Government’s letter to the Lords re TEF: A reply

Opinion piece by Dorothy Bishop

The Higher Education and Research Bill (HERB) has had a rocky passage through parliament. As explained here, a Bill goes through several stages before it becomes law, with debate in both the House of Commons and the House of Lords, as well as Committee work that involves detailed line-by-line scrutiny of the text.  The Lords are primarily the revising chamber and they have passed a series of major amendments to HERB. The government has incorporated some of these amendments, but on its return to the Commons, the Bill may lose the Lords’ changes, and, as discussed in the Times Higher, there could be some to-and-fro before the Commons votes through a final version.

We have featured a series of posts on this blog discussing the amendments that have been proposed over the past two months:

One topic that particularly exercised the Lords was the new Teaching Excellence Framework (TEF). Introduction of the TEF did not require legislation: it was a manifesto commitment. Specifically, the Conservative manifesto stated: ” “We will ensure that universities deliver the best possible value for money to students: we will introduce a framework to recognise universities offering the highest teaching quality; encourage universities to offer more two-year courses; and require more data to be openly available to potential students so that they can make decisions informed by the career paths of past graduates”. Accordingly, the TEF is already underway in a preliminary form. Nevertheless, numerous objections have been raised to it. Many of these were stated in the response to the initial Green Paper introducing the idea, including our own response. Yet, as documented in an earlier post, these objections were largely ignored. However, the Lords, who include many people with considerable experience in Higher Education, continued to have concerns.

At last, it seems, the Government are taking the concerns seriously. Jo Johnson, the Minister responsible for HERB, and Viscount Younger of Leckie, a Conservative Peer who is the Lords Spokesperson for Higher Education, have written a letter on 3rd March to offer clarification of questions that had been raised about the TEF in the House of Lords.

As someone who has voiced repeated concerns about the TEF, I offer here an analysis of the points made in that letter. For detailed sources please see these slides from a lecture on this topic.

Page 1. Para 2a states ‘The TEF is essential to driving up standards of teaching. All those who spoke during the Committee stages of the Bill agreed that teaching quality is of paramount importance.’

We can all agree that teaching quality is of paramount importance in our Universities – this is motherhood and apple pie. However, the statement that the TEF is essential to drive up teaching standards contains two shaky premises: that standards need ‘driving up’, and that the TEF would achieve this. We only need to introduce sector-wide measures to address teaching if there is evidence it is inadequate. I have argued elsewhere that this case has never been made. In a speech in 9th September, Johnson talked of ‘patchiness in the student experience’ but presented only anecdote to support his case. In the Green Paper, it was claimed that both students and employers were dissatisfied with teaching, yet the evidence was cherry-picked and mis-represented the sources from which it came.

The Government is fond of treating Higher Education as a market, yet their ideas for improving the market are ones that few businesses would adopt. Anyone operating a widget factory knows that to maintain quality control, you don’t give every widget a detailed inspection: you adopt a process of sampling a small proportion, so you can be ready to check the production process if you find an unacceptable level of problems. Even Jo Johnson accepts that our Universities are world-leading, yet he wants to impose a further burden of evaluation to complement the Research Excellence Framework (REF). This will take money and resources from research and teaching and so be counterproductive. I would suggest that instead of a TEF we need:

  • A system of quality control that will scrutinise any institutions that show signs of failing (e.g. because of high level of complaints). We already have this with the Quality Assurance Agency (QAA).
  • Incorporation of some information about teaching quality in the REF Impact section – see this proposal by Roger Brown.
  • Disincentives for Universities to use zero-hours contract staff for teaching; this could include a section on staff well-being and moral in the Environment section of the REF.
  • Incentives for sharing good and innovative teaching practices

Page 1 para 1b. ‘The TEF will provide the financial and reputational incentives for providers to prioritise teaching excellence and student outcomes. Genuine and clear differentiation between providers and a link with fees are essential to achieving these outcomes.

