Overall on access and participation in England we are where we thought we’d be back in September.
The Office for Students (OfS) is setting out what it thinks are the big risks for students, and won’t rest until it is confident that higher education providers have taken account of them, worked out their own version of the risks based on their own deep understanding of their own students, and then set a stretching but credible plan to mitigate the impacts of those risks.
In his accompanying commentary to the new guidance, OfS Director of Access and Participation John Blake dwells on the familiar theme of equality in lockstep with quality – reiterating the familiar message that students from disadvantaged backgrounds should not accept poor quality courses.
Two becomes one?
The idea of the two regulatory priorities pulling in the same direction is a good one – but we do need to be very clear, just as providers need to be in developing their own interventions, on causality and evaluation.
The mere existence of a national risk register that argues from a research-informed perspective that student background has a course and provider independent impact on progression and completion would suggest that these same measures may not be a reliable way to identify course quality – and we’re pretty sure OfS is not arguing that recruiting disadvantaged students is what makes a course poor quality.
If you’re a provider stuck in the mindset of jumping through regulatory hoops with the minimum of fuss, and doing what you have to do to get John Blake off your back, it remains the case that you’ll almost certainly fail. But it’s where a more earnest and sophisticated analysis leads you that is more interesting.
Taking Blake at his word
If you were to take a step back and ask the person on the Clapham Omnibus what the risks to equality of opportunity in higher education are, you’d include all sorts of discrimination or even harassment as defined in the Equality Act.
That this agenda, and the twelve risks identified, don’t mention racial harassment, or the reasonable adjustments that providers should be making for students with mental health conditions, or the levels of sexual violence experienced principally by women and LGBT+ students that OfS told us a couple of weeks ago were so high, is odd – unless you want to file those under “environment not conducive to good mental health” which as a risk category in itself, is already at risk of being stretched well beyond the capability of institutions to mitigate.
A provider doing a proper risk analysis might therefore include those factors – many of which really are outside of their control, and evaluated by a different part of OfS.
But much more importantly, if you take John Blake at his word that OfS is genuinely committed to understanding what works and what doesn’t and it’s all about hard evidence, then the risks that a half decent analysis would show up in the external environment would need to be included.
Put another way – if OfS on behalf of the sector is concerned about continuation or completion rates for students on the lowest incomes, can student financial circumstances realistically not be considered to be part of its national picture of risk?
Where to put the Treasury on your risk register
So a provider that did not include in its assessment of risk: “the government may not raise student maintenance in line with inflation over the next five years” would be making a fundamentally dishonest assessment of the reality facing students on low incomes.
Likewise a credible assessment of risks to full participation in the range of opportunities available would need to discuss the parental income threshold for the maximum maintenance loan or the state of the private rental market.
If a provider did the evaluation maths on the last plan and worked out how much a student needs to live on, we know said students will now be £1,500 further behind where they need to be thanks to DfE. Is a provider supposed to pretend that that hasn’t happened? Or won’t get worse? Does it factor in the magic money twig? And is the provider supposed to make up the full £1,500 to stand still, or admit fewer low income students?
It’s all very well saying that students from disadvantaged backgrounds shouldn’t be prepared to accept poor quality courses where too many students drop out and do not find graduate level work. But what if the course is great, but in your honest risk assessment, you don’t trust the state to do its bit? What if you conclude that the best thing you can do for large swathes of low income students right now, given your budget, is not admit them?
Black swans from hell
Blake has expressed a degree of pragmatism about holding providers to account for the failure to meet targets in current plans – on the basis that factors like the pandemic would cloud a judgement on the extent to which it was reasonable to exercise that accountability.
You could perhaps argue that the pandemic, or the current cost of living crisis are black swan events – something that essentially allows providers to be let off from meeting the targets because they couldn’t have reasonably predicted or planned mitigations at the time of setting those targets. That is different from making a judgement about the quality of the institutional response to those events when they did materialise – although Blake has consistently avoided even requiring a meaningful response to those.
But the danger in the expectation that universities set out “ambitious” plans on access is that the incentive is for providers to plan on the basis of only white swans, and the pretence that the government will fix student financial support.
It would be strange indeed, but better, if those that genuinely and reasonably conclude – with all the evidence behind them – that mitigating the risks in full is pretty much impossible, and make a realistic assessment of more modest mitigations that are within their power and resource to achieve, get the nod from OfS.
