In December 2017, the Students’ Union submitted a response to the government’s consultation on the new regulatory framework for higher education. Our response covered concerns about equality of access and participation, freedom of speech regulations, risks of course and institution closures, and the marketisation of higher education.
What was the consultation about?
The Department for Education (DfE) released the consultation document in October last year, entitled Securing student success: risk-based regulation for teaching excellence, social mobility and informed choice in higher education. This was open for universities, unions and individuals to respond to.
The new framework proposed within the consultation proposes risks and priorities for the Office for Students (OfS) to work on as the government’s new regulating body for UK universities. The OfS which will be formally established in April this year, replaces the Higher Education Funding Council for England (HEFCE) and the Office for Fair Access (OFFA); the two bodies which currently regulate higher education.
The consultation also sets out more extensive powers for the OfS, which include:
Ensuring ‘value for money’ for students
Ensuring all students have equality in access to, success in and progress from higher education
Ensuring all students receive a high quality academic experience
Ensuring students’ rights as ‘consumers’ are protected, such as in the case of course or institution closures
What did our response say?
Our full response was fourteen pages long, so here is a brief summary of our key points:
Our response was highly critical of the format, layout and content of this consultation as we felt it was inaccessible for students. The questions were convoluted and restrictive, requiring us to provide a prelude which covered areas not mentioned in the consultation. This included an overarching critique of the ‘market logic’ on which the proposals are premised. We view students as ‘co-producers’ in their education, not just consumers.
Overall, there is a very narrow focus throughout on the ‘academic’ aspects of Higher Education. In reality, the areas discussed also relate to all non-academic aspects of the student experience. For instance, the consultation does not consider other harmful risks to students, such as inadequate policies and provision for support regarding issues such as mental health and sexual or domestic violence.
Value for money, which is framed within the consultation as one of the primary concerns for the OfS, relates to more than just how well paid a student’s job following graduation is. The additional costs students are made to bear, for instance, include ‘hidden’ course costs such as printing and books, as well as the provision of mental health services, decent and affordable accommodation and accessible social opportunities. Regulation should view student experience more holistically, taking into account all aspects beyond the academic.
Our response highlighted a concern with concepts, such as ‘success’ and ‘quality’, being measured solely through graduate salaries and degree outcomes. Recent research has shown that students across the UK value adequate resources (in particular, IT services and the library) and teaching quality during their degree more highly than graduate employability.
It is very positive that inclusivity and equality in access and participation are included as one of the key risks for OfS to monitor, but the body must be compelled to do more. For instance, while tackling the attainment gap is a crucial measure of racial equality in education, ‘soft’ measures of equality in voice and student support should also be considered. We also posed questions regarding how institutions’ adherence is monitored, and how those institutions who fail to do this are sanctioned by OfS, stating that we support punitive measures that force higher education institutions (HEIs) to act on equality metrics.
The OfS must take action to regulate senior staff pay and introduce a regulation on including students on university remuneration committees.
Student voice and representation appear to be missing from the governing principles of the OfS. Student voice should be included as a core measure, and regulations put in place to ensure appropriate systems of representation.
While the move towards consumer rights is important with regards to protecting students’ rights in the context of course closures, the use of such ‘contracts’ only protect students interests as consumers, not as co-producers of their education. This consultation, however, frames such challenges as uprooting students, massive redundancies, and courses being closed for good, as merely par for the course for universities. We feel as though this is unacceptable, and if a truly risk based approach were being taken by the OfS, there would be more in this consultation about preventing such closures, as opposed to merely alleviating the effects of this.
It is vital that one of the outcomes of this consultation is that there is a guarantee that there will be no end to the cross-subsidising of courses at universities, as this would cause huge course closures for many science and technology based courses. This would be detrimental to students, universities, the economy, and society on the whole.
Grainne, Welfare Officer, who lead on the consultation response, said:
“It is really important that the Students’ Union were able to respond to the consultation and make sure students’ voices were listened to. Not only through our responses to the consultation questions, but also by making it clear that we stand against the marketisation of education and risk based approach that the OfS wants to take to higher education, which will further the marketisation of education, and create a needlessly competitive field.
“When consulting students on their education in the future, the OfS should bare in mind that they should be approaching students in an accessible way, and not getting bogged down in bureaucratic inaccessible language that only those who are really in to policy will understand!”
SU President, Frida Gustafsson, also attended Parliament last week to give evidence to the ‘Freedom of speech in universities’ inquiry, alongside the University’s Vice Chancellor, Adam Tickell. At the inquiry, she reinforced a number of the concerns included within our consultation response, such as the damaging limits to free speech that are imposed on students and students’ unions as a result of the government’s Prevent duty and the bureaucracy imposed on SUs by the Charity Commission. Our consultation response also suggested that the focus should be on creating a framework to ensure students are able to have challenging and respectful debates, criticising current proposals for not recognising the complexity of the issue.
Read our full consultation response.
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