A focus on…Consultations

The House of Lords Industry and Regulators Committee launched an inquiry into the Office for Students (OfS), the regulator of the higher education sector in England. The EPC made a candid response highlighting that the OfS was conceived as a regulator, to enable an established HE ‘market’. Regulation might therefore have reasonably consisted of interventions and rules where existing market forces were such that the market was unable to deliver.

However, there is evidence currently of the market no longer working as intended as a consequence of the regulator’s intervention, that is, where OfS has created the conditions leading to market failure. Within our detailed responses to the consultation, we highlight that the OfS:

• focuses on student outcomes that create incentives which are at odds with OfS\ statutory interest to support access and participation;
• is not developing regulations focused on a good student experience;
• has too narrow a view of student outcomes;
• fails to appreciate the existing regulatory landscape at discipline level, in particular in Engineering;
• is lowering standards below those professionally acceptable;
• is subject to English political influence leading to fracture from the devolved nations.

See here for details.

UCAS shared plans to reform the personal statement to a series of questions. You can read UCAS’ Future of Undergraduate Admissions report here.

It was clear from our recent Recruitment and Admissions Forum that there is a multiplicity of uses of personal statements and views on their reform within the Engineering Academics network. None the less, the EPC Recruitment and Admissions Committee identified a number of areas in relation to engineering HE that they would like UCAS to consider further, including:

• the practical nature of engineering courses;
• the typical absence of engineering from the key stage 1 –  5 curriculum;
• the extent to which engineering applicants apply to other subjects;
• the extent to which engineering applicant apply across engineering disciplines;
• the need for grades on entry to include subject information (physics / maths);
• how grades on entry will be presented to applicants with a mix of qualifications (e.g. BTEC and A level);
• how new qualifications, such as T levels, will be addressed;
• the need for greater transparency around contextual offers.

See here for details.

This inquiry, led by Lord Willetts (Conservative) and Lord Knight (Labour) in partnership with EngineeringUK, was launched to investigate the urgent need to grow apprenticeships in engineering, manufacturing and technology. The EPC response focused on degree apprenticeships and the need to put the learner front and centre of this debate.

See here for details.

The latest consultation from the OfS on equality of opportunity and access and participation plans provoked a keen response from within the EPC and EAN. The following are highlights from the response:

Metrics
We are concerned that the metrics used for assessment may be insufficient proxies and they may, as a result, support gaming rather than authentic impact. Until more detail is provided about the risk and the metrics being used to assess those risks, it is hard to say the extent to which gaming be revealed. If the risks identified are too broad, the exercise of identifying them may be meaningless in terms of influencing what activities take place because nothing will be outside the scope of the broad risks. But, if the risks are too granular, the approach may end up as too prescriptive and the aim of a nuanced approach will be undermined. Getting the right balance will be a difficult feat for OfS to achieve and bad faith metric players may be the winners.

Lifelong learning and part-time courses
We are concerned about the interrelation between this approach and the Government’s plans for increased lifelong learning and short courses. How will this approach support access to these courses? Short course and CPD staff have more experience in a range of qualifications and come from a wider cross-section of society.

Many of the gains in wider access in the past few decades were made through the expansion of part-time courses. Then the collapse of part-time student numbers in the past decade dealt the heaviest blow to the admission of students from underrepresented backgrounds. There is no clear strategy in the consultation to address this situation which has a greater potential to address equality of opportunity that almost any other measure.

Admissions criteria
To detect potential rather than attainment is a lot more difficult. Openness to other qualifications is critical to equality of opportunity, and this consultation does not address that. One the contrary, it encourages the risks to be mitigated by universities helping everyone to get 3 good A levels. In Engineering, academics have to recognise the difference between learners. We are disappointed that the word “admissions” only appears five times throughout the whole consultation (four of those are in case studies and the final one in a reference to duties under HERA). We would like to see a requirement that providers are
clear and open about their admissions policy, which may be supportive of the risks that the providers chose to address.

Some providers are reluctant to embrace contextual offers because they limit league table performance, but this becomes a circular mechanism to ever greater exclusivity. Contextual admissions may be extremely relevant to Engineering as potential for success in the area can be assessed in a variety of ways.

