LONDON’S GLOBAL UNIVERSITY
Draft Response by UCL to CL11/05: QAA Draft Strategic Plan 2006-11: consultation.
Introductory comments:
UCL welcomes the opportunity to comment on the Agency’s draft strategic plan. In
general, we feel that this is a disappointing document in that it focuses too much on
narrative of past activities rather than setting out a clear plan for the Agency’s future
activities and priorities. Further explanation will be required in order to support
claims being made in the draft strategic plan. For example: although it is
understood that the QAA will demonstrate in more detail how it has achieved its
2003-05 plans, more analysis should be provided of whether, in achieving its plans,
QAA has achieved its own standard of ‘high standards in all its work’.
The strategic plan is right to acknowledge that the Agency’s future activities need to
be firmly risk-based but we see little evidence of how this crucially important principle
will be reflected in the design of QAA review processes. We draw attention below to
some further specific points of concern with the draft strategic plan. Our comments
have been structured in response to the questions posed in the consultation
document.
(1) Is the general thrust of the plan right?
Are the QAA priorities for the evolution of their portfolio of work and
development as an organisation the appropriate ones? Will they allow the QAA
to provide the right services and benefits to the sector and stakeholders in an
effective way?
(1.1)
While UCL welcomes in principle the indication that the QAA intends to
provide protection for the ‘UK brand’ in Europe (page 17, paragraph 5), we
see it as essential:
(i)
that this protection should extend to ensuring that this will not involve
institutions in any extra layers of quality assurance requirements;
(ii)
that the QAA clarify the way in which it sees itself as operating within
the European context and as offering a voice for the UK in that context
(page 11, paragraph 3). If the Bologna process and other initiatives
are to contribute to the quality of experience for students in the UK
and in Europe, it is important that the focus be on thresholds and
outcomes, not on structures and duration, and that the principle of
subsidiarity be built into quality assurance for higher education. UCL
would wish to see this sense of flexibility within commitment to
standards explicitly expressed.
(2) Is the structure of the plan right?
Does the structure of strategic themes and strategic goals provide a clear
picture of what the QAA want to achieve over the medium term?
(2.1)
UCL would appreciate clarification of the statement (page 21) that ‘The goals
we have set ourselves in this plan are not easily measured’. Specifically, it
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would wish to know how the various evidence then listed will be evaluated to
‘gauge [its] achievements’.
(2.2)
While we recognise the potential value of briefings on emerging issues, we
would welcome clarification of how regularly the proposed ‘thematic briefings’
will appear (page 14, paragraph 5). Implicit in the document is a suggestion
that review methodology may be continuously adjusted in response to
evidence emerging from reviews and included in thematic briefings. While
responsiveness is welcome, this could give rise to confusion and/or
inconsistency. How will a steady state be achieved, if processes are being
continuously reviewed in the light of experience?
(3) Is the content right?
Is the proposed portfolio of work one which you [UCL] would support? Or are
there proposals that are either not clear, or that represent activity that we are
not sure that the QAA should be doing? Conversely, does UCL feel that they
have missed or not prioritised, areas of work that should have a higher
profile?
Specific points made in response to this question have been grouped under relevant
headings:
Diversification of Range of Services and Clients:
(3.1)
UCL would wish to express concern about the professed intention of the QAA
to ‘diversify the range of services’ it provides (page 15, paragraph 2). QAA
should ensure that by so doing it does not neglect to meet the needs of its
core clients and/or move too far away from its core activity. The aim of
diversifying the range of services provided would perhaps be better
expressed as ensuring that appropriate information is collated in a form which
is useful to the full range of interested parties. Institutions already provide a
great deal of information of use to a wide range of interested parties. This
should not be seen as a case for demanding more information to serve new
user groups.
(3.2)
UCL would also wish to express caution about the QAA’s intention to develop
relationships with ‘a wider range of clients’ (page 15, paragraph 7), as this
also might have implications for its ability to carry out its core activity. The
desire to expand the client base sits uncomfortably with the statement that at
present, the QAA is ‘asked to make many more contributions than we have
the capacity or resources to meet’ (page 8, paragraph 1). There are no more
than hints as to how this can be achieved. And there is no rationale for the
value of expanding the client base, beyond ensuring the longevity of the
QAA.
