The Office for Students consulted on a new strategy for 2025 to 2030. The OfS published its last strategy in 2022 for the period 2022 to 2025. Some of the concerns the EPC raised at that time have been addressed in the latest strategy document:
- A focus on continued improvement.
- Alignment with quality standards (possibly).
- Adaptation to emerging educational trends like Higher Technical Qualifications (HTQs).
The EPC response is as follows:
Question 1: Do you have any comments to make on the OfS’s proposed strategy for 2025 to 2030 or the priorities set out within it?
The Engineering Professors’ Council (EPC) is the representative body for Engineering academics in higher education. There are currently 83 institutional members encompassing over 7,500 academic staff.
Our comments concur that sector resilience, quality improvement and governance checks and balances are appropriate levers for the regulator to deploy. However, we highlight that in the absence of a subject focus, the regulator may not be adequately protecting students or ensuring quality provision; the needs of both students and the broader UK workforce are not always being properly met.
While higher education institutions (HEIs) and strategically important subjects such as Engineering are seen as increasingly important to support government plans, they are also under significant financial and operational pressure. The strategy does not clearly explain how the Office for Students (OfS) can assist HEIs in balancing these pressures. The need to align educational offerings with the strategic requirements of the country is paramount. The regulator has a role to play to ensure that strategically important subjects are protected and adequately resourced.
We provide a relatively brief response. If you would like to discuss any of the areas herein in more detail, please do contact us and we will be happy to help.
- Financial sustainability
There is deep concern about the affordability of specialised courses such as Engineering and Computer Science and the increasing financial pressure on HEIs, where the basic and the high-cost element of Engineering higher education is not adequately funded. There is a role for the regulator to ensure the financial viability of strategically important subjects.
The cost of Engineering higher education provision significantly outweighs the domestic fee income. In 2019, the Department for Education measured Engineering at double the cost to run of many classroom-based courses, and we have calculated an estimated tuition fee shortfall of £7,591 per year per domestic Engineering student in the 2025/26 academic year. Providers are left footing almost half of Engineering course running costs from other sources; typically through cross-subsidisation from other subjects, research funding and international student fees.
Engineering and other STEM programs are particularly at risk from funding cuts due to a lack of discipline resilience. Required infrastructure, beyond the sector norm – including specialised labs, procuring and maintaining equipment (including software for simulations), materials and machines for hands-on experiments and practical work – all contribute to the resource load.
It has become unaffordable for HEIs to service and maintain the requisite specialist facilities and infrastructure (let alone replace them), and maintain student access to equipment, materials, computing suites, licences, etc. The time lag in seeing widespread department closures in Engineering (such as is now being witnessed in Nursing in Wales[1]) is due to the high levels of investment in expensive facilities and the resistance of HE providers to see the value of those assets turn into a loss. However, as those assets depreciate, in the current financial climate, they are likely to be equally resistant to renewing them.
The threat of course closures and a diminishing capacity to meet the UK’s skills needs in key industries such as Engineering is a real and significant issue. The need to intervene in the subjects HEs are delivering and to align educational offerings with the strategic requirements of the country is paramount. Ensuring that UKHE can meet the skills needs of UK plc. is a key role for the regulator.
- Staffing and workload
There is a need to differentiate between efficiency and standards to ensure courses can still realistically be delivered properly.
Essential practical labs and hands-on learning necessitate smaller groups of students than can be catered for in large lecture approaches and this is coupled with higher contact time than for other subjects. Running an Engineering degree is, therefore, staff intensive, requiring high-quality academic and support staff. Engineering is a professional pathway, in which the standard of accredited degrees is assured both nationally and internationally (through alignment with international accords) to create industry-ready graduates.
According to the Higher Education Statistics Agency (HESA) and OfS data for the 2019/20 and 2020/21 academic years, universities in the UK typically allocated around 50-60% of their total expenditure to staff costs, with higher amounts for resource-intensive programs such as Engineering. In 2024, PWC reported that staff costs account for c.54% of total expenditure on average (all subjects) leading to a material cost base exposed to inflation and salary negotiations.[2]
Restructures, redundancies and early retirement schemes have led to the attrition of the most experienced lecturers and senior Engineering staff, who have opted for final salary schemes instead of pay cuts, compounded by staff attrition to industry. Recruitment challenges have led to a culture of academic or industry-based hourly paid lecturers (HPLs) pushing up costs further and presenting course delivery uncertainty.
