Written evidence from Ulster University (QHE 48)

 

 

Executive Summary

 

 

Introduction

1.                      Ulster University, located in Northern Ireland, was founded in 1984 by Royal Charter. The University is an independent educational charity registered with the Charity Commission for Northern Ireland. The University is a multi-campus University with over 25,000 students and employing over 3,000 staff. Additionally, there are approximately 5,000 students currently studying for Ulster-accredited qualifications at other institutions or via its e-learning provision. Ulster receives its funding from the Department for Employment and Learning Northern Ireland (DELNI) and charges the capped maximum £3,805 tuition fees to students coming from Northern Ireland and non-UK EU countries.  The University charges fees of £6,000 for GB students. 

2.                      Currently the proposals for a TEF are not intended to apply to Northern Ireland Universities.  The consultation on quality assurance has been jointly published by the funding bodies for England, Wales and Northern Ireland although whether Northern Ireland will follow the same model as England is not yet determined.  The University has provided a response to the consultation.

 

  1. We note that there is no representative from Northern Ireland on the select committee and wish to ensure that a Northern Ireland perspective is included in the consideration of the application of the quality assessment review.  It is our view that, as much as possible, a UK-wide system should be maintained to protect the UK HE reputation as a whole.  We have also included comment on the proposed TEF as we consider that there would be merit in incentivising teaching excellence linked to additional funding for subjects demonstrating excellence and, in this event, we would welcome the TEF being extended to Northern Ireland. 

 

What issues with quality assessment in Higher Education was the Higher Education Funding Council for England's (HEFCE) Quality Assurance review seeking to address?

 

  1. The starting point for the current consultation and proposed new system for quality assessment review has, at no point, indicated that there are issues with the current system. 

 

  1. HEFCE advised that the main purpose of seeking views from the sector was “to explore new models and approaches to quality assessment, while building on past experience, good practice, and our existing international reputation”.  It continued that it was “looking to develop innovative approaches that are risk-based, proportionate, affordable, and low burden, and that will be widely respected in the UK and overseas”. There is recognition within the sector that the existing process of external review on a cyclical basis has become overly burdensome for established providers with a strong track record as evidenced by outcomes of previous review exercises.  Whilst there may be some benefits to be gained from these reviews these are diminishing as institutions have become more mature and confident in their own processes, whilst the bureaucracy associated with the reviews remains high.  There is therefore merit in rebalancing the system.   A more proportionate and targeted approach would help to streamline regulatory demands and burdens on institutions, while maintaining the integrity of the quality assurance system.

 

  1. Subsequent consultation documents have been more wide-ranging in their scope and have included considerations around grade inflation, comparability of degree classification systems and academic standards, the role of external examiners in quality assessment, and the regulation of alternative providers.

 

Will the proposed changes to the quality assurance process in universities, as outlined by HEFCE in its consultation, improve quality in Higher Education?

 

  1. UK Universities already have a justifiable and well established reputation for quality.  The question that remains is whether enhancement can be facilitated further through a revised system. 

 

  1. There is potential for some of the proposed changes to impact positively on quality.  However, some of the proposals may have unintended consequences.

 

  1. There is a danger that the increasing fragmentation of the various elements of the system loses the benefits of a single-event cyclical external review which provided the assurances required by all stakeholders and that multiple reporting methods would not be helpful or efficient in this regard.    In addition, the increasing fragmentation within the regions of the UK of operating differing quality assessment systems provides a further risk to the international reputation of each of its constituent parts. The need for all awards of UK HEIs, regardless of where they are offered, to be subject to a UK-wide quality assessment system should be maintained.  The current system permits quality assessment from other jurisdictions to be obtained as well (and in some cases, this is a local requirement).  Again, the reputational brand of UK HE is maintained through these processes and is often the motivating factor for international partners seeking collaboration.

 

  1. It also aids student mobility.  UK students and graduates gain competitive advantage in the labour market from the international comparability of their qualifications, the recognition for which is often based on the perceived standing of the relevant assurance or accreditation system.  Poor quality provision by a single institution can damage the overall reputation of UK Higher Education.

 

  1. There are also potentially inherent dangers in the proposal to conflate the roles of funder, regulator and quality assurer.  Such a move would undermine the strong support, and consensus within the sector, for the principles of co-regulation and shared responsibility.

 

  1. We are supportive of a risk-based, proportionate and contextualised process, based on a solid understanding of the provider’s capacity to manage its own quality as demonstrated by its past track record.  We commend an approach that retains important key principles from the current system including respect for institutional autonomy, external and independent peer review and student partnership.

 

  1. We would also welcome proposals to make better use of existing quantitative and qualitative data sources with more emphasis on student outcomes rather than process, whilst accepting some of the limitations in terms of the need for transparency, robustness and contextual considerations.

 

  1. We have reservations about the Funding Councils’ proposals to replace external peer review with the inclusion of a review of institutional processes in their own accountability reviews – in the case of Northern Ireland - on an annual basis.

 

What should be the objectives of a Teaching Excellence Framework ('TEF')? 

 

  1. The objectives of a TEF should be to promote, enhance, recognise and reward excellence in learning and teaching.  This should result in an enhanced academic experience for students irrespective of mode, level, type of funding or provider type.

 

  1. More specifically, TEF should:

 

  1. However, there is no shared understanding of ‘teaching excellence’.  Excellence will and should vary by discipline and programme, by institution and in the context of the student profile.  It is therefore important to maintain a subject focus within the process. It is also impossible to extract teaching from learning and the teaching and learning experience as a whole should therefore be considered.


a. How should a TEF benefit students? Academics? Universities? 

