Tag: Quick

  • How higher education became a get rich quick scheme

    How higher education became a get rich quick scheme

    Sometimes, the problem with both media coverage and regulation is that critique of a part of the sector taints it all.

    When ministers or media outlets find sharp practice in recruitment or failings in student support, everything from OfS Insight Briefs to Sunday Times splashes can feel like the whole class being kept in for lunch when you weren’t making any noise.

    So has been the case for franchising. A specific group of universities has been subcontracting out to a specific group of private colleges in recent years – a group which has rightly picked up attention from the media, the National Audit Office (NAO), the Public Accounts Committee (PAC), the Office for Students (OfS), the Student Loans Company (SLC) and the Department for Education (DfE).

    Independent HE, for example, have argued elsewhere on the site that while they strongly support a tougher regime around franchising, the proposed approach of requiring only larger providers (300+ students) to register would be insufficient – missing many bad actors while creating administrative bottlenecks and failing to hold lead providers properly accountable for their partners. Instead, they advocate for universal basic registration for all teaching providers.

    Now, following last week’s long-awaited publication of data on subcontractual partnerships from OfS, we’re pretty confident that it’s possible to isolate and identify a specific subset of undergraduate providers in the English sector.

    Its defining characteristics are that its providers are privately owned, are (very much) for-profit, deliver non-specialist courses principally in Business and Management, and have been (very) rapidly expanding in recent years.

    Last year OfS said that in some cases there has been an “exponential growth” in student numbers in subcontractual partnerships over the last few years, with some lead providers now teaching more students through these arrangements than directly on their own campuses.

    It said that among other potential concerns, this raises questions about the direction of travel for the lead provider’s own strategic identity, aims and objectives.

    Our definition of a specific sub-sector is not perfect. There are a number of providers whose wholly-owned or directly-delivered satellite campus operations share some of those characteristics. Student numbers have not been formally published, and as ever there is lag in the data in general.

    In 2023-24, OfS’ student characteristics data dashboard shows that there were 101,950 students enrolled overall on subcontracted Business and Management courses – up from just 5,630 a decade ago.

    And if we derive from full-time, first degree continuation statistics, aggregate where companies are owned by the same parent, and attach those characteristics to partnerships where the entrant population was 100 or more in 2023-24, we can see 16 providers that enrolled over 40,000 FT FD entrants in 2022.

    Below threshold

    Aggregating both multiple providers in a group, and this sub set in general, is not an exact science. For each partnership between a university and private college, OfS has only published a denominator population rounded to 5 – which makes precision impossible. But we can estimate this sub group’s outcomes “performance” by implying a numerator from the percentages, and recompiling the numbers.

    The result is not stellar. In OfS’ press release to accompany the data, we learned that 77 per cent of FT FD subcontracted students continued courses into a second year, compared to 88 per cent in the sector as a whole. Against a regulatory minimum of 80 per cent, this group of providers averaged just 70 per cent.

    We learned that 74 per cent of subcontracted students completed their course, compared to 87 per cent for the sector as a whole and a regulatory minimum of 75 per cent. This subgroup scored just 70 per cent.

    The further out that a metric is from when students start, the longer it takes to pick up results – a real regulatory issue in a subsector that is expanding so rapidly. But when we look at progression to a graduate job or further study, it’s 71 per cent for the sector as a whole, 57 per cent of subcontracted students, and just 53 per cent of this subsector – against a regulatory minimum of 60 per cent.

    These providers are almost certainly inflating the sector’s performance on access – especially for those who are doing the franchising-to – access and participation stats are not (yet) split by partnership. But they are also dragging down the sector’s performance on outcomes, and giving subcontracting a bad name – all three of the key metrics would likely be above threshold if this group was removed.

    More importantly, if we follow OfS’ logic on outcomes and thresholds – that the figures are signals of whether students have the potential to succeed on the course, and receive good teaching and support through their studies – the group has been expanding yet failing.

    One area, though, where the group is not failing, is on financial performance.

    Healthy profits

    In 2023, the Russell Group estimated that in 2022/23, English universities on average supplemented the cost of educating each UK undergraduate student by £2,500 per year, with all subjects now making a loss on average.

    Not so much here in this sub sector. Because most of the 18 providers are not on the OfS register, the format (and even visibility) of annual accounts is uneven. Financial years and levels of disclosure differ, some are showing on Companies House as posting accounts late, and in many cases some of the income from fees moves up into a parent company in a way that prevents proper transparency.

    But on the basis that the bulk of their income is tuition fees after any franchising fee retained by the university passing on the SLC money that it gets, and assuming that “cost of sales” usually covers the provision of education rather than administrative expenses that are often dominated by acquisition costs, we can calculate a gross profit for the latest year that figures are available for.

