In particular, UUK calls on the government to reconsider plans for subject-level assessment following the challenges arising from pilots in 89 universities, and to look again at its value for students, universities and taxpayers.
The report contributes to the independent review of the TEF being led by Dame Shirley Pearce. In it, UUK concludes:
The TEF is having an impact on the sector, in teaching and learning strategies and the monitoring of outcome measures.
It is however hard to gather conclusive evidence of its contribution to teaching and learning experience and outcomes.
Its definition of excellence is weighted heavily towards employment outcomes, without full consideration of a student's overall study experience and the wider benefits of teaching and learning for students and society.
Awareness of the TEF is still low among students while gradual and piecemeal changes have made it complicated for them to understand or to use it most effectively.
New governance arrangements should be made to ensure the government, the Office for Students, students and providers have a clear stake in strategic decision-making.
A year into piloting subject-level assessment, there is considerable doubt over whether this will drive real value for students, while it is adding significant complexity and cost which could divert resource from other student-focused areas.
UUK believes that plans for subject-level TEF should not proceed until the limitations of the methodology, its resource impact, and the actual value of its contribution to student decision-making, have been fully considered.
Estimates from UUK put the cost of taking part in year two of the TEF at £4 million for participating universities, a figure which would increase significantly with a full roll out of subject-level assessment. UUK is calling for further consideration to be given to whether the aims of subject-level assessment could be met through existing or alternative information sources such as Unistats, university websites and league tables. Further work into this area should also look at the risks of the subject-level TEF; including concerns around the quality of the data and metrics, and their ability to support students in important and complex decisions.
Professor Debra Humphris, Chair of UUK's Student Policy Network, said: "We support an effective TEF as a tool to help students find the right place of study for them. Done well the TEF could make a positive contribution to enhancing the teaching and learning experience of students across the whole sector.
"However, the increasing complexity of the TEF process risks undermining its purpose, and this is a particular risk for subject-level TEF. While universities have engaged constructively with the pilot, there is no denying its potential to add complexity and considerable cost burdens to institutions. This in turn could force a diversion of resource away from other investment programmes from which students benefit more clearly.
"This report to the independent reviewer also highlights our concerns about continuing to incentivise a narrow targets culture to the detriment of the range and richness of academic practice and the long-term quality of the sector. We hope the review panel will listen carefully to the sector and considers our proposals."
The independent review of the Teaching Excellence and Student Outcomes Framework continues, and is due to conclude in summer 2019.
The Teaching Excellence and Student Outcomes Framework (TEF) is a national exercise, introduced by the government in England. It assesses excellence in teaching at universities and colleges, and how well they ensure excellent outcomes for their students in terms of graduate-level employment or further study.
At its creation, the TEF was said by government to be the world's first government-led university rating system, ranking universities as gold, silver or bronze, and measuring them by the level of high-quality teaching and graduate outcomes.
The £4 million cost of taking part in year two of the TEF for participating universities comes from the responses to UUK's survey, which found that participating higher education institutions spent a total of £3.3 million in salary costs, which when NI and pensions are added in rises to £4.1 million.
UUK's report The future of the TEF – report to the independent reviewer can be found here.