Final Response by UCL (University College London) to the QAA
consultation on changes to the Academic Infrastructure December 2010
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UCL welcomes the opportunity to comment on the proposed changes to the
Academic Infrastructure and, in particular, welcomes the statement (page 3, final
paragraph) that ‘there has never been an expectation that every member of staff
involved in delivering higher education will be familiar with every part of the Academic
Infrastructure. Rather, the guidance within the Academic infrastructure is embedded
within the individual providers’ policies and processes’, as this fits with and
acknowledges our view 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. We also
welcome the QAA’s recognition (page 16, first paragraph) of the importance of taking
account of individual institutional needs, tradition, culture and decision-making in tackling
effectively the issues addressed by the precepts of the Code of Practice. Our responses
to the specific consultation questions are as follows:
Consultation question 1
For the purposes of the UK Code of Practice for standards, quality and
enhancement, the following definitions will apply:
Threshold academic standards are the level of achievement that a student has
to reach to gain an academic award. For similar awards, the threshold level of
achievement should be the same across the UK.
Academic quality is a way of describing how well the learning opportunities
available to students are managed to help them to achieve their award. It is about
making sure that appropriate and effective teaching, support, assessment and
learning opportunities are provided for them.
Are these the appropriate definitions?
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Overall, a single, overarching Code of Practice would seem to simplify and make
more explicable the steps the sector takes to ensure standards and quality (however,
see our response to question 4 below) but if the Academic Infrastructure is to be
renamed the ‘Code of Practice for standards, quality and enhancement’, it seems
inconsistent to define standards and quality but to refuse to define enhancement. If it can
be assumed (as implied by the consultation document, page 6, first paragraph) that
enhancement proceeds automatically from effective quality assurance, the word
‘enhancement’ should be removed from the title. However, given that it is proposed that
‘enhancement’ will now form the basis of a judgement in Institutional Review, it remains
unclear why this cannot be more clearly defined.
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Consultation question 2
Do you agree that the components of the Academic Infrastructure should be
restructured into the UK Code of Practice for standards, quality and
enhancement? Will the new Code of Practice make clear the distinction between
standards and quality?
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In UCL’s response to the original consultation on the evaluation of the Academic
Infrastructure, we noted that there was 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. The
restructuring of the components of the Academic Infrastructure into a Part A and Part B
therefore seems broadly appropriate. However, great care should be taken regarding the
language used in the Code of Practice, as this will be used by Reviewers to make
judgements on institutions during the process of Institutional Review. It will need to be
explicit both to institutions and to Institutional Reviewers what is obligatory and what is
intended as guidance.
4
The proposal for a new chapter (B4) on Student Support, Guidance and Learning
Resources raises some issues. The introduction of a chapter indicating minimum
expectations in the area of learning resources extends the scope of the Code of Practice
beyond that of the current Academic Infrastructure. It should also be remembered that
the provision of learning resources in some programmes of study are driven by the
relevant Professional, Statutory and Regulatory Body and could come into conflict with
any minimum expectations set out in the Code of Practice.
Consultation question 3
The two areas highlighted for future work are the status of credit frameworks and
provision of information at programme level. Do you agree that these should be
priorities for future work ? Do you agree that in due course the Code of Practice
should include a Part C on Information?
5
We have no objections to the suggestion that the status of credit frameworks
should be a priority for future work, provided that this does not result in proposals that
are overly prescriptive.
6
In considering the provision of information at programme level, the consultation
document appears largely to have glossed over the issue of Programme Specifications
pending the outcome of the current review of public information on teaching quality. As
we have previously noted in our response to the evaluation of the Academic
Infrastructure, in our view, institutions, rather than finding Programme Specifications
innately useful, have found ways of making them work in the context of their own internal
arrangements. We feel that the time has come to recognise that Programme
Specifications are not an appropriate means of communicating key information about
programmes of study to an external and non-specialist audience and that a more
effective way of doing this needs to be found. In the QAA’s own words (Supporting
Document, page 7, final paragraph) 'over half of the respondents who answered the
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question about programme specifications directly considered that they had not met their
original aims, expectations and anticipated benefits’.
Consultation question 4
Will the UK Code of Practice make clear how UK higher education providers set
and maintain threshold academic standards and assure and enhance academic
quality? Is the name 'UK Code of Practice for standards, quality and enhancement
in higher education' appropriate?
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The proposed Code of Practice will make clear to quality practitioners and others
in the sector how higher education providers set and maintain threshold academic
standards and assure and enhance academic quality but this will remain unclear to ‘lay’
readers without a considerable rewrite which would then render it less useful to quality
practitioners. In our original response to the consultation on the evaluation of the
Academic Infrastructure we did not support the suggestion that restructuring all
information on the current system into a single document might make things clearer to all
potential audiences. We contended that it would not be possible for a single document to
be intelligible to academic staff, students, potential students, parents, the media,
specialists and non-specialists alike, noting that if it were possible, it would presumably
have been done before now. In our view, it may still be necessary to develop different
means of communicating with non-specialist audiences.
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Our views on the name 'UK Code of Practice for standards, quality and
enhancement in higher education' can be found in our response to Question 1.
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Finally, while we support the proposed protocol for the future development of the
Code of Practice (Annex, pages 15/16) we note that in developing each chapter
sequentially and with the help of various specialist advisory groups, great care will need
to be taken to ensure the continued coherence of the document as a whole.
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