Our response to the Office for Students’ consultation on the future approach to quality regulation

The consultation proposals include: 

• Modifying the overall quality regulatory system to make it more coherent and more integrated and to reduce burden.
• Expanding the TEF to include all OfS registered providers, to be assessed on a cyclical basis.
• Changing the definition of a Bronze rating to mean meeting minimum requirements rather than quality above minimum requirements.
• Implementing a rules-based approach to determining a provider’s overall TEF rating, following an assessment of the quality of student experience and student outcomes.
• Simplifying minimum requirements for students achieving positive outcomes and testing this as part of the TEF assessment.
• Applying a new incentives and interventions system linked to TEF ratings.

• We support the principle of a more integrated approach to quality where this will bring greater coherence and reduction in regulatory burden.
• We do not support the proposal to redefine Bronze as ‘meeting minimum requirements’ as this is an inaccurate reflection of provision that is consistently performing above high quality baselines. It is also confusing to students and stakeholders, and risks damaging the sector’s international reputation for high quality education.
• While we agree that providers falling short on quality should be subject to regulatory intervention, we strongly oppose the proposed penalties for Bronze-rated providers. They are inappropriate to apply to institutions meeting regulatory baselines and could undermine improvement efforts, reduce student choice, and disproportionately affect providers working with diverse and disadvantaged student populations.
• We do not support the proposed shift to a rules-based approach for determining overall TEF ratings and the reduced role for contextual information. While we appreciate the OfS’s intention to address regulatory burden, we are concerned the proposals prioritise this at the expense of an effective and nuanced approach to quality assessment.  

Our response to the Office for Students’ consultation on the future approach to quality regulation [PDF]