Tag: Paper

  • Making sense of specialisation: what the Post-16 White Paper means for university identity

    Making sense of specialisation: what the Post-16 White Paper means for university identity

    Over the weekend we published blogs on the art of reimagining universities and on why the TEF could collapse under the weight of DfE and the OfS’ expectations.

    Today’s blog was kindly authored by Nick Barthram, Strategy Partner at Firehaus and Merry Scott Jones, Transformation Partner at Firehaus and Associate Lecturer at Birkbeck, University of London.

    It is the tenth  blog in HEPI’s series responding to the post-16 education and skills white paper. You can find the other blogs in the series here, here, here, here, here, here, here, here and here.

    The government’s Post-16 Education and Skills White Paper sets a new tone for tertiary education in England. It is not just another skill or funding reform. It is a statement of intent about how universities, colleges, and employers should work together to build the country’s economic capability.

    The paper sets out a broad reform agenda built around stronger employer collaboration, higher-quality technical education, and a more flexible lifelong learning system. Initiatives such as Local Skills Improvement Plans and the Lifelong Learning Entitlement illustrate how the system is being reshaped to enable post-16 institutions to play distinct, complementary roles within a shared ecosystem of skills and innovation. All of this will unfold against a backdrop of constrained funding, uneven regional capacity, and growing regulatory pressure, making clarity of role more important than the White Paper itself acknowledges.

    While the paper avoids overt market language, the phrase comparative advantage does a lot of work. It invites universities to reflect on what they are best at and how that compares with others, without requiring them to openly compete. The intention is clear: to encourage institutions to define, and then demonstrate, their unique value. This is not new thinking. Advance HE, supported by a sector steering group including representation from AHUA, CUC, Guild HE and UUK, published a discussion paper last year on Measuring What Matters, exploring institutional performance and the importance of evidencing and communicating value creation.

    For some, that will mean sharper choices about subjects, audiences, partnerships, and purpose. For others, it will be about aligning their contribution to regional priorities. Not every university serves its region in the same way. The most prestigious universities will act as lighthouses, shaping national and international ecosystems through research and innovation. Others will play a more local role, deepening their community impact and supporting regional industry.

    The common thread is focus. Universities can no longer rely on breadth as a badge of strength. The challenge now is to identify what makes their contribution distinct and coherent, and to express that with clarity.

    From strategy to articulation

    Responding to the White Paper will be a demanding process. It will call for rigorous analysis, evidence-gathering, and an honest evaluation of institutional strengths and weaknesses. It will also require a sophisticated understanding of stakeholders’ and audiences’ needs. And of course, diplomacy will be required to manage the trade-offs that follow. Every decision will carry consequences for identity, culture, and relationships.

    In time, many universities will produce credible strategies: detailed statements of focus, lists of priorities, and maps of partnerships. But the real risk is stopping there. Institutional strategy alone will not create coherence.

    Universities often complete strategic work and then move straight to execution, adding imagery or campaigns before uniting everything around a purpose that aligns what you offer and who it’s for. The step that often gets missed is articulation – translating strategic intent into something people can understand, believe in, and act on.

    The White Paper calls for coherence across regions and the sector. Universities need to mirror that with coherence within their own walls. When purpose, culture, and communication line up behind a shared sense of direction, policy responses become practice, not just strategy. And this, fundamentally, is what the Government is seeking.

    The groundwork for meeting these changes is only just beginning, with many hard yards still to come. While covering that ground, there are lessons from outside the sector worth remembering.

    1. Specialisation  is relative
      A university’s strengths mean little in isolation. What matters is how those strengths stand out within the broader system of institutions, partners, and employers. Understanding where your work overlaps with others and where it uniquely contributes is essential. Knowing what not to do is often as important as knowing where to lead.
    1. Demand is defined by more than the UK Government
      The White Paper rightly highlights the importance of the national industrial strategy in shaping what is ‘in demand’. But universities should also consider the needs and motivations of their wider audiences: students, partners, and communities. Clarity about who your work matters to is as important as clarity about what that work is.
    1. Purpose must be expressed, not just defined
      Defining purpose is a strategic exercise; expressing it is an act of leadership. Purpose that remains on paper does not change behaviour, attract talent, or inspire partners. It must be made visible and tangible across everything the institution says and does, from how staff describe their work to how the university presents itself to the world.
    1. Perception matters as much as reality
      Universities are naturally driven by research and evidence. Yet specialisation is as much about being perceived as specialised as it is about being so in practice. The most successful institutions will work not only to build genuine expertise but also to occupy space in their audiences’ hearts and minds. Shifting perception requires consistency in both story and substance.
    1. Alignment is critical to success
      The institutions that succeed will be those that align intent, culture, and message. When leadership, staff, and students share a single understanding of what the university stands for, decision-making becomes simpler, collaboration easier, and communication more powerful. Alignment is not achieved through a campaign but through ongoing dialogue and consistent behaviour.

    A catalyst for clarity

    The Post-16 White Paper is ultimately a call for focus. For universities, that means not only deciding where they fit but demonstrating that fit clearly and consistently to students, partners, and staff.

    Those who stop at strategy will adapt. Those who move beyond it — articulating their role with confidence, coherence, and conviction — will help define what a purposeful, modern university looks like in the decade ahead.

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  • Three hot takes you may have missed from the Post-16 Education and Skills White Paper.

    Three hot takes you may have missed from the Post-16 Education and Skills White Paper.

    This blog was kindly authored by Rose Stephenson, Director of Policy and Strategy at HEPI.

    It is the ninth blog in HEPI’s series responding to the post-16 education and skills white paper. You can find the others in the series here, here, here, here, here, here, here and here.

    There have been oodles of column inches already published about the Post-16 White Paper, and many have rightly focused on the headlines: increased tuition fees, a return of targeted maintenance grants funded by an international students levy and a move towards more specialist institutions.

    In this blog, I want to dive beyond these headlines, as the paper contains a number of further bold policy proposals, some of which could be transformational for the sector.

    Break points

    The White Paper places a strong focus on flexible learning, including a greater number of Level 4 and 5 qualifications. There is a specific target of at least 10% of young people going into Level 4 or 5 study, including apprenticeships, by 2040. Clearly, the Government wants to see more movement in this direction from the sector, adding:

    We need to build clear and well-understood pathways at these levels [4 and 5], underpinned by qualifications that are easier to study close to home, which are both modular and flexible.

    In terms of higher education providers, the Government sets out:

    We will expect providers to offer more flexible, modular provision and strengthen progression routes from further education into higher education, supported by transferable credits. We will consult on making student support for level 6 degrees conditional on the inclusion of break points in degree programmes. This marks a significant shift towards a more inclusive and adaptable model of learning, empowering individuals to tailor their educational journey.

    There is little detail, but it reads to me that the Government will consult on a proposal that students will only be able to access student loan funding for institutions that offer ‘break points’ at Level 4 and 5 of a full three-year degree.

    This was also a recommendation from the Augar report, which outlined:

    … providers with degree-awarding powers will be required to offer them [level 4 and 5 qualifications] as ‘exit’ qualifications if learners choose to leave a course early.

    In my experience, most institutions now do this. If a student wants or needs to finish their studies at the end of their first year, for example, (providing they have passed the required modules), the institution would offer to award them with the Level 4 qualification that recognises their learning to date – most likely a certificate of higher education. However, ‘CertHEs’ are only routinely awarded ‘mid-degree’ if a student withdraws, and many students don’t know that there is an option to take a qualification at the end of their first year. One might wonder if providers could maintain this ‘consolation prize’ status quo. However, the paper goes further, stating:

    The introduction of break points will ensure that learners are acquiring vital, usable skills in every year of higher education. It will give them the option to break down their learning, achieving a qualification at level 4 after the first year and level 5 after their second year of studies, while also ensuring institutions are incentivised to support those who wish to continue their studies. This will enable young people to ‘stay local and go further’ by connecting local provision at level 4 and 5 with internationally recognised degree-level providers, unlocking opportunity and ambition across every region.

    I am reading between the lines here, but it looks as though providers may be expected to award students at the end of each year of learning, increasing awareness of stackable, flexible learning, and potentially a knock-on increase in student mobility between institutions. As with much of this White Paper, we await the details.

