- Stephanie Marshall is Vice-Principal (Education) at Queen Mary University of London. She is the author of the forthcoming Strategic Leadership of Change in Higher Education (3rd edition). Ben Hunt is Executive Officer (Education) at Queen Mary University of London.
In contrast to the adage that ‘good strategy closes doors’, the Office for Students (OfS) Strategy consultation has left many options open. This is true of the Teaching Excellence Framework (TEF), which the OfS intends to bring into alignment with its wider quality regime:
‘TEF will be the core of our new integrated approach to quality, with assessment activity becoming more routine and more widespread to ensure that institutions are delivering high quality academic experiences and positive outcomes’.
Cart before the horse?
The OfS has stated in its consultation that it will expand its quality assessment regime without evaluating how this exercise has, or will, enhance education provision.
Previous investigations were seen as burdensome and lacking transparency.[1] On transparency, Professor Amanda Broderick, Vice-Chancellor & President at the University of East London, reflected on a quality investigation: ‘…we were not informed of what the OfS’s concerns had been at any point of the review’.
On burden, Professor David Phoenix, Vice-Chancellor of London South Bank University, has written about an investigation at his provider: ‘…providers are already very used to…scrutiny. Professional and regulatory bodies (PSRBs) have their own approaches to course review and validation, and in many instances the level of scrutiny can greatly exceed that of the OfS’.
And in a recent HEPI blog, the ex-higher education minister and architect of TEF Lord Jo Johnson asserts that the OfS has consistently deprioritised innovation.
So perhaps the OfS has reached a moment of choice: to stick or pivot.
Stephanie Marshall has written previously about the different global ‘pivots’ in higher education quality: ‘massification, quality assurance, quality enhancement, and then a move to addressing equity deploying large data’.
The OfS’s decision to pause new provider entrants has arguably stalled massification. It is duplicative when it comes to assurance with other regulators such as Ofsted. And its deployment of data through the Data Futures process is beset by delays. Instead of enabling providers to embrace change, an unintended consequence of these decisions is that sector innovation is slowed. Amidst this and the sector’s financial challenges, the OfS seeks to expand its investigatory regime without a clear theory of change linked to enhancement.
Pivot Part 1: From assurance to fremragende
In a Norwegian report to which Marshall contributed, it was noted that: ‘In English, the term ‘excellence’ is now much overused…In Norwegian the word “fremragende” has a sense of moving forward (frem) and upward (tall or reaching above the rest, ragende) and is reserved to describe something really cutting-edge’.[2]
Centres for disciplinary excellence in education were established in Norway through the Centres for Excellence (CfE) Initiative, introduced by their previous Quality Assurance body, NOKUT. To be eligible for CfE status and funding, higher education institutions had to meet baseline standards and evaluate the distinctive quality of their provision. Each Centre selected its own criteria aligned to the provider’s vision and mission.
Of course, there were challenges with this process, particularly when it came to differences in judgements of the panel assessing, against the institution being assessed. However, NOKUT was open to evolving its views, positioning itself as a ‘critical friend’. This process set out to be supportive and iterative, focused on both past impact and continuous improvement. The success of this approach has been validated over the years by regular evaluations of the impact of the scheme.
In England there were 227 providers who participated in TEF. Adopting a system from a country with 21 higher education providers is clearly not practical. The important lessons are, firstly, a critical friend approach can be beneficial to enhancement, and, secondly, institutions can be trusted to evolve some of their quality metrics in line with their mission and values. This is particularly important in a system as diverse as in England where most providers are already above the quality baseline.
Fremragende may be a more accurate framing of authentic educational enhancement rather than the English buzzword ‘excellence’. Frenragende suggests an ongoing journey: a verb rather than a noun. The higher education environment is and will be in a state of flux where quality frameworks need to be agile and unlock innovation, particularly in the territory of AI.
Pivot Part 2: Enabling enhancement through data
The OfS has a basket of lagging indicators: the National Student Survey (NSS) and Graduate Outcomes Survey (GOS) which comprise the TEF. If they are utilised in the next TEF, which seems likely, one way to begin to move from assurance to continuous improvement could be for the OfS to encourage greater use of the optional NSS bank. There are additional questions in place regarding the views of healthcare students, and several optional additional questions. An integrated approach could also be taken to the questions within the GOS, either enabling some optional questions for graduates, or mapping the GOS questions to those in the NSS.
This flexibility would demonstrate trust, give providers a way to articulate ‘learning gain’, and capture the diversity in the sector. It would also maintain many of the positive aspects of TEF for key stakeholders, including the centrality of the student voice through the NSS and other mechanisms.
Pivot Part 3: Quality through partnership
Any approach to integration should be a partnership with students, providers, international organisations and employers. We hope that entrance into the International Network for Quality Assurance Agencies in Higher Education will enable the OfS to collaborate with other global quality bodies.
The OfS should consider how, in its assessment of excellence, it integrates learning from other inspection regimes, such as Ofsted and existing PSRB requirements. Through this, it should reduce regulatory duplication. This is in line with the Regulator’s Code principle of ‘collect once, use many times’.
A mindset shift from assessing the baseline to forward-facing, continuous enhancement is required, both by the OfS and the sector. With further contextualisation of provision, the sector can exercise its autonomy to drive excellence, and the OfS can fulfil its statutory role in enabling quality and innovation.
Let’s join our Norwegian colleagues in adopting the fremragende approach.
