Not Thinking of Numbers!

For the first time in almost a decade, we now have controls on undergraduate numbers for providers in England, and controls on the recruitment of English students who may want to cross the border of one the three other home countries

The Department for Education (DfE) has attempted to stabilise 2020 undergraduate recruitment by doing something which arguably manages to make it significantly less stable, and at the same time undo many years of trying to widen access.

Although the caps are not public, providers have just been told how many undergraduates they can recruit based on last year's numbers, plus whatever was forecast for 2020/21, plus another 5%.

Instead of the expected (and frequently threatened fine) over-recruitment will be punished by a reduced fee level next time round for providers in England, and there’s a reduced Student Loan Company payment for the devolved nation miscreants.

And if that's not enough to disadvantage increasing popular FECs (and the majority of HEIs), there's a competition for 5,000 additional student numbers in subjects without an obviously common economic or societal skills need, which has designed to be available (at least in part)only to “elite” institutions. Numbers in these subjects (architecture, science, maths, engineering, and veterinary science) will only be available to providers whose non-benchmarked continuation rate is over 90 per cent, and which have a highly skilled employment/further study rate of over 75 per cent, and I can't think of a single FEC with a student demographic profiles those measures will apply to.

But the most damaging aspect, at least as far as FECs and any basic concepts of sense is concerned, is that the Full Time Student Number includes Apprentices, and most of them only attend college for one day a week, some maybe just for an afternoon or evening, So since their employers consider them to be PT they pay only PT fees - and why wouldn't they? - and the students don't come with OfS funding, colleges are now punished for recruiting the students the government has spent the last few encouraging them to educate!!!

All of which leaves me struggling to think of a positive. It certainly isn't to the benefit of students now more likely to want to study locally instead of leaving home for an expensive university experience. And it's going to negatively impact FECs by hundreds of thousand of pounds.

Who comes up with ideas like this and why?

Don't Even Think About Asking

All a FEC wanted from me was a little advice on whether or not an “Annual Assurance Statement” had to be provided to the Office for Students every year (and as far as I know they all submitted one when registering in 2018).

On the face of it, this doesn’t exactly sound like something out of Alice in Wonderland, but it’s not mentioned in either of this month’s new OfS regulatory advice notes – #15 covering monitoring and intervention, and #16 explaining reportable events. So does that mean that it wasn’t “annual” at all, and should have just been called an “Assurance Statement” or is one still required because it hasn’t explicitly been superseded or withdrawn and is in the framework?

Note #15 tells us how the OfS will monitor compliance of registered providers with the ongoing conditions of registration and the activities which allows it to respond proportionately to regulatory risks and identify changes to risk levels which are basically:

• Data and information flows that will assist the OfS in the identification of trends and theoretically help them to predict the future,
• notifications of material decisions/issues/changes,
• and other intelligence such as whistleblowing or student complaints.

None of which really fits with my understanding of “quality assurance” as it’s not doing all that much to actively assure quality, it’s more like trying to get somebody (Who? Students? Government? The public?) to believe that quality is actually present until there is something to show that it isn’t. Which as I see it is rather like the religious types who knock on my door every few months and leave still convinced that God must exist because I couldn’t prove that He doesn’t.

Anyway, despite this flaw and the fact that looking at outcomes rather than inputs leaves colleges (and HEIs/others) operating under a constant threat of failing to meet Condition B3 (“the provider must deliver successful outcomes for all of its students”) thresholds which are always in the future and so can’t actually see.

But the real fun, the “Alice Through the Looking Glass” moment if you like, is in Regulatory Advice 16 which explicitly warns HE providers not to ask the OfS any sort of question:

"Where a provider seeks to abdicate responsibility for decision making, and seeks steers from the OfS, this behaviour may indicate non-compliance with condition E2."

So, in addition to what we’ve known for 18 months or so in that under/over reporting can have serious consequences – basically sending the OfS something they don’t want might be a sign of incompetence, as could not sending them something they need to “assure quality” - we now know that just asking for guidance from the regulator if in doubt is just as bad.

All of which is why I was asked to ring the OfS on behalf of someone who daren’t speak to a regulator that assures baseline quality not by looking at what goes on, but the outcomes from it, and threatens those it regulates with serious penalties just for asking questions which may help them to deliver outcomes they probably can’t really control because they don’t know what they are.