    Accommodation

    The white paper outlines:

    We will work with the sector and others so that the supply of student accommodation meets demand, including increasing the supply of affordable accommodation where that is needed. We will work with the sector, drafting a statement of expectations on accommodation which will call upon providers to work strategically with their local authorities to ensure there is adequate accommodation for the individuals they recruit.

    Firstly, this statement is a little ironic given that the Renters Reform Act that has just passed through parliament is likely to reduce small (generally one to two bedroom) off-street student housing provision – as outlined by Martin Blakey in his blog.

    This feels woolly to me. What levers does the Government have to pull to increase the supply of affordable accommodation for students? If it does have any, why have these not been pulled already? The main driver of expensive student accommodation is that there are not enough houses (for the general population as well as students), allowing rents to be driven ever higher. Providers working strategically with local authorities won’t deliver more housing stock. (Unless the magic house bush grows alongside the magic money tree?)

    We’ve seen a ‘Statement of Expectations’ previously, delivered by the OfS in relation to sexual harassment prevention and response on campus. This was an evaluated stepping stone on the way to regulation. Could there be an increased expectation on institutions to provide affordable accommodation as part of future regulation? A sensible ideology, perhaps. After all, we know students want and need cheap places to live. But given the financial position of many institutions, the resulting pause in capital building projects, the increase in commuter students and the impending decline in 18-year-old population numbers, I can’t see many subsidised student flats being built anytime soon.

    Apprenticeship ‘units’

    We have known since before the 2024 General Election that Labour wanted to expand the Apprenticeship Levy to become the Growth and Skills Levy. We see some more detail about this in the paper:

    We want employers to be able to use the levy on short, flexible training courses.

    Currently, apprenticeships are funded by the apprenticeship levy. Businesses with a pay bill of over £3 million pay 0.5% of this into the levy ‘pot’. Businesses can then use the levy fund to cover the cost of training apprenticeships. Since the introduction of the levy, the number of apprenticeship starts has fallen, and the age profile of apprenticeships has changed. Since 2015, proportionately more apprenticeships have been started by those aged 25 or over.

    Source: Department for Education, Apprenticeships and traineeships data

    So – the apprenticeship levy was, unintentionally, a good policy for lifelong learning; businesses wanted to reinvest their levy costs into their business and found that an effective way to do this was to upskill colleagues already employed in their organisation, often on higher or degree apprenticeships. The flip side of this meant that the intended outcomes of the policy, supporting school and college-leavers into apprenticeships, were stymied.

    To tackle this, most Level 7 Apprenticeships were defunded, with the aim of pushing funding back towards younger learners and lower-level apprenticeships. So the move to ‘apprenticeship units’ feels undermining of this aim. Again, this is likely to be great for lifelong learning. Employers will be able to upskill their workforce, initially in ‘priority areas’ such as artificial intelligence, digital and engineering.

    There is a limited pot of growth and skills levy funding, which has been fully or overspent for the last two academic years. So if the Government wants to increase apprenticeships for younger learners, it will need to expand this pot, and potentially ring-fence some of this. The potential for a bigger pot is hinted at:

    We will work with businesses and employers over the coming months to ensure that the growth in skills levy author is developed to help meet their needs and incentivise further employer investment in training.

    However, ring-fencing is not mentioned. The Government will need to put some guardrails in place here if they want to meet their target of two-thirds of young people going to university, further education or a ‘gold standard apprenticeship’ by the age of 25.  

    Conclusion

    So, while some of these statements are bold, remember that White Papers set out proposals for future legislation; there is a long way to go before legislation is in place. Further, there are several places in the white paper where the Government doesn’t specifically propose legislation; instead, there’s a sense of just asking the sector nicely. This is all well and good, but in times of severe financial constraint, asking institutions nicely to take steps that will cost them money is unlikely to yield results.

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  • WEEKEND ESSAY: Summarising and responding to the post-16 white paper

    WEEKEND ESSAY: Summarising and responding to the post-16 white paper

    This blog was kindly authored by Professor Roger Brown, the former Vice Chancellor of Southampton Solent University and Dr Helen Carasso, Honorary Norham Fellow of the Department of Education at the University of Oxford. Their previous book, Everything for Sale? The Marketisation of UK Higher Education was published by Routledge in 2013.

    It is eighth blog in HEPI’s series responding to the post-16 education and skills white paper. You can find the others in the series here, here, here, here, here, here and here.

    We need a reset to ensure the system can play its critical role in delivering provision aligned to the government’s growth and Industrial Strategy ambitions, support training at scale, deliver opportunity and outcomes for all, and reduce the persistent gaps in outcomes for the most advantaged students.

    (HM Government, 2025, p.46).

    As this statement of intent shows, the post-16 Education and Skills White Paper published last month has ambitious aims for the higher education sector in England. These are framed in the context of a wide range of proposals covering not only higher education but also further education and what used to be called ‘industrial training’. So far as higher education is concerned, the main proposals are:

    • To promote greater provider specialisation, including through greater collaboration
    • To increase financial sustainability and efficiency
    • To improve access and participation
    • To strengthen the incentives on providers to promote growth
    • To improve quality

    Specialisation and collaboration

    The Government wants to see greater specialisation: ‘over time there will be fewer broad generalist providers and more specialists’ (p.49). The White Paper seems to envisage two types of specialisation (a) by broad orientation, ‘teaching only’, ‘research’ and ‘teaching with applied research in specific disciplines’ (p.49) and (b) by discipline ‘a provider may decide to specialise across multiple disciplines or to focus on one or two where they are strongest’ (p.49). It is not clear how this will be achieved, but the White Paper speaks of ‘incentivising a more strategic distribution of research activity across the sector’ (p.50). This would be done through reforms to research funding. There will be a more permissive approach to collaboration on the part of the regulators. The Government declares that it will work with the Office for Students ‘to ensure there is a more robust process for market entry’ (p.50) but nothing is said about market exit.

    Financial sustainability and efficiency

    The White Paper confirms the earlier announcement by the Secretary of State that the undergraduate tuition fee cap for all providers will be increased in line with forecast inflation in the academic years 2026-27 and 2027-28. These ad hoc increases are intended to support the financial sustainability of institutions until legislation can be put in place to make such increases automatic. The Government will work with the sector to improve research cost recovery, with measures including improvements to TRAC (Transparent Approach to Costing) and support for collaboration and sharing of infrastructure. The White Paper also notes the potential of AI for dramatic improvements in research productivity. However, future Government support for research will be tied to ‘three distinct priorities’:

    Protecting and promoting curiosity-driven research; supporting the delivery of government priorities, missions and the Industrial Strategy; and providing targeted innovation, commercialisation and scale-up support to drive growth.

    (p.50)

    Moreover, improving cost recovery may ‘result in funding a lower volume of research [but] at a more sustainable level’ (p.52) and the research assessment system will be reformed ‘to better incentivise excellence and support the Government’s vision for the sector’ (p.53).

    Improving access and participation

    There are signs that the Government has registered the scale of the financial pressures on students with maintenance loans increasing with forecast inflation each year. Means-tested maintenance grants for students from the lowest income households (funded by the new International Student Levy) will be introduced. However these will be confined to those who are studying courses that support the Government’s missions and Industrial Strategy. The long-awaited introduction of modular teaching funding through the Lifelong Learning Entitlement (LLE) will also be focused on ‘key subjects for the economy, informed by the Industrial Strategy’ (p.56). However, given that the LLE model is to be used to operate loans for all eligible home undergraduates, it is unclear what this will mean in practice.

    To reduce administrative burdens, the regulation of Access and Participation Plans will be refined to focus on those parts of the sector where there is the greatest room for improvement. The Government will ‘develop options to address cold spots in under-served regions and tackle the most systemic barriers to access’ (p.57). It will also explore the reasons for the declining proportion of UK doctoral applicants in some fields. This could include reducing the financial barriers for those from lower socio-economic backgrounds.

    Incentives for growth

    The Strategic Priorities Grant will be reformed so as to align with the priority sectors that support the Industrial Strategy, the Government’s Plan for Change and future skills needs. Providers will be expected to review their curricula to increase flexibility and strengthen progression. Student support (i.e. eligibility for SLC loans) for Level 6 courses may be made conditional on the inclusion of accredited break points in degree programmes. Universities will be required to engage with Local Skills Improvement Plans. There will be ‘a new market monitoring function, drawing together key datasets to provide a clear, single picture of higher education supply and demand’ (p.61).