The downside of yet another ranking system are simply ignored here. What is needed is a diverse higher education system, with different institutions developing their own specialised approaches to suit the very varied needs of our population. A crude ranking, further subdivided into Gold, Silver and Bronze, treats higher education as some kind of horse race, where quality can be measured on one dimension.

Page 1 para 2-3 notes that ‘It is important that we treat fairly those who have already decided to take part….The assessment process is already well underway and to change the “rules of the game”… would be extremely unfair on those who have invested their time and effort to participate this year’

I’m tempted to respond, ‘Well, whose fault is that, Minister’. It is Johnson who has chosen to implement an ill-thought-through evaluation system, with threats to participating organisations that they will lose their ability to raise fees unless they take part. And he also promised that TEF would not be onerous. But now we are told that those institutions who have taken part would have invested time and effort and so it would be unfair to stop. One is reminded of someone who orders a meal that makes them sick but persists in eating it, because the money has been spent.

What is really unfair is to adopt a system of evaluation that is based on unsuitable metrics, is incapable of making meaningful distinctions between institutions, yet which has the potential to damage the standing of a University.

Page 2, para 2. ‘We recognise the genuine and considered concerns raised by noble Lords about the TEF, in particular around the speed at which it is being implemented and on the use of metrics and ratings….a genuine lessons-learned exercise will take place after this trial year.’

Well, at last it seems there is recognition that the TEF in its current form is unworkable. Criticism has come from individuals who might be expected to support it; see e.g. this account of an interview with Chris Husbands, Chair of the TEF Panel on Jan 25th in the Times Higher:

‘“I do not think student satisfaction is an accurate proxy for teaching quality,” said Professor Husbands, a former director of the UCL Institute of Education who was named chair of the TEF panel by the Department for Business, Energy and Industrial Strategy in August 2016.

Professor Husbands drew attention to US studies that show that student satisfaction scores are heavily influenced by non-academic factors, including the sex or ethnicity of a lecturer.

“Student satisfaction seems to be driven by the physical attractiveness of academics rather than anything else,” he said of the US research findings.’

And Stuart Croft, VC at Warwick on Jan 31st wrote in the Times Higher ’…the metrics are flawed. This is not renegade opinion, but rather the overwhelming view of those actually involved in higher education….Yet the government has us over a barrel. It has linked the TEF to tuition fees and, potentially, our ability to recruit international students.

Page 3. Para 1 states that ‘…the TEF is about much more than metrics. Providers submit additional evidence alongside their metrics and this evidence will be given significant weight by the panel.’

But what is the reliability and validity of the ‘additional evidence’? This seems like encouragement to Universities to tell plausible stories about their teaching and try to anticipate which buttons they need to hit to convince a panel that they are Gold rather than Silver and Bronze. There is huge scope here for subjectivity at best and corruption at worst.

Page 3. Para 2 state ‘All of the metrics used in the TEF are trusted, widely used and well established in the sector….. The NSS is just one of three principal sources of metrics data being used, and we have explicitly said that the NSS metrics are the least important. The TEF does not use in any way the overall ‘satisfaction’ rating, about which the House has rightly expressed concern, but instead uses specific questions from the NSS, related to teaching and learning.’

It’s hard to know where to start with this. There are numerous issues with using the NSS for assessing teaching quality, and changing the items that are used does not solve them. There are problems with validity – does the measure assess what it is supposed to measure, bias – are ratings affected by the teacher’s gender, race or disability, and sensitivity – is the spread of scores adequate for differences between institutions to be meaningful? Statistical criticisms have been made by both the Royal Statistical Society and the Office of National Statistics. We are told in para 2 that ‘the Government has already taken a number of steps to ensure that the statistics being used are robust, including commissioning a report by the Office of National Statistics.’ They seem to think that the ONS will somehow be able to magically transform an unreliable, insensitive scale into a meaningful indicator of teaching quality. Statisticians are good, but not that good. Furthermore, all the statistical problems that afflict the TEF are magnified with small samples, and small samples are going to be inevitable if we move, as we have been told we must, to subject-specific assessments.

