This is our response to the Office for Students’ (OfS) consultation on the regulation of access and participation plans (APPs) in England. It covers the eight proposals and our recommendations.
Summary
We are broadly supportive of the OfS’ proposal. It is a risk-based, university-led approach to regulating equality of opportunity in higher education. This includes the need to enhance universities evaluations of ‘what works’ and to support attainment raising in schools.
However, we are concerned about:
- the short window the OfS has given the sector to engage and respond
- how much turnaround time there will be for access and participation plans to be submitted and approved
- the need for more clarity on certain expectations from the OfS
Our recommendations
We want the OfS to:
- Commit to ongoing close engagement with the sector between autumn and spring to prevent surprises as universities work to develop and signoff new access and participation plans.
- Minimise burden through the process. In particular avoiding duplicating effort between the Teaching Excellence Framework (TEF) and new access and participation reporting.
- Issue additional information sooner than proposed. In particular, this should include, the new Equality of Opportunity Risk Register (EORR), and about what would meet the OfS’ expectations on how universities should partner with schools.
- Be mindful of the challenging financial environment for students and universities, and the impact this could have over the medium-term.
We look forward to working with the OfS in the months ahead to make sure the new approach gives universities the flexibility they need to deliver on widening access, participation and student success.