    The Government has protected the overall funding of UKRI (at £8.8bn). It will continue to ensure that there is ‘the right balance’ between the three research funding priorities. Some of UKRI’s funding will be ‘pivoted to align to areas of strategic importance as described in the Industrial Strategy sector plans’ (p. 62).

    The country’s ‘global leaders’ will be placed on a more sustainable footing through the linking of fee cap increases to quality (as discussed below) and the projected improvements in research cost recovery. The Government will work with the sector ‘to maintain a welcoming environment for high-quality international students’ (p.63). However, there will be tighter enforcement of visa approvals and monitoring of international students’ course enrolments and completions. Finally, providers will be encouraged to develop ‘civic plans’ that fit with their strengths and priorities.

    Improving quality

    Even though three-quarters of providers received Gold or Silver ratings in the last (2023) TEF, ‘we need to raise the bar across the system…with pockets of poor provision undermining the reputation of the sector’ (p.64). On the REF, the White Paper acknowledges the risk that research funding and assessment frameworks can incentivise ‘perverse behaviours’ with publication becoming ‘the main aim’ (p.65) (why did it take them so long?).

    There will be an increase in the OfS’s capacity to conduct ‘quality investigations’. Ultimately, the Government will legislate to ensure that the Office is able to impose recruitment limits where growth risks poor quality and future fee uplifts will become conditional on providers achieving a higher threshold through the Office’s quality regime.

    The Government will work with UCAS, the OfS and the sector to improve the quality of information for individuals ‘informed by the best evidence on the factors that influence the choices people make as they consider their higher education options’(p.66). An OfS review of its approach to degree awarding powers will include the role of external examiners and ‘the extent to which recent patterns of improving grades can be explained by an erosion of standards, rather than improved teaching and assessment practices’ (p.67). Employers will be consulted on whether the academic system is giving graduates the skills and knowledge they need for the workplace (p.67). Using the model of Progress 8 in the schools, the Government will work with the OfS to develop options for measuring and comparing progress in higher education.

    The Government will also consider its approach to research assessment ‘to ensure it meets our needs and ambition for research and innovation’ (p.68). There will be a pilot ‘to seek better information on how our strategic institutional research funding is used’ (p.68).

    The White Paper in its historical context

    In our forthcoming book Every Student Has Their Price: The Neoliberal Remaking of English Higher Education,to be published by Policy Press next year, we identify the progression of reforms that have enable the marketisation of English higher education. These reforms to funding, regulation and market entry have enabled a significant growth in the number of competing higher education providers to more than 400 (see the December 2023 HEPI Debate Paper Neoliberal or not? English higher education in recent years Roger Brown and Nick Hillman).

    The White Paper vigorously reaffirms the official view, evident in the 1985 Green Paper The Development of Higher Education into the 1990s (Department for Education and Science, 1985) that the role of higher education is first and foremost about meeting the needs of the economy: what Salter and Tapper many years ago termed ‘the economic ideology of higher education’ (The State and Higher Education, 1994). But whereas most previous White Papers have at least paid lip service to the wider functions of higher education this one doesn’t even bother. It is, in fact, the most wide-ranging attempt yet to tie the future development of the sector to the Government’s perceptions of the present and future requirements of the economy, and specifically the presumed requirements of the labour market.

    The White Paper’s impacts can be expected to mostly reinforce those of the earlier reforms in at least six areas: demand and equity, supply, funding, the higher education workforce and the system.

    Demand and equity

    The White Paper is silent on the future size of the sector. So far, the neoliberal reforms have done little to check the huge increases in numbers and participation rates that we have seen. Nor have they made much difference to the continuing gaps in participation by different social groups or the tendency for students from wealthier backgrounds to go to better-resourced institutions. This is because – as nearly every independent analysis has shown – the major barriers to wider participation lie much further back in the education system and these in turn largely reflect the structure of our society and economy. So it is very hard to see the White Paper proposals making much difference to access or demand. But there are one or two warning signs. The stipulation that maintenance grants will be restricted to students on courses closer to the Industrial Strategy will not only constrain student choice but perhaps also reinforce the divisions between higher and lower tariff providers that were exacerbated by the abolition of the numbers limits in 2015. Is there perhaps another potential binary line here, with better off students free to pay to study humanities and social science at wealthier and more prestigious institutions and go on to well-paid jobs in the City or the professions, while poorer students are obliged to study ‘practical and applied’ subjects at less well resourced and less prestigious ones?

    Supply

    It is striking that there are no proposals for expanding the number of providers, indeed the White Paper envisages toughening the rules for market entry, as we have seen. The Government appears to assume that it will be existing providers that will cater for the cold spots in under-served regions, rather than new ones. This will at least mean some greater stability.

    Funding

    It seems highly unlikely that the proposals for fee indexation will be sufficient to redress the post-2016 funding squeeze, wean universities off of their reliance on international student fees (even without the tax represented by the International Student Levy) or restore the unit of resource in real terms. UUK analysis suggests that there will be an overall £2.5bn reduction in sector funding across the academic years 2024-25 to 2026-27 compared to 2023-24. Whilst the intention to improve research cost recovery is welcome, it will almost certainly be insufficient to reverse the long-term decline in research funding since 1980, and indeed the Government partially accepts this.

    This combination of some additional funding, together with a strong drive towards increasing efficiency and encouragement for institutions to consider specialisation, collaboration and restructuring as options, is placed within the context of recognition that ‘the higher education sector is rightly and proudly autonomous’(p.53). This freedom, the Government states, has its consequences, so ‘the leadership of the sector must take responsibility for managing their institutions robustly and in the public interest’ (p.53). The OfS will therefore be supported to tighten the management and governance requirements of institutional registration. Indeed, there will be a ‘….focus on targeting sharp regulation where it is most needed, to drive the positive change required to maintain our world-leading higher education system.’ (p48)

    Quality

    The White Paper notes some of the quality issues that have arisen over the period, including grade inflation and (some) sub-contracting (franchising), most of which are in fact due to the combination of increased competition and reduced funding that has characterised the period of the reforms. The proposal that future fee increases should be linked to quality raises as many questions as it answers. Whilst this idea has often been floated in the past, it has not been seriously applied in the UK since the days of the Polytechnics and Colleges Funding Council when sector committees advised the funding council on the allocation of additional funded student numbers to ‘deserving’ institutions on a broadly disciplinary basis.

    The proposal that the OfS should be able to confine future fee uplifts to ‘providers achieving a higher quality threshold through the OfS’s quality regime’ is also par for the neoliberal course. The potential weight that this places on TEF outcomes makes the current review of the exercise even more crucial, including the importance of designing a process that acknowledges the role of a variety of institutions offering forms of education that might be different but not automatically ‘better’ or ‘worse’.

    The proposal that the OfS should review the degree awarding powers process and the role of external examiners in protecting standards also raises many questions.  But the issue is the same, namely, how and to what extent can the traditional ways in which the academic community has, generally, successfully guarded its standards resist the combined pressures of competition, consumerism and inadequate funding.

    The proposals on information for students continue with the hopeless – in the authors’ view – quest for the Holy Grail of information that will quickly and cheaply enable students and other ‘users’ of the system to make reasonable choices about subjects, courses and providers, the insuperable difficulties of which were explained at length in the HEPI Debate Paper referred to earlier. Similarly hopeless is the idea of a progress measure for higher education along the lines of Progress 8 in the schools. We can only sympathise with the hapless individuals who will be tasked with taking these ideas forward.

    The proposal to review research assessment raises concerns that future exercises could be tilted, like research funding, towards greater emphasis on (a) impact, and (b) subjects considered most relevant to the Industrial Strategy. Haven’t the reforms to increase the role of impact in research assessment over the years already gone far enough?

    Staff

    The White Paper breaks new ground in one respect at least, in that the position of staff, and in particular the precarity of many early career researchers, is mentioned. However, what will happen here will depend very much on how much of a financial recovery there will be (if any), on how much system restructuring takes place and on what form any increased collaboration takes. If this takes the form of institutional mergers, we can expect more redundancies and potentially worsening of terms and conditions. The experience of mergers in HE indicates that the only significant, permanent savings come from disposing of assets: any savings on things like shared services are offset by the greater costs of the managerial coordination required.