It is depressing, though not surprising, to find that the letter ends by telling us the university sector must be ‘shaken out of its complacency’. It’s an easy but lazy point to say that opposition to the TEF is just the response of a complacent group of academics who are set in their ways, because it means you don’t actually have to consider the arguments. I suspect that Johnson would be surprised to find just how passionately many of us care about our Higher Education system. If he could grasp that point, he might start to take note of us when we tell him his superficial and rushed approach to evaluating teaching is resisted because of the considerable potential it has for harm.








Why the NSS is garbage

A note by Lord Lipsey    

The National Students Survey results matter. First, they are used by students to evaluate institutions by comparison with rival institutions. Secondly, they are one of the metrics to be used in the TEF, in awarding gold, silver or bronze markings to institutions which apply to take part. These ratings will decide if an institution can or cannot raise its fees beyond £9K.

The idea that student satisfaction should play a major role in the rating of universities is controversial. Research shows that there is no correlation between student satisfaction and student results in terms of degree grade . However the government has opted to increase the importance of student choice, competition and satisfaction in the higher education landscape; and this short note does not seek to address the rights and wrongs of that.

Rather it focusses on a narrow point: whether the National Student Survey (NSS), the chosen instrument to measure student satisfaction, is fit for purpose or not.  Here the evidence is unequivocal, The NSS is statistical garbage, The reasons are widely understood by the statistical community and were set out inter alia by the Royal Statistical Society in its response to the government’s technical consultation about the TEF Consultation-on-Teaching-Excellence-Framework-year-2.pdf.

  1. The NSS is not based on a random or representative sample of students. It is more akin to a census, which includes everyone who chooses to complete the form but not those who don’t. Some groups eg ethnic minorities are seriously underrepresented. As the final report of the ONS Review of Data Sources for the TEF 2016 said: “under-reporting of certain groups and over-coverage of others …could lead to bias in use of the data.”

I chair Trinity Laban Conservatoire of Music and Dance, a leading London Conservatoire. This year Trinity Laban’s response rate to the NSS rose from about 60% to about 80%. This makes any comparison between last year’s results and this year’s results invalid. We know nothing about the 20%; so a 50% satisfaction rate amongst respondents could perfectly well be a 70% satisfaction rate amongst students as whole.

  1. Even if the responses are treated as a random or representative sample, making calculations of statistical significance possible, the margins of error in the NSS figures are large. The ONS concluded that “differences between institutions at the overall level are small and are not significant” Yet on that are being based student decisions on where to go, and the level of fees institutions can charge.

So for example Trinity Laban’s  music results – and music is our biggest group of students -are based on 112 students. To take an example only 49% of these students say that marking on their course has been fair. Statistically however and treating the returns as if they were a sample, this means that there is a 95% chance that between 34% and 64% of students think it is fair. This perhaps exaggerates the unreliability of the NSS insofar as. if response rates are high, then the results may be less unreliable that they would be for a sample. But the point still applies. cases of smaller sub-samples the low response renders the results vacuous. For example for Trinity Laban Musical Theatre the poor results were based on response from just 23 students.

The small sample size is a particular problem for small institutions. It is also a grave problem in that the most valid comparisons are not between institutions, but between particular departments in institutions teaching the same or similar courses. For individual courses, there will tend to be only a fraction of the responses obtained for institutions as a whole.

  1. The results can be greatly affected by happenstance. Results in the TL musical theatre department in the past have been good which suggests that there was some peculiar chemistry about this year (and also there is some suggestion that students coordinated their responses to make a point). A survey of dance satisfaction for Trinity Laban was completed the day after a one-off cock-up about room bookings; had it been done two days earlier the results might have been much better.
  1. There is scope for “gaming” the results and encouraging students to give positive results,. Trinity Laban does not do this. Anecdotal evidence, as cited by the RSS paper above suggests that less scrupulous institutions do, and the incentive to do so will be greatly increased now that the NSS has new significance as a metric for the TEF.
  1. Less concrete but not less important, an emphasis on the student experience may lead to undesirable effects on what they are taught. Institutions focussed on a high NSS score will tend to dumb down degrees or go for safe options on content. ]

Here is an example from Trinity Laban. TL exists due to an amalgamation of Trinity College of Music and Laban dance. A few years ago, the Principal introduced a compulsory two-week course called CoLab which was a creative programme involving dance and music working together. At first students were furious at being deprived of these two weeks off from the focus of their studies – and no doubt this would have been reflected in their satisfaction ratings. However time has passed; familiarity has grown; and CoLab is now one of the most popular things we offer with our students.

