Over at The Disorder of Things, Lee Jones has posted a response made by 80 academics to HEFCE’s Review of Quality Assessment. I have added my name to this, and I am grateful to Lee for his leadership and energies on this response/refusal.

HEFCE proposes a radical shake-up of these arrangements. Its main ideas are as follows.

• The funding bodies will shift from assessing quality directly to merely certifying HEIs’ own internal QA processes as meeting a ‘baseline quality’ threshold. This is described as a ‘light touch’ approach that would supposedly reduce the regulatory burden. The proposals are open-minded about whether any routine checks would ever be conducted once HEIs are certified with a proposed ‘kite mark’. HEIs’ governing bodies, which would assume overall responsibility for quality, would merely certify their ongoing compliance in annual reports. The QAA is apparently to be scrapped. But funders would ‘intervene’ rapidly if there is suspicion of a collapse in standards.
• Internal QA would be guided by data on ‘student outcomes’, presented in an easy-to-follow format (though the proposals, for now, eschew ‘star ratings’ – that’s probably for the TEF). The proposed goal is ‘constant improvement’. This is presented alongside contradictory goals like curbing grade inflation. This is perhaps the most problematic aspect of the proposals, as discussed further below.
• The system of external examiners would be ‘professionalised’ (which assumes we are not already professionals). Externals would be trained and accredited by some additional body. While this is not quite an ‘OFSTED’ for HE, the tendency of the bureaucracy to expand to meet the growing needs of the bureaucracy means it could well evolve into an external inspectorate. At the very least it means external examiners are likely to become progressively divorced from the activities they are meant to be judging.
• To help curb grade inflation, there are also calls for internal and external examiners to form (inter-)disciplinary groups to develop shared assessments of work – a sort of nationwide moderation process. The idea is to help police the pass/fail and 2(i)/2(ii) borderlines. Anyone who has ever marked assessments (i.e. virtually no one at HEFCE) will know that even expert judgements within a single department can vary substantially, but the notion here is that hundreds of academics working within very different traditions and environments with very different learning objectives can somehow agree definitively what constitutes a ‘59’ and what constitutes a ‘60’. At the very least, coupled with ‘professionalised’ external examination, this is likely to create pressures for curriculum standardisation.

Our response focuses upon the following.

1. This is not a ‘light touch’ regime at all. The proposals would merely displace regulatory activity into HEIs themselves and into new regulative spaces such as the external examiner accreditation and macro-moderation bodies (which, of course, HEFCE does not wish even to fund).
2. The proposals do not acknowledge that self-regulation in an era of markets always fuels over-compliance because of its inherent vagueness and because the reputational costs of non-compliance are potentially disastrous.
3. These proposals seek to extend the marketisation of HE. Post-Browne, whilst the cap on fees was lifted to £9k, universities were expected to compete on price, driving ‘efficiency’. The provision of ‘Key Information Sets’ including earnings data for degree programmes would enable ‘consumers’ to make the ‘right’ choices about how to ‘invest’ in their ‘human capital’. The assumption was that students would only be willing to pay high prices for a high ‘return’ on their ‘investment’. Universities would accordingly be pressured into maximising the employability of graduates. Higher quality and institutions and subjects which offered more intellectual capital would expand, while lower-quality universities and ‘irrelevant’ subjects would contract.
4. HEFCE’s QA proposals are an effort to disrupt this status quo by lowering barriers to ‘market entry’ for private providers and thereby trigger the price competition that has so far largely failed to materialise. HEFCE seeks to do this in two ways.
   • By relativising the notion of ‘quality’. HEFCE states that because there is growing ‘diversity of providers, provision, and students’, we should abandon a ‘one size fits all’ approach to quality. It suggests that ‘there are “student experiences” – and therefore different conceptions of “quality” – that could and should be determined by the mission of the provider, the type of provision, and the needs of the student.’
   • By making it easier for ‘new providers’ to attain and retain their accredited status. Rather than being exposed to ongoing inspections by the QAA, all they would need to do is demonstrate compliance with a low baseline and then self-certify thereafter (with or without a ‘probationary’ period included in the proposals).
   • NOTE: the rationale of all this is to deflate the notion of what constitutes ‘quality’ higher education in order to allow private providers who cannot meet current standards to enter the market. An example of what is presumably envisaged is Coventry University College Ltd (CUCL), a subsidiary of Coventry University. CUCL offers part-time degrees in vocational areas like law and accountancy. Its staff teach 40+ weeks per year and consequently are not engaged in research; most are not ‘academics’ but merely ‘deliver’ teaching. It students are denied access to facilities afforded to Coventry University students, like library borrowing rights or participation in the student union – justified explicitly on the grounds that such things are ‘added extras’ and not all students want the same ‘student experience’. As a result of shaving its provision and costs to the bone, CUCL charges fees below £6,000 per year.
5. There is no reason to believe that price competition will benefit students or have any beneficial impact on quality. The whole logic of these proposals is to destroy an existing notion of ‘quality’ HE, defined by tough regulation and the historic culture of British universities, and introduce a variety of possible definitions of ‘quality’, some lower than the current definition. What is called a set of proposals on ‘quality assessment’ actually seeks to reduce average quality. This is a deliberate attempt to usher in a multiple-tier HE system with HEIs having ‘different missions’ and ‘different students’. The implication is clearly that it should be acceptable for some students to opt for cut-price, low-quality (sub-prime) HE if it meets a low baseline standard, and the low expectations of their particular ‘consumers’.
6. We are concerned that private providers will specialise in cheap-to-provide vocational courses that are attractive to students seeking remunerative post-graduation employment. This will drain established HEIs of income that they currently use to cross-subsidise more expensive subjects. If universities are forced to compete on price, or lose market share, cross-subsidy may become impossible and render many departments financially unviable.
7. Moreover, price competition can only be pursued by worsening the wages and conditions of staff.
8. A final highly problematic element of the proposals is the use of data on ‘student outcomes’ as a proxy measure for teaching quality.

The reasons why using student outcomes data are wrong are outlined in an open letter on the Disorder of Things, which all academic colleagues are invited to sign.