    The system

    The Government clearly hankers after a more streamlined system that is both more efficient in its use of resources and offers a wider, or at least clearer, set of choices for students, employers and other ‘users’. As with so many other aspects of the White Paper we have been here before. In the early 1980s the old University Grants Committee consulted on designating the existing universities as ‘R’, ‘X’ or ‘T’, depending on their research intensity. The proposals were universally rejected. In the early 2000s, HEFCE toyed with the notion of dividing institutions into separate and distinctive groups depending on their overall orientation, but this also foundered. The institutions were almost all strongly opposed, the criteria and data for selection were insufficiently robust to be a basis for policy and the Funding Council anyway lacked the necessary powers. The same seems likely to be the case here, especially given the renewed emphasis on institutional autonomy built into HERA(2017).

    Where does the sector go next?

    In our forthcoming book, we argue that the post-80s reforms of higher education in England are a reflection of the key planks of neoliberalism: privatisation, marketisation and reduced claims on the taxpayer. The press release accompanying the White Paper speaks of it being a ‘landmark statement’. This it certainly is, if not in the sense seemingly meant by its authors. If the essence of neoliberalism is the subordination of all social and cultural activities to the needs of the economy, then this is indeed a ‘landmark’ document of which the authors of neoliberalism would have been justly proud.

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  • What the white paper told us about the Government’s future plans for R&D

    What the white paper told us about the Government’s future plans for R&D

    Author:
    Dr Hollie Chandler

    Published:

    This blog was kindly authored by Dr Hollie Chandler, Director of Policy at the Russell Group. It is the third blog in HEPI’s series responding to the post-16 education and skills white paper. You can find the first blog here, and the second blog here.

    When the white paper finally arrived, much of it confirmed the speculation that’s been rife all summer. Namely, that the Government wants a more joined-up skills sector where universities and FE collaborate more, offer a clearer set of pathways for post-16 choices, and widening opportunity for students from disadvantaged backgrounds. There was also a strong focus on quality, presented as a deal for the increase in tuition fees – a step towards financial sustainability that will be significantly undermined by the international levy.

    But alongside the paper’s focus on further education and vocational qualifications – most prominently the newly-announced V-levels – there was plenty of recognition for postgraduate skills and the UK’s world-leading research base.

    This was a welcome moment of focus for the postgraduate research community. These students are the lifeblood of our research and development ecosystem, but the number of new researchers starting a postgraduate qualification is in decline – decreasing by 10.4% between 2018/19 and 2023/24. If the UK is to become a true world leader in high-growth R&D sectors, then this is a real concern. The government’s own labour market projections show demand for workers educated beyond graduate level will grow 53% by 2035: the biggest increase for any qualification level. So it’s encouraging to see the Government considering how to bolster this vital talent pipeline.

    Part of this involves ensuring postgraduate study is more accessible to students from broad backgrounds, as well as increasing opportunities and support for people to use their skills and expertise in research settings. It’s an area that has long been overlooked in widening participation conversations, which is why the Russell Group recently launched a dedicated workstream to consider policies and share best practice. It’s about increasing opportunity, but also about ensuring we harness a wide spectrum of skills, knowledge and perspectives to inform vital research. For this to succeed, the conditions and culture of research must be set up to retain talent through the trickier early-career stages. It’s promising to see commitments to improving conditions, such as parental and medical leave, so postgraduate researcher students have the support they need.

    As always, many of the challenges come back to funding. Cost recovery on research is at a historic low, threatening the sustainability and global competitiveness of valuable R&D. Although UKRI commits to funding 80% of the full cost of grants, the reality is UK universities are only receiving 67% of their costs from funders – down from 75% in 2015/16. The Russell Group has previously explored a number of drivers behind this, and the white paper does reiterate some of the useful steps UKRI is taking. This includes making sure equipment is funded at 80% and confirming that matched funding by universities, which increasingly eats into cost-recovery rates, is not required. These are not new announcements – and there’s a long way to go if we’re to reach that 80% funding benchmark – but the government is making the right noises on better understanding cost-recovery challenges and pledging a concerted effort alongside charities, funding bodies and universities to tackle the problem together.

    The white paper places significant emphasis on the role of universities in regional economic growth and commits to creating a research system that enables collaboration and supports specialisation. We await further details on the “funding reforms” that will achieve this, but it’s encouraging to see a renewed commitment to dual support research funding and QR, and protecting curiosity-driven research through a new strategic objective for UKRI. We hope this means the government will be looking to address the real-terms decline in QR seen in recent years (down by 16.5% since 2010).

    The white paper also confirms that we can expect a review of the HEIF as the Government looks to align it more closely with the growth mission. We know HEIF brings great returns on investment: every £1 invested yields £14.80 at sector-level. Large research-intensive universities deliver an even higher return on investment from their HEIF allocations, as much as £20 once spinout performance is accounted for. We have long called for caps on HEIF to be raised, given its potential. For example, our modelling suggests that tripling HEIF could deliver around £11bn for the economy.

    There was no such funding boost indicated in the white paper, but there was recognition of HEIF’s power to generate growth by de-risking innovation, driving technology transfer and building entrepreneurial capacity locally and nationally. However, there are a lot of unanswered questions on how exactly HEIF could be pivoted towards the growth mission.

    A major benefit of HEIF, just like QR, is its flexibility. Our universities use it for everything from boosting pre-seed investment capabilities to establishing regional business hubs and empowering student entrepreneurs. It’s natural that the government wants the return on public investment to meet national priorities, but any blanket tailoring of how the fund is spent could impact its regionally specific benefits. It will be important to consult closely with the sector to make sure any review of HEIF enhances how universities contribute to local economies and doesn’t restrict initiatives that are already performing well.

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  • New HEPI Debate Paper: Higher Education for a Sustainable Economy

    New HEPI Debate Paper: Higher Education for a Sustainable Economy

    Author:
    Professor Tim Blackman

    Published:

    Too many students studying full-time honours degrees at university are causing higher education to be ‘over-consumed’.

    A Call for Radical Reform: Higher Education for a Sustainable Economy by Professor Tim Blackman argues that full-time honours degrees were created when universities were small and elite institutions. They were rolled over into the modern mass system of higher education we have today, with little thought about the appropriateness and affordability of providing such a large volume of learning straight after school, with the educational content expected to last a lifetime.

    Instead, Professor Tim Blackman says more people need to be studying shorter courses, spreading the cost over time while encouraging lifelong updating of skills and knowledge.

    You can read the press release and access the full report here.

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  • What does the post-16 education and skills white paper say about access and participation?

    What does the post-16 education and skills white paper say about access and participation?

    Author:
    Charlotte Armstrong

    Published:

    This blog was authored by Charlotte Armstrong, Policy Manager at HEPI.

    It is the second blog in HEPI’s series responding to the post-16 education and skills white paper. You can find the first blog here.

    Despite the post-16 education and skills white paper devoting an entire sub-section to ‘Improving Access and Participation’, the genuine challenges facing students receive minimal attention. The skills agenda within the Government is so strong that the paper frames students, and the student experience, in terms of their potential future contribution to the economy and regional growth. This results in little attempt to understand and address the student experience and the very real challenges that students are currently facing.

    A shift to the skills agenda

    The Lifelong Learning Entitlement (LLE) takes up several bullet points within this section of the paper. In fact, the decision to categorise the LLE under the heading of access provides an interesting insight into the Government’s broader approach to access and participation. Considering the LLE as a subsection of this initiative reframes the focus of access from entrance to higher education to employment outcomes and progression throughout a person’s life. This shift is an idea repeated throughout the white paper that dovetails with the Government’s skills agenda. It indicates that the Government views higher education as a means to add future value to the economy and a tool through which its Industrial Strategy can be furthered. This approach leaves little room for those subjects and disciplines that fall outside the strategy, let alone for learning for its own sake.

