OFFA’s response to the Government’s higher education Green Paper
We have produced this short briefing to share the key points we have made in our response to the Government’s Green Paper – ‘Fulfilling Our Potential: Teaching Excellence, Social Mobility and Student Choice’.
For our full response to the consultation, see here.
Our key points
Continued independence is the key to strengthening the role of the Director of Fair Access to Higher Education
The Green Paper proposes that the “role of the Director of Fair Access will continue to be a specific and strengthened role within the Office for Students.”
We welcome the proposal that the Director should play ‘a specific and strengthened role’ within the proposed new Office for Students. This is a real opportunity to continue the progress that has been made in the last decade and to help meet the Prime Minister’s ambitions around fair access.
In order to accelerate recent record progress on fair access, we believe the Director must remain a high-profile, single-focused role within the OfS. To ensure fair access is not diluted by other priorities, it will also be crucial for the Director to have the independence, powers and profile to support and challenge the sector to make further improvements across the lifecycle. We therefore say that the Director should:
- be a publicly appointed individual with a single focus on fair access and the independence to operate free from conflicts of interest or regulatory capture by the sector
- retain their independent power to require institutions to have an access agreement approved and signed off by them in order to charge fees above the basic amount. The Chief Executive of the OfS should not be able to bypass this power
- have this power secured in primary legislation
- continue to receive guidance from Ministers, and report on progress direct to Ministers and Parliament
- not report directly to, but work with, the Chief Executive of the OfS in order to ensure that fair access does not compete with other priorities
- attend the Board of the OfS – ensuring that access is considered and embedded across the wider organisation’s remit.
Continuing to require institutions to set their own access agreement targets will help drive further progress
The Green Paper proposes: “an option would be for the new Office for Students to have the power to set targets for providers that are failing to make progress on agreed widening participation goals, or where the outcomes for specific groups are below expectations.”
We believe that the responsibility for setting access agreement targets should remain with individual universities and colleges with the Director of Fair Access to Higher Education helping to set expectations for institutions and being responsible for approving targets. This is because:
- the current system works well – it preserves institutional autonomy while allowing the Director to intervene where he/she believes that targets are not sufficiently ambitious. Ultimately the Director has the power to refuse to approve an access agreement if targets are not suitably stretching. For the latest set of agreements, OFFA secured improved targets at 94 institutions following negotiation
- external target setting would reduce ownership and make it more difficult for the Director to hold institutions to account for failing to make progress against agreed targets
- central target setting would be a bureaucratic and resource-intensive exercise.
The creation of the Office for Students brings opportunities for fair access
The Green Paper proposes “to establish a new regulator and student champion, the Office for Students.”
If single focus access regulation is retained within the new architecture, so ensuring that access is not traded against other priorities, the proposed changes could represent a major opportunity to enhance fair access. It could help bring greater coherence and ensure that widening participation is embedded across the different regulatory functions of the new Office for Students. For instance, the Teaching Excellence Framework could work to ensure that the future system of quality assessment enhances and reinforces policies on access and supports a reduction in differential outcomes.
Because of the wide remit of the Office for Students, there is an opportunity to consider fair access issues more effectively across the different functions of the OfS, including ensuring that:
- any new providers take into account how they can widen access to their courses
- disadvantaged students are protected in the event of providers exiting the sector
- prospective and current students from disadvantaged backgrounds have access to good quality information.
Ensuring the Teaching Excellence Framework works for students from disadvantaged backgrounds
The Green Paper proposes “to introduce a Teaching Excellence Framework [which] will deliver better value for money for students, employers and taxpayers.”
We are pleased that the Green Paper identifies the importance of fair access to the TEF.
We especially welcome:
- that the metrics in the TEF should be broken down and reported by disadvantaged backgrounds and under-represented groups
- that the TEF will recognise those institutions that do the most to welcome and support students from a range of backgrounds.
In order to ensure that the TEF supports students from disadvantaged backgrounds the Government should work to ensure that outcomes – rather than inputs – are key to informing an institution’s TEF award level.
Promoting fair access to postgraduate study and reversing the decline in part-time student numbers
When discussing ambitions for further progress on fair access, the Green Paper asks if there are any other groups or measures the Government should consider.
We set out our full response in answer to Question 12c. In particular, we highlight part-time and postgraduate students as areas where the Government should look to develop policy.
On postgraduate study, our view is that the postgraduate loan system should require institutions to have a firm commitment to improving widening participation – in the same way that institutions are required to have an approved access agreement if they want to charge undergraduate students higher fees. The Government should consider what role the Director of Fair Access to Higher Education can play to promote and safeguard access to postgraduate taught study as well as undergraduate study. This could include using legislation to extend our remit to cover postgraduate taught students. This would ensure that barriers to access are considered at all levels of study, and would help to unlock access for postgraduate study for disadvantaged students.
We also recognise the dramatic and worrying decline in the number of part-time students. We welcome proposals from the Government to introduce maintenance loans for part-time students, and we make a number of suggestions to further support part-time students as follows:-
- Allowing fee loans to be applied to part-time credits, regardless of whether a student wishes to secure a full qualification. This would enable people from disadvantaged backgrounds to have a ‘taste’ of higher education without needing to find funds upfront.
- Encouraging credit accumulation and transfer between recognised awarding institutions.
- Extending the relaxation of restrictions on students with ‘equivalent level qualifications’ to all part-time courses.