Our members have found that A level success is not a reliable predictor in Engineering of a students’ future success. Students from more challenging backgrounds with lower attainment my experience a more difficult first year, but their learning is often accelerated by Level 6.

Outcomes
We are concerned about the conflict between the stated goals in the consultation and the B3 conditions which tend to drive in the other direction, acting as an encouragement to providers to be as selective as possible in their admissions in order to ensure the most straightforward pathways to positive outcomes metrics. OfS should reconsider whether this conflict is likely to achieve a harmonious balance or set up a conflict that undermines both the B3 and equality of opportunity goals (probably to the greater detriment of the latter). A more consistent message from the regulator would be appreciated.

Foundation Years
We are disappointed by the lack of focus on Foundation Years. Funding changes have made provision of this pathway in higher education more challenging for providers to offer. We would have liked to have seen an explicit steer from the regulator that these would be recognised as an effective way of tackling risk to equality of opportunity. We remain hopeful that the EORR may be clearer on this as we would consider the loss of such pathways to be a risk that would be worth identifying in the register.

Foundation Year courses have an excellent track record of success in delivering access to Engineering degrees and progress to positive outcomes in the long term.

See here for details.

The Quality Assurance Agency (QAA) invited responses to the draft Engineering subject benchmark statement. The submitted a brief executive response highlighting that the statement could do more to promote ethics and sustainability. Meanwhile, the EPC team has compiled an opinion piece, the engineering benchmark statement is invaluable, let’s defend it well to engage our members in this consultation.

These Statements are reviewed on a cyclical basis to ensure they are as useful as possible for discipline communities and can inform a range of purposes across the sector, including course design and providing support for securing academic standards. Alongside discipline-specific information, the revised Statements consider the role of equality, diversity and inclusion (EDI), Education for Sustainable Development (ESD), enterprise and entrepreneurship, and accessibility for disabled students within the context of the respective discipline area.

The EPC has been represented on the Advisory Group which helps ensure each review considers a diverse and broad spectrum of intelligence, opinion and experience.

See here for details.

This consultation was concerned with minimum entry requirements and the future of foundation years, among other topics. The EPC response vehemently defended Foundation years and articulated their value to engineering education.

The EPC established a group of experts under the auspices of the EPC Research, Innovation and Knowledge Exchange Committee to make a detailed response to questions around the purpose and principles of the REF (as we know it).

See here for details.

The House of Lords Science and Technology Committee conducted an inquiry into the Government’s plans to deliver a UK science and technology strategy. The EPC offered expert evidence in the following areas:

• Levelling Up
• Sustainability
• Post-pandemic recovery
• Skills shortages in STEM
• Innovation and entrepreneurship
• Differences in engineering research and science research
• Funding of the Engineering skills pipeline

See here for details.

The Education Committee held an inquiry on the effectiveness of the careers advice given to students. The EPC supported a joint response of a collective of eight leading bodies in the fields of STEM and careers education, information, advice and guidance led by Engineering UK. We collectively asked the government to urgently publish a new careers strategy for England. We asked that careers hubs are rapidly expanded to cover all secondary schools in England. We recommended that there is a dedicated STEM leader within each careers hub and that government provide additional funding including for a digital learning strategy for schools. We also asked that the government embeds careers into the subject content of the STEM curriculum and ensures that it highlights the diverse range of roles and people in science and engineering. Our final recommendation was that teacher training and continuous professional development includes information and training on STEM careers, including careers in modern engineering.

See here for details.

The Education Committee held an inquiry on the effectiveness of the careers advice given to students. The EPC supported a joint response of a collective of eight leading bodies in the fields of STEM and careers education, information, advice and guidance led by Engineering UK. We collectively asked the government to urgently publish a new careers strategy for England. We asked that careers hubs are rapidly expanded to cover all secondary schools in England. We recommended that there is a dedicated STEM leader within each careers hub and that government provide additional funding including for a digital learning strategy for schools. We also asked that the government embeds careers into the subject content of the STEM curriculum and ensures that it highlights the diverse range of roles and people in science and engineering. Our final recommendation was that teacher training and continuous professional development includes information and training on STEM careers, including careers in modern engineering

See here for details.