    Both modular LLE courses and the newly announced maintenance grants (as announced within the white paper, and previously at the Labour Party Conference) are available only to those studying courses that link to the Government’s wider Industrial Strategy. As may be easily guessed, this results in a list of subjects that largely dovetail with the science and technology sectors – arts and humanities subjects don’t get a look in. Tying maintenance grants to the study of pre-approved science subjects risks disincentivising students from low-income backgrounds from pursuing arts and humanities subjects – potentially entrenching bias and elitism within this sector, as well as furthering the narrative of ‘Mickey Mouse degrees’. As the costs of studying at university continue to rise, some prospective students will struggle to justify studying the subject of their choice if it means losing out on access to maintenance grants. Many of these excluded subjects are already in crisis – as the HEPI / Duolingo report The Language Crisis: Arresting Decline demonstrates, undergraduate enrolments in ‘Language & Area Studies’ have decreased by 20% in five years. Disincentivising students from taking these courses will surely only deepen this crisis further.

    These criticisms do not mean the LLE and the reintroduction of maintenance grants are bad policies. The latter is a particularly welcome development that has long been campaigned for by HEPI and the National Union of Students. However, the limited nature of their current form limits the positive impact they could otherwise have. While there is no current clarification on the precise threshold that will be placed on access to maintenance grants, the Government’s lack of movement on the parental income thresholds within the student finance system likely means only a very small number of students will be eligible.

    When first announcing this policy at the Labour Party conference, Education Secretary Bridget Phillipson claimed that the reintroduction of maintenance grants would ensure students spent their time at university ‘learning or training, not working every hour God sends’. This perhaps suggests that maintenance grants will be available in addition to, not instead of, the maintenance loan for those eligible students, although we keenly await the detail which will be outlined by the Chancellor in the upcoming Budget. However, this doesn’t solve the deepening financial crisis facing a large number of students in higher education – many of whom simply will not be eligible for the new maintenance grants.

    HEPI’s research into the Minimum Income Standard for Students highlights how the current maximum maintenance loan covers just half of the costs faced by freshers. Furthermore, the parental income threshold for eligibility for the maximum loan is currently so out of touch that a student from a household with a single parent earning just above the minimum wage will not be eligible for the maximum loan. The Government has sought to highlight that maintenance loans will increase in line with forecast inflation for every academic year, but this is merely a continuation of the current policy and will not address the financial crisis that many students face. Plus, forecast inflation tends to be lower than actual inflation. Similarly, the promise that care leavers will automatically become eligible to receive the maximum rate of loan is also a reiteration of a policy already in place. Care leavers (and estranged students) are classified as independent and therefore are eligible for the maximum loan. To reiterate, this maximum loan covers only half of the costs these students will face while at university.

    Postgraduate access

    The inclusion of postgraduate access in the white paper is a welcome addition – and an unsurprising one when considering how this white paper has framed access in terms of career progression and skills. However, once more, the inclusion of postgraduate students within access goals falls short due to a failure to address the root causes of the widening crises for home postgraduate students in England. Postgraduate taught tuition fees now exceed the maximum postgraduate loan – meaning that a student has used up their entire loan before even considering their cost of living.

    Instead of engaging with this, the paper encourages providers to include postgraduate study in their Access and Participation Plans (APP). This is, in itself, a positive development; however, without addressing the financial barriers faced by many prospective postgraduate students, this inclusion will have very limited impact.

    The access and participation section of the post-16 education and skills white paper provides an insight into how this Government conceives of these issues. However, the focus on students as future employees paints a worrying picture of a Government that is more concerned with next steps than with higher education itself.

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  • The white paper is wrong – changing research funding won’t change teaching

    The white paper is wrong – changing research funding won’t change teaching

    The Post-16 education and skills white paper might not have a lot of specifics in it but it does mostly make sense.

    The government’s diagnosis is that the homogeneity of sector outputs is a barrier to growth. Their view, emerging from the industrial strategy, is that it is an inefficient use of public resources to have organisations doing the same things in the same places. The ideal is specialisation where universities concentrate on the things they are best at.

    There are different kinds of nudges to achieve this goal. One is the suggestion that the REF could more closely align to the government missions. The detail is not there but it is possible to see how impact could be made to be about economic growth or funding could be shifted more toward applied work. There is a suggestion that research funding should consider the potential of places (maybe that could lead to some regional multipliers who knows). And there are already announced steps around the reform on HEIF and new support for spin-outs.

    Ecosystems

    All of these things might help but they will not be enough to fundamentally change the research ecosystem. If the incentives stay broadly the same researchers and universities will continue to do broadly the same things irrespective of how much the government wants more research aimed at growing the economy.

    The potentially biggest reform has the smallest amount of detail. The paper states

    We will incentivise this specialisation and collaboration through research funding reform. By incentivising a more strategic distribution of research activity across the sector, we can ensure that funding is used effectively and that institutions are empowered to build deep expertise in areas where they can lead. This may mean a more focused volume of research, delivered with higher-quality, better cost recovery, and stronger alignment to short- and long-term national priorities. Given the close link between research and teaching, we expect these changes to support more specialised and high quality teaching provision as well.

    The implication here is that if research funding is allocated differently then providers will choose to specialise their teaching because research and teaching are linked. Before we get to whether there is a link between research funding and teaching (spoiler there is not) it is worth unpacking two other implications here.

    The first is that the “strategic distribution” element will have entirely different impacts depending on what the strategy is and what the distribution mechanism is. The paper states that there could, broadly, be three kinds of providers. Teaching only, teaching with applied research, and research institutions (who presumably also do teaching.) The strategy is to allow providers to focus on their strengths but the problem is it is entirely unclear which strengths or how they will be measured. For example, there are some researchers that are doing research which is economically impactful but perhaps not the most academically ground breaking. Presumably this is not the activity which the government would wish to deprioritise but could be if measured by current metrics. It also doesn’t explain how providers with pockets of research excellence within an overall weaker research profile could maintain their research infrastructure.

    The white paper suggests that the sector should focus on fewer but better funded research projects. This makes sense if the aim is to improve the cost recovery on individual research projects but improving the unit of resource through concentrating the overall allocation won’t necessarily improve financial sustainability of research generally. A strategic decision to align research funding more with the industrial strategy would leave some providers exposed. A strategic decision to invest in research potential not research performance would harm others. A focus on regions, or London, or excellence wherever it may be, would have a different impact. The distribution mechanism is a second order question to the overall strategy which has not yet dealt with some difficult trade offs

    On its own terms it also seems research funding is not a good indicator of teaching specialism.

    Incentives

    When the White Paper suggests that the government can “incentivise specialisation and collaboration through research funding reform”, it is worth asking what – if any – links there currently are between research funding and teaching provision.

    There’s two ways we can look at this. The first version looks at current research income from the UK government to each provider(either directly, or via UKRI) by cost centre – and compares that to the students (FTE) associated with that cost centre within a provider.

     

    [Full screen]

    We’re at a low resolution – this split of students isn’t filterable by level or mode of study, and finances are sometimes corrected after the initial publication (we’ve looked at 2021-22 to remove this issue). You can look at each cost centre to see if there is a relationship between the volume of government research funding and student FTE – and in all honesty there isn’t much of one in most cases.

    If you think about it, that’s kind of a surprise – surely a larger department would have more of both? – but there are some providers who are clearly known for having high quality research as opposed to large numbers of students.

    So to build quality into our thinking we turn to the REF results (we know that there is generally a good correlation between REF outcomes and research income).

    Our problem here is that REF results are presented by unit of assessment – a subject grouping that maps cleanly neither to cost centres or to the CAH hierarchy used more commonly in student data (for more on the wild world of subject classifications, DK has you covered). This is by design of course – an academic with training in biosciences may well live in the biosciences department and the biosciences cost centre, but there is nothing to stop them researching how biosciences is taught (outputs of which might be returned to the Education cost centre).

    What has been done here is a custom mapping at CAH3 level between subjects students are studying and REF2021 submissions – the axis are student headcount (you can filter by mode and level, and choose whichever academic year you fancy looking at) against the FTE of staff submitted to REF2021 – with a darker blue blob showing a greater proportion of the submission rated as 4* in the REF (there’s a filter at the bottom if you want to look at just high performing departments).

    [Full screen]

    Again, correlations are very hard to come by (if you want you can look at a chart for a single provider across all units of assessment). It’s almost as if research doesn’t bring in money that can cross-subsidise teaching, which will come as no surprise to anyone who has ever worked in higher education.