In addition, during the ONS review of the NSS,  respondents expressed reservations about wider issues related to the use of information from the NSS and the DLHE. Concerns included:

  • limited variation between institutions of the raw scores from the student responses
  • difficulty in trying to compare widely differing institutions
  • difficulty in capturing the wider benefits beyond academic results of attending a higher education institution

The government has already downgraded the importance of the NSS in TEF – the so-called LSE amendment made when it was pointed out that NSS suggested that LSE and a number of other prestigious institutions were rated low by students. The metric should be subject to intense scrutiny when the House of Lords debates the Higher Education and Research Bill in committee; and I am tabling amendments to make sure it is.

The spurious precision of the NSS has the capacity to damage staff morale, to put students off certain institutions and affect the validity of the TEF. I know of at least once case where a head of department at a major institution came close to resigning because of a disappointing NSS result. I know of another where a Principal was dismissed inter alia because of the failure of that institution’s NSS results to improve. This is terrifying.

Lord Lipsey is joint Chair of the All Party Statistics Group, a Fellow of the Academy of Social Science, a Board member of Full Fact the fact checking charity, a former member of the advisory council of the National Centre for Social Research,  founder of Straight Statistics and a former adviser on opinion polling to James Callaghan as prime minister. In other words, though he may talk nonsense on many subjects, this is not one of them!

Perils of ignoring consultation on the Higher Education and Research Bill

Opinion piece by Dorothy Bishop

Earlier this week, Lord Patten, former Conservative chairman, published a searing attack on the government’s Higher Education and Research Bill in the Observer, stating:

“It seems ham-fisted to turn the academic world upside down when universities face so much turbulence and uncertainty after the Brexit vote and the rhetoric surrounding immigration.”

He was supported by a cross-party group of peers, including Labour’s shadow higher education minister Lord Stevenson, who stated:

“This bill is an attempt from the Government to run a market experiment through the bloodstream of our university system, and a classic case of understanding the cost of everything and the value of nothing.”

These comments are closely aligned with the CDBU’s evaluation of the Bill, and we are pleased to see a list of 516 Amendments to the Bill has now been proposed by the Lords.

We have to ask how on earth the situation has arisen whereby a Bill is not only being comprehensively revised at this late stage in its progress, but is also receiving criticism from heavyweight Conservatives who might have been expected to support the Government.

The problem appears to be the intransigence of the Minister, Jo Johnson, who has  ignored serious arguments against his Bill, which have been flagged up many times over the last year.

Let’s start by looking at the responses to the Green Paper which outlined the main proposals in the Bill. The volume of responses to the consultation was quite remarkable: there were 618 respondees in all, including 136 Higher Education Institutions, 26 alternative providers, 22 further education colleges, 78 student unions, and a large number of individuals and organisations with a stake in the sector.

These responses were summarised in a report by BIS. In addition, many institutions posted their response on the web, including the Universities of Cambridge and Oxford: I’ve singled these out because they are our most ancient universities, and might be expected to represent an establishment view. Critical comments in their feedback anticipated the points now being raised in the House of Lords, and might have been seen as a canary in the mine by a Minister less self-assured than Jo Johnson. Consider this comment from the preamble to the response by the University of Cambridge:

“The Green Paper fails to demonstrate an understanding of the purpose of our universities and the reasons for the sector’s international standing. Universities exist to pursue knowledge for the benefit of society, through education (teaching and learning), scholarship and research.”