    Below that line often huge dividends, director remuneration, domestic agent fees and the costs of renting space or borrowing from a parent co deflate the final profit figures. But in gross terms, notwithstanding that some of the group were micro-entities and exempt at last accounts publication, the group in scope posted gross profits of £504m on an income of £815m.

    Company Period end Turnover (£) Gross profit (£) Note
    Cecos Computing International Limited 31 Mar 2024 £ 20,269,818 £ 9,916,813
    Elizabeth School of London Limited 31 Aug 2024 £ 74,947,093 £ 46,856,529
    Fairfield School of Business Ltd 31 Aug 2024 £ 10,463,430 £ 7,254,024
    Global Banking School Limited 29 Feb 2024 £ 233,566,242 £ 128,068,724
    LCA (Education LTD + London LTD) 31 Dec 2024 £ 70,068,058 £ 36,388,054
    Ld Training Services Limited 31 Aug 2024 £ 10,185,134 £ 9,460,083
    London College of Contemporary Arts Ltd 31 May 2024 £ 25,360,932 £ 17,223,552
    London PT College Limited Not disclosed in abridged filings
    London School of Commerce & IT Limited 31 Mar 2024 £ 6,385,138 £ 3,434,817
    London School of Science & Technology Limited 30 Jun 2024 (15months) £ 83,771,009 £ 62,903,105 Group figures as filed
    Mont Rose College of Management and Sciences Limited 31 Aug 2024 £ 9,904,941 £ 8,489,293
    Navitas UK Holdings Limited (group) 30 Jun 2024 £ 57,222,133 £ 27,004,304
    Oxford Business College UK Limited 31 Aug 2023 £ 49,734,100 £ 31,030,795
    QAHE (LM+NU+UR) Limited 31 May 2024 £ 60,800,000 £ 34,400,000
    St. Piran’s School (GB) Limited 31 Dec 2024 £ 72,470,964 £ 59,211,778
    UK College of Business and Computing Ltd 31 Jul 2024 £ 18,032,506 £ 14,196,396
    Waltham International College Limited 31 Jul 2024 £ 12,127,614 £ 8,118,100
    TOTAL £ 815,309,112 £ 503,956,367

    Figures like that should push any sensible policymaker into windfall tax territory – or at the very least taking some of that profit and using it to relieve students burdened by a lifetime of debt of some of the balance. But more broadly, perhaps policymakers should take a step back and ask whether what’s being facilitated here should be.

    Avoiding scandals

    Ever since I was sent a photo back in 2022 of a domestic agent’s pull-up banner in a London shopping centre inviting students to claim their £15,000 in maintenance support, we’ve been trying to get to the bottom of what’s been happening with franchising.

    There’s a compelling reason for that. Franchising scandals over the last decade caused huge reputational damage for the sector and created an enormous regulatory distraction. When HEFCE and the Department for Education were spending their time devising ways to crack down on sharp practice, they weren’t focusing on improving the sector. The opportunity costs of franchising scandals are significant.

    We could see what was coming – a repeat of the problem. The Office for Students, already stretched, would end up spending much of its time attempting to regulate the rapid expansion. There was real danger of further reputational damage for the sector.

    What we’ve found are highly litigious providers, and real difficulty in getting the data we needed. We wanted to see who these rapidly expanding private companies were – companies specialising in “widening access” students, and lead providers appearing in graphs showing students claiming maintenance loans without fee loans.

    And from a student perspective, one of the issues has long been that if they want to find out what the outcomes would be like, they can’t really tell.

    This matters because almost all higher education advertising says “here’s what this has been like in the past, and so here’s what might happen to you.” The big problem was that when they apply to those providers, they are often told about the franchising provider’s outcomes – not the franchisee provider’s. They hear about the university’s figures for business studies, but can’t see the actual provider’s numbers.

    Franchise partners change frequently, and course names change often. The historical data needed to support statistics on Discover Uni simply aren’t available. Given that providers often have franchising deals with multiple universities, it can’t be unreasonable to ask how well these colleges perform on continuation, completion and graduate employment – especially when so much advertising focuses on careers and improving life chances, while obscuring debt.

    In OfS’ words:

    This [data] will be useful for prospective students, lead providers responsible for registering the students, and institutions responsible for teaching students on these courses.

    Even if the regulation was tightened, the incentives for the latter two of the parties on that list may be too strong to ever aspire beyond minimums. And for students – who have characteristics that are least frequently associated with an “informed actors in a choice market” ideal, even OfS’ data doesn’t show each of the franchised-to providers in aggregate.

    Why?

    This leaves us with a simple question. If the problem is non-specialist franchised provision – which certainly appears to be the case – why is the Department for Education funding it?

