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An independent provider response to The Green Paper

10 December 2015
Aldwyn Cooper

Professor Aldwyn Cooper

Vice-Chancellor and Chief Executive
Regent's University London
green paper



As Vice-Chancellor of an independent, charitable, alternative provider, I welcome the publication of a green paper that heralds real change. It has the potential to promote a more diverse sector with fewer restrictions, greater opportunities, an increased range of suppliers, more student focus and enhanced equality of provision. This is a comprehensive paper and there is not room to cover everything so I will focus on those elements of most interest to alternative providers.

Universities exist to create and disseminate knowledge, not one or the other but both. The balance of incentives has clearly been weighted too far towards research and the creation of knowledge rather than effective teaching and learning. Institutions charging fees to deliver educational programmes must become student centred and deliver a fully supported, satisfying learning experience and outcomes that represents value for money. The Teaching Excellence Framework is welcome in that regard, as a complement to the REF and I look forward to helping shape its development.


Access and social mobility are important issues and institutions should be judged on their suc​cess in promoting access and providing opportunity. However, collating access and mobility with teaching excellence confuses the issues. An institution could be good at access but poor at teaching and may deliver poor student experience and outcomes. There is also a danger that the TEF becomes a tool for driving wider policy objectives, rather than creating incentives for excellence in teaching and learning.

The issues of most concern must be the proposals to expedite the diversity of providers in the sector. Ways do need to be found to facilitate ease of entrance. However, those alternative providers that have gained Degree Awarding Powers and University Title are concerned about the specific proposals in the paper. This is not sour grapes or a desire to limit competition – we welcome competition. However, having been through the process, we recognise the importance of being able to demonstrate a genuine track record in HE provision acquired by working with validating institutions before being entrusted with the task of managing our own validations through proven processes. Providers must be able to demonstrate financial sustainability, a high quality of teaching and learning, relevant provision, student support, consistency of degree grading, pastoral care for learners and first class student outcomes. Of course, they must not be held hostage by validators and the acquisition of early rapid growth should not be impeded.

Learners need to be reassured that the investment they put into gaining their degrees will retain value not only up to gaining their award, but also throughout their lives. Care must be taken not to expedite the process in ways that may increase the risk of failure to ensure quality and sustainability.

The current route to the acquisition Taught Degree Awarding Powers (TDAP) does not hold back entry for ‘the highest quality alternative providers’. The majority of potential providers who complain about the present process have not even entered into pre-application discussions with the QAA.

The prospect of giving TDAP to an institution based on two years of accounts and two years track record of validated delivery (less than even one academic cycle) is very high risk. The concept of awarding powers based on the track record of particular individuals within the institution is also ill advised. Eminent academics or established public intellectuals may have no competence in teaching or understanding of the complex processes of managing and safeguarding a successful higher education institution that delivers a high standard of student experience, outcomes and consistency. The award of provisional or probationary TDAP is very high risk.

The green paper appears to make little distinction between an institution with TDAP and one with the title of University. One of the strengths of the UK system, which leads to its recognition as a gold standard, is the carefully guarded title of ‘University’.

In the UK, we have fewer than 175 universities. Their quality is recognised globally and is a major factor in attracting international students. In America there are close to 5,000 ‘universities’ of extremely varying quality. If we follow down the track proposed in the green paper, Great Britain could have c.1,000 ‘universities’. This could have a strongly negative impact on the perceived quality of the UK-HE brand.

The UK QAA is respected globally and most countries aspire to emulate its processes and match its standards. International agreements require ‘independent’ quality oversight. There may be a case for looking at how the current system can be reformed, so to target regulation more effectively, but bringing quality assessment into BIS, even within the proposed ‘Office for Students’, could cause substantial problems and loss of international compliance, recognition and reach.

QA should remain with an independent organisation and the TEF should also be managed through the agency. Both the state funded universities and alternative providers should be subject to a regular, risk determined institutional review, which could, perhaps be from 3–10 years dependent on institutional maturity and previous performance.

A level playing field is a beautiful thought provided that its is carefully considered, is level in all directions and does not risk freedoms and legitimate differences that exist currently. Alternative providers who have gained TDAP or University Title should not be disadvantaged against the state sector. Students at alternative providers should have the same access to loans and their institutions should not be forced to apply again periodically for TDAP whereas state funded institutions have this in perpetuity.

There is much to be commended in the Green paper. The full potential of the diverse UK HE sector needs to be grasped and the UK must maintain its reputation for delivering the gold standard.

'The higher education Green Paper, what it means for your institution'​ conference in January will give delegates a unique opportunity to debate political, institutional and operational perspectives on key topics raised in the paper.

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