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.


Steps were already taken under the Coalition Government to help new providers enter the market: to allow smaller providers to obtain a university title, and to encourage private ‘for profit’ organisations to do so.  We now have a number of private universities, some of them profit making. This was in spite of very clear evidence from America of what happens when the profit motive is introduced into the supply of higher education.

The Green Paper proposals reflect the belief of the Government that:

(a) increased competition is the key to improving quality, efficiency and student satisfaction;

(b) publicly funded universities and colleges still do not have enough competition;


(c) the market entry (and exit) barriers to new providers are still too high.

An alternative view – based on what we know from research about what happens when market competition is introduced into higher education (Brown, 2011) – is as follows.

Because of the impossibility of producing ‘robust, timely and objective’ comparative information about quality (as would be expected in any conventional market), what you have in higher education is not resource competition as envisaged by the economists, but status competition as theorised by the sociologists (Hirsch, 1976).  Brand substitutes for quality. Rather than competing for students and income, universities compete for reputation and status. What is needed therefore is not greater competition for students and income, but stronger regulation to prevent the more prestigious (and better resourced) institutions exploiting their market power at the expense of less prestigious and poorer ones by, for example, charging more (as they do in the uncontrolled markets for postgraduate and overseas students), and thus exacting rents that are ultimately borne by the taxpayer.

This leads naturally on to the question of how quality and standards will be protected in a situation where competition between different categories of institution is being intensified and extended, for the first time in the mainstream undergraduate market, to price.

It is concerning that the Government is also envisaging opening up the supply of degree course validation services to a wider group of organisations, including possibly the OfS itself: a classic conflict of interest if ever there was one.

Although one would never know it from the Green Paper, historically the main part in protecting quality and standards in British higher education has been played by universities’ quality assurance processes, underpinned by the periodic system-wide reviews conducted by the QAA and its predecessors. These are based on the notion – and, for the most part, the reality – of the ‘self-critical academic community’, regulating quality through such processes as course approval and validation, external examining, and peer review. It is on these arrangements that our high international reputation for quality rests.

Whilst the Green Paper refers to academic freedom and autonomy, it is clear from the document as a whole, as well as a series of texts going back well before the 2011 White Paper and the wretched Browne report, that this Government believes that the real protection for quality lies in market competition, and not in the self-regulating processes of the academic community. This explains the equation of quality assurance with quality assessment (for example, on pages 23 and 59) and the paucity of references to QAA.

This means we are weakening the main quality safeguards we have, and which have generally served us well, without putting anything worthwhile in their place. By intensifying competition to include competition on price we are further reducing the ability of academic peer review to hold the line when, for example, institutional management puts pressure on examiners to vary standards by inflating grades or passing students who should have been failed because of the potential loss of income. Having begun to destroy the universities’ resource base directly through the intensification of immigration controls, the Government is now undermining our reputation for quality by displacing or downgrading the means through which we earned that reputation in the first place. This is all very sad.

As far as arrangements for ‘provider exit’ are concerned, one has to ask whether the person drafting this section of the paper has the remotest notion of how complex and difficult ‘exit situations’ actually are in practice.

Hardly any of the proposals in the Green Paper are needed. By intensifying marketisation they will further weaken the system, and make it even harder for the universities to discharge their central function of providing the best possible education for their students with the resources available against ever increasing international competition. This will damage not only the institutions and their students but also the wider public interests they serve. This in turn will weaken our ability to achieve the objectives of improving productivity and social cohesion that the Government professes to want. The Green Paper is a disaster not only for British higher education but for the British economy and British society. The universities should have nothing to do with it.

Note: This blogpost is based on a longer article by the author, which is available for download here.