    It’s not provision that’s otherwise unavailable. It’s not serving some niche that doesn’t already exist. Students with talent, drive and aspiration would still access traditional universities. Students unsuitable for full-time study would pursue other routes. Students who need more support would have more money spent on them if it wasn’t being delivered to the bottom line in profit.

    This is, lest we forget, a part of the sector where expectations on harassment and sexual misconduct, or free speech, or charter work on mental health or fair admissions, are established only in part and often only in theory – and where student protection in the event of course, campus or provider closure is even thinner than it is elsewhere. Why are these risks concentrated on some of the least advantaged students in the sector?

    There are now real risks in contraction. Already some of the providers on the list have closed campuses and shuttered courses. Have reportable events been made? Are students being compensated for any breach of contract? And what happens if any of these companies just collapse – when the lead provider is often hundreds of miles away? These are tasks the government needs to take on.

    There are risks to allowing franchising, risks to allowing private providers to access the loan book, and risks to having no student number caps. In the last decade, the view was that the potential rewards were greater than risks. But notwithstanding the need to contract with care, it simply cannot be true that the world would be worse if these providers didn’t exist.

    Many things could be done. We’ve made proposals over on the Post-18 Project on different ways to regulate and restrict what’s happening here that draw on valuable lessons from colleagues in FE. But at the simple core, it comes down to this – why does DfE think it’s worth the risk to keep open the student loan book to private providers through franchise agreements for non-specialist subject higher education?

    The faster the government changes course, the faster all of us can turn our attention to improving higher education’s contribution to society and economic growth – rather than chasing around owners of colleges who, collectively, are getting rich off outcomes which OfS says are unacceptably poor.

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  • The Quick Convo All Writing Teams Should Have (opinion)

    The Quick Convo All Writing Teams Should Have (opinion)

    Scenario 1: You’re part of a cross-disciplinary group of faculty members working on the new general education requirement. By the end of the semester, your group has to produce a report for your institution’s administration. As you start to generate content, one member’s primary contributions focus on editing for style and mechanics, while the other members are focused on coming to an agreement on the content and recommendations.

    Scenario 2: When you’re at the stage of drafting content for a grant, one member of a writing team uses strikethrough to delete a large chunk of text, with no annotation or explanation for the decision. The writing stops as individual participants angrily back channel.

    Scenario 3: A team of colleagues decides to draft a vision statement for their unit on campus. They come to the process assuming that everyone has a shared idea about the vision and mission of their department. But when they each contribute a section to the draft, it becomes clear that they are not, in fact, on the same page about how they imagine the future of their unit’s work.

    In the best case scenarios, we choose people to write with. People whom we trust, who we know will pull their weight and might even be fun to work with. However, many situations are thrust upon us rather than carefully selected. We have to complete a report, write an important email, articulate a new policy, compose and submit a grant proposal, author a shared memo, etc., with a bunch of folks we would likely not have chosen on our own.

    Further, teams of employees tasked with writing are rarely selected because of their ability to write well with others, and many don’t have the language to talk through their preferred composing practices. Across professional writing and within higher education, the inability to work collaboratively on a writing product is the cause of endless strife and inefficiency. How can we learn how to collaborate with people we don’t choose to write with?

    Instead of just jumping into the writing task, we argue for a quick conversation about writing before any team authorship even starts. If time is limited, this conversation doesn’t necessarily need to be more than 15 minutes (though devoting 30 minutes might be more effective) depending on the size of the writing team, but it will save you time—and, likely, frustration—in the long run.

    Drawing from knowledge in our discipline—writing studies—we offer the following strategies for a guided conversation before starting any joint writing project. The quick convo should serve to surface assumptions about each member’s beliefs about writing, articulate the project’s goal and genre, align expectations, and plan the logistics.

    Shouldn’t We Just Use AI for This Kind of Writing?

    As generative AI tools increasingly become integrated into the writing process, or even supplant parts of it, why should people write at all? Especially, why should we write together when people can be so troublesome?

    Because writing is thinking. Certainly, the final writing product matters—a lot—but the reason getting to the product can be so hard is that writing requires critical thinking around project alignment. Asking AI to do the writing skips the hard planning, thinking and drafting work that will make the action/project/product that the writing addresses more successful.

    Further, we do more than just complete a product/document when we write (either alone or together)—we surface shared assumptions, we come together through conversation and we build relationships. A final written product that has a real audience and purpose can be a powerful way to build community, and not just in the sense that it might make writers feel good. An engaged community is important, not just for faculty and staff happiness, but for productivity, for effective project completion and for long-term institutional stability.

