far from unique in making this kind of contribution to its region. Indeed, the reason why the UK’s higher education system is internationally regarded does not lie only in the small number of research intensive institutions but in the depth and complexities of the ecosystem as a whole, in which regional anchor institutions are key. Governments of all complexions have paid lip service to the importance of place and the added value that a university can bring to economic growth.  However, many of the current policies and institutions governing the sector appear to work against this outcome.

The role of the Office for Students

The OfS was explicitly created to protect student interests. The first three requirements were:

  1. The need to protect the institutional autonomy of English higher education providers.

In practice, we have seen an approach based on an ever increasing requirement for quantities of data whose relevance has seemed to be geared more to the demands of central government control than the interests of students. The use of standard targets, such as with Access Participation and Progression entry measures, is aligned neither to the nature of the provision or the market within a particular provider operates. The aim appears to be to create a monoculture in which the same solutions can be imposed across the board. The role and purpose of data collection is often not clear nor how it is contributing to protecting student interests in the HE system.

  1. The need to promote quality, and greater choice and opportunities for students, in the provision of higher education by English higher education providers.

Opportunities are if anything declining. The funding squeeze, resulting from frozen tuition fees means that universities are having to cut back on courses that they offer, potentially leading to ‘subject deserts’ in some parts of the country. Arts and Humanities subjects, for example, are increasingly becoming concentrated in what are referred to as ‘Russell Group’ Universities. The consequence of this is that for some areas of the country it will not be possible for people based in those regions to study certain subjects close to home.

  1. The need to encourage competition between English higher education providers in connection with the provision of higher education where that competition is in the interests of students and employers, while also having regard to the benefits for students and employers resulting from collaboration between such providers.

We are currently operating in a system of competition which favours one type of institution (self-defined and selected) over others. To explain, the success of our secondary schools and colleges is not only determined through the progression of their students to university but this is further divided to progression to a particular group of institutions. It is not clear why this distinction has been embedded into school performance reports but it creates a clear driver to direct students to particular institutions. We would welcome further discussion as to why a decision taken by the DfE over 10 years ago to collect data on how many pupils each school is sending to ‘Russell Group’ Universities remains in place when it is clearly anti-competitive. In addition, along with the removal of the student number cap this is creating a consequence of uneven distribution of students across the national HE offer.

Other Pressures

There are other features of the framework within which we operate that also damage our ability to contribute to our region to the extent that we understand the government would wish to see:

  1. Access, Participation and Progression and Cost of Living

Cost of living impacts will mean many students will be considering the financial impact of attending University, and looking at ways of doing so including living at home and attending a local university. This should be supported and rewarded, not feel like a compromise choice – decisions should be based on what is right for the individual.

Moreover, the impact of inflation on household spending is going to bring more students into financial hardship. This will increase the support institutions recruiting a wide demographic will need to provide to ensure these students have suitable housing, food and heating. Where there are not large endowments or other streams of income (such as rents) to support these students this is becoming ever more challenging. This will create a larger demand on institutions least able to support it. Students at the start of this year were reporting a significant gap between their financial needs and the available student support through loan and grants. We are already seeing the impact of this in students choosing not to return to University to complete their studies and in non-payment (and late payment) of fees. As an aside, the methodology used by the OfS is likely to evidence non-payment/late payment as an institutional performance issue, rather than a wider cost of living matter.

  1. Regulatory Competition

No one disputes the need for regulation. Good and proportionate regulation is part of good governance. We are fully supportive of this. However, the OfS itself is imposing a level of detail (thousands of metrics/split metrics at institutional level) within the conditions of registration that is determining operations rather than regulation. There is no consideration of the cost and effort needed to meet a requirement such as the retention of assessments for a 5 year period. Moreover, a single institution, such as Kent, has to take account of not only OfS but also UKVI, Ofsted, CMA plus a wide range of other bodies, each of which is committed to ‘excellence’ within its own regulatory framework and thus imposes ever growing demands on individual universities, often in isolation from other regulatory bodies. This requires increasing staff resources - which has to be paid for at the expense of investing in student education and experience.



  1. Levelling Up

Kent and Medway is often seen as a part of the ‘prosperous South East’.  However, it contains Thanet and Sheppey, two of the most deprived areas in the country. Of the four boroughs in England with the worst ratio of GPs to population, three are in Kent; and the wider region has the second lowest number of consultant physicians per capita. Kent and Medway’s population is expected to grow up to a quarter by 2031, with the number of over-65s expected to grow more than four times faster than the number of under-65’s, increasing the pressures on health and social care.

When the University of Kent raised with DLUHC that universities could better deliver a regional role with central government engagement, the then responsible minister made a general point about universities’ value in building institutional capital and referred us to the Department for Education. Instead we experience a series of centrally controlled competitions for small pots of money seemingly predicated on rewarding certain types of local government arrangements, rather than local needs. Bidding for funding is, moreover, resource intensive and the quality of proposals is in large part determined by being able to fund staff to respond to the process.

  1. Future Investment


The impact of the frozen tuition fee is well documented. But it is also difficult for universities to access finance to support long term sustainability models. There are opportunities to access smaller amounts of funding from OfS but these are often non-recurrent. There was talk of a national investment bank post Brexit but the idea appears to have been shelved. Institutions such as Kent, which have relied in the past on the European Investment Bank, are finding that EIB itself is no longer engaging helpfully with existing loan arrangements.  Brexit has been damaging for the University In other ways. We have lost over 1000 European students each year from our intake, we are having to close our Brussels study centre, have already closed our Rome and Athens Centres and are no longer able to access Horizon funding – for which there has been no replacement. 




We recognise that we, and the sector, need to ensure we are running ourselves effectively and efficiently, as well as embracing and innovating on new and different ways of running and delivering our activity. We of course need to be offering value for money, diversifying income, be financially sound and continue looking at how we can maintain and sustain quality. In addition, we recognise that the current system could be justified in terms of choice, competition, innovation and enterprise.


We would argue, however, that there are a number of structural and system issues, applied by central government policies and funding, that are working against choice, competition, innovation and enterprise. The frozen home undergraduate fee, the lifting of student number caps, the focus on the ‘Russell Group’ as a secondary school performance measure, Brexit and the negative messaging around international students is creating an environment that is increasingly fragile, unstable and unsustainable. We hope this review surfaces these issues, enables them to be creatively addressed and opens up a debate about the importance of diversity in the HE ecosystem and how this diversity can ensure that significant economic, social, cultural, and public good that universities bring to their local communities and regions can continue to develop and grow.


04 April 2023