Written evidence from the University of Warwick (QHE 66)
1.1 The HEFCE review was intended to develop an approach to quality assurance which would be fit for purpose for the next ten years, recognising the changing nature of the higher education sector both globally and in the UK. The HEFCE indicated that the review was not intended to assess the effectiveness of the current system operated by the QAA, nor to cast doubt on its ability to secure academic standards and the reputation of higher education in the UK. It should be noted that the UK Higher Education system is already recognised for its quality.
1.2 However the current quality assurance review methodology operated by the QAA does not differentiate significantly between providers. Concern has been expressed by the sector that the methodology is administratively burdensome and does not have a sufficiently differentiated risk based approach. There is also a concern that the current methodology lent itself to a ‘tick-box’ approach to compliance with the UK Quality Code. A national quality assurance process should be risk-based and proportionate; it should recognise strengths in established providers but ensure a rigorous approach to those entering the sector.
1.3 The proposed approach of the HEFCE was therefore to enhance externality in the oversight of quality and standards through institutions’ own governance procedures and external examining and other measures, while ceasing to operate cyclical reviews. It was intended that this would therefore allow institutions to develop internal quality assurance processes which were appropriate for their contexts. Institutions already have in place established quality assurance processes and are also subject to scrutiny by professional, statutory and regulatory bodies (PSRBs).
2.1 The intention of the existing QAA quality assessment methodology and that of the approach proposed by HEFCE is to:
2.2 Improvement is therefore achieved through institutions’ own approaches to continual enhancement. The HEFCE’s proposals in themselves will not therefore drive an improvement in quality in Higher Education.
2.3 The HEFCE’s proposals include measures which it would argue may enhance external oversight of academic standards and greater standardisation of academic outcomes across the sector:
2.4 A framework which intends to improve quality in Higher Education should support universities in managing and delivering high quality teaching and learning. It should help encourage esteem and reward for high quality staff.
a) 3.1 A TEF should benefit universities through the recognition of excellence and facilitating the sharing of good practice across the sector. Collegiality in the review and development of teaching practices and associated procedures is fundamental to the sector. A TEF could support and enhance such an approach but should not undermine it. A TEF could benefit an institution through the enhancement of its reputation nationally and internationally through public recognition of teaching excellence.
3.2 However the esteem that leading universities already place on teaching should be recognised and schemes for the reward of excellence at an individual level could be introduced. A TEF, if judged at the institutional level, is otherwise unlikely to benefit individual academic staff directly.
(b) 3.3 A TEF should be designed to drive the ongoing enhancement of teaching and learning to improve students’ learning, and recognition of the value of teaching within institutions. However this must take into consideration the differing contexts within which providers operate. The size of a provider, the characteristics of student populations, the type of delivery used and the disciplines taught, will all shape student expectations and the definitions of excellence.
3.4 In order to ensure that a system does not have unintended consequences, it is critical that the methods for assessing excellence are appropriate and a limited range of measures should be used. This should include a measure to reflect the proximity of teaching to high quality research activity.
3.5 In addition, the mechanisms for collation and publication of the data should be secure and aligned to the requirements of the Information Commissioner.
3.6 The assessment of quality has to be nuanced and to reflect the individual contexts of each provider, as the expectations and abilities of students will be significantly different. There could be a core set of metrics which are used for all institutions and an additional set from which institutions could choose to reflect their context. A judgement would then need to be made as to how these elements are to be weighted.
3.7 In addition a textual commentary would allow providers to set out how they work towards and achieve excellence within their own environment and form a qualitative measure of the teaching environment. This would be akin to the assessment of research environment which contributes to the Research Excellence Framework (REF). This narrative should allow for a measure of the research environment in which the student is a learner and demonstrate how excellent teaching is informed by the best research.
3.8 The use of metrics which do not measure quality and excellence appropriately would have unintended consequences, including potentially negative impacts on institutions’ individual reputations and the reputation of UK HE. A system must recognise such differences and not introduce a methodology which does not reflect the diversity of the sector.
3.9 The TEF should also be risk based in its approach with institutions considered to be ‘high risk’ examined more frequently than those considered ‘low risk’. In addition assessment should recognise the extent to which universities’ teaching provision is already reviewed by PSRBs.
(c) 3.10 The success of the TEF could be assessed through the metrics used to assess providers’ own teaching excellence. Should they increase over time this would indicate that improvements were ongoing. While international indicators might also be sought, such measures are not currently in place to assess the TEF appropriately.
4.1 Ideally there should be one regime which both assesses whether providers are meeting threshold standards and which also rewards excellence but at a minimum the two systems should be closely aligned to avoid duplication and extension of the regulatory burden. The regimes need to reflect the way in which institutions are responding rapidly and flexibly to the changing environment around them. A compliance approach risks stifling innovation and leading to excessive bureaucracy in the delivery and oversight of teaching.
5.1 The main challenges will be as follows:
6.1 The University is strongly opposed to linking the TEF to a potential increase in fees. It is not clear that the methodology will be sufficiently robust to be used in this way nor how variations in the quality of teaching will be reflected if fees are set at an institutional level, rather than subject level. Similarly if fees are permitted to rise for some disciplines in an institution and not others, there will be implications for the reputation of those which are not classed as ‘excellent’. If there were an impact on student recruitment this would then have a further negative impact on the financial health of those disciplines.
6.2 There is a risk that unintended behaviours would be incentivised depending on the method of assessment used. In addition students would have to bear a higher level of fee when it is possible that their own feedback (through NSS) will be used as one of the metrics.
6.3 Where fees are not governed by legislation, a number of factors are taken into consideration in setting those fees including market position, reputation and costs. The introduction of variable fees based on TEF outcomes would not create a true market based on all these factors.
30 October 2015