(3.3)
Finally, the QAA is indeed perceived as having a regulatory role. Extending its
remit and client base - particularly if this entails the contracting out of PSRBs’
audit activities to the QAA - may mean that the QAA will be perceived as
having an increasingly regulatory role. There is an inherent conflict between
this role and the QAA’s professed aspiration of increased support to
institutions.
Development of Quality Enhancement Role:
(3.4)
The Agency’s renewed confirmation that higher education institutions are the
locus of quality assurance and quality enhancement is welcome. However,
UCL would appreciate:
(i)
clarification of the role and nature of quality enhancement. The
Agency’s stated purposes indicate that it will ‘enhance the assurance
and management of standards and quality’. Elsewhere, the plan
refers to the enhancement of quality, rather than of enhancement of
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the management of quality. Also, some clarification of the distinction
between ‘improvement’ and ‘enhancement’ would be welcomed
(pages 14 & 15, bullet points in boxes);
(ii)
assurance that the Agency’s expressed intention to ‘devote more time
and resources to development and enhancement across the UK’
(page 10, paragraph 2) will not overlap with the remit of the Higher
Education Academy.
Management of Risk:
(3.5)
As indicated in our general comments, UCL would wish to endorse
recognition that standards and quality assurance frameworks should be
‘proportionate to risk’. But there is no indication in the draft plan of how QAA
will identify ways of realising this strategic goal. The section on ‘Managing
risk’ refers to management of risk in order to enable the QAA to achieve its
goals: it does not make clear how this approach would inform institutional
audit. UCL firmly believes that the Agency’s review processes should be
designed according to assessed risk at each institution, not applied uniformly.
(3.6)
Potential loss of ‘reputation and standing’, is listed as a strategic risk (page
19). UCL would welcome some information concerning the ways in which the
QAA intend to address this issue.
Information Role:
(3.7)
The emphasis on the information role of the QAA is welcome, but should be
subject to the following provisos:
(i)
that the information required is necessary and useful to interested
parties (i.e. that the test of fitness for purpose is always applied);
(ii)
that the cost for institutions of collating information is not excessive;
(iii)
that the demands for information are aligned with the primary
relationship between students and institutions. For instance, there is a
need to revisit the issue of provision of information to students,
prospective students and parents, to see how the activity can be
carried out both at institutional and at QAA level without meeting
resistance caused by duplication;
(iv)
that the reference (page 8, paragraph 1) to the QAA website being ‘a
prime source of information’ be supported by some evidence that it
has taken note of UCL’s repeated suggestions - which our Institutional
Liaison Officer has conveyed to the Agency - that QAA should send
news bulletins to institutional contacts, drawing attention to news on
its website;
(v)
more clarification of the developing role of TQI in the reference to the
‘publication of a range of differentiated information to meet the needs
of students and employers’ (page 12, strategic goals, bullet 8), and to
‘ensuring that straightforward information about quality and standards
is available to anyone who needs it’ (page 10, paragraph 3).
Regulation Burden:
(3.8)
The stress on rationalisation of the regulation burden (page 12, strategic
themes, bullet 4) is welcome; in particular the introduction of regulatory
impact assessments, if this means the evaluation of the added value of
regulation and the scale of cost to the sector.
(3.9)
However, the Agency should also in its strategic plan explicitly:
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(i)
recognise the need for cost-effectiveness: institutions operate under
tight financial constraints and all external monitoring must be sensitive
to the implications for providers of any additions to the overall
demands;
(ii)
recognise the diverse goals and natures of institutions. This is
mentioned only in passing but is relevant to the issue of regulatory
burden;
(iii)
provide assurance that the regulatory impact assessments themselves
will not be conducted by institutions and will not impose additional
costs; UCL would wish the QAA to build on the work already done by
the Burslem Group and to keep under active review the internal costs
to institutions of external regulatory requirements;
(iv)
explain the way in which Major Review serves as a useful example of
how the QAA can help develop systems ‘that do not impose
disproportionate burdens on the institutions’ (page 16, paragraph 3).
In UCL’s experience of Major Review, the reverse has definitely been
the case.
1.11.2005
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