EPC response to OfS consultation on inclusion of Higher Technical Qualifications in student outcome measures

The EPC responsed to the Office for Students (OfS) is consultation on the introduction of a separate “split indicator” for higher technical qualifications (HTQs) to enable the regulation of student outcomes. HTQs are L4 and 5 HE qualifications linked to occupational standards approved by the Institute for Apprenticeships and Technical Education (IfATE). They can include existing higher national certificates (HNCs), higher national diplomas (HNDs) and foundation degrees, but these qualifications are not necessarily approved as HTQs. The first engineering HTQs were approved in 2022 as part of the third tranche of subjects to be onboarded.

Split indicators are used by OfS, providers, Government and others with an interest in HE outcomes to measure performance of student cohorts – against minimum thresholds – by mode and level of study, subject and student characteristics.

The introduction of a split indicator for HTQs will decouple student outcomes measures for Level 4 and 5 HTQ qualifications from ‘other undergraduate’ with a view to establishing these courses as a distinct type of higher education. The Government also wants to demonstrate the benefit to taxpayers of giving students on these courses early access to the lifelong loan entitlement or additional funding or benefits in future.

EPC response

1. As it is not proposed to establish HTQs as a level of study, performance data for these courses cannot be split by subject, which renders the data unhelpful. Although the OfS signal that they will review this again following an increase in student numbers, there is not currently evidence of demand or additional supply.

  • The latest reform of Level 4 and 5 apprenticeships, to provide an employer-led technical route to Level 4 and 5, has not substantially increased the numbers embarking on such technical routes and anticipated demand has not been met. HTQs could make a valuable contribution to this shortfall – and consequents skills shortfalls, particularly in engineering – if and only if they are led by demand by employers and students, rather than by supply on the part of providers and Government.
  • The risk of innovation in the sector in relation to HTQs is big HTQs are effectively badged on existing quals or modules in higher education.
  • Even if a larger market can be created for level 4 and 5 qualifications, it will remain small and, for many, will be regarded as part an ongoing journey. There is widespread research on the ‘signalling’ effects of an undergraduate degree. Most employers, especially SMEs, have neither the resources nor the expertise to distinguish between less familiar levels of qualifications.

2. With existing qualifications, such as Foundation degrees, sometimes being badged as HTQs and sometimes not, it is unclear to both the EPC, and presumably to students, what exactly would be covered by the HTQ split indicator and what remains in other undergraduate. Additional transparency is needed here.

3. OfS’s approach is a concern in relation to regulation hierarchy, specifically for high-cost subjects; including burden on providers; workload and impact on students. The proposal to introduce split indicators for HTQs will introduce up to nine additional data cuts for each provider on the proportion of students who continue with their studies, complete their studies and go onto professional employment, further study or other positive outcomes. This is an additional burden.

4. In engineering, overregulation and disregard for existing regulation frameworks has an onward negative impact of UK engineering’s international standing. Engineering as a subject is already heavily regulated and HTQs are already effectively regulated by IfATE.

  • The EPC would welcome an approach which makes better use of existing regulation frameworks (such as IfATE and accreditation in relation to professional courses), where on the ground evidence of high quality is recognised as a positive indicator without deferring to deficit model proxy measures. Established regulatory and professional outcomes already hold providers to account, at subject level, tending to over-regulation of the highest quality courses in the sector.
  • The alignment of HTQs with accreditation is a further complicating factor as there is a disconnection between what might properly belong at different levels as qualification content and what level of learning outcome might be expected to have been achieved.

5. We remain concerned that the partial exclusion of international students from metrics is likely to lead to an incomplete and potentially inconsistent picture, while the employability of engineering students on a global stage will lead to underrepresentation of performance. Approximately one in four students is international in Engineering; a higher proportion than in almost any other discipline.

6. We continue to urge OfS to adopt criteria for success that better recognise the distance travelled in terms of achievement for students who reach degree standard from a lower base of prior attainment and in the face of greater challenges.

  • A one-size-fits-all model is not fit for the diverse HE sector our students enjoy today and a focus on outcome based on anything other than individual student potential is at odds with the entire preceding UK education system.
  • We recommend developing progress measures that appraise skills on entry to higher education, and reassessment at the end. This would both quantify learning gain and help to identify gaps in understanding at a personal level to support a lifelong learning approach.
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