If we must have a market in higher education, it’s important that there’s a regulator that secures and strengthens students’ rights in it – so we were thrilled to be invited to give evidence to the Lords’ Industry and Regulators Committee and its inquiry into the work of the Office for Students (OfS).
We were especially pleased because unlike universities and colleges, neither students nor their students’ unions have previously been asked for their views on OfS, and so nor has any action plan to improve engagement with us been developed.
We did not want to dwell too much on issues of process, but it is important that OfS takes extra steps to involve students in its work given the name over the door.
In our view the regulator is very difficult to engage with – outside of the TEF, engagement amounts to being invited to round tables on specific policy issues and being invited to submit responses to consultations.
But as everyone knows locally, when students can’t see the difference their input is making, they stop bothering.
Mack and I made our way to London today to give evidence to @UKHouseofLords Industry and Regulators Committee as part of their inquiry into the work of OfS. We talked about students priorities, OfS student engagement processes and the importance of students knowing their rights! pic.twitter.com/unnzGMdP8p
— Rania Regaieg (she/her) (@TheSUPresident) May 2, 2023
Providers or partners?
We think OfS is confused about us. Calling their universities and colleges “providers” and refusing to frame us as “partners” means that our agency in the development of policy, the governance of institutions or even just the way we are treated by the regulator over our rights feels wrong.
We do have consumer rights, but we don’t think of our lecturers as “providing” our education – we partner with them. Why is this so hard for OfS to understand?
We both for example were happy to lead a student submission into the TEF at our universities. But the idea that that process was not compulsory feels baffling. Even in the smallest providers, if your students can’t be supported to offer an independent view on quality, what kind of “higher” education are you offering?
Priorities matter too. We have no idea how OfS sets its priorities. But if, for example, it was responding strategically to the biggest survey on student opinion, it would be bearing down hard on universities’ efforts on assessment and feedback, and ensuring that student voice was stronger than NSS results suggest it is.
Instead we’ve heard nothing from OfS on generative AI and assessment, and OfS offers neither sticks nor carrots on the engagement of students in decisions about their education. And while, thanks to Shirley Pearce’s review, students are treated as experts on quality panels in the TEF, students are excluded from being treated as experts when OfS is interrogating quality against its B conditions. Why?
Panel beating
When it comes to consultation, we are sure that the OfS student panel is full of committed and hard working students.
But it can’t be representative of all students, and we note (for example) that Ofgem’s panel is 100-strong, and Ofwat places much much more ambitious requirements on water providers over customer engagement.
If they can manage it in water regulation, surely OfS can manage it in higher education.
We do not take the view that it is important that all students know who, or what, OfS is – any more than we think it’s not vital that people know the details of what Ofgem or Ofwat do. But we do think OfS could take more care to ensure that students and their representatives know what its regulatory requirements are.
How are students supported to raise a complaint or submit a notification if they don’t know the basis on which they might do so?
A big part of that is making sure that universities and colleges make promises that enable students to choose, and then keep them. Even if the sector wasn’t so marketised, students would want good information and would want those commitments to be delivered.
That OfS has said little since launch on applicant information, never interrogated the actions of international agents and appears to have dropped work on student contracts suggests its priorities are not aligned with those of our members.
Students care
What really matters to us is the issues that really matter to students. Cost of living has been top for our students this year, but all we’ve had from OfS has been some research that told us what everyone already knew – student financial support can impact students’ experience and outcomes.
There are obvious links to both its A and B conditions, but you’d never know it from OfS.
While many support the cause, many students are also desperately worried about the impacts of industrial action and in other cases at some universities upset at the downsizing and course restructuring that seems to be becoming commonplace as the impact of frozen fees takes effect.
That OfS has little to no advice for students on their rights in cases like this, nor case studies on what it itself has done with providers on these issues, is deeply problematic.
Mental health continues to really matter. It’s not extra curricular – how universities teach and support students can have a huge impact – but there’s barely a mention of mental wellbeing in the B conditions, and OfS has dropped its NSS question on belonging and community.
And while OfS is asking students about their awareness of wellbeing services in the NSS, it isn’t asking about quality. We’d be voted out of office if we did that in our surveys.
Value for money still matters too. Try finding information on hidden course costs on the OfS website and you’ll come up short. And while it’s true that higher education is an investment into our future, and overall value for money can’t be determined until later in life, we do know that students want the basics to be delivered.
Without clarity on what those basics should be, our successors will be in meetings where they see our own universities doing their best – but their members won’t know if that is good enough.
It’s not impossible. A bolder, braver and more confident OfS wouldn’t spend so much time responding to the government and instead would set out a positive vision for students – their experience, their outcomes and their lives.
Taking the latest edict from ministers, spinning that as “in the student interest” and being aggressive with providers over those issues doesn’t help. Listening to us, and giving us the tools we need to be assertive about our education and our future, would.