    Specialisation

    The government’s vision for higher education is clear. Universities should specialise and universities that focus on economic growth should be rewarded. The mechanisms to achieve it feel, frankly, like a mix of things that have already been announced and new measures that are divorced from the reality of the financial incentives universities work under.

    The white paper has assiduously ducked laying out some of the trade-offs and losers in the new system. Without this the government cannot set priorities and if it does not move some of the underlying incentives on student funding, regional funding distribution, greater devolution, supply-side spending like Freeports, staff reward and recognition, student number allocations, or the myriad of things that make up the basis of the university funding settlement, it has little hope of achieving its goals in specialisation or growth.

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  • The white paper on regulation

    The white paper on regulation

    The Office for Students is a creation of the 2017 Higher Education and Research Act, but this legislation was not the last word on the matter.

    It has gained new powers and new responsibilities over the years, and – looking closely at the white paper – it looks set to expand its powers, capabilities, and capacity even further.

    As the Department for Education, and as ministers and politicians more generally, make new demands of the regulator it needs to be given the power to meet these demands. And this generally needs to happen via the amendment of HERA, which almost always requires further primary legislation.

    It is clear that much of the change that ministers expect to see in the higher education sector – as set out via the white paper – needs to happen via the action of the regulator.

    Regulation, rebooted

    The 2022 Skills and Post-16 Education Act gave OfS explicit powers to assess the quality of higher education with reference to student outcomes, protection from defamation claims based on regulatory decisions, and the duty to publish details of investigations.

    The 2023 Higher Education (Freedom of Speech) Act, alongside the various measures linked directly to freedom of speech and academic freedom, attempted to grant OfS the power to monitor overseas funding – this was, in the end, not enacted.

    These decisions to give OfS new powers and new duties will have been influenced by legal embarrassment (the student outcomes and defamation issues) and perceived threats (such as on overseas funding or freedom of speech), but measures are generally finessed in conversation with the regulator and its own assessment of powers that it needs.

    It is fair to assume that OfS – famously careful around legal risk – would largely prefer to have more powers rather than less. The diversity of the sector, and the range of political and public concern about what providers actually get up to, mean that the regulator may often feel pressured to act in ways that it is not, technically, permitted to. This is not a risk limited to OfS – witness the Department for Education’s legal travails regarding Oxford Business College.

    Aspects requiring primary legislation

    The white paper offers the Office for Students a number of new powers to do things which – on the face of it – it can already do and has already done. What we need to keep an eye on here is where the amping up of these existing powers happens in a way that overrides safeguards that exist to prevent arbitrary and unfair regulatory action. It is already troubling that, unlike pretty much anyone else, the Office for Students is legally unable to defame a provider (for example by posting details of an investigation including details that are later shown to be false).

    Quality

    The Department for Education seems to labour under the misconception that OfS cannot restrict a provider’s ability to recruit on the basis of “poor quality”. It can – and has done so four times since the regulator was established. Nonetheless, the government will legislate “when parliamentary time allows” to give OfS these powers again using slightly different words – and probably modifying sections 5 and 6 of HERA to allow it to do so (currently, the Secretary of State cannot give OfS guidance that relates to the recruitment and admission of students).

    This would be part of a wider portfolio of new powers for OfS, allowing it to intervene decisively to tackle poor quality provision (including within franchise arrangements), prevent the abuse of public money at registered providers, and safeguard against provision with poor outcomes for students).

    Again – these are powers, in the broadest sense, the OfS already has. It has already intervene to tackle low quality provision (including poor quality outcomes for students) via the B3 and other B condition investigations and linked regulatory rulings. And it has already intervened on franchise arrangements (most recently opening an investigation into the arrangement between Bath Spa University and the Fairfield School of Business).

    There will be a strengthening of powers to close down provision where fraud or the misuse of public funds is identified – and here it is fair to read across to concerns about franchise provision and the work of (“unscrupulous”) UK recruitment agents. Condition E8 – which specifically addresses the wider issues of fraud and misuse of public funds, currently applies only to new registrants: it is fair to ask why extending this to currently registered providers is not under consideration as a non-legislative approach. Clearly the infamous powers of entry and search (HERA section 61) and the power to require information from unregistered providers (HERA section 62) are not cutting it.

    Linked to these, OfS will be able to build capacity to carry out more investigations and to do so at greater speed – for which in the first part we should read that OfS will get more money from DfE. It already gets roughly £10m each year, which covers things like running TEF and administering the freedom of speech complaints scheme – this is on top of around £32m in registration fees from the sector (also public money) which sounds like a lot but doesn’t even cover staff costs at OfS. We are awaiting a consultation on OfS registration fees for providers for the future, so it is possible this situation may change.

    OfS’ proposed new quality regime is centred around TEF, a “section 25” scheme in the language of HERA. Schedule 2, section 2, of HERA is clear that a section 25 scheme can be used to vary the fee cap for individual providers. Indeed, it is currently used to vary the cap – if you don’t have a TEF award (at all) you can only charge a maximum of £9,275 next year. So no fancy legislative changes would be required to make fee uplifts conditional on a “higher quality threshold” if you happened to believe that a provider’s income per student should be determined by outcomes data from a decade ago.

    Not strictly speaking “quality”, but OfS will also get stronger regulatory power to take robust action against providers that breach their duties under the Higher Education (Freedom of Speech) Act – beyond even fining providers (as it has recently done to the University of Sussex) and deregistering (or adding a condition of registration via conditions E1 and E2), a power it has had since HERA was passed. I’m not sure what would constitute more robust action than that.

    Access and participation

    The access and participation plan (APP) regime is a remnant of the work of the former Office for Fair Access (OFFA). The Higher Education Act 2004 gave this body the ability to call for and assess “access agreements”, with the approval of OFFA needed for a provider to charge higher fees. Section 29 of HERA gave the impression that handed these powers directly over to the Office for Students – but in actuality it gave a lot more direct power to the Secretary of State to specify the content of plans and the way they are assessed via regulations.

    The proposals in the white paper look for a risk-based approach to APP, but at provider level – not the more general risks associated with particular groups of students that we find in the OfS’ current approach. Providers that do well at access and participation will benefit from streamlined regulation, for those that do not the experience may involve a little more pain.

    The big change is that access and participation will now look in a lot more detail at postgraduate provision and the postgraduate student experience. And section 32(5)(b) of HERA specifically prohibits plans from addressing “education provided by means of any postgraduate course other than a course of initial teacher training”. So we could expect some kind of legislative action (it may be possible to do via regulations but if there is a bill coming then why not?) to address this issue. And besides that, there will be a load of regulations and guidance from the Secretary of State setting out what she would like John Blake or his successor to do.

    Aspects requiring changes to the regulatory framework

    Registration

    In what is fast becoming a more closely coupled tertiary sector, OfS is set to become a primary regulator for every provider of higher education. There are three sets of providers that will be affected by this move:

    • Further education colleges (FECs) delivering higher education (courses at levels 4 and above)
    • Other providers delivering provision currently funded via Advanced Learner Loans (ALL)
    • Other providers designated for student loan support, including those delivering courses via franchise and partnership arrangements.

    In each of these cases, provision that is to all intents and purposes higher education is currently delivered without the direct oversight of the higher education regulator. This may be delivered with the oversight and approval of a higher education provider (franchise and partnership provision), or with the oversight of Ofqual (there are hundreds of these).

    The regulation of this kind of provision within FECs is probably best understood – as things stand all of the fundamental regulation of these bodies (stuff like governance and financial planning) happens via the Department for Education, which took on this role from the Education and Skills Funding Agency when it was abolished on 31 March 2025. The Department then provides assurance to the Office for Students and data to HESA.

    Designation for student support nominally happens via a decision made by the Secretary of State (section 84 of HERA) – in practice this happens by default for anyone delivering higher education. As we saw in the Oxford Business College case, arrangements like this are predicated on the assumption that what we might call regulation (quality and standards, and also – I guess – fit and proper person type stuff) is pushed onto the validating organisation with varying degrees of confidence

    Advanced Learner Loan (ALL) funded provision, confusingly, is technically further education (level 3 and up) but the logic of the machinery of the Lifelong Learning Entitlement wants to bring the upper end of this provision into the ambit of OfS. There was initially supposed to be a separate category of registration for ALL provision with OfS, this plan has been scrapped.

