Written evidence from Miranda Harmer (WOS0064)


  1. How does the Student Panel provide input to and operate within the OfS? How often were you consulted on the OfSwork and did you feel your views were listened to? Are there any examples of times when the OfS made changes to decisions because of the Panel’s input?

Formally we met once a quarter. We were given an agenda, briefing paper, and provided input through discussions and workshops.

I was on the Panel during the Covid years (2020-2022), so we had many more meetings. The student engagement team also advertised additional opportunities, but we represented the OfS / provide student voice externally to others in the sector (e.g. University Minister’s HE taskforce on mental health and wellbeing, Association of University Directors of Estates, Inside Government, HEPI, Department for Education etc.)

I do believe that individual panel members may have been approached to feed into certain topics based on their specialisms or lived experiences (mature, care leavers etc.).

I feel that our views were listened to, to a certain extent. There were often times we were told it wasn’t within the OfS’ remit, or there were suggestions that we could return to that topic at a later date, where 90% of the time the OfS never did. However, they did listen and consider our feedback on the topics which they asked for. For example we may have been participating in a workshop on the Access and Participation Plan, so of course our views were listened to and considered.

It is rare that conservatoire education or small and specialist institutions are involved in these top-level discussions when policy and procedures are being created, so it was a fantastic opportunity to bring our often unique perspective and experiences to the table.

If we had been given the opportunity we would have met more frequently.


a. Did you feel you had a free hand to raise issues of interest to students, or were you mainly asked to comment on issues raised by the OfS?

We were mainly asked to comment on issues / topics that were put on the agenda by the OfS. As with life issues can be interconnected, so it would have been impossible to solely discuss an issue that was raised by the OfS without broaching other topics. There was rarely an opportunity for us to turn that into another piece of work, and we were constantly reminded of our position and therefore didn’t have the authority to mandate the OfS’ work, even though we entered the role believing we were there in an advisory capacity. We were also reminded that we aren’t representatives, which felt like their way of dismissing things they either didn’t want to hear, or didn’t have the capacity to work on.


b. Did you feel that the Student Panel was representative of the entire student population?

No, but it’s an incredibly difficult thing to achieve given the diverse nature of the UK population. I believe the OfS did a good job at trying to recruit people with diverse backgrounds and specialisms, but how can 16 people be truly representative of 2m students? There was a good diversity of thought, experience, and political ideologies among us.

There was an expectation that we would be able to gather widen student opinion to inform discussions. During the first round of interviews (group stage) we were asked how we would gather student opinion but then before the first meeting we were told that everything was confidential. After our first meeting I approached the OfS and asked what topics we could and couldn’t gather external opinion on, to which they added a column to the agenda which highlighted topics we could speak about with others first. A lot of the feedback came from our personal lived experiences, but because of the personal qualities of the Panelists we tried to be as representative as possible rather than bring personal opinion.


2.  How well does the OfS engage with students more broadly? To what extent do mechanisms such as the Student Panel, the student representative on the OfS’ Board and the National Student Survey really drive the work of the OfS?

It get the impression that the OfS engages relatively well outside of the usual suspects (OfS Student Panel and NUS) by hosting roundtable opportunities, formal consultations etc., but it feels like they are limited due to internal resource capacity (staff members), and the lack of awareness of the OfS by the wider student population.

It feels like the OfS’ work is influenced by others with the student voice shoehorned in - but this unfortunately is quite typical of my own experiences in student representation. Realistically the Student Panel could have more of a collaborative say in what work is mandated based on current student experiences.


a. Are these processes overly formal and consultative? Should student representatives such as the Student Panel be supported to undertake student-led research and operate more independently?

Perhaps there is too much formality to these processes of gathering student opinion. The danger with consultations and round table discussions is that many issues can be raised which makes it easy for them to be ignored or pushed to one side in lieu of other priorities - I experienced this during our discussions.

There was a promise of the Student Panel being able to undertake research and we began mindmapping possible topics, but this never came to fruition. I believe there was a reluctance on the OfS’ side due to staff capacity and because of potential research topics, possible outcomes, and potential backlash from the sector or the public.


3. Students are involved in some OfS processes, such as Teaching Excellence Framework reviews. Does the OfS ensure that students are involved in all of its regulatory activities, including in relation to quality, student outcomes and Degree Awarding Powers assessments? Does the OfS have a clear, consistent approach to student input, and is it clear why students are consulted in some areas and not others?

On the B conditions changing, we were consulted on these changes and had workshops with internal teams but as far as I am aware Student Panel members were only involved in the shaping of the regulatory activities.

