Supplementary written evidence submitted
by the Quality Assurance Agency for Higher Education (QAA)
INTRODUCTION
1. The Higher Education White Paper, Students
at the Heart of the System, highlighted what is good about
the quality assurance system, and proposed some development of
the way in which it operates. We welcome this opportunity to respond
to those comments and proposals, and would be happy to answer
further questions from the Committee if required.
2. Independent, external quality assurance will
continue to play a critical role in the regulation of higher education
in England and the safeguarding of its reputation internationally,
and we welcome this vote of confidence in our work.
3. The White Paper described UK quality assurance
as "highly regarded and influential around the world".
It highlighted the way QAA has adapted so far, involving students
in all aspects of our work, strengthening our system for investigating
concerns about higher education, and working closely with private
providers. In addition, the Paper draws attention to our work
on strengthening external examining arrangements, saying it will
lead to "greater transparency, increased consistency of practice
and confidence in those arrangements."
4. We also welcome the Paper's positive references
to other aspects of QAA's work. For example, our key role in assuring
the quality of public information provided by universities and
colleges; our regulation of the highly successful Access to Higher
Education Diploma for adults with few qualifications from school,
and projects such as our coordination of a group developing guidance
on how universities can foster entrepreneurship among students.
NEW REGULATORY
FRAMEWORK
5. To ensure a level playing field, quality assurance
will be extended to cover all UK higher education, including that
delivered in private colleges, but it will be proportionate and
targeted to where the greatest risk lies. We believe the new regulatory
framework can and will work in the interests of students and will
also serve the public interest in a high quality higher education
system.
A RISK-BASED
APPROACH TO
QUALITY ASSURANCE
6. We welcome the prospect of a more diverse
and potentially larger sector, open to new providers delivering
education in new ways. In such a sector, it is right that quality
assurance effort should focus on areas of greater risk to standards
and quality.
7. Our way of working is flexible enough to accommodate
new priorities in higher education, while ensuring the application
of a common framework of quality and standards. Our work across
the UK has already begun to incorporate risk-based approaches.
For example, in Wales, the frequency of our reviews is determined
by risk; and in other review methods the scope and nature of reviews
differ according to factors that could be described as risk. Our
Concerns scheme supports our reviews, allowing us to quickly investigate
concerns that are reported directly to us at any time.
8. However, we believe that every institution
offering UK higher education qualifications should be part of
a common quality assurance framework. This means they should work
to the same UK Quality Code for Higher Education, within the same
qualifications framework, and be subject to external reviews by
QAA. How frequently those reviews happen, and the intensity of
the form they take, is something that we look forward to discussing
further as part of the consultation process.
9. It is also important not to lose sight of
the key role that external quality assurance plays in identifying
and communicating excellence and supporting improvements to students'
experiences, as well as identifying problems and evaluating risk.
The challenges to consider as part of the consultation on this
approach include:
— the
need to develop a set of criteria to measure risk—this is
critical in any risk-based system to avoid it being perceived
as arbitrary;
— the
importance institutions will place on being identified as "low
risk" and the need to respond to their challenges to any
other assessment and categorisation of risk;
— the
need for risk to be monitored as institutions' circumstances change;
and
— the
importance of quick responses when risk triggers occur.
THE PRINCIPLE
OF DEREGULATION
10. Of course the demands of quality assurance
should not be disproportionate. QAA works through the Higher Education
Better Regulation Group to reduce the requirements on institutions,
and also works closely with professional, statutory and regulatory
bodies (PSRBs) to minimise duplication. This work will be further
developed and accelerated. However, quality assurance does need
to be rigorous, to protect students and the integrity of higher
education in the UK. The quality of the education offered by UK
institutions is its strength and the basis of its strong reputation.
QAA's role in maintaining consistency of quality and comparability
of standards underpins this reputation.
PRIVATE PROVIDERS
AND CHANGES
TO DEGREE
AWARDING POWERS
11. The White Paper proposes changes to the criteria
for degree awarding powers. QAA has long been trusted to assess
and advise on degree awarding powers, based on principles and
guidelines set by the Government. We believe that a diversity
of provision could benefit many people and could help widen access
to higher education. However, new providers, including those with
degree awarding powers, must be within the same quality assurance
framework as existing providers.
PUBLIC INFORMATION
12. We welcome the clear recognition of the importance
of public information in the White Paper. Good student choice
must be informed by good information from institutions. Institutions
in England will be required to publish information in the Key
Information Set from next year, but this should not be the extent
of institutions' response to the need for clear information. Across
the UK, institutions are finding new and helpful ways to engage
with the public and with future students, and this work should
also be encouraged.
13. QAA will, in our reviews, be making a formal
judgement on the quality of information that an institution provides
about itself from 2012 (in England and Northern Ireland). This
will reassure prospective students that they can trust the information
on which they are basing their decision and that their chosen
institution is making appropriate use of the information it gathers
and publishes to improve the quality of the student experience.
14. A key element of the information that the
Key Information Set will require institutions to publish relates
to contact hours. Contact hours are not a simple measure of the
quality of a course; a university education is about learning,
not just teaching, and different courses demand different levels
of contact. However, students should know what they can expect,
and it should be delivered. Not only should students have appropriate
contact time with their tutors, they should also receive sufficient
feedback on their work, and their independent learning should
be supported. QAA will be publishing draft guidance for institutions
on effectively communicating practice about contact hours to students
later in the summer.
ACCESS TO
HIGHER EDUCATION
15. The White Paper recognises the importance
of the QAA-regulated Access to HE Diploma, the qualification for
adults returning to education, in widening participation among
low-participation groups. It suggests that the reasons for the
success of the Diploma should be researched and perhaps similar,
or even more flexible, routes into higher education should be
developed. QAA strongly welcomes this proposal and looks forward
to contributing to the research.
— This
year has seen a 40% jump in the number of adult Access to HE Diploma
students accepted onto UK higher education programmes. 19,165
Access to HE students—69% of applicants—successfully
gained places on higher education courses for 2010-11 entry; up
from 13,265 acceptances the previous year.
— Access
to HE applicants were more than twice as likely to come from the
most deprived areas of England and Wales than applicants to higher
education from other routes in 2010.
— In
2009-10, 15% of Access to HE students were Black or Black British;
6% were mixed or other; 5.7% were Asian or Asian British; and
0.4% were Chinese.
— Thirty-eight
per cent of accepted applicants with an Access to HE Diploma were
aged 30+, compared with 5.5% without an Access to HE Diploma.
CONCLUSION
16. The proposals in the White Paper have been
characterised as leading to a consumerist model of higher education.
As fees increase, students' expectations may also increase, and
institutions will have to respond. However, QAA has a track record
of independently safeguarding standards and improving quality
through external quality assurance. We will continue to play this
role in a rapidly changing sector, protecting the interests of
students wherever and however they study, and maintaining the
value of their qualifications.
17. Sir Steve Smith, President of Universities
UK, said the following in response to the White Paper: "The
UK has one of the best higher education systems in the world.
Our rigorous quality assurance system has been vital to this success.
It's encouraging that government is seeking to strengthen this
system while lightening the bureaucratic burden on universities.
It is crucial that this tough quality assurance system applies
in the same way to any new providers of higher education."
We fully endorse this view.
7 July 2011
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