    We’ve known informally that it was unlikely to happen for some time, but it was actually the white paper that put the nail in the coffin. OfS will be consulting, this autumn, on the disapplication of certain conditions of registration for providers in the further education sector – though this shift will be a slow process, with current ALL arrangements extending through to 2030. But this consultation is very likely to extend much wider – recall that OfS is also tasked with a more robust approach to market entry (which, again, would be done via registration).

    Likewise, OfS has been tasked with toughening up the (E) conditions on governance, and the (D) conditions on financial sustainability (which would include forming a system-wide view of sector resilience working with UKRI) – we’ve seen evidence of a rethought approach to governance in the new conditions (E7 and E9) for initial registration, and have suspected that a further consultation would apply this to more providers.

    Degree awarding powers

    The ability to award your own qualifications is an important reputational stepping stone for any provider entering the higher education sector. It has an impact on the ability to design and run new courses, and also brings a financial benefit – no need to pay capitation on fee income to your academic partners. While quality and standards play a role in OfS registration decisions, these two aspects of provision are central to assessment for degree awarding powers as expressed via:

    An emerging self-critical, cohesive academic community with a clear commitment to the assurance of standards supported by effective (in prospect) quality systems.

    The current system (as of 1 April 2023) is run by the Office for Students after the decision of the QAA to demit from the role of Designated Quality Body. There are aspects that deal with student protection, financial probity, and arrangements for progression dealt with as a precursor to a full assessment – and here OfS looks for evidence that courses have been developed and approved in accordance with sector recognised standards: currently copy-pasted from the QAA’s (2014) framework for higher education qualifications and the UKSCQA degree classification descriptions (2019).

    When this arrangement was set up back in 2022 it was somewhat controversial. There was no sign of the sector recognised standard that is the QAA Quality Code, and seemingly no mechanism to update the official list of standards recognised by the sector as they are restated elsewhere. There is a mention of sector recognised standards in HERA, but these need to be determined by “persons representing a broad range of registered higher education providers” and “command the confidence of registered higher education providers”.

    External examiners are not mentioned in the sector recognised standards (despite being a standard that is recognised by the sector), but are mentioned in DAPs criterion B3k on the quality of the academic experience, in C1g on allowing academics to be external examiners elsewhere to gain experience (which F1i clarifies should be a third of academic staff where research degrees are offered). If you are applying for full DAPs you need to send OfS a sample of external examiner reports.

    In the white paper it is suggested that government is not convinced of the value of external examination – here’s the charge sheet:

    • We will consider the extent to which recent patterns of improving grades can be explained by an erosion of standards, rather than improved teaching or assessment practices
    • We will also continue to build the evidence base on the effectiveness or otherwise of the external examining system, which we will feed into the Office for Students’ programme for reform
    • We will also seek employers’ views about whether the academic system is giving graduates the skills and knowledge they need for the workplace.

    Of course, this sails worryingly close to devolved issues, as the external examiner infrastructure extends far beyond England: it is a requirement, supported by the sector, in Wales, Scotland, and Northern Ireland. External examiners do not often have any input into awarded degree classifications (that’s degree algorithms that are set internally by providers) so are not particularly likely to be a determining factor in more people getting a first.

    Indeed, the sector came together (back in 2022) to publish a set of External Examining Principles which exist as an annex to the statement of intent on degree classifications that forms a part of the OfS’s “sector-recognised standards.” It’s a good read for anyone who does not have a full understanding of the role of external examiners, both within institutional processes and those of the many professional, statutory, and regulatory bodies (PSRBs).

    This isn’t yet at the point of a consultation, just work the Office for Students is doing to update the process – a body of work that will also establish the concept and process of granting Higher Technical Qualification awarding powers. But we should watch some of the language around the next release of the OfS’ monitoring work on grade inflation – especially as the 2022 insight brief highlighted UUK work to strengthen the external examiner system as a key tool to address the issue.

    Other new responsibilities

    White papers generally try to make changes to the provision of applicant information – we have the 2004 white paper to thank for what is now known as Discover Uni, and the 2015 white paper put forward a simple precious metals based system that we have come to love as the Teaching Excellence Framework. Thankfully this time round it is a matter of incorporating Discover Uni style data onto UCAS course pages (which, and honestly I’m sorry to keep doing this) you can already find in a “student outcomes” section operated by the Office for Students. The white paper asks for continuation data to be added to this widget – I imagine not a huge piece of work.

    It’s 2025, so every document has to mention what is popularly known as “artificial intelligence” and we more accurately describe as generative large language models. A few paragraphs tacked on to the end of the white paper ask OfS to assess the impact of such tools on assessments and qualifications – adding, almost in passing, that it expects that “all students will learn about artificial intelligence as part of their higher education experience”. In direct, but light-hearted I am sure, contravention of section 8 (a)(i) of HERA, which says that providers are free to determine the content of courses.

    Which brings us to Progress 8 – a measure used in schools policy which adds together pupils’ highest scores from eight (hence the name I suppose) GCSEs that the government thinks are important (English and maths, plus “English Baccalaureate” subjects like: sciences, history, geography, languages) and produces a cohort average used to compare schools (here it is called “Attainment 8”) and compare average performance pupils in a given school cohort with how they did in simpler subjects at primary schools as a kind of value added measure (“Progress 8”). In other words, DfE looking in the white paper to work with OfS to build Progress 8 but for higher education is another stab at learning gain measures – something we’ve been investigating since the days of HEFCE and have never been shown to work on a national scale.

    Trust and confidence

    Regulation works via the consent of the regulated. Everyone from Universities UK down has been at pains to point out that they do see the value of higher education regulation, even if it was expressed in kind of a “more in sorrow than in anger” way at the primal therapy that was the House of Lords Industry and Regulator Committee.

    But this agreement over value is determined by a perception that the actions of the regulator are fair, predictable, and proportionate. These qualities can be seen by inexperienced regulators as a block to speedy and decisive action, but the work OfS has done to reset what was initially a very fractious relationship with the sector (and associated bodies) suggests that the importance of consensual regulation is fully understood on Lime Kiln Close.

    Every time the OfS gets, or asks for, new powers it affects the calculus of value to the sector. Here it is less a matter of new powers and more an issue of strengthening and extending existing powers (despite the occasionally confused language of the white paper). Everyone involved is surely aware that a strong power is a power that is perceived as fair – and is challengeable when it appears to be unfair. The occasional lawsuits OfS (and DfE) have faced have happened when someone is keen to do the right thing but has not gone about it in the right way.

    The coming consultations – ahead of legislation and changes to the framework – need to be genuine listening exercises, even if this means adding the kind of nuance that slows things down, or reflecting on the powers OfS already has and looking for ways to improve their effective use.

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  • What’s in the post-16 white paper for postgraduate study?

    What’s in the post-16 white paper for postgraduate study?

    The term “postgraduate” appears exactly 14 times in the Post-16 Education and Skills white paper : a clear improvement over 2021s Skills for Jobs (a mere two mentions in the appendix) and one more than 2016s Success as a Knowledge Economy (the one with the actual postgraduate student loans).

    So it looks like, more so than I’d personally have expected, “post-16” really does include “postgraduate” for once. But what does that mean?

    Fees & maintenance

    The obvious place to start is with the big headline: the planned increase to maximum tuition fees in the next two parliaments and the legislation to enable this to happen automatically thereafter. There’s also the (re)commitment to increase maintenance loans each year (I’ll leave Jim to explain what’s wrong with that).

    None of this really impacts postgraduate Masters and PhD students. Masters loans will also continue to increase with forecast inflation, but fees aren’t regulated and still aren’t properly monitored, despite promises to do so in 2016. PhD fees are largely shaped by the size of UKRI studentships, about which more below.

    I do think it’s interesting to consider what these undergraduate changes will do to perceptions of postgraduate fees. Will the cost of an MA or MSc provoke less sticker shock once BA and BSc fees (very quickly) cross the £10k rubicon? Or will greater undergraduate student loan debt make another £13k or so for a Masters feel less palatable?

    Personally, I think this stuff could end up mattering a lot, particularly if the government wants to improve postgraduate participation. Which apparently it does.