 

  1. TEF should drive institutions towards improving the learning experience for their students who should be the primary beneficiaries. It should drive the enhancement of teaching through proactive staff development that ensures staff have the opportunity to develop their teaching skills and are exposed to best international practice and scholarship in their discipline areas.  TEF should also provide opportunities for academics to have their achievement recognised and rewarded with enhanced opportunities for professional recognition and career progression.  Universities could also benefit from the enhanced reputation that the imprimatur of an excellence accolade might confer.  This might lead to better recruitment of both home and international students. 


b. What are the institutional behaviours a TEF should drive? How can a system be designed to avoid unintended consequences? 

 

  1. TEF should facilitate engagement of all staff in Universities in determining what excellence in teaching and learning looks like for their discipline and in the context of their University and the individual course and with the student cohort enrolled.  TEF should facilitate excellence by permitting and recognising different and innovative approaches within these contexts.  It is consequently necessary to avoid identifying a set of metrics common to all and applied at institutional level or to select a subset of metrics that is likely to favour particular types of institution but to allow subjects to demonstrate excellence within their own context.  Metrics should also be selected with a view to minimising the opportunities for ‘gaming’ or encouraging short-termism. 

 

  1. It is important to avoid a system where areas deemed not to be excellent are considered substandard and that students on these programmes are receiving a second-rate experience. 

 

  1. The HEA has proposed a model whereby, once a baseline of evidence has been provided at Institutional-level, subjects can put forward a ‘case for excellence’ which is peer-reviewed, results in an award at different levels and provides feedback to enable further enhancement and a subsequent resubmission for a higher level of award[1].  We would consider such an approach to be facilitative and developmental and that it warrants consideration. 


c. How should the effectiveness of the TEF be judged?

 

  1. If a progressive scheme whereby different levels of award are possible (as in the HEA’s proposed approach), the improvement in the number of areas of excellence would be evident in the number of institutions/subjects progressing through the award structure and the number of higher level awards given.  It should also be evident in higher levels of reported student satisfaction, and greater parity of esteem between teaching and research.

 

How should the proposed TEF and new quality assurance regime fit together?

 

  1. Currently, it is only proposed to introduce the TEF in England, whilst variations on the quality assurance regime are intended to be introduced in Northern Ireland and in Wales.   Whilst the two systems should provide a level of complementarity this would therefore only be possible in England.  It is likely that as the TEF and quality assurance regimes evolve and are refined, they would do so in reference to each other, and this would therefore lead to increasingly complex variations and adaptations in Northern Ireland and Wales and further divergence.  A simple, integrated system would be preferable.

 

What do you think will be the main challenges in implementing a TEF? 

How should the proposed connection between fee level and teaching quality be managed? 

 

  1. The main challenges in implementing a TEF currently are related to the proposed link to permitting institutions to raise fees in line with inflation and the timescale associated with this.  For the framework to be successful there needs to be widespread buy-in from the sector and the student body.  The current timetable is challenging and may prove to be problematic in this regard.  Whilst a period of piloting any new system would be very welcome, the consequent need to introduce a TEF-lite approach in the first instance before a system is fully developed could constrain future choices in methodology and outcomes given that discussions are at an early stage and the timescales for introduction are short. 

 

  1. A huge challenge arises from the need to identify and agree data and metrics that will be used to evidence teaching excellence.  A ‘one-size fits all’ set of metrics could not be agreed for the Research Excellence Framework 2014 and would be equally impossible to achieve across all institutions or different discipline areas for measuring teaching excellence.  Existing metrics have not been designed to measure teaching excellence and to use them now for this process would undermine their original purpose.  Excellence in teaching and learning is a developmental process and should be context specific and cannot be measured by existing metrics alone.   Peer review must continue to be an essential element of assessing teaching excellence.


a. What should be the relationship between the TEF and fee level? 

 

  1. The linking of TEF outcome to student fess is of concern to institutions and student representatives.  If TEF is linked to fees, then it should be possible for all institutions, on achieving the required level of excellence, to charge the maximum fee. This would be likely to result in all institutions achieving this over a period of time at which point the TEF would become redundant. 

 

  1. In Northern Ireland the link to fees does not apply in the way as, currently, fees are capped at £3,805.   There would be little purpose in Northern Ireland adopting the TEF, therefore, if TEF is purely intended to operate as a mechanism for fee-setting.  However, comparisons would and should be made between the quality of provision across similar institutions within the UK and institutions, students and other stakeholders will wish to be able to do this.  The fragmentation of the system will hinder any such benchmarking by stakeholders.   

 

b. What are the benefits or risks of this approach to setting fees?

 

  1. The benefit of linking TEF to fee setting is that it gives the process teeth and consequently, raises the importance of teaching excellence.   However, the difficulties of measuring excellence at Institutional-level and the likely resultant two-tier system are likely to undermine any such system.  Teaching quality may be variable within institutions/subjects and at different times and any system should take account of this.

 

RECOMMENDATIONS FOR ACTION

 

  1. The following elements of the existing quality assurance system should be retained (possibly with some refinement);

 

 

October 2015

 

 

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[1] https://www.heacademy.ac.uk/blog/hea%E2%80%99s-proposed-%E2%80%98case-excellence%E2%80%99-approach-tef