UK Quality Code for Higher Education – Chapter B4 Supporting Student Achievement:
UCL response to consultation.
General Comments
UCL welcomes the opportunity to comment on this consultation. We have answered the
more detailed questions in the prescribed format as set out below. However, there are a
number of general comments which we would wish to make.
Firstly, while we welcome the broach approach, there should be clearer recognition and
separation of the different aspects of student support to which the document refers. At
present it is unclear throughout the document whether the ‘student support’ referred to is
academic or pastoral (sometimes referred to as ‘personal’, with the two terms being used
interchangeably). We would suggest restructuring the document in order to separate and
clarify these aspects. The document also seems to be particularly focused on institutional
approaches towards the needs of undergraduates. That is to say that the Indicators overall
are not yet pitched at a level of principle which does not assume a particular model of the
student journey.
Throughout the Chapter, the tone is inconsistent; alternately opaque, slightly old-fashioned
and, at times we felt, unintentionally patronising. The concept of ‘partnership’ between
student and institution, so prominent in other Chapters of the Quality Code, seems also to
have been mislaid and the emphasis here is rather on the student being a passive recipient
of support. There are also a number of grammatical infelicities and errors which are picked
up in the comments on individual Indicators below.
The web addresses at the foot of each Indicator link to documents which set out a mixture of
legal requirements and best practice. We feel this approach is unhelpful and that these links
too should be separated and it should be clarified as to whether legal requirements or best
practice are being flagged.
Finally, we would like to note that the views expressed in this response are subject to the
publication of those as yet unwritten Chapters which will make up the new Quality Code;
particularly those with clear links to this Chapter. We may wish to revisit our response in light
of the publication of these subsequent Chapters.
Consultation Questions
Chapter B4: Supporting Student Achievement – Overview
5. Does the title of this chapter adequately reflect the content?
We feel that the emphasis on student ‘achievement’ in the Chapter title and throughout the
document focuses too much on the ‘endpoint’ of the student experience and not on the
student journey as a whole, from the support required pre-arrival to the support required for
graduate employment or further study.
6. Is the remit of the Chapter appropriate and clearly stated?
Not particularly. We also feel that the Chapter should be more explicitly linked to Chapter B1:
Programme Design and Approval, to ensure that any special arrangements required are built
into programmes of study from the outset.
7. The Chapter will replace guidance previously contained in the Code of practice for
the assurance of academic quality and standards in higher education (the Code of
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practice) Section 8: Career education, information, advice and guidance (2010) and
aspects of the Code of practice, Section 3: Disabled students (2010) as they relate to
supporting student achievement. Does the new Chapter adequately capture the
relevant content of these two documents?
The coverage of these former Sections of the Code of Practice is adequate and encourages
a holistic approach to support. However, there are some omissions. In particular, we feel that
the former Section 8: Precept 7, the important requirement that ‘institutions make it clear to
prospective and current students how the knowledge, understanding and skills acquired
during study are intended to be of use to them in the development of their future academic or
career progression routes’ should be included in the new Chapter.
8. Is this Chapter sensitive to the diversity of higher education providers, higher
education students, and modes of learning?
As stated above, we feel that the Chapter assumes a particular model of the student journey
and fails fully to address the diversity of students and modes of learning. Distance learning in
particular is given rather short shrift, as are mature students. As a global university, we also
feel that the particular support requirements of overseas students have been overlooked, as
has the assumption of a more outward-looking, global reach in terms of graduate
employment. The overall feel of the Chapter is insular and slightly old-fashioned.
Chapter B4: Supporting student achievement - Expectation (Page 5)
The Quality Code sets out the following Expectation about supporting student
achievement, which higher education providers are required to meet.
Higher education providers have effective arrangements in place to support all
students appropriately in achieving their learning objectives.
9. Do you agree with the wording of the Expectation for this Chapter?
Firstly, we feel that ‘their learning objectives’ should read ‘the learning objectives’, given that
the definition of these is more rightly the responsibility of the higher education provider than
the student. Secondly, we would suggest using alternatives to the phrase ‘learning
objectives’ such as ‘personal, professional and academic objectives’ or ‘learning potential
and wider personal development’.
