Response by UCL to QAA Higher Education Review, a handbook for higher
education providers: Draft for consultation
UCL’s overall assessment of the proposals set out in the draft Handbook is that they fail
to deliver the new approach to quality assurance called for in the Government’s White
Paper ‘Students at the Heart of the System’ and as described by the Chief Executive of
HEFCE in his letter to the Chief Executive of the QAA of November 2012. In UCL’s view
the process described in the draft Handbook fails to set out a truly risk-based approach
to external quality assurance, does not contain convincing proposals for reducing
unnecessary burden and for achieving better regulation, or for targeting the QAA’s
efforts where they are most needed. Furthermore, the proposals risk undermining the
role of Students’ Unions in the review process, which would be a retrograde step, given
the efforts that the QAA and HEIs have made in recent years to increase student
engagement with, and involvement in, quality assurance processes.
UCL’s particular concerns are as follows (responses to the formal consultation questions
can be found below):
(1) We do not see how these proposals can be considered as introducing a ‘risk-based’
approach in any meaningful way. Indeed, having examined the formula for deciding the
intensity of reviews, it seems that a simplistic approach has been adopted in relation to
risk where ‘size’ equates to ‘risk’, irrespective of track-record. This effectively means that
large, multi-disciplinary institutions will always receive the most intensive reviews (in
terms of team numbers and length of visit) irrespective of their previous track record or
performance. The QAA has an opportunity here to develop a truly risk-based approach
to external quality assurance which takes note of the increasingly sophisticated
approach to risk assessment and management that has been adopted within HEIs and
the established sector more generally, and we would urge it to do so.
(2) The review process which emerges from this consultation process needs to achieve
the clear objectives set out in the White Paper for reducing the burden on those
institutions with a proven track-record and for focusing efforts and scarce resources on
those areas which pose the greatest risk to quality and standards within the sector. It is
difficult to see how the HER process would be significantly different from the current
process of Institutional Review, or its predecessor Institutional Audit. The QAA seems
wedded to operating a ‘universalist’ approach to external quality assurance.
(3) We do not support the introduction of international reviewers, unless and until
convincing evidence is provided as to how this will improve the process. The
consultation document notes that this has been introduced successfully in Scotland but
no evidence is provided to support that claim. There is a very real risk that international
reviewers (who could be staff or students) could impede the review process by not being
fully conversant with the QAA's methods or, more generally, with the UK higher
education system. We are concerned that this lack of familiarity may well cause
particular difficulties in practice when it comes to the formulation of useful and detailed
review judgments and recommendations. We are particularly concerned that the
document only proposes initial use of international reviewers from countries within
Europe, on grounds of cost. We understand that the QAA will shortly be undergoing its
ENQA review and that it will wish to be seen as implementing the appropriate European
standards and guidelines, but UCL wishes to warn against this leading to the QAA to
adopting an approach which is too ‘Eurocentric’.
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(4) Finally, we would like to register our concern at the proposals for enabling students to
input directly in to the review process by ‘providing an alternative way of enabling
them to share any views directly with the review team through an online tool’ [P24, Para
108]. We believe not only that this may jeopardise the huge amount of work which HEIs
have done over the years in involving Students’ Unions in university-level QME but, by
allowing students to input directly in to the process unmediated by established Union
representation, may also undermine the work of Students’ Unions themselves.
UCL requests that the QAA reconsiders these proposals and revises them so that they
deliver on the aims set out by the Government in its White Paper and by HEFCE in its
November 2012 letter to the Agency.
Consultation question 1
Should a judgement of 'requires improvement to meet UK expectations' be
available in the area of threshold academic standards?
Yes
No
Consultation question 2
Should an initial appraisal be used to tailor the intensity of individual review
visits?
Yes but with the explicit coupling of risk with size proposed (see our commentary
above, Paras 1 and 2) the comparability of judgments would be open to question.
No
Consultation question 3
Should the process involve international reviewers?
Yes
No See our commentary above, Para 3.
Consultation question 4
Does the pilot proposal offer a reasonable way to introduce international
reviewers?
Yes
No
See our commentary above, Para 3.
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Consultation question 5
Please note any brief suggestions you have about introducing international
reviewers.
See our commentary above, Para 3.
Consultation question 6
Do the proposals for the review of arrangements for working with others establish
an appropriate demarcation between the areas reviewed at a degree-awarding
body and those reviewed at the partner, delivery or support organisation?
Yes
No
Consultation question 7
Should the new method include a separate judgement about managing higher
education provision with others?
Yes
No
Consultation question 8
Is the proposed scale and provisional level of confidence appropriate for the initial
appraisal to determine the intensity of the review visit?
Yes
No
Consultation question 9
Is the proposed approach to determining the scale of the provision appropriate?
Yes
No see our commentary above, Para.1.
Consultation question 10
Is the proposed approach to determining the level of confidence appropriate?
Yes
No
We are unsure.
Consultation question 11
Should the information base used to identify the level of confidence:
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a) be enlarged
b) be reduced
c) be changed in some other way
- see our response to Question 12 below.
d) remain the same
Consultation question 12
Please note any brief suggestions you have about changes relating to the
information base.
We have concerns about the weight which will be given to the student submission if
views can be shared by individual students directly with the review team through an
online tool and without the oversight of Students’ Unions.
Consultation question 13
Should provider self-evaluation documents have a bearing on the initial
appraisal?
Yes
No
Consultation question 14
Should student submissions have a bearing on the initial appraisal?
Yes
No
See response to 12 above.
Consultation question 15
Is the concept of high, medium and low intensity review visits appropriate?
Yes
No
Consultation question 16
Please note any brief suggestions you have about the intensity of review visits.
See our commentary above, Para 1.
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Consultation question 17
If you have any further comments about the initial appraisal please provide them
here.
Consultation question 18
Should there be just one visit to the provider?
Yes
No
Consultation question 19
Should we allow professional support staff to be reviewers?
Yes
No
Consultation question 20
Is the proposed categorisation of operational, minor and major changes
appropriate?
Yes
No
Consultation question 21
Should the role of students in Higher Education Review be strengthened
compared to the role of students in IRENI and RCHE?
Yes
No
Consultation question 22
Please note any brief suggestions you have about strengthening the role of
students in the review process.
We would anticipate that, given the enhanced role of the lead student representative in
the revised process, full briefing will be needed.
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