    Set the Relational Vibe

    To get the conversation started, talk to each other: Do real introductions in which participants talk about how they write and what works for them. Talk to yourself: Do a personal gut check, acknowledging any feelings/biases about group members, and commit to being aware of how these personal relationships/feelings might influence how you perceive and accept their contributions. Ideas about authorship, ownership and credit, including emotional investments in one’s own words, are all factors in how people approach writing with others.

    Articulate the Project Purpose and Genre

    Get on the same page about what the writing should do (purpose) and what form it should take (genre). Often the initial purpose of a writing project is that you’ve been assigned to a task—students may find it funny that so much faculty and staff writing at the university is essentially homework! Just like our students, we have to go beyond the bare minimum of meeting a requirement to find out why that writing product matters, what it responds to and what we want it to accomplish. To help the group come to agreement about form and writing conventions, find some effective examples of the type of project you’re trying to write and talk through what you like about each one.

    Align Your Approach

    Work to establish a sense of shared authorship—a “we” approach to the work. This is not easy, but it’s important to the success of the product and for the sake of your sanity. Confront style differences and try to come to agreement about not making changes to each other’s writing that don’t necessarily improve the content. There’s always that one person who wants to add “nevertheless” for every transition or write “next” instead of “then”—make peace with not being too picky. Or, agree to let AI come in at the end and talk about the proofreading recommendations from the nonperson writer.

    This raises another question: With people increasingly integrating ChatGPT and its ilk into their processes (and Word/Google documents offering AI-assisted authorship tools), how comfortable is each member of the writing team with integrating AI-generated text into a final product?

    Where will collaboration occur? In person, online? Synchronously or asynchronously? In a Google doc, on Zoom, in the office, in a coffee shop? Technologies and timing both influence process, and writers might have different ideas about how and when to write (ideas that might vary based on the tools that your team is going to use).

    When will collaboration occur? Set deadlines and agree to stick with them. Be transparent about expectations from and for each member.

    How will collaboration occur? In smaller groups/pairs, all together, or completely individually? How will issues be discussed and resolved?

    Finally, Some Recommendations on What Not to Do

    Don’t:

    • Just divvy up the jobs and call it a day. This will often result in a disconnected, confusing and lower-quality final product.
    • Take on everything because you’re the only one who can do it. This is almost never true and is a missed opportunity to build capacity among colleagues. Developing new skills is an investment.
    • Overextend yourself and then resent your colleagues. This is a surefire path to burnout.
    • Sit back and let other folks take over. Don’t be that person.

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  • When You Need An Online Presence Quick

    When You Need An Online Presence Quick

    Do you need an online presence yesterday? You may be wondering how can I improve my online presence as a professor, researcher, or scientist quick.

    “I have a big talk coming up, it would be great to have my website up by then.”

    “My tenure review packet is due next month. Any chance we could have the website up?”

    “The book comes out in X month, my publisher needs my bio soon.”

    “It would be great to have this done before our grant proposal is submitted.”

    You may want to be intentional about your online presence if you need it for a

    • Conference, talk, or event
    • Book
    • Job search
    • Funding application or annual review
    • Award
    • Application
    • Press release
    • Board meeting

    I’m not always able to help academics who come to me with a short turnaround. But that doesn’t mean there aren’t ways for you to have a stronger online presence now. You have agency in how you show up online.

    What should I do 1st?

    Google yourself. What’s can people find about you and your research now? What makes up your digital footprint?

    Gather what they need from you. We’re you asked for specific materials such as your bio, headshot, or social media handle? If yes, these may be items to consider improving. This is more for an event, media appearance, or announcement.

    Update your bio, it’s a living document, adaptable to your needs. If you’re unsure where to start with your online presence, I always recommend your bio. In this video, I share top tips for writing and revising your academic bio with my friend, presentation expert, Dr. Echo Rivera.

    Here’s advice for writing your LinkedIn headline specifically.

    Need new photos of you? It’s okay to ask for support. For instance, can your university provide a professional photographer for the event? If not, can they recommend someone local? You can seek approval for use of funds towards that or other things for your online presence. If you’re doing a media appearance or event, it’s okay to ask your host if there will be photos or video.

    You can also ask a friend or family member to take photos of you. While selfie are a good option, a phone-camera savvy friend is ideal.

    I did my 1st professional photo shoot this year. It was much more comfortable than I expected because I had a great team there to help me. You can hear all about it in an upcoming interview for The Social Academic with the photographer and makeup artist I’ll be recommending to my clients. I can’t wait to share our conversation with you. I’ll update this article when that interview goes live, so bookmark it if you’d find it useful.

    Update your social media profile(s). Any small change makes a difference for how you communicate with people. While there’s a few tips in this article, here’s your how to guide for updating your social media profiles.

