Response by UCL (University College London) to QAA consultation on the
evaluation of the academic infrastructure
Introductory comments
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UCL welcomes the opportunity to comment on the consultation. However it
should be noted that our comments are made in advance of (i) the review of the external
examiner system being conducted by Universities UK and Guild HE, (ii) the outcomes of
the HEFCE 2009/47 consultation on the principles for future arrangements for quality
assurance in England and Northern Ireland and (iii) the proposed consultation on the
operational detail of a new method for Institutional Audit and Integrated Quality and
Enhancement Review. Bearing in mind the crucial importance of these as interrelated
mechanisms for the setting, monitoring and maintenance of quality and standards, our
comments are subject to the outcomes of these reviews.
Question 1 - Role, purpose and audience
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We have already made the point in our response to HEFCE 2009/47 that the
current system has many strengths and includes a number of characteristics which
should be retained. In particular, we endorsed strongly the principle that primary
responsibility for the maintenance of standards and quality should lie with individual
institutions, operating with reference to, and within the parameters set by, agreed
national threshold standards and reference points.
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Although we have concerns about individual components of the academic
infrastructure (and these are set out below under their individual headings) as a whole it
provides an important sector-wide reference point for assuring threshold standards and
quality which is now fully embedded in institutions’ internal quality management and
enhancement structures, policies and processes
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However, communicating the role and purpose of the academic infrastructure to
a wider audience and explaining how it contributes to maintaining academic standards
and quality of provision needs to be improved This is, in our view, an area where the
higher education sector (both the representative bodies and institutions themselves)
must do more to make sure that they communicate effectively with external audiences
about the various processes which exist for assuring quality and standards.
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There also needs to be increased recognition of the different audiences for this
information. While we believe that the sector itself is, and should remain, the primary
audience, we would still support the notion that the language of the academic
infrastructure could be made less technical and more accessible to a non-specialist
audience. However, we would not support the suggestion in ‘Scenario 2’ that
restructuring all information on the current system into a single document might make
things clearer. It would not be possible for a single document to be intelligible to
academic staff, students, potential students, parents, specialists and non-specialists
alike (if it were possible, it would presumably have been done before now?) In our view,
it may be necessary to develop different means of communicating with non-specialist
audiences. In this context, please also see our comments at paragraphs 9-11.
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Question 2 - Connection to quality assurance and enhancement activities
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There is a need for a clearer articulation of the difference between the tools we
as a sector use for the setting and maintenance of threshold standards and the tools for
enhancing the quality of student learning opportunities. For an illustration of how these
might be more clearly differentiated, see our comments at paragraphs 12 and 13 below.
Question 3 - The Framework for Higher Education Qualifications (FHEQ)
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We feel that the FHEQ remains fit for purpose and that the way in which it is
currently used is appropriate and effective in setting and maintaining threshold academic
standards. However, as we have noted elsewhere, its pivotal role in assuring
comparability of threshold standards of qualifications across the higher education sector
could be more clearly communicated to a non-specialist audience.
Question 4 - Subject Benchmark Statements (SBSs)
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While these remain useful for articulating and setting threshold standards, we
note that as a result of the circumstances of their composition (ie they are written by
subject communities under the aegis of the QAA) there is wide variation in their content.
Also, in some cases, they have been written by these subject communities in such a way
as to entrench existing approaches and maintain the status quo, rather than encourage
more innovative practice. This can also cause problems within an institution when efforts
are being made to introduce greater internal coherence across disciplines.
Question 5 - Programme Specifications (PSs)
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These have always been problematic for the QAA and institutions for, despite the
statements made in the Dearing Report, there has always been confusion as to their
primary purpose and audience. In our view, institutions, rather than finding PSs innately
useful, have found ways of making them work in the context of their own internal
arrangements. The QAA has to date, and despite periodic and extensive discussion and
consultation, been unable to confirm guidelines on PSs which clarify their primary
purpose in the face of evidence of a continued lack of shared understanding across the
higher education sector as to whether they should be regarded as a source of
information to students and prospective students or as an internal planning tool for
institutions. PSs are a prime illustration of the difficulties inherent in trying to make a
single document intelligible and applicable to a variety of audiences. We note their
incipient role in the preparation of the Higher Education Achievement Record (HEAR)
but, in our view, the time has come to recognise that PSs are not an appropriate means
of communicating key information about programmes of study to an external and nonspecialist audience and that a more effective way of doing this needs to be found.
10
In this context, the current review of public information on teaching quality led by
the Teaching Quality Information (TQI)/National Student Survey (NSS) steering group is
relevant, as it is in the process of commissioning research into the information that
students and potential students need from institutions and how best this should be
presented. We would like to refer the QAA to the response we gave to HEFCE 2009-47:
question 7
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‘one of the most problematic issues in the development of the national quality
assurance system has been that of the provision of public information: identifying
the information that stakeholders really require and designing procedures for
assessing effectively the accuracy of that information in institutional audit has
been far from straightforward.’
11
We feel that more clarification is needed of how a single TQI dataset will meet
the very different needs of students, stakeholders and the wider public and we hope that
the review will provide this. We also trust that the lessons of the past have been learned
and that the eventual dataset agreed upon will not involve the commitment of large
amounts of scarce institutional resource to the preparation and maintenance of
qualitative data.
Question 6 - Code of Practice (CoP)
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The CoP has largely been effective in helping institutions to ensure that their
policies and procedures set and maintain appropriate standards and enhance quality.
However, some of the sections have now been rendered virtually obsolete by rapidly
changing legislation. Examples of this are section 3: Disabled students and section 5:
Academic appeals and student complaints on academic matters1. . We feel these
sections might usefully be replaced with web links to relevant legislation or external
information.
13
It might then be useful if the remaining sections of the CoP could be grouped so
as to clearly distinguish between those sections which are more directly linked to the
setting and maintenance of academic standards and those which focus more on
improving the quality of the student learning experience. It is difficult to be too specific
about what this should consist of until we know the outcome of the review of the external
examiner system but, for example section 4: External examining, section 6: Assessment
of students and section 7: Programme design, approval, monitoring and review might be
grouped together and linked to an explanation of how they assist in the setting and
maintenance of threshold academic standards. These might then be grouped together
with those other parts of the academic infrastructure whose primary focus is on the
identification and maintenance of standards, ie the FHEQ. The remaining sections of the
CoP (ie. those which are more focused on the enhancement of learning opportunities
and improving their quality) might then form a coherent and separate grouping.
Question 7 - Future of academic infrastructure
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Subject to the suggestions for revisions set out above, we feel that the concept of
the academic infrastructure should be retained, although the structure of the
infrastructure should be reviewed. Also, its title should be revisited and any new title
should be more descriptive of its true role and purpose. However, whether the principles
All sections are obliged to contain the following caveat: ‘The Code of Practice does not
incorporate statutory requirements relating to relevant legislation, for example, the Disability
Discrimination Act (1995) (as amended). It assumes that institutions have an overriding obligation
in all such cases to ensure that they meet the requirements of legislation. However, where a
section of the Code of Practice is related to legislative or similar obligations, efforts have been
made to ensure compatibility with them.’
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it articulates continue to be set out within the existing structure or within a revised or
strengthened system, a core principle should remain:

the facilitation of comparability between institutions and academic disciplines
whilst recognising the considerable diversity of different institutional missions
and cultures.
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