There is much that is useful in the Independent Review of the Office for Students (OfS).
Unfortunately, this does not include the section on “regulating quality”.
The overall impression it gives is that the review does not really understand how the OfS has operated in relation to quality, its capacity for carrying out work in relation to quality or the potentially profound implications of its recommendations.
Although, if it did understand these things, then its recommendations would be even more concerning.
TEF work
In terms of how the OfS has operated in relation to quality, the review seems to mistakenly think that, because the OfS organised the Teaching Excellence Framework (TEF), it was somehow responsible for the judgements the TEF made about quality. It was not.
This was undertaken by a separate TEF Panel who had expertise in educational quality. Similarly, it misleading claims that the OfS “developed” case studies of excellent practice from the TEF whereas these were written by selected HE providers.
It is only this kind of misunderstanding of the track record of the OfS that allows the review to conclude that the OfS should act as the Designated Quality Body (DBQ) and should “form a view of what quality above minimum standards looks like, and to use that intelligence to disseminate best practice and drive quality across the sector for all providers and students” (p.60).
Co-ordinated
This misunderstanding of the OfS role is equivalent to thinking that UK Research and Innovation (UKRI) has the expertise to judge the quality of research because it organises the Research Excellence Framework (REF) and the research funding councils. If it needs stating, both represent a profound level of misunderstanding.
Neither UKRI nor the OfS have the expertise, experience or credibility to make these judgements. Their important role is rather to organise and co-ordinate systems of peer review that are then the vehicle by which the quality review is undertaken. It may be that there is an unstated assumption in the review that the OfS will co-ordinate a rigorous form of peer review by experts in each disciplinary and professional field to determine quality but this is not mentioned in the review and there is no recognition of the amount of additional work this would create for the OfS.
This matters because, unlike in other sectors where regulators do assess quality, the quality of education offered by higher education providers is related to the purposes of the particular programme they are studying, the forms of knowledge that are the focus of the programme, the students who are studying the programme and the setting in which the programme is located.
To give the OfS the power, let alone the responsibility, to define educational quality across the sector raises huge questions in relation to institutional autonomy and academic freedom.
It is remarkable that such potentially far-reaching recommendations can be made without any reference to, or apparent awareness of, these kind of issues. Particularly as the first duty of the OfS listed in the Higher Education & Research Act is to “the need to protect the institutional autonomy of English higher education providers”.
That the Review not only proposes that the OfS can act as the DBQ but that the Higher Education & Research Act should be amended to make this the only possible arrangement suggests that the OfS have undertaken a much more successful job of convincing the Independent Review of its view of the sector than it did with the House of Lords Industry and Regulators Committee. Indeed, one is left with the impression that, on quality, the review gives the OfS precisely what it would have asked for.
The problem is that this is at the expense of proposing an approach to quality assessment and enhancement that is rigorous but maintains institutional autonomy and academic freedom across the sector.