    Try pinning an introduction post (or post about what you most want to share with people) to the top of your profile.

    What can I use for my online presence

    LinkedIn is great for academics. Here’s 32 reasons why. Updating your LinkedIn profile instantly improves what people can find about you online. These LinkedIn resources are here to help you.

    Want section-by-section support? Sign up for my LinkedIn Profile for Professors and Researchers course.

    If you have access to make updates yourself, your faculty profile is a great way to improve your online presence. For most academics, it can be a slow process to request an update be made. If you’re unsure how to make changes to your faculty profile, now is a great time to ask.

    You could make a 1-page personal faculty website. Here’s what to include on yours.

    As part of the Best Personal Academic Websites Contest, Brittany Trinh, Ian Li, and I put together this Setting Up Your Personal Academic Website event. The replay will help you set up your website today with Owlstown, a free website builder for academics. Plus, what to expect with other website hosts (like my favorite, WordPress.com).

    If you need your website today, Owlstown is a great option for you.

    If you don’t want a website, but you still want something for people to view online, consider a Google Doc, Word Doc view only, PDF or other media with a public share link. If you need something more visual, consider a Canva presentation.

    Need a social media graphic? Canva is my favorite option. I’ve helps professors around the world feel comfortable using Canva for their social media. I even went to Cava Create last year in Los Angeles. This year’s event is coming up on April 10.

    Canva Create stage with a panel of speakers on Being a Force for Good: Meet the Action-Inspiring Changemakers with 4 people on stage.

    Social media graphic ideas:

    • Introduce yourself
    • Share your research
    • Meet your team
    • Share a paper or publication
    • Talk or event info
    • Invite people to your course (okay this one isn’t as timely, but still a fun idea, I had to share it with you)

    You don’t need to work with me to have a stronger online presence now. Find resources on The Social Academic blog (try searching by category). There are interviews you may find helpful on the podcast and on YouTube. You’ve got this! ✨

    Work with me on your online presence

    You don’t have to do it alone. I’m Jennifer van Alstyne. I help individual professors, research labs and groups communicate who you are and what you care about online. You can have your website designed for you. You can have set-up of their LinkedIn profile done for you. You don’t have to write your own bio (unless you want to). It’s okay to get support for your digital presence as a faculty or researcher.

    Professors with a tight turnaround typically book a private 1-on-1 consultation with me on Zoom. That way we can work together in real time to make a difference for your online presence. Academics like having an expert to ask their questions. Most save significant time with ideas that just won’t work for their goals and needs. I’m happy to help you on a private consultation too.

    Sure, there’s other ways we can work together on your website project, but sometimes you need a website “like yesterday.” Is that you? A quick website may be a good fit for you.

    But if your schedule is a bit more flexible, let’s meet on a no pressure Zoom call about working together so we can customize a service that fit your lifestyle, needs, and goals. Find a time on this online calendar.

    While I can’t promise I’m able to work with you when it comes to a quick turnaround, I promise to help you in the right direction (even when it isn’t working with me).

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  • The franchise problem may not have a quick answer

    The franchise problem may not have a quick answer

    So everyone is (still, after more than a decade) agreed that student loan fraud and poor quality provision is a huge mark against the practice of franchise provision.

    Moreover, we’ve generally come to the conclusion that something needs to be done – and although an investigation will be helpful, that something needs to be fairly swift and concrete action.

    Most people are assuming that this will take the form of a requirement to regulate franchise partners, via compulsory registration by the OfS, or some other regulatory change.

    Didn’t we try something like that before?

    The government is currently consulting on whether all institutions in England delivering higher education to more than 300 students should register, at some level, with the regulator.

    This in itself is far from a new idea. When the Department for Education first consulted on what became the Office for Students regulatory framework, providers had the option to register in the “Registered basic” category – a third category that simply recognised that an institution was providing higher education in England.

    This category will provide a degree of confidence for students that is not present in the current system with providers in the Registered basic category being able to let students and other bodies know that they are recognised by the OfS as offering higher education courses.

    As registration in this category was intended to be optional there would need to have been a benefit to registration, and there would be no way of assuming that all England’s higher education provision was covered. On franchise arrangements in particular, the initial proposals suggested that:

    the delivery provider [in a franchise arrangement] will not normally be required to register. If it chooses to register, the Registered basic category will normally be the most suitable category because the lead provider is responsible for compliance with all required registration conditions for the Approved and Approved (fee cap) categories.

