EPC responses to OfS Consultations

After an opinion-gathering exercise among our members, the EPC has published its responses to two consultations from the Office for Students, summarised here by Chief Executive Johnny Rich. They are on proposed changes to Student Outcomes and TEF (use the links to find the full responses).

These are 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. There was a third consultation on metrics, which the EPC considered outside the scope of its representative role.

Student Outcomes

  • We are 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 are 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 create 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. 

Teaching Excellence Framework (TEF)

Many of the concerns above also related to the TEF proposals, but there were also a number of other key points to make.

  • 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’.

In both consultation responses, the EPC was clear that 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. 

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