Universities UK's position has long been that we recognise and support the need for a bill, but the legislation as originally drafted contained many areas where clarification or substantial revision and refinement were required. We have therefore been working hard to ensure that outstanding concerns within the higher education sector are addressed, raising these with the government, with MPs and peers and through the media.
One of Universities UK's top priorities is to protect the independence and autonomy of the higher education sector. The success of our universities is founded on robust institutional academic governance, free from government interference and red tape. It means our diverse universities can create, develop and teach an incredibly wide range of courses that meet the needs of over 2 million students and responds to the workforce needs of the country. In light of this, Universities UK is proposing a series of amendments in relation to academic standards.
The HERB marks a significant departure from the Further and Higher Education Act 1992 by adding the assessment of standards as a requirement of registration and funding alongside quality. Academic standards are set by individual degree-awarding bodies for the award of their academic credit or qualifications. Academic quality covers how students are supported to progress and achieve their award.
Until now academic standards have been rightly excluded from these arrangements in order to protect universities from political and regulatory interference. It is not appropriate for government or an arms-length body of government to be involved in defining academic curricula or the associated academic judgements of universities.
The approach to standards in the Bill as currently drafted leaves a wide scope for interpretation that could be detrimental to academic autonomy, quality and diversity of the sector. Standards mean different things to different people, and the definitions of standards in the bill don't always align with the specific, technical usages already employed in the higher education sector.
The sector has always recognised the need for a shared national framework of basic requirements to award higher level qualifications. These academic threshold standards are set out in Part A of the Quality Code and the Framework for Higher Education Qualifications. These maintain that the award of a degree is founded on core principles of learning outcomes and skills.
What this doesn't cover is academic judgement – how well a student has performed above a threshold requirement, for example. It is essential that these judgements remain the responsibility of self-critical academic communities. Academic communities are best placed to support and challenge students and judge their attainment against academic criteria.
In particular, academic judgements are fundamentally linked to academic curriculums – how well a student has performed against the requirements of a course. Different universities teach different curriculums that reflect the specialisms of an institution and the goals of their students. As is often remarked, the universities of Oxford and Oxford Brookes are not the same and rightly so. One size does not fit all.
This isn't to say that there shouldn't be consideration of standards in the system, but this should be focused on ensuring good academic governance so that academic judgements and curriculums are robust. External peer review of judgements and patterns of awards can also help to maintain this confidence. The Quality Code and FHEQ also needs to keep pace with the needs of the sector, students, employers and wider society.
We are supporting amendments to the bill to ensure that standards are clearly defined in the new framework, in a way which protects the principles of a high quality, autonomous sector. These amendments include:
These are basic requirements that should give all students confidence in the quality of the academic governance of the institution at which they are studying. These should apply to all providers in the sector to avoid undermining the experience of students and the reputation of the whole sector.
The current approach to standards in the bill risks drawing the higher education sector into the cyclical debates about national curriculums and grade distributions which we see in the schools' system.
High level education needs the flexibility and freedom to be responsive to significant student and workforce demand and develop new and innovative approaches to meeting the needs of learners. The system would be in danger of ossifying quite quickly and risking long-term damage to the sector's standing and competitiveness if we go down the route set out in the bill.