Students and Universities - Innovation, Universities, Science and Skills Committee Contents

Memorandum 105

Submission from the Quality Assurance Agency for Higher Education

  In my letter of 26 March 2009, with which I enclosed a copy of the progress report on the thematic enquiries[378] we have been undertaking into media stories about higher education, I wrote that I would shortly be providing you with additional information, in the light of your Committee's questions to me at the evidence session on 9 March 2009.

This submission contains the following information:

    — an answer to the specific request made by Dr Harris in respect of my remarks on primary and secondary evidence, together with comments concerning the possible future development of institutional audit (Annex A);

    — our annual report to HEFCE explaining the work of QAA in England during the academic year 2007-08 (Annex B)(not printed);

    — a paper with documentary evidence of the follow-up activity undertaken by institutions consequent upon the receipt of judgements of "no confidence" and "limited confidence" in their institutional audits (Annex C) (not printed);

    — report on QAA by an independent panel including international membership (Annex D) (not printed);

    — a guide to the Academic Infrastructure (Annex E) (not printed);

    — a guide to the qualifications framework that now underpins all HE qualifications in England, Wales and Northern Ireland (the FHEQ) (Annex F) (not printed);

    — a copy of the report on the Verification of the compatibility of the FHEQ with the Framework for Qualifications of the European Higher education Area (FQ-EHEA) (Annex G) (not printed);

  I am submitting this additional material because I came away from the evidence session unsure that members of your Committee (or at least the small number present on that occasion) had as full an understanding as they might need, not only of the work of QAA but also of the general organisation of quality and standards in UK higher education as it currently exists.

  In particular I wish to dispel the notion that QAA is a "toothless watchdog", because it is not true.

  As a number of your witnesses have made clear, QAA's institutional audits are no easy touch. Since 2002 we have interviewed more than 10,000 students and a similar number of staff in HEIs, to discover whether their institutions' views of themselves and the way they assure their own standards stand up to scrutiny. This contrasts markedly with the handful of individual complainants who have written to us since last summer and with the equally small number who have responded to your Committee's invitation to make submissions. Every audit has led to both commendations for good practice and recommendations for action, categorised as being either "essential", "advisable", or "desirable", and these are almost invariably accepted and acted upon.

  Annex C (not printed) provides excerpts (by way of illustration of our effectiveness) from QAA Board papers, which describe the specific responses and actions from those institutions that received judgements of "no confidence" and "limited confidence" in their institutional audits between 2003 and 2007. The information in respect of the American Intercontinental University London (AIUL) is of particular interest, as it is the only institution, so far, to which we have given a judgment of "no confidence". You will note the way in which the University made root and branch changes to its provision and management in the light of our recommendations. You may also wish to note that the Senior Vice-President and Academic Dean of AIUL (the academic head) at the time of the audit was the author of a written submission to your Committee and has been a witness before you, one of the more critical voices in respect of QAA. I am pleased to say that following its wholesale restructuring, AIUL is now in good standing with QAA.

  Annex D (not printed) is the report of an international panel which inspected QAA in 2008 to assess our compliance with the European Standards and Guidelines for Quality Assurance in Higher Education (ESG). While I would commend the whole report to you, as it provides much useful contextual information (paragraphs 8-16 offer a helpfully succinct account of the development of both quality assurance in the UK and QAA), the final paragraph is particularly relevant:

    "QAA's overall performance against the standards of the ESG is very high. Where the Panel has made detailed comments on particular aspects of its work, these are designed to deliver further incremental improvement to an already strong organisation. QAA is fit for purpose, well-led and well-managed at both Board and Executive levels. The Panel has been consistently impressed by the calibre and professionalism of all those contributing to the work of QAA in maintaining quality and standards across HE in the UK."

  My reading of some of the lines of enquiry pursued by you and your colleagues in your evidence sessions suggests that there is surprise that the autonomous status of higher education institutions should allow them to set their own academic standards. Why there should be this surprise is not clear to me, as it has always been the case and does not represent some recent departure from established practice. Autonomy is inherent in the legal status of HEIs' degree-awarding powers, which gives each of them (118 with powers to award taught degrees) the right to award whatever qualifications they wish, so long as the students are following a course of instruction. That is the nature of their autonomy, and its virtues are that it gives them the freedom to experiment and innovate, allows them to respond quickly to local needs, and saves them from the deadening and ossifying effects of state direction and control. Autonomy, however, has to be exercised responsibly, because society needs to be confident that there is reasonable consistency in the way HEIs exercise their individual awarding functions. They need to be able to demonstrate that, collectively, they comprise an effective national tertiary qualifications system. This has been done through the development of the Academic Infrastructure (AI), which in its totality provides the necessary statement of UK-wide expectations of degrees. Annex E (not printed) explains how the AI provides all HEIs with a shared starting point for setting, describing and assuring the quality of their courses. Annex F (not printed) provides detailed information about one of the central elements of the AI—the Framework of Higher Education Qualifications in England Wales and Northern Ireland (FHEQ). The FHEQ has been verified as compatible with the Framework for Qualifications of the European Higher education Area (FQ-EHEA). A copy of the report is included (Annex G) (not printed).

  The alternative to this moderated self-regulation (moderated, that is, by QAA, which checks that HEIs are managing their responsibilities effectively, by external examiners who oversee the standards achieved by students, and by the professional, statutory and regulatory bodies in those areas where the award of a degree confers entry to a profession) would be a centralised inspectorate which would judge the quality and standards of individual programmes and qualifications. In 2007 alone, 650,000 HE qualifications were awarded, covering about 50,000 different degree courses. They were taught by about 170,000 academic staff, leaders in their fields of research and scholarship. Although no detailed statistics exist on the numbers of external examiners currently in post, they are generally thought to number between 20,000 and 25,000. The costs of a national HE standards inspectorate, regulating in detail 118 awarding bodies (cf the five awarding bodies for secondary education qualifications) would be huge, and the benefits would be very unlikely to outweigh the costs. Not only would such an organisation have to check the assessment standards directly (an activity that would last for most of the year, given the variety and timing of assessments now prevalent), but a way of establishing and approving the appropriate standards across all 50,000 courses in the 118 institutions would have to be developed, and agreed with the academic community. Unless the idea would be to turn universities into state-controlled bodies and introduce a single national curriculum for higher education, which would put an end to the UK's distinctive, successful, and internationally admired system, then the current arrangements represent a very good balance of effectiveness, efficiency and economy that respects diversity, supports academic standards and promotes quality.

  That is not to say that there is no room for change and improvement, both for HEIs and for QAA. As well as requiring those providers that are close to or below the acceptable threshold to improve, every institutional audit (whatever the auditors' judgement) results in recommendations for improvement in the institution concerned, and the audit reports collectively provide a wealth of information and intelligence to guide good practice across the higher education sector. During the past year, we have been considering how effective the current institutional audit process is in delivering the sort of reassurance that the changing profile of students and employers is now expecting. We discuss this further in Annex A, and our early thoughts are to offer more information on the areas of recent public interest, while not losing sight of the other fundamental elements that underpin the quality and standards of HE programmes and awards. This could require longer audit visits, however, or more documentation, and we are always properly conscious of the considerable pressure on us from the "better regulation" interests, not to add to institutional burdens. The balance between "light touch" and "right touch" has to be struck carefully.

  I hope this additional information may help your Committee to a better understanding of the complexities surrounding matters of quality and standards in higher education. As I have said in previous correspondence, we continue to stand ready to assist your Committee in any way we can.

March 2009

378   QAA, Thematic enquiries into concerns about academic quality and standards in higher education in England, Final report, April 2009 Back

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