    Postgraduate participation

    We’re told that the government will “for the first time seek to address the barriers faced by disadvantaged students in accessing and succeeding at postgraduate level.”

    It’s fascinating to think about what this actually means.

    On access right now, little is known and less is done. There are some pockets of committed good work, often spotlighted here on Wonkhe and often supported by organisations like UKCGE (who I’m pleased to see will be funded to develop their involvement). But I can still point to data across our platforms demonstrating that postgraduate participation often looks very different to postgraduate interest.

    Postgraduate success, meanwhile, isn’t included in OfS B3 metrics and there’s still no postgraduate TEF. That means that, whilst continuation to a Masters records a good outcome for a university, progression from there isn’t really evaluated. The closest we have is LEO, which, though cited as “one of the best data sources” to drive informed student choices, is a crude and lagged metric taking no account of someone’s background.

    But what’s most intriguing is that all of this appears in relation to Access and Participation Plans.

    APPs determine a university’s ability to charge the higher undergraduate fee level. Postgraduate fees aren’t regulated, which leads to some of the mess around postgraduate funding. What’s here clearly isn’t a proposal to start scrutinising and intervening around PG fees but – like several other parts of the white paper – talking in this way is a potential step towards fundamental change.

    Home-grown PGR

    The white paper actually has a lot more to say about PhDs than it does about Masters degrees. Here’s where we find the most specific references to barriers faced by disadvantaged students and to challenges faced within specific subject areas.

    Here’s also where we find repeated references to a ‘home grown’ pipeline for UK research talent. Again, this is an interesting distinction to make. One of the few major interventions in PhD funding in recent years was the decision to open 30 per cent of UKRI studentships to international applicants from 2021. It hasn’t had a big impact on enrolments but it has meant more students – of all origins – competing for the same broad pot.

    The specific policy is light here (lots of verbs like ‘explore’ and ‘consider’) but prioritising domestic PhDs leads naturally to thinking about interventions around domestic funding.

    Elsewhere there are much clearer and very positive changes to medical and parental leave for UKRI-funded PhD students. This is explicitly framed as bringing conditions in line with employment law and therefore a step towards recognising that PhD students aren’t just students. Of course, this only applies directly to the relatively small proportion of students funded by UKRI.

    Post 16 postgraduate

    This is the first white paper in around ten years with a meaningful amount to say about postgraduate study. It does seem to understand what some of the key problems are and it seems to appreciate that PG is part of a joined-up system.

    There are other questions to ask – there’s little on Masters study and the perverse quirk of the international fee levy robbing PG to pay for UG feels worth scrutinising – but for once the government is asking questions about PG too. That is a good thing.

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  • The white paper kept quiet on market exit

    The white paper kept quiet on market exit

    The Department for Science, Innovation and Technology’s annual report in early July said that the government was working on a legislative programme to “ensure higher education sector access to an insolvency regime.”

    Yet for all that Monday’s post-16 white paper compiled together much of the ongoing work that had been trickling out of Whitehall for the previous 12 months, such plans were notable by their absence.

    Similarly, the Office for Students’ 2025–26 business plan said it was putting together proposals for a system whereby a “validator of last resort” for the English sector, which would protect students if the provider that validates their degree exits the market, as well as a possible “bespoke clearing system” for students in the event that their institution closes.

    Again, neither of these ideas got airtime in the white paper, despite skills minister Jacqui Smith having given her endorsement to the latter in comments to the media.

    The white paper in fact steers wholly clear of policy thinking around what would happen in the (ever more likely) event that a large English higher education provider finds itself in severe financial distress threatening its very viability. This omission is even more stark even against a background where we know that this risk has been scored “critical” and “very likely” on the DfE risk register, and the Office for Students has told the Commons education committee that it would be unlikely that it could “secure reasonable outcomes” for students if a large multi-faculty university closed, reeling off a list of all the ensuing risks ranging from students losing access to their academic records to PGRs whose work is tied to a particular supervisor finding transfer “difficult or impossible.”

    Perhaps the government simply wanted to steer clear of any negative news as it seeks to pat itself on the back for putting higher education on a “firm financial footing”, by way of keeping tuition fees at the same level in real terms (as long as inflation forecasts do not prove to be underestimates) while piling on additional costs to universities in areas including national insurance, pensions and a future fee levy. But – especially given that the white paper rounded up almost every policy initiative that is currently underway elsewhere in government, OfS and UKRI – it does feel, rather, that the idea of making legislative change to pre-empt issues around “market exit” has disappeared from the government’s to-do list.

    Pros and cons

    The education committee’s ongoing inquiry into higher education funding, which has the risks around insolvency as one of its central concerns, is shedding some light on the issues involved, both in the written evidence that has come the committee’s way and the first hearing which took place on Tuesday this week.

    Neil Smyth of lawyers Mills & Reeve told the committee that the fundamental answer to the question of what happens to an insolvent university which is not incorporated as a company – a large slice of the sector – is that “no-one quite knows”. He emphasised that there is debate about what the law entails, noting:

    At the moment, it is believed that the only insolvency process that would be available for a royal chartered entity or non-corporate entity would be to be wound up by the court as an unregistered company. That is a terminal process, it is a shutdown process, it is not a process that allows you to continue to trade.

    This uncertainty complicates what advice can be given to university governors about their responsibilities and liabilities – and also makes it difficult to see how student protection can be regulated for in such a situation. Mills & Reeve’s evidence to the committee adds that the unclear dispensations for unsecured creditors has, in their experience, led to something of a “land grab” among creditors:

    Key creditors, including pension providers, have sought to improve their position by demanding legal mortgages over land as these confer the contractual remedy of fixed charge receivership. This leads to highly expensive and time-consuming legal due diligence at just the point where the HEI can ill-afford those costs.

    Smyth, as he has previously argued on Wonkhe, told the committee that the advantages of some kind of restructuring regime being introduced included clarity for governors, confidence for lenders, and – as exists in the relatively new further education special administration regime – the potential for legal protections for students’ academic interests. That said, he warned that he couldn’t see a university coming out intact from such a process, given that student demand would inevitably collapse once the institution went into administration.

    However, Universities UK – represented at the committee hearing by chief executive Vivienne Stern – has moved away from advocating for a special administration regime. As the representative body’s evidence to the committee puts it:

    Universities UK’s current view is that it would be preferable to work with government, regulators and other sector bodies to clarify how existing arrangements can apply to higher education institutions, supported by stronger contingency planning at institutional level, and at the level of government, regulators and funders.

    The consequences of a large scale institutional failure would be so significant that policy effort should be primarily focussed on averting this outcome, rather than on mitigating its impact after the event.

    Stern highlighted the risk that a formal administrative process could be drawn out and expensive, and might even make it more likely that an institution collapses once entry into regime had taken place.

    The committee’s report will make a recommendation – it could be that Universities UK’s line of thinking has already swayed the government away from such a move. Committee chair Helen Hayes hinted that the committee will conclude that formal systems are needed, via her question to the effect of what would happen if there were a slew of insolvencies in short succession which compromised governmental and regulatory capacity to thrash out suitable arrangements behind the scenes.

    Fuzzy logic

    Keeping the threat of market exit – and the massive and unpopular clean-up job that would accompany it – hanging over the government’s head rather than handing off responsibility to a predetermined legal and fiduciary process is, sad to say, probably one of the few trump cards the sector still has to play around advocating for greater government investment.

    The lessons from FE, where a special administration regime has been in place for a few years now, are that the government seems reluctant to let things go as far as formal processes. In higher education, while it would depend on geography and circumstances, the smart money is probably still on Labour stepping in before push came to shove in a similar way to how the SNP felt forced to in Dundee.

    But there won’t be a Labour government forever. Future ministers who were relaxed (on paper) about universities going bankrupt would almost certainly be less keen to have to step in and make the final decisions in the places affected – while perhaps not being so worried if it ended up being purely a matter for the courts and the banks – and so keeping things fuzzy might end up being a sensible long-term strategy for the sector with an eye beyond 2029.

    That said, the apparent move away from government interest in legislating for a higher education insolvency regime doesn’t really explain why the white paper was quite so silent on other mitigating actions and the whole question of student protection (especially given its inclination towards “consolidation”). Is it really betting the house on the magical healing properties of holding tuition fees stable in real terms?

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