The Behan report, published last week, is a robust and thorough analysis of higher education regulation in England.
Scrutiny by the external eye of a regulation heavyweight like David Behan can only be a good thing.
The report’s recommendations around the student interest, independence and financial sustainability will be a relief for so many across the sector.
Quality matters
It is also welcome that the review looked in detail at the quality system. As QAA has said previously, the value of enhancement above the baseline, qualitative intelligence, and the ability to respond with agility to emerging developments are characteristics of any world-leading quality system.
Another principle of world-leading quality systems is alignment with international good practice. The review’s recognition of the importance of alignment with the European Standards and Guidelines is really encouraging to see. In our role as one of the world’s leading experts in quality assurance, and indeed as a key ambassador for UK higher education overseas, we see and hear first-hand the confusion that the lack of alignment in England creates.
Students deserve a quality system that involves them at all levels. Providers deserve a quality system that supports them to improve and provides an accurate public track record of their quality. And international stakeholders deserve a quality system that delivers trust in English provision for partnerships and international students.
International reputation
The review astutely identifies a number of flaws in the quality system. The question is whether or not its recommendations will address those flaws. There is a danger that issues with international compliance with the European Standards and Guidelines, and UK-wide coherence, have been underplayed.
The UK Government is signed up to complying with the European Standards and Guidelines as part of its commitments under the European Higher Education Area. This is called the Bologna Process. Countries demonstrate their system’s compliance by ensuring their quality body is on the European Quality Assurance Register.
As it stands, the map that indicates how well a country meets these commitments shows England as “yellow” (partially aligned), rather than the “green” (fully aligned) that Scotland, Wales, Northern Ireland and most of Europe are. One of the reasons it is yellow (partially aligned) and not orange (not aligned) is because QAA still conducts a small volume of ESG-compliant cyclical reviews in England for providers who aren’t on the OfS register, improving England’s overall rating.
The Behan report stops short of recommending that OfS seek EQAR registration. This is perhaps understandable. The OfS has a much broader remit than just quality. But merely demonstrating equivalence will not deliver on the UK Government’s commitments under the EHEA. It is unlikely to turn the map green and therefore unlikely to fully reassure international stakeholders.
Self-defeating
This fact, combined with the recommendation to remove provisions for a DQB from HERA, has concerning implications. In the above context, the DQB provisions in HERA could end up being an important insurance policy should the suggested reforms in Behan not go far enough to reassure international partners and the risks of non-compliance continue to crystallise.
It seems self-defeating to remove a provision in HERA which is not compulsory and so provides no obstacle to implementation of the Behan recommendations. Moreover, it could be the key that unlocks ESG compliance in the future if the UK government wishes to remain committed to its obligations under the EHEA, and OfS decides not to seek EQAR registration.
Recent comments from Secretary of State Bridget Philipson at the Education Embassy conference on international collaboration in higher education were a breath of fresh air. They also did not sound like a Secretary of State willing to turn their back on the European Higher Education Area.
UK coherence
The Behan report also shines a light on the issue of UK-wide coherence. Bridget Philipson’s recent phone calls with her Scottish and Welsh counterparts indicate that UK collaboration and coherence could be more of a priority for this Westminster government than the last. As the UK higher education sector becomes increasingly internationalised, the need for coherence across the nations and a strong UK-wide narrative is increasingly important.
International stakeholders see the UK as a single entity. As reform continues in Wales and Scotland, and the Behan report recommendations are implemented, it is vital that these cross-nation conversations continue to ensure we don’t sleepwalk into a level of incoherence that stifles the UK higher education system’s reputation internationally.
Any reform that continues to strengthen the quality system in England is welcome. But UK coherence, and international good practice under the European Higher Education Area, should form key considerations of that reform moving forward. We look forward to working with governments and regulators across the UK to ensure that happens.