Are such objections restricted to the Russell Group? It would appear not. The summary of the consultation findings by BIS does not break down responses according to their origins, but it does provide quantitative data for several items where respondents were asked to state Agree/Not Sure/Disagree. These had a worrying high level of Not Sure responses, suggesting that the proposals in the Green Paper were too vague or unclear to evaluate; in addition, the rates of Disagree were higher than Agree for many items – only 6 of 24 items attracted more than 50% agreement. And where Agree outnumbered Disagree, it tended to be for questions concerning general ideals, such as the desirability of improving access for disadvantaged groups; questions about specifics of implementation of proposals received a higher rate of negative responses.  The two items marked with * concerned the link between TEF results and fees, and were among those with lowest levels of endorsement.

screen-shot-2017-01-07-at-09-11-40Figure 1: Proportions of Agree/Not Sure/Disagree to items included in the Green Paper consultation (See report for details of items; number in bracket refers to consultation question number).

There was also a technical consultation on the TEF, which fared no better. The Office of National Statistics expressed concern about the suitability of the metrics to be used to evaluate teaching quality, and the Royal Statistical Society witheringly noted:

“It is concerning that Figure 4 equates student satisfaction as measured by the National Student Survey (NSS) with Teaching Quality. We are not aware that there is any evidence of a statistical association between the two concepts.”

Given this level of concern, one might have expected some radical revisions between the Green and White Papers. In fact, there were few changes, except that the TEF, which had been a major (and much-criticised) feature of the Green Paper was removed from the White Paper. Because it does not require legislation to introduce the TEF, it was possible to keep its implementation separate from the rest of the Bill, so it could be steamrollered through ready for introduction in 2017.

There were further opportunities for the Bill to be amended as it proceeded through the Committee stage in Parliament. And Jo Johnson described himself as listening to feedback, saying:

During September and October, a cross-party committee of MPs scrutinised the Bill, along with over 300 additional tabled amendments. We heard evidence from a wide range of witnesses from university vice-chancellors and the National Union of Students to the head of Research Councils UK and consumer groups such as Which? And now we’re at Report Stage, you will see that we have reflected on these views.

Except that none of the 300 tabled amendments were included! A handful of modifications were made to some statements to increase clarity and avoid ambiguity, but the core plans remained unchanged.

The House of Lords includes peers of all political stripes, but a key point is that many of them have extensive experience of the HE sector. They have run universities, sat on Councils, and they understand about all kinds of higher and further education, not just Oxbridge. Similarly, the CDBU has members covering a wide political spectrum, who are not always in agreement about issues affecting universities. The Higher Education and Research Bill has, however, created a united front: left- and right-leaning academics agree that the Bill shows little understanding of the nature and purpose of Higher Education and risks damaging the reputation and autonomy of our universities.

In future, if a Minister invites comments on a consultation document, he might be well advised to take notice of the responses, to avoid the kind of embarrassment that Johnson is now confronted with.

TEF and tuition-fee rises are not in the Higher Education and Research Bill. Why?

No.  2 in a series of guest posts by G.R. Evans


The Secretary of State, introducing the Higher Education and Research Bill at the Second Reading, urged that ‘the teaching excellence framework is such an important part of the Bill’. But the Bill does not mention it. The new legislation will not directly affect the plans to introduce a Teaching Excellence Framework, or decisions about raising tuition fees, both of which are being taken forward down separate tracks.

The Teaching Excellence Framework began as an announcement by Jo Johnson as the new Minister for Higher Education in a speech in July 2015, to Universities UK. It had a prominent place in the Green Paper published in November 2015 and again in the White Paper published on May 16 2016, which explained how it was to be ‘designed’ and ‘implemented’ in straightforward ‘it’s going to happen’ language of ‘will’ and ‘shall’ and a timetable making it clear that it did not depend on the coming into force of new legislation.

The TEF does not form part of the Bill because it requires no legislative change except possibly ensuring that the new Office for Students (OfS) will have powers to ‘rate’ English higher education providers ‘regarding the quality of, and the standards applied to, the higher education they provide’ (Bill s.25), with provision for ensuing adjustment of fees under Bill Schedule 2 (The Fee Limit).

