Our responses to the Office for Students' consultations on student outcomes, Teaching and Excellence Framework, and the construction of indicators

However, we also know that in some cases there are students that are not receiving this level of quality and this is not good enough. We agree students have a right to expect the high quality that exists across most of the sector and therefore we support a regulatory environment that seeks to protect students and drive improvements where necessary. Our 2022 Framework for programme review has been designed to support universities in England to identify courses where value or quality might be a problem and act on it.

We have responded to the three Office for Students (OfS) consultations launched in January 2022. 

You can read our briefing [PDF], which covers our five main asks for each consultation. 

Our full responses 

You can also read our full responses to each consultation: 

• regulation of student outcomes [PDF] 
• the Teaching Excellence Framework (TEF) [PDF]
• construction of indicators [PDF]

In all our responses, including earlier responses on phase one and phase two, we have emphasised the importance of regulation being proportionate.

It needs to be there to protect students. However it shouldn’t impact on universities’ ability to deliver for their students because they are focusing too much of their attention on administrative jobs and not enough time on teaching, assessment, and student support.

Across our responses, we argue that good regulation of quality in universities must:

• be risk-based, targeting areas where the risk to students is greatest, where there are the most severe breaches, or the most students affected
• give universities enough time to engage with new processes and work with both their staff and students to respond and act
• as far as possible, accurately measure and assess the things the OfS is looking to measure and assess
• consider the differences between universities, courses, and students, the context in which universities are working, and the wide range of benefits and good outcomes that universities support
• align with other regulatory and policy agendas, including access and participation, levelling up, lifelong learning, and international partnership
• have a long-term perspective that makes sure the regulation can adapt to changes in how higher education is delivered in the future and the types of students universities are and will be working with
• not undermine the reputation of the higher education sector by over-emphasising the prevalence and severity of low quality courses