    For many in the sector responding to these ideas, these assumptions offered little to protect students or the system as a whole. In summarising the consultation responses, the government reported that

    there were widespread calls for the Registered (basic) category to carry additional conditions to protect students’ interests, such as transparency, student protection plans, student transfer and electoral registration conditions. Respondents were concerned that students at those providers in the Registered (basic) category would be at risk of assuming greater protection than will be provided in that category

    The combination of the limited oversight offered to those in the “Registered basic” category (which was configured pretty much as a list of people who had paid OfS £1,000), and the additional burden that that any more active requirement would place on smaller providers, meant that OfS concluded that:

    we have decided to remove the Registered (basic) category from the published regulatory framework. The effect of this decision is to avoid misleading students about the protections available at Registered (basic) providers

    But that wasn’t the end of it. OfS also noted (and this is worth setting out in full):

    we recognise that unregulated providers will continue to operate, as they would have done even if the Registered (basic) category had been included (albeit, possibly, in lesser numbers). We are concerned with all students, not only those at registered providers, and remain committed to the policy intention set out in the regulatory framework consultation – to improve transparency and student protection at those higher education providers that are currently unregulated. We shall therefore give priority to developing our understanding of providers and students in the unregulated parts of the sector, to determine how we can most effectively have a role in protecting the interests of students at these providers

    At the time, when franchise arrangements were considered at all by ministers, they were painted as an unnecessary rigmarole for exciting new entrants to the market. Speaking to Universities UK in 2015, then higher education minister Jo Johnson famously said:

    Many of you validate degree courses at alternative providers. Many choose not to do so. I know some validation relationships work well, but the requirement for new providers to seek out a suitable validating body from amongst the pool of incumbents is quite frankly anti-competitive. It’s akin to Byron Burger having to ask permission of McDonald’s to open up a new restaurant.

    So how’s all that going, then?

    Byron Burger, of course, entered administration twice in three years. In contrast, the franchise model in higher education never looked short of cash or interest. The Office for Students never used its own “validation powers” (section 51 of the Higher Education and Research Act allowed the OfS to get involved in academic partnerships directly, as kind of a response to the argument that delivering courses on behalf of a competitor in order to enter the sector was anti-competitive). Instead, it commissioned the Open University to be (effectively) a validator of last resort for FE colleges on others seeking to enter the HE market (this arrangement is set to conclude in July 2025).

    When the Higher Education Funding Council for England closed in March 2018, it directly funded 313 higher education providers, while having at least an awareness of 816 places in England where higher education was being delivered. The Office for Students currently has a funding and regulatory arrangement with 425 providers – for the current regulator, there is no regulation without funding. The impact assessment published alongside HERA implied that in 2024-25 there would be 631 in either the Approved or Approved (Fee Cap) registration category – postulating 1,131 institutions delivering higher education in England in total.

    The postulated rush to register did not happen, even when DfE closed the old “specific course designation” route to regulated and funded provision for alternative providers in August 2019. As sector interest group Independent HE has documented, the Office for Student registration process was generally experienced as expensive and cumbersome: where providers have been actively seeking regulation and oversight, it has been very difficult to obtain. Indeed, when OfS faced pressure to get more actively involved in securing sector finances, it was able to unlock significant internal resources by “pausing” registration.

    By closing the “specific course designation” route, and making full registration slow and difficult, OfS has incentivised smaller providers to enter the least regulated (and riskiest, for students and public funds) part of the higher education sector. If that constitutes “developing an understanding” of the unregulated part of the sector, one has to question what this “understanding” actually is.

    The other end

    The financial pressures currently engulfing the sector has encouraged many established providers to get involved in franchising arrangements – they get to keep a portion of the fee income related to students involved in such arrangements. In return, they are expected to provide oversight of quality and standards on courses leading to awards bearing their names, and handle all of the regulatory requirements relating to those students.

    The numeric threshold approach to regulation (wherein a provider faces further investigation if the proportion of students continuing on their course, completing their course, and progressing into employment or further study, falls below a minimum) does mean that such provision is regulated, after a fashion. There is an open investigation on franchising at Leeds Trinity University, and we understand that current quality-related investigations are focused in part on franchise provision.

    Where the Student Loans Company spots evidence of potential fraud (or when OfS is notified of a concern) usually but not always involving a franchise arrangement, both OfS and DfE may become involved in an investigation. A recent uptick in such cases has led OfS to set out expectations in more detail.

    For these reasons most providers that franchise out provision are assiduous in ensuring what is being delivered is of a decent quality. However, the market incentives – at least in the short term – are stacked in the other direction. Some larger providers are increasingly reliant on income relating to students studying within franchise arrangements, and the demand for such relationships gives franchise providers the ability to shop around. Where an awarding organisation has attempted to impose more stringent quality requirements, there have been instances where the delivery partner has simply ended the partnership and entered a new relationship that offers less work and/or more cash.