The Office for Students OfS issued three related consultations in February 2022 with detailed proposals on their approach to regulating quality and standards in higher education.

As the three consultations were extremely long and detailed, the EPC produced brief summaries of each of the consultations’ key points to help distill the detail for our members (with thanks to London Higher for their starting point summary) and an introduction to the general policy implications for engineering.

Each consultation stood alone; the EPC produced two member surveys to ensure the EPC’s response to the consultations was fully representative: one on quality and standards (B3) and one on excellence (TEF). Where we thought there was a particular relevance to engineering, we also included some general questions on the detailed metric proposals; and asked members to skip these if they were too technical in nature or provide details where they thought we should be making more technical comments. Please see the other tabs on this page.

This third consultation was on metrics, which the EPC considered outside the scope of its representative role.

See here for details.

The Office for Students OfS issued three related consultations in February 2022 with detailed proposals on their approach to regulating quality and standards in higher education.

These were among the most important regulatory changes we have faced since the formation of the OfS and the EPC felt it was important to respond comprehensively. As the three consultations were extremely long and detailed, the EPC produced brief summaries of each of the consultations’ key points to help distill the detail for our members (with thanks to London Higher for their starting point summary) and an introduction to the general policy implications for engineering.

Each consultation stood alone; after an opinion-gathering exercise among our members, the EPC published its responses, in summary:

• We were concerned the proposals will damage access. This is important to the EPC as a greater diversity of engineers is good for those who enter the profession, good for engineering and good for society.
• Contrary to the aim of raising standards, the proposals may lead to grade inflation.
• Rather than raising educational standards through incentives based on outcomes, the need for outcomes may become an excuse for admitting the students who need education least to get good outcomes. This would drive down standards.
• The proposals were incompatible with the forward-looking and flexible model of HE envisaged by the government in its proposals for the Lifelong Loan Entitlement. As such, the proposals are not fit for the future.
• The proposals will duplicate or sometimes be at odds with other regulatory frameworks for certain courses, such as Engineering which is subject to strict regulations for accreditation.
• The proposals estimate the value of higher education too narrowly.
• The proposals will damage efforts to diversify engineering, particularly in terms of gender balance, but other characteristics too.
• By using a poor proxy measure for educational quality, rather than attempting to measure learning gain, the proposals value outcomes that are beyond universities’ direct control over the standard of the education provided.
• By seeking to penalise universities for offering courses with supposedly poor outcomes, the proposals may inadvertently make courses with good outcomes, such as Engineering, less viable.
• The proposals may discourage educational innovation.
• The proposals created incentives in opposition to the government’s mission to level up. This is a policy area where higher education – and Engineering, in particular – can effect real change, but only if they are not penalised for doing so.

The EPC calls on the Office for Students to abandon its regulation plans for student outcomes and instead to adopt measures of ‘learning gain’ and ‘value added’. These would give a more direct and useful measure of educational quality – both baselines and excellence – and would incentivise desired outcomes rather than unintended consequences. Learning gain is not easy to measure, but as the hundreds of pages of these consultations demonstrate, it’s not as if the OfS has found an easier or better alternative.

See here for details.

The Office for Students OfS issued three related consultations in February 2022 with detailed proposals on their approach to regulating quality and standards in higher education.

These were among the most important regulatory changes we have faced since the formation of the OfS and the EPC felt it was important to respond comprehensively. As the three consultations were extremely long and detailed, the EPC produced brief summaries of each of the consultations’ key points to help distill the detail for our members (with thanks to London Higher for their starting point summary) and an introduction to the general policy implications for engineering. After an opinion-gathering exercise among our members, the EPC published its responses, in summary:

• Given the proposals for student outcomes baselines, it is not clear what distinctive purpose TEF serves in spotlighting teaching excellence.
• We are unconvinced that a system of badges is a sufficiently nuanced representation of an institution’s reputation, which should be viewed in terms of good and bad, but in terms of having a reputation FOR something. The proposals are too reductive to achieve that.
• The proposals for TEF are not likely to improve its previous poor record of usefully informing student choice. In order to be informative it would need to be more granular, but a more detailed TEF would be less appealing and therefore less useful.
• There’s a similar inherent contradiction in the proposed periodic cycle of the TEF exercise: in order to be useful it needs to be frequent, but in order for its useful to come close to the burden involved, it needs to be infrequent.
• The 3-band Gold, Silver, Bronze approach to TEF is unhelpfully heuristic. That is to say, a TEF band does not provide anyone with good information, but rather the band is used *instead of* good information.
• The proposed fourth band – “requires improvement” – serves no positive purpose as it undermines reputation without providing any information about what improvement might be required.
• This is particularly damaging as the TEF band will be institution-wide, even when an institution may have pockets of excellence whose staff, students and graduates will be unjustly tarred with the same brush of inadequacy.
• By failing to represent the experience of international students properly, the TEF exercise will misrepresent excellence in certain parts of the sector – such as Engineering courses, in particular, where they comprise an especially significant proportion of students.
• We are concerned that the proposals will further undermine foundation years – a critical pathway to access and successful student outcomes, particularly in Engineering. This is especially troubling when foundation year funding is under threat from government proposals.
• Student insights is important, but they need the framework to provide points of reference so they can be comparative and useful.
• We are concerned that the proposals both for TEF and student outcomes will be unfair to smaller specialist providers in Engineering and other disciplines.

The EPC calls on the Office for Students to abandon its regulation plans for student outcomes and instead to adopt measures of ‘learning gain’ and ‘value added’. These would give a more direct and useful measure of educational quality – both baselines and excellence – and would incentivise desired outcomes rather than unintended consequences. Learning gain is not easy to measure, but as the hundreds of pages of these consultations demonstrate, it’s not as if the OfS has found an easier or better alternative.

See here for details.

The Education Committee held an inquiry that examined how effectively post-16, level 3 education and qualifications (such as A Levels, T Levels, BTECs and apprenticeships) prepare young people for the world of work. The Committee considered the Government’s current work and proposals in this area and looked at whether an alternative model, which enables a greater blend of academic and vocational pathways, should be explored. The EPC response headlined with it’s support for the continuation of BTEC qualifications alongside Advanced Levels (A level), Technical Levels (T levels), Business and Technology Education Council Nationals (BTECs) and apprenticeships as these offer high quality and highly regarded routes into Engineering. See here for details.

The consultation was concerned with cyclical changes to the requirements for external quality assurance review in Wales which regulated institutions are required to undergo at least every six years. This represented a step change away from the evolving English model under the OfS. See here for details.

The consultation was concerned with the “Impact of Vocational Qualifications on Young People’s Employability and Labour Market Outcomes” following the Department for Education (DfE) proposed the streamlining of post–16 qualifications by removing funding for some vocational, technical, and other vocational technical qualifications including BTEC qualifications by 2024–2025. The EPC response was made through the Royal Academy of Engineering Education and Skills Group in support of retaining BTEC qualifications as an important pipeline for Engineering. See here for details.

The consultation proposed a plan of action to guide activities as a regulator over three years. The EPC raised a number of concerns including the potential impact of OfS’ approach on the international standing of engineering; regard to institutional autonomy; and the limitations of a singular focus on the exchange value of HE for employment. See here for details.

This was a relatively technical consultation in which the Institute for Apprenticeships & Technical Education looked to change its existing policies that affected the development, approval, and operation of degree apprenticeships. We agreed with the proposals in the round, which  reflected recommendations addressed to IfATE in the EPC’s Experience enhanced Report: improving engineering degree apprenticeships. See here for details.

The OfS undertook a preliminary consultation on a range of quality and standards issues during the winter of 2020-21.  This consultation took forward some aspects of that consultation and made more detailed proposals about new regulatory requirements. The EPC made a brief response to the consultation challenging the efficacy of the latest in an extensive run of OfS consultations on quality and standards. See here for details.