Gordon Marsden pointed out in the Second Reading debate that Parliament will have no opportunity to debate the plans to introduce a Teaching Excellence Framework (TEF). He added that ‘the University and College Union and others are deeply concerned by the lack of parliamentary scrutiny built into the TEF’.

Nor does the Bill involve further consideration or review of the operation of the student loan system, which Liam Byrne described in the debate of 19 July as underpinned by a ‘Ponzi scheme’. It does not need to do so in order to achieve its purposes.

The press was quick to remark on the Ministerial Announcement days after the debate that an inflation-related increase above the previous maximum of £9,000 was to be allowed. Universities, including Manchester and Durham, were quick to advertise the new higher fees. Continue reading

What is the Purpose of the Teaching Excellence Framework?

Opinion Piece by Joshua Forstenzer (Vice-Chancellor’s Fellow for the Public Benefit of Higher Education, University of Sheffield)

The higher education Green Paper is a radical document. From its proposed rework of the higher education sector’s governance and regulation structure, to its plans designed to introduce greater competition between newly formed private providers (giving them greater access to university status and degree bearing capacity) and public universities (ridding them of the responsibility to respond to Freedom of Information requests), the Green Paper presents a series of sweeping changes to British higher education. However, nowhere is the Green Paper’s radical potential more directed at the very core of university life than in the proposed Teaching Excellence Framework (TEF). That is why this report focuses exclusively on the TEF.

The general ambition of the TEF is to rebalance ‘the relationship between teaching and research’ in universities and to put ‘teaching at the heart of the system’, by introducing a teaching quality assessment mechanism using core metrics and qualitative evidence. In exchange, universities deemed to have ‘excellent’ teaching will be rewarded with the right to increase undergraduate fees in line with inflation. Although there will be a technical consultation about the exact metrics used in the TEF, it will start with three readily available common metrics, namely: Employment/Destination; Retention/Continuation; Student Satisfaction indicators from the National Student Survey (teaching quality and learning environment).

While the government has sought to depoliticise the TEF, there is a more fundamental set of political and ethical questions about the purposes and social value of higher education that needs to be at the heart of this debate. Indeed, over the last few decades, much has been written about the overall trend towards marketisation in British higher education. This report proposes to understand the TEF as a policy proposal forming part of that wider trend, by considering the following criticisms: the TEF is not really about teaching excellence, but about fees; the TEF does not serve students, but an imagined group of employers; the TEF ignores the wider public benefits of undergraduate education.

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CDBU’s Response to the Green Paper

The Council for the Defence of British Universities (CDBU) today submitted its response to the Green Paper “Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice“.

We undertook this exercise in good faith and with good will since the focus of the Green Paper is on issues close to the heart of our founding values: how to assure the continued high quality of university education in the UK, and how to ensure wide and fair access to higher education. One of our aims as an organization is to provide expert, insider advice on, and responses to, government policy proposals that look to build on the already considerable achievements of UK higher education. What our close analysis of the Green Paper has revealed, regrettably, is that ‘consultation’ is a misnomer, since in its content and wording the document reveals time and again that the recommendations, far from being proposed as possibilities, are assumed by the authors of the Green Paper to be acceptable and to be awaiting implementation.

Equally, if not more worryingly, the quality of the arguments, of the evidence used, and of the presentation of the recommendations, is inadequate. One of the chief policies – the Teaching Excellence Framework (TEF) – is put forward to address putative problems, without providing any evidence that these problems exist. The proposed TEF would be an expensive and bureaucratic system that would entail increasing complexity and disruption for years to come. The use of proxies, such as the NSS or graduate income, for teaching excellence is at odds with the ethos and values of education and scholarship. Both the content and the methodology behind the Green Paper come across as counter to the academic values that lie at the heart of any university worthy of the name. These values include reliance on reason, argument, and evidence; critical and creative thinking; rigorous analysis of data; and precise and meaningful communication. There is no recognition in the Green Paper that the primary purpose of universities is to foster these values; instead, universities are equated with businesses, value is defined purely in economic terms, and students and staff are set up in opposition as consumer and vendor respectively, working to serve conflicting interests (to pay as little as possible for the product purchased and to charge as much as the ‘customer’ will take). This is to misunderstand how universities work; to ignore the fact that unlike profit-driven organizations, the idea – and subsequent success – of our UK universities is rooted in staff and students working not towards a transaction but towards collaboration in the pursuit of understanding, knowledge, and truth.