Chapter B4: Supporting student achievement – Indicators of sound
practice (Pages 5 - 16)
Indicator 1
Support for student achievement is included in higher education providers' strategic
planning.
10. Do you agree with the wording of this Indicator?
Notwithstanding our previously expressed reservations about the focus on student
‘achievement’, we broadly agree with the principle expressed in this Indicator.
11. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
No.
Indicator 2
Higher education providers have in place policies and procedures in which
responsibilities for student support are clearly defined.
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12. Do you agree with the wording of this Indicator?
The Indicator itself is unproblematic. However, paragraph three, line two of the explanatory
text is strangely worded (‘support helps students to understand their aptitudes and
preferences’) and does not seem to fit into this Indicator. It seems to be about challenging
attitudes and reflecting on learning, whereas the Indicator is about making sure that policies
and procedures are clearly defined. We would suggest removing this paragraph altogether.
13. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
In the indicative list of reference points should be included Chapter B10: Management of
Collaborative Arrangements.
Indicator 3
The provision of student support is guided by a commitment to equitable access and
outcome.
14. Do you agree with the wording of this Indicator?
We feel that the phrase ‘equitable access’ is unclear, implying physical access to a building
or space. This could be replaced by a phrase such as ‘equality of learning opportunity’. We
also feel that some profession-specific language is used which may not be readily
understood by all staff in the higher education provider (‘client-centredness’ paragraph 1, line
2, ‘protected characteristics’ paragraph 2, line 8). We also feel that the suggestion
(paragraph 2) that the higher education provider is meant to ‘identify the needs of disabled
students who do not formally declare them’ at paragraph 2, line 2 is confusing. We would
suggest that this be clarified to read ‘do not formally declare them at the point of admission’
or similar.
15. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
No.
Indicator 4
Higher education providers promote internal collaboration, collaboration with external
partners and understanding of individual responsibilities in order to provide student
support.
16. Do you agree with the wording of this Indicator?
This Indicator refers to the definition and clarification of responsibilities and as such seems
to be saying broadly the same as Indicator 2. We would suggest conflating the two.
17. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
The QAA’s own Guidance for international Students could usefully be added to the list of
reference points.
Indicator 5
Higher education providers make information available to students about the extent
and range of support services provided before, during and after their registration.
18. Do you agree with the wording of this Indicator?
This Indicator and the accompanying explanatory text covers similar ground to that already
covered by the QAA Quality Code Part C: Information about Higher Education Provision.
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Beyond providing a link and explicit reference to Part C, we suggest that this Indicator is not
really necessary.
It also exemplifies the slightly old-fashioned approach to which we refer in our general
comments above; particularly in its references to students preferring to ‘receive information
electronically rather than in paper form’ (paragraph 4, line 5).
If this Indicator is retained however, we would like to query whether paragraph 4 is, in fact,
suggesting that a ‘mixed economy’ approach of paper-based and electronic communication
should be abandoned, as this is how it reads.
19. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
No.
Indicator 6
Higher education providers have policies, practices and systems to actively support
students in making a successful transition into higher education.
20. Do you agree with the wording of this Indicator?
Indicator 6 should cover all transitions within the student’s higher education experience, and
not only transitions into higher education or induction. We therefore suggest that the
Indicator text be amended to read ‘Higher education providers have policies, practices and
systems actively to support student in making a successful transition to their studies.’
We feel that the accompanying explanatory text does not adequately capture the work on
social and academic orientation which takes place prior to enrolment. Nor does it capture the
particular issues faced by overseas students.
Finally, the mention of ‘a sense of having a recognised identity’ (para 1, line 3) makes more
sense in the context of student societies etc than student support. Group identity and student
support is a sensitive area and we wonder whether the document is actually referring to the
pastoral support offered specifically to women students. If this is the case, this should be
made clear.
21. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
No.
Indicator 7
Higher education providers ensure that academic progression and completion are
actively supported.
22. Do you agree with the wording of this Indicator?
Broadly. However, the accompanying text provides a number of particular examples of the
use, referred to in our general comments above, of ‘personal’ where the term ‘pastoral’
would be more appropriate.
23. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
The indicative reference list could be more up to date. For example, UUK’s ‘Student
Services: effective approaches to retaining students in higher education’ is ten years old.
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Indicator 8
Higher education providers' support facilitates student progression to employment
and further study.
24. Do you agree with the wording of this Indicator?
We would suggest that the Indicator might more appropriately read ‘Higher education
providers' support facilitates student progression to graduate employment and further
study’. We would also suggest that the accompanying text should contain some explanatory
information about further study as this is missing entirely.
25. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
As paragraph 4 makes explicit reference to programme design, there should be a crossreference to the Quality Code Chapter 1: Programme Design and Approval.
Indicator 9
Higher education providers ensure that all members of staff who provide students
with support and guidance as appropriate to their role are trained, supported and
resourced.
26. Do you agree with the wording of this Indicator?
Broadly. However we would suggest that if specific roles are going to be mentioned in the
explanatory text, that careers staff/employability professionals should be included as well as
librarians. We also suggest that student disability services are specifically mentioned, along
with the inclusion under the explanatory text of this Indicator, Precept 16 of the former
Section 3: ‘Institutions ensure that there are sufficient designated members of staff with
appropriate skills and experience to provide specialist advice and support to disabled
applicants and students, and to the staff who work with them’
We would also note that the profession-specific terminology which we mention in respect of
Indicator 3, appears here also (‘entitlements’ (paragraph 3, line 1)). It is also important to
note that entitlements do not necessarily apply to other protected characteristics.
We would suggest that paragraph 3, line 1 be revised to read ‘induction programmes for all
new staff’ ie. not just academic staff.
27. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
No, but the indicative list does seem rather thin and could usefully be amplified with links to
relevant professional associations which offer training in these matters.
Indicator 10
Higher education providers ensure there are appropriately maintained physical and
virtual learning resources and learning environments.
28. Do you agree with the wording of this Indicator?
Broadly, although we would suggest that ‘appropriately maintained’ be amended to read
‘well maintained’.
29. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
No.
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Indicator 11
Higher education providers ensure that students are supported to acquire appropriate
skills to support their learning and transferable skills which will enable their
progression into the workplace or into further study.
30. Do you agree with the wording of this Indicator?
There is nothing about employment or employability in the explanatory text and we would
reiterate the point we make above, that the former Section 8: Precept 7, that ‘institutions
make it clear to prospective and current students how the knowledge, understanding and
skills acquired during study are intended to be of use to them in the development of their
future academic or career progression routes’ should be included in the new Chapter and
probably in the text accompanying Indicator 11.
We also feel that Precept 9 (from the former Section 8) ‘CEIAG provision is responsive to
and guided by developments and trends in the UK and global employment market’ should be
included in the new Chapter and probably in the text accompanying Indicator 11.
31. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
In the indicative list of reference points should be included Chapter B1:Programme design
and Approval, B5: Student engagement and B10: Management of Collaborative
Arrangements.
Indicator 12
Higher education providers ensure that the provision of student support forms part of
its quality assurance processes and management of enhancement activities.
32. Do you agree with the wording of this Indicator?
Broadly, but we would note that in the accompanying text at paragraph 2, line 4, the
reference to equality impact assessments is now out of date as these are no longer a legal
obligation. We also feel that the phrase at line 5, ‘students disadvantaged by protected
characteristics,’ is rather unhelpfully emotive.
33. Do you have any suggestions for additional explanatory text or signposts to
further information it may be helpful to include?
No.
Chapter B4: Supporting student achievement - Further comments
34. Do the Indicators of sound practice in this Chapter adequately set out what
higher education providers might do to meet the Chapter Expectation?
Please see our general comments and our comments on specific Indicators above.
35. Are any additional Indicators needed? If so, please give details.
No, but some might usefully be conflated. See our comments on Indicators 2 and 4 above.
36. Do you agree with the order in which the Indicators have been arranged?
No. We would suggest that Indicators 8 and 11 should be together, in order to make the
notion of transition clearer. The Indicator order would then run as follows: 7, 8, 11, 9, 10 and
12.
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37. Please use this space for any further comments on the Chapter. There is NO
word limit for this question.
Please see our general comments above.
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