High attrition rates – which can be particularly high-risk among small teams of staff – and the difficulty in recruiting qualified staff in STEM fields is putting the sector under unprecedented stress. EPC members have given examples of high-quality, accredited, engineering courses ripe for closure due to costs and staffing, where no other providers in the nation deliver the much-needed programme economically. This is already happening in Nursing (see point 1, above).
The legacy of Covid has created the need to backfill educational gaps pre-HE against a backdrop of expectations of apparent reduction in workload of online delivery. Staff stress, mental health issues, and the impact of efficiency drives are major concerns for maintaining quality delivery.
Meanwhile, the broader market for higher education is fragmented, with a shift toward Further Education (FE) institutions seeking degree-awarding powers within an uncoordinated funding environment. Better alignment with level four partners, as well as the pipeline of engineers, is hampered by the lack of funds to support subsidies and staff arrangements at (local) FE level.
The best protection for students is to ensure the cost of delivery is sustainable. The regulator needs to understand the discipline nuances as highlighted above, using the available levers to encourage a diversity of institutions and discipline profiles which embraces both breadth and specialism, not a one size fits all approach. While autonomous providers operate independently of one another, the future of the sector requires sector collaboration and supporting. The regulator needs to step in to facilitate effective collaborations and be clear on allowable and encouraged models in terms of anti-competitive behaviours. It is not clear what levers are available to the regulator in this emerging environment.
Students’ needs and expectations vary widely, and the strategy does not account for this diversity adequately, particularly regarding the practicality of meeting diverse and shifting student expectations. Further, the gap between employer expectations and the readiness of graduates needs to balance personalised learning with the practical skills required by industries, particularly in engineering. The regulator should provide clarity on the role of higher education in terms of the morphing expectations of training rather than education.
- Quality and standards
The importance of focusing on quality over compliance with regulatory frameworks is a welcome move towards an approach more aligned with Ofsted. We would particularly welcome guiding principles on quality and standards akin to the Intent, Implementation and Impact framework to create a culture of appropriate stretch and challenge without creating unrealistic student expectations. Matching high quality educational delivery to student needs without being overly restrictive or draconian is key.
A focus on provider self-regulation and self-reflection to achieve appropriate levels of challenge without overwhelming the sector is crucial. With regards to the proposed risk register, the devil will be in the detail. We are, however, concerned that a lack of appetite for risk will stifle innovation, which is an absolute imperative in Engineering education. Tensions between innovation and risk, as well as concerns about restraining creativity within regulated environments are high. You can’t have radical structural change without innovation, which is compromised by a draconian quality and standards regime.
- Quality assurance and governance
We welcome the focus on franchising. The potential risks of franchised programs lacking proper quality assurance processes and the challenges of ensuring consistent delivery across different institutions should be noted as a risk. Franchising sign-off where quality assurance processes are effectively left with franchisee can present as better results where the assurance is not consistent. It is right that this should be a focus of institutional governance.
Where Engineering courses are accredited, professional, statutory and regulatory body (PSRB) standards already provide exhaustive quality assurance within industry and business standards. However, there is a risk of private providers delivering unaccredited engineering programs that don’t meet PSRB standards. There is a need for checks, balances and consistent quality checks for non-accredited programmes which draw down on high-cost funding and enhanced foundation year funding. The process by which programmes are assigned high-cost funding is decided by the provider (through HECOS coding, e.g. Computer science / AI / Cyber security (high-cost) v business computing (not high-cost). However, as this process is not currently audited, spurious high-cost draw-down may be a threat to the wider sustainability of the sector. Something like end-point assessment (EPA) (apprenticeships employer checks) for unaccredited programs would be desirable to ensure regulations are protecting the interests of the students and not damaging universities that are delivering high quality courses. Further, in its role to protect what both the students and UK plc. need, the regulator may want to look at the relationship between high-cost funding and accreditation, where accreditation already guarantees Engineering standards.
Meanwhile, a laissez faire approach to programme accreditation requires good information, advice and guidance to students to support informed choice and guard against high-cost courses with low-cost delivery models.
- Measures
The strategy’s aims of transforming quality assessment and expanding the Teaching Excellence Framework (TEF) is an increase in administrative burden without sufficient explanation of how it will improve outcomes. The proposed metrics for success, such as student satisfaction and employer confidence, are dependent on context, making them difficult to apply universally. Autonomous governance is the only lever by which the regulator can oversee this.
