Regulating for students, with students

A new Guild HE briefing that we have contributed to argues that defining what is in the student interest must actively involve students.

Decisions about regulation that directly impact on students’ experiences should be informed by student views, feedback and evidence of what students consider to be important. This is a fundamental component of good regulation in the student interest.

As former student leaders with a combined 15-years of experience in student engagement and representation within providers, regulators, and government policymaking, we have viewed the student experience from several angles.

Previously, we collaborated in our Office for Students (OfS) roles on a refreshed student engagement strategy, which distinguished between OfS’ activity to engage students in its own policymaking, and OfS’ regulation of student engagement in higher education institutions.

The student engagement strategy focussed on positioning the OfS as a regulator on behalf of students. With the next iteration due in 2024, we’ve been reflecting on practical suggestions for a step-change in OfS’ engagement with students.

This could also bring OfS into line with the practices of several regulators in their engagement with consumers.

Doing more to engage

Student engagement improves policymaking and outcomes. The evidence shows this, as does our own experience.

It will improve policy at OfS as it does in universities and colleges. This is especially pertinent given the increasing breadth of OfS’s regulatory responsibilities which directly affect students’ lives and experiences.

We are deeply supportive OfS’s focus on students. But to enable credible regulation in the student interest, we believe that OfS should be bolder in its engagement with students in the two pillars of the OfS’s strategy – quality and equality of opportunity.

Firstly, there should be mandatory student involvement in shaping access and participation plans – these plans impact the life chances of underrepresented and underheard students for years after they are written.

As a matter of social justice and credibility, providers should demonstrate how they have involved underrepresented students in the formation of these plans.

Secondly, students are experts in their own experience, and as such, their views should be harnessed as part of any future quality regime. Student views are integral to quality assessments, both as student assessors which OfS should facilitate, and the views of students on the ground.

Engaging students in regulation

OfS’s regulatory framework commits to student involvement in regulatory activity, including the existence of a student panel. The student panel has been pivotal over the last few years in beginning to develop a student-centred culture.

But to act in the student interest, OfS must understand broader student views on regulatory issues too.

Firstly, the panel should be supported to undertake student-led research and publish evidence in line with OfS’s priorities, as was initially envisaged when it was established.

Secondly, OfS should publish an annual report detailing the impact of student engagement on its policymaking and priorities (as providers will be required to to when submitting APPs), and a scorecard as part of consultations affecting students on how their views have shaped resultant policy. This would enable OfS to walk the talk when it comes to engaging with students.

We believe these actions would start to enable the to translate current well-intentioned student interaction and “closed doors” influence into transparent and legitimising engagement.

This would put students at the heart of regulation, as well as the system.

The authors are both writing in a personal capacity. This is an edited extract of Regulating in the Student Interest, GuildHE’s third briefing on regulation – you can read the full publication here.