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More Misrepresentation in the Green Paper Damages its Credibility

Opinion piece by Dorothy Bishop

In my previous post, I queried the justification for the proposed new Teaching Excellence Framework. According to the Green Paper, research-intensive universities undervalue teaching, and students and employers are dissatisfied with the quality of teaching in UK Higher Education. I argued that evidence for these claims was lacking. I have now scrutinised in detail the case made in the Green Paper. I thought that perhaps there was better evidence buried in there that I had missed. What I discovered was alarming. I found numerous instances where evidence was cited but in a misleading way.

Here are some examples:

Introduction: The productivity challenge, point 9: Higher education providers need to provide degrees with lasting value to their recipients. This will mean providers being open to involving employers and learned societies representing professions in curriculum design. It will also mean teaching students the transferrable work readiness skills that businesses need, including collaborative teamwork and the development of a positive work ethic, so that they can contribute more effectively to our efforts to boost the productivity of the UK economy.”

A report by the UK Commission for Employment and Skills is cited in the Green Paper. There is just one mention of graduates in the report, on page 3. It states: “Over eight in ten employers found university graduates to be well prepared for work.”

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The shaky foundations of the TEF: neither logically nor practically defensible

*Opinion piece by Dorothy Bishop

I spent Sunday reading the Green Paper “Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice“, a consultation document that outlines radical plans to change how universities are evaluated and funded. The CDBU is preparing a response, but here’s the problem. BIS is not seeking views on whether the new structures they plan to introduce are a good idea. They are telling us that they are a good idea, a necessary idea, and an idea that they will implement. The consultation is to ask for views on details of that implementation.

The government will no doubt be braced for howls of protest from the usual suspects. Academics are notorious for resisting change, so there is an expectation that there will be opposition from many of the rank and file who work in universities, especially from those whose political allegiances are left of centre. CDBU is, however, a broad church, and disquiet with the Green Paper comes from academics covering a wide range of political views.

The idea behind the TEF is that teaching has not been taken seriously enough in our Universities, because they have been fixated on research. As a consequence, students are getting a raw deal and employers are dissatisfied that graduates are not adequately prepared for the workplace. However, the evidence for these assertions is pretty shaky. If you’re going to introduce a whole new administrative machinery, then you have to demonstrate that it will fix a problem. A number of commentators have warned that TEF is a solution to a problem that does not exist.

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Reflections on the Green Paper (2): Opening the Market to New Providers

Opinion piece by Roger Brown


The focus of the Green Paper is not just on students and teaching: it also envisages a situation where there will be more competition among providers of higher education, and new entrants into the system:

We hope providers receiving a lower TEF assessment will choose to raise their teaching standards in order to maintain student numbers. Eventually, we anticipate some lower quality providers withdrawing from the sector, leaving space for new entrants, and raising quality overall. (page 19)

The proposal is for a ‘single route into higher education, through which all providers are equally able to select an operating model which works for them – both at entry and once in the system’ (page 42). This new single route would give:

  • Quicker access to student funding (and no cap on student numbers);
  • The ability to apply earlier for degree awarding powers (DAPs) (with a more flexible approach to track record);
  • A shorter time for DAPs assessment;
  • The ability to secure university title much earlier, if conditions are met.

The proposal is also for providers to have contingency arrangements in place that set out the approach and commitments to students in the event of course or campus closure. This would cover both continuity of provision and financial recompense. In addition, it is suggested that the OfS could support (and if necessary direct) regulated providers to consider whether and how they should exit the sector in an orderly way, where it is in the public interest to do so.

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