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A summary of UUK’s response to the Green Paper

Chris Hale

Chris Hale

Director of Policy
Universities UK
Department for Business, Innovation and Skills


Just before lunchtime on Friday I hit the send button for the Universities UK response to the consultation on the government’s higher education Green Paper.

The last few months have been a pretty busy time in terms of consultations and dialogue with our members. As part of this process, I have been struck by, not only the level of interest and engagement with the issues across the sector (both in England and the UK more widely), but with the consistency of the messages we received back. This is reflected in our response. Some of the headlines are set out below.

Overall, there has been a positive response to the focus given to teaching within the Green Paper, not least given the major changes we have seen in the last five years and the need to ensure students are absolutely clear on the value they will get from the significant contribution they now make to their tuition.

There is widespread concern, however, that it does underplay the significant success the sector already demonstrates. For example, eighty-six per cent of students studying in the UK are satisfied with the quality of their course. And we outperform our international competitors in 15 out of 23 International Student Barometer benchmarks.

In our response, as many others have already highlighted, we set out the challenges and complexity of assessing teaching excellence and linking this to funding incentives. Because of this, we believe that piloting new approaches would be the most sensible way forward in the short term and the best way of ensuring TEF has a long-lasting impact to the benefit of students.

There are many experts and views on what metrics and other evidence might or might not work and what the consequences (unintended or otherwise) might be. The reality is this is uncharted territory. The sector needs to work with government to test and evaluate different approaches to arrive at something that works and has the confidence of students, institutions and other stakeholders. The TEF will be a lot stronger for it.

We also propose looking carefully at the suggested linking of funding incentives to the TEF. Any system that introduces multiple fee caps across multiple levels, based on partial models of teaching excellence and assessment, has the potential to be disproportionate, burdensome and counter-productive.

The focus on a high quality

student experience in the proposed Office for Students (OfS) is welcome and reflects the proposal made in our own report on the future of higher education regulation back in February this year. If the OfS is going to truly reflect the student interest, its mandate must, however, be widened.  The totality of what universities do also includes research and other forms of knowledge dissemination (including public and industrial engagement), as well as broader community engagement, skills development and support for entrepreneurship, all of which can have an enriching effect on the student experience, in addition to their own intrinsic value.

There are also broader issues relating to the operation of a university as a whole that will have an impact on the student experience, such as its overall financial sustainability. To reflect this need for a wider perspective, we propose modifying the OfS to become the Office for Students and Higher Education.

In terms of the proposals for market entry set out in the Green Paper, our clear message is that students and graduates are best protected by a system that sets consistent and robust standards of entry and promotes the sustainability of providers. High thresholds for entry into the sector are essential and the proposed changes should not erode these.

The consolidation of the current regulatory requirements into a single gateway into the higher education sector makes a lot of sense, but the current process for degree awarding powers is underpinned by requirements for an extensive evidence base and track record and we would not want to see this diminished.

It is also essential that the value of university title is protected and criteria should reflect the wider characteristics associated with a university. In order to protect the value of university title, we propose the introduction of a public-interest test. Both in relation to degree awarding powers and university title, we would not want to see significant divergence of criteria across the UK as the collective reputation of UK higher education is underpinned by robust standards. We continue to be strongly committed to student protection, and support the principle that providers should have contingency arrangements to support students in the event that their course cannot be completed.

The Green Paper and Sir Paul Nurse’s review of the research councils suggest a reconfiguring of the research funding landscape and has been one of the more contentious areas of the Green Paper. We have a very effective research funding and policy system across the UK, which includes the dual support funding system. Our response raises a number of concerns about the risks associated with the shift of block-grant (or QR as it is known) funding to Research UK (RUK). Creating an administrative and funding gap between teaching and research runs the risk of damaging the interactions between these functions within universities, to the detriment of both.

Any measures related to the transfer of QR to RUK should also be accompanied by a clear commitment to maintaining a dual support funding system and preserving the critical features that underpin each funding mechanism. Our response sets out what some of these protections should look like, but any future Research Excellence Framework (REF) will play a critical role in maintaining dual support. If dual support is to continue in any meaningful way we do need a separate mechanism for driving the allocation of QR funding. We believe, however, that there is scope for further streamlining the REF, although it must continue to be underpinned by peer review.

The open and consultative nature of the Green Paper has been welcome, but the critical question is, where next?

We know that there will be a technical consultation on the TEF in the coming weeks, but how government will respond to the feedback it has received and what the next steps are is still uncertain. Ideally, a number of the proposed changes will require primary legislation, such as the creation of RUK and the creation of OfS (or OfSHE as we suggest).

If we are to have an open and transparent debate about these reforms and an opportunity to shape them, legislation will not only be desirable, but necessary. Also, the current regulatory framework for higher education is already quite fragile and contains a number of ‘work-​arounds' ​given there was no legislation to bring it up to date in the last parliament. It’s by no means certain that there is a political will for legislation, however, and the looming EU referendum and any fallout from this also has the potential to knock any plans sideways.

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