The Office for Students has not evidenced sufficient grasp of how student factors, including widening participation and protected characteristics, influence and are influenced by different institutions, different disciplines and different regions. Diversity of provision and innovation should be supported by metrics which support diversity rather than undermine all the money and effort spent on outreach and progressive admissions policies.
Regional benchmarking – indeed benchmarking wherever possible – and value-added remain limiting omissions in this strategy and we maintain that the regulator should use its position and powers to encourage innovation rather than incentivise homogenous approaches designed to deliver metric-satisfying outcomes. The current B3 metrics mitigate on any progress towards access and discourage innovation and diversity.
To drive genuine improvement and transformation, and to create the workforce of the future, we need to add value to the system, not exclude swathes of student who have the capability and potential to successfully complete their course but are disadvantaged by their circumstance or prior educational experience. The best course is not the one with the best students, but the one whose students gain the most from their educational experience.
Question 2: Do you have any comments about any unintended consequences of the proposed strategy or the priorities set out within it, for example for particular types of providers, particular groups of students, or for individuals on the basis of their protected characteristics?
In already highly regulated professions, including Engineering, we continue to urge caution with regard to the regulator undermining established professional quality standards and compliance with accords at international level.
The latest HESA data[3] shows that one in four Engineering first degree students are from overseas (compared with circa 15% across all subjects). As already discussed, without a maintained international subsidy, the current funding model for domestic Engineering students will collapse. The value in UK higher education engineering programmes is that they are professionally regulated as part of a professional programme, not as part as in internal UK quality infrastructure. The way engineering is regarded internationally is a key dependency of its sustainability. The regulator’s use of metrics defines the entire sector internationally, and this presents a risk.
Further, we have deep concerns that the Office for Students does not adequately understand transnational education in relation to Engineering. Much more work is required by the regulator towards an understanding of the complexities of transnational education to anticipate the many unintended consequences.
Ultimately, what is measured will always draw the focus and distract from other dimensions of quality and therefore create unintended consequences. When proxies are used for decision-making, people are incentivised to pursue the data rather than – and even at the expense of – the intended goals. As soon as you create a proxy measure, a window for gaming or chasing numbers rather than outcomes is presented and that bifurcation always creates unintended consequences.
Question 3: Are there aspects of the proposals you found unclear? If so, please specify which, and tell us why.
We found the definitions (terms like “student interest” and “high quality”) and expectations vague, with no clear OfS view about “the wider experience” beyond making provision to ensure students get what their provider said they would. It is unclear how the regulator plans to ensure continuous improvement in education. The broad nature of these goals and the disconnect between student expectations and what HEIs can provide in the areas of tailored learning and student choice needs more elaboration. A rich student experience is increasingly out of HEIs’ control, influenced by factors beyond the institutions’ influence.
We welcome the Office for Students’ inclusion of lifelong learning and higher technical qualifications (HTQs) in their strategic thinking in this strategic period as it was a significant gap in the previous strategy. However, increasing numbers of HTQs, as well as degree apprenticeships, need regulation which is squared off with parallel Ofsted and EPA regulation. Students need help navigating the complexity of differential degree apprenticeship funding models across the nations and across funding pathways.
The Lifelong Learning Entitlement (LLE) strategy doesn’t really address how the Office for Students proposes to regulate new LLE funding. Most existing OfS measures are completely inappropriate for LLE outcomes and would exacerbate the challenges we have highlighted throughout this response.
Question 4: Our previous strategies have covered periods of three years. For this strategy, we are proposing an extended strategy period of five years. Do you have comments on this proposal?
The need to take a discipline-based approach is urgent; a five-year strategy going in the wrong direction will compound damage to the sector and impinge upon an agile regulatory approach.
Question 5a: Do you think that our proposed ‘I statements’ appropriately and clearly describe the impact that delivery of our strategic objectives should have on our key stakeholders?
We do not think internal OfS leadership metrics should be the subject of wider review. Any successes metrics should be tested by the regulator through its own internal governance channels.
Question 5b: Do you think that the strategic objectives distilled in our proposed ‘I statements’ are the right ones? Do you propose any additional ‘I statements’?
We do not think internal OfS leadership metrics should be the subject of wider review. Any successes metrics should be tested by the regulator through its own internal governance channels.
[1] https://www.walesonline.co.uk/news/education/cardiff-university-job-cuts-400-30882168
[2] https://www.universitiesuk.ac.uk/sites/default/files/field/downloads/2024-01/pwc-uk-higher-education-financial-sustainability-report-january-2024.pdf
[3] HESA HEDI+ All providers student FPE record, accessed 04/02/25