    What regulatory tools are actually workable?

    So when something bad is identified, there’s always a subset of the population who think that there should be a law (or at least, regulation) to stop it happening. It’s an attractive idea, until you start to think about implementation. There are many trade offs.

    Option one: ban all franchise provision

    In other words, you would decree that unless you have degree awarding powers, you shouldn’t be delivering higher education. You would, in practice, have to ban all new recruitment to franchised courses and allow for some form of teach-out, unless you want to face a mass legal action. On a teach out, with no likelihood of any new students, the quality of provision would fall even further as providers withdraw funding and interest.

    Meanwhile, a fair number of large providers rely on franchise income to make ends meet. So factor in the closure of a few universities – with further pressure on other providers to offer teach out – as that part of the sector slowly becomes unviable. Which would be a shame for all those students working hard at FE colleges (franchising pretty much started as a way to support FE colleges delivering HE in hard-to-reach areas), and at the quality and specialist end of franchise provision, and for on campus students at providers heavily involved in franchise provision.

    To be clear – you may not value some of the providers involved, or some of the courses students are enrolled on. But if either disappeared you would need to come up with a way to look after the interests of the legitimate students involved.

    Option two: selectively ban some franchise provision

    Take all the drawbacks of option one, but also add in the difficulty of reliably and consistently distinguishing the kinds of provision you want to see supported in this way from that which you want rid of. You could use metric thresholds in a B3-esque way, you could attempt to do something clever with subject areas, or even base the ban directly on your suspicions of fraudulent activity. You’d have to be absolutely certain, mind – such decisions will almost certainly end up in court (you are dealing with a lot of higher education income, and it is unlikely you will get it dead right every time). Even something as straightforward as a subject area (“business studies”) is notoriously tricky to define when you get down to actual course content.

    Option three: require all providers involved to register with OfS

    Even assuming OfS has the capacity to quickly register a load of providers currently delivering franchise provision, there has to be a question as to how quickly and how well the regulator can then act where there is low quality provision. Back in 2024 we got a promise that the next round of OfS quality investigations would have a particular focus on franchise provision (from last time this story cropped up) – as yet we’ve not even seen reports, much less regulatory action.

    It’s looks like this has been one of many casualties of the regulator, at the urging of the government, throwing as much effort as possible behind addressing the financial issues the sector has been facing (we’re also expecting findings from the investigation into the academic partners of Leeds Trinity University that kicked off more than a year ago)

    Option 4: continue with tripartite enforcement

    OfS, DfE, and SLC already work together (increasingly regularly) to act on evidence and information relating to student finance fraud. One approach to address the problems as reported – which encompass value for taxpayer funding in the wider sense of good quality provision as well as the more specific fraudulent and criminal examples – would be to continue to reinforce and prioritise this collaboration and data sharing. There have been some steps taken to ensure that OfS is gathering and using the appropriate data, and that the three organisations are able to work together in using regulatory or financial sanctions to deal with concerning situations.

    However, this is what we are doing currently, and it would appear that the rate of success is not yet high enough. There were recommendations in the NAO report that cover stuff like risk management, drawing on evidence, and agreeing responsibilities: all of which are examples of basic stuff that is not being done consistently or well. That’s a worry.

    Option 5: number controls

    There is a case for number controls for franchised provision, linked to a regular (ideally cyclical rather than risk based) quality engagement. Where there is good and useful franchise provision we should be happy to let it expand, where there are even mild concerns we should be happy to constrain recruitment. And there is no way that the kind of rapid scale up of activity we’ve seen at some providers can be done without compromising quality – there should be an absolute proportional limit on expansion.

    Last time this story did the rounds, Jim made a compelling case for a 25 per cent of total provision cap similar to that used by the ESFA to regulate franchise FE provision in 2020. There’s not a lot of the current HE sector that would be hit by such a rule, but there are a handful of prominent examples for whom a higher ratio is pretty much existential (yes, you could argue that such institutions may not be viable anyway, but how does that help students or the wider sector?). There would need to be a time delay on full implementation, and support and guidance for those that need to rapidly downsize existing operations. Again, you might need to consider teach out arrangements as well.

    So where next?

    If you’ve set up, as the government in England has over the last decade, a fairly open market for higher education provision based on students as consumers having enough information, you need to regulate in the interests of the consumer (in this case both the individual students and the taxpayer). It’s neither unexpected or unprecedented for schemes with incomplete safeguards and developing approaches to regulation to be at risk of fraud – and it is essential to be able to quickly identify and act where it is happening.