I suspect, like with the rest of the sector, that sometimes the student voice is merely ‘forgotten’. With the Blended Learning Review for example, four panelists reviewed institutions and assisted with the research, but only one was credited - eventually... There were often times when we would receive an email 1h before a press release was being made regarding a variety of issues (the biggest one for me personally was the closure of a performing arts provider). 

There is a student engagement strategy but we had little involvement in it from my own recollection (I believe it launched before I joined the Panel), so it doesn’t feel like the OfS has a clear, consistent approach to student input on regulatory activities.


  1. Does the OfS make clear how student input impacts on its policymaking and priorities? Should the OfS report more clearly on this, for instance through an annual report on how student views have shaped its work?

If I looked closely enough there were things I observed that were amended based on the Student Panel discussions, but on the whole there isn’t a lot of clarity on this. An annual report on student voice impacting OfS’ work would be a fantastic outcome of this inquiry: it would hold the OfS to account and give the Student Panel more ownership over the work they do and impact they have.

Currently the OfS’ comms strategy feels very geared towards senior leaders, administrators and policymakers - everyone but the main stakeholder. I suspect some of this can be put down to growing pains of a new organisation, but more communication directly to students in an accessible way (language, tone etc.) would encourage more students to be involved.


4. Has the OfS clearly set out what it views as the interest of students? Do you have concerns that the OfS’ view of the student interest is driven by political priorities, as opposed to student engagement and input?

I don’t believe the OfS have clearly set out what it views as the student interest. It feels like the OfS’ work and perspective of student interest is driven by other external factors rather than through real student engagement. As a Panel we were asked our experiences and perspectives on particular topics and issues - it was always top down rather than bottom up student engagement. Being realistic, it would be beneficial for the Panel to have more of a collaborative role in the regulatory / research work that the OfS does. Perhaps more engagement with the DfE?


a.  Do you feel that the OfS is sufficiently independent of government? Did political considerations ever give rise to conflicts between the Student Panel and senior OfS staff?

I believe that there were instances where the OfS did not feel independent of government, particularly within senior leadership. The Student Panel was made aware that our position was one of privilege, and there were comments and concerns about having that privilege revoked. This made the Panel’s position feel very precarious - there were worries about damaging future iterations of the Panel and destroying independent and impartial student engagement within the OfS and its work, which impacted the engagement and voice of the Panel. 


5. The OfS and the legislation underpinning it place great focus on the value for money of higher education. How do students view whether higher education provides value for money? Is it possible for the OfS to measure value for money objectively or do these judgements reflect political and economic priorities?

I believe that this discourse of students being a consumer has been very damaging for all corners of the sector, particularly within the performing arts. I can only speak from my personal experiences: with vocation-led study programmes we are training to become exceptional at a particular craft with world leading artists. Music is a very expensive course to run because of the individual timetables and the high rates for hourly paid lecturers (e.g. instrumental teachers). We are going to study because of the teaching, access to industry-standard facilities, and to make lifelong connections. Personally I had to rationalise and perceive it as an investment in my career and therefore I believe my own educational experiences provided value for money.

This vastly differs from person to person however. The entire student experience has to be accounted for when students think about value for money, so this includes the education, the facilities, the communities. The disparity in provisions offered by providers during the pandemic brought this topic to the forefront of the student’s minds.

With my little insight it appears that the OfS can measure value for money objectively regardless of external pressures or priorities. The problem is the way in which they measure it. For example, analysing the annual salary of graduates from particular courses and defining a certain salary as value for money regardless of the societal impact that course may have had on the community or country.


6. Do higher education institutions give prospective students adequate information on what they can expect to receive as part of their studies? Given the amount of debt students take on, is enough information provided on how many contact hours they will receive, or whether their course may be cross-subsidising other courses at the same institution?

There is a disparity among HEIs and I feel I can only talk about conservatoires. Prospective students do receive a lot of information about the course, teaching staff, contact hours, extracurricular activities etc., to help them make an informed decision. But the majority of the time students go to a conservatoire because of their reputation or because of a particular teacher. I don’t believe cross-subsidising goes on much at conservatoires because of how expensive it is to run each course per student.


7. To what extent do higher education providers engage with their students and involve them in their decision-making? Is such activity mandated by the OfS or is it undertaken at the discretion of providers?

Again I can only speak for conservatoires and other small and specialist institutions: student engagement is undertaken primarily at the discretion of providers, however the OfS does mandate student involvement in some of their activities, but only in the activities that come within the remit of the OfS.

  1. What changes would enable the OfS to better reflect the views, interests and priorities of students?

Overall, giving the Student Panel more opportunities to proactively influence and advise within the OfS - this feels like a cultural change rather than a procedural one. It has such great potential, but there were many missed opportunities during my tenure.


25 April 2023