Written evidence from the University of East Anglia, UEA (WOS0057)


The University of East Anglia (UEA) is a UK Top 30 university (Sunday Times, Guardian, Complete University Guide) and is ranked in the UK top 20 for research quality (Times Higher Education REF2021 Analysis). It also ranks in the UK top 10 for impact on Sustainable Development Goals and UK top 25 in the Graduate Outcomes Survey. Known for its world-leading research and good student experience, its 360-acre campus has won six Green Flag awards in a row for its high environmental standards. The University was awarded Gold in the Teaching Excellence Framework and is a leading member of Norwich Research Park, one of Europe’s biggest concentrations of researchers in the fields of environment, health and plant science. www.uea.ac.uk    

UEA welcomes this Committee’s inquiry. It is a timely opportunity to reflect on the development and success of the OfS and its impact across the whole of the UK HE market. We welcome the Committee’s scruitiny of the role of the regulator and the financial sustainability of the sector.  We would urge the Committee to recommend a change to government policy by replacing anti-competitive performance indicators with alternative metrics that promote fairness, equity, and evidence-based performance in the sector.

Like many universities in the UK, UEA’s financial sustainability has been affected by a combination of cost pressures including the impact of the pandemic, the freeze in home tuition fees, the lifting of the student number cap, A’ level grade inflation, the fluctuation in the international student market, the inflation in the cost of living and our infrastructure investment requirements. UEA has been impressed by the response of the OfS in respect of our current financial position. In our experience, the OfS has struck an appropriate balance between information requirements and pragmatism.

Remit, Capacity and Performance of the OfS

1)   If the university fails to meet the need to have processes to monitor quality (as exemplified in condition B7)

2)   If the university materially fails to meet the established data-related benchmarks and requirements for quality (for example those for student outcomes set out in condition B3) and

3)   If the university needs to report an event set out in regulatory advice 16.

The OfS charges a fee to institutions that are subject to investigation. This creates a perverse incentive for the OfS to extend/increase the number of investigations. However, it should be noted that the OfS has just launched a consultation on this.


Requirements of the Regulators’ Code 

  1. It is long and complex, a total of 220 pages, up from 166 in 2018)
  2. It has not been fully or consistently updated, for example paragraph 30 refers to the data futures project and 2018 in the future tense, although the new data arrangements have been in place since 2022.
  3. In places it seems to be out of date, for example paragraph 33 mentions the Quality Assurance Agency as the designated quality body, although it was established months before the publication of the revised framework that this relationship would end.
  4. It is confusingly presented, for example paragraph 44 is simply missing, whereas paragraph 363 has 28 subclauses.


Financial sustainability of the HE sector


Urgent policy change

In promoting the interests of students and considering the overall sustainability of the HE sector, the OfS should highlight, and seek to mitigate, structural concerns in the UK HE market, particularly where they are deliberately driven by government policy.  One such area is the impact of DfE performance indicators for 16 to 18 years olds, that ask schools and colleges to measure successful applications to Russell Group universities and Oxbridge.

Schools and colleges apply this data for marketing and recruitment purposes, using their students’ progression to Russell Group universities as a measure of their success and reputation. This indicator is therefore driving a disproportionate application interest in Russell Group institutions. The relatively recent removal of the student number cap, and the grade inflation associated with teacher assessed grades, has compounded this disproportionate interest.  As a result, Russell Group university numbers have swelled in recent years, at the expense of non-Russell Group universities like UEA. The increasing polarisation of wealth within the UK HE market is essentially driven by government policy. Many non-Russell Group universities have been forced to make cost savings as a result of falling income.

The Russell Group is a self-selecting, advocacy organisation that promotes only the interests of its paying members. It is not subject to any qualifying measures of quality. UEA is not a Russell Group member, but we outperformed eight of the Russell Group universities in our most recent Research Excellence Framework results. It is deeply flawed for the DfE to be (inadvertently) skewing the HE market by driving more applications to the universities represented by the Russell Group.

UEA is asking the DfE to make a small adjustment to the performance indicators for 16 to 18 years olds. Rather than recording how many students progress to Russell Group universities, the DfE should use independently verified, evidence-based measures of university success and reputation, such as the Times Higher Education rankings based on the Research Excellence Framework and the Teaching Excellence Framework. This small adjustment would mean that schools and colleges would no longer be incentivised to discourage applications to non-Russell Group universities.

Therefore, there is a substantial place-based impact of the DfE promoting Russell Group universities in this way. Cambridge University is the only university in the east of England that is a member of the Russell Group. Effectively the DfE is suggesting that all HE institutions in the east of England are of less value than any in the Russell Group. The DfE must re-rationalise this policy in the context of Lifelong Learning policies and apprenticeships which are likely to drive more local interest in flexible, short-term, non-residential university course offers.

UEA would welcome the opportunity to provide the Committee with further evidence in respect of this area of policy reform.

07 April 2023