    For me, the speedier collection and use of data around franchise provision – regarding the student experience, student outcomes, and the financial and operational approaches involved – is essential. There should be specific and regular data submission points for lead providers involved in franchise provision – this should be assessed quickly and action taken where there are causes for concern. OfS already has a notification system, which should be better promoted – it should also work with other bodies who collect information about the student experience. As much data as possible should be published: transparency is a valuable tool in avoiding murkier practices.

    I’m not convinced of the benefit of a full regulatory relationship with franchise providers. OfS does need to know who they are and keep some records as to which delivery providers have been problematic in the past – but in terms of incentives it makes more sense to regulate the lead partner. And number controls, while far from universally popular, would help in this case.

    You’ll note that none of this requires new legislation – we should take with a grain of salt the claim that OfS does not have the powers to act in these situations, it absolutely does. However the regulator may not have the capacity to act as quickly or as decisively as it may like – so there may need to be additional money available from DfE to build these capabilities.

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  • Quick Update on Research Funding

    Quick Update on Research Funding

    Remember the spring budget, when the Federal government announced a heavily back-ended $1.8 billion (spread over five years) boost to research grant funding, as well as the creation of a capstone research organization which might have its own funds to co-ordinate challenge-based research? Well, the federal government has recently been fleshing out these announcements through a series of badly coordinated media releases. And so today, we’re going to go on a quick government press release safari to try to work this out.

    The three granting councils have all issued statements about how much new funding they expect to receive over the next five years. SSHRC says that its share of the $1.8 billion will be $316 million. CIHR says it is in line for $540 million over five years. NSERC does not provide a figure over five years, but it does say it what it will receive in years one and five, and since these figures are both pretty close to the numbers CIHR cites, I’m going to go ahead and say that NSERC is set to get something around $540 million as well. Total to the councils is therefore $1.396 Billion over five years.

    In addition to this, the government says it is going to give $182 million over five years for the creation of 224 new Canada Research Chairs. It also says it will be providing $452 million to the Research Support Fund (RSF) for things such as establishing digital tools to support research and cybersecurity and supporting inclusive and indigenous research. A separate press release says it will be providing $354 million to support the indirect costs of research

    Now, if you’re counting carefully, you’ll realize that total government announcements total to $2.03 billion. Which, it should be superfluous to add, is not $1.8 billion.

    Confused? Me too.

    And the government is not done with announcements. Recall from the spring budget that one of the key announced changes was the creation of a “capstone” organization which would sit above the tri-councils without actually directing them. Details on what it would do and how were scarce, mainly because ISED and Finance were at loggerheads over the issue and so the feds did what they always do and punted the question for a few months with the magic words “details to come in the Fall Economic Statement.” 

    Now, it’s not entirely clear that there actually will be a Fall Economic Statement (Dec. 21st is fast approaching and there’s still no date set), but one key question it was meant to resolve was whether or not the capstone organization would, as recommended by l’Université de Montréal’s estimable Frederic Bouchard and the rest of his Advisory Panel, have funds of its own (beyond those run by each of the tri-councils) for a) multi- and interdisciplinary research that falls through the cracks between the councils and b) mission-driven research. I think the general assBudumption in the research community is that while the capstone organization might not get a ton of money for these activities, the sum would nevertheless be non-zero. So we’re more than likely not just $200 million dollars over the originally-announced budget but probably $300 million or more.

    It’s not peculiar that this government might go over budget on something. What is peculiar is that the current government, famous for believing (or at least giving every evidence of doing so) that spending money is in and of itself evidence of program effectiveness, wouldn’t take credit for it. If they were actually bumping up their overall spend, past form suggests they’d be shouting it from the rooftops instead of letting some random higher education blogger work it out on his own and then share it with a few thousand of his closest followers. 

    A mystery to be cleared up soon I guess. 

    One other point of note here is a wrinkle in how the additional indirect support grants will work. Overall, indirect support has been equal to about 22% of “direct” funding: that is, for every dollar of tri-council grant that goes out, 22 cents accompanies it to cover overhead (most informed observers think actual overhead is closer to 50 cents, but this is another story). The sum being allocated in these announcements—$354 million to accompany a $1.4 billion increase in council grants—is more or less in line with this figure.

    BUT—and this will be a big but for some people—the money is only going to be given to institutions which receive more than $7M/year in tri-council grants, which basically means the U15 plus a half-dozen others. Why? Well, because that 22% average is just that: an average. The biggest tri-council grant recipients (i.e. the U15) only get indirect funding equal to about 18% of their tri-council grant haul. At some of the smallest institutions, the figure can be as high as 80%. This equalization formula has, as you can imagine, driven the U15 absolutely spare over the two decades it has been in force, and so you can read this part of the announcement as a victory for the Big Rich Universities. 

    More when we get a Fall—or possible a Winter—Economic Statement. See you then.

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