Yesterday saw the launch of a new consultation on the Quality Assurance Agency’s Quality Code.
The new draft version retains twelve “sector agreed principles” which align to European Standards and Guidelines (ESG), and these are underpinned by 70 “key practices” to provide more detailed recommendations for providers.
Still here
The QAA Quality Code is very much still a thing. In Scotland, Wales, and Northern Ireland it forms a key component of quality assurance practice – setting out the key expectations that will allow a provider to prove, via a cyclical inspection conducted by the QAA, that it is serious about higher education.
The Quality Code also has standing overseas – fully compliant with international expectations, it is used in countless countries as a point of reference. It’s an example of best practice, underpinning the outside impact that UK higher education has on systems around the world. If you have overseas provision, or recruit internationally, you can use the Quality Code to reassure international regulators that you comply with international quality expectations.
In England, the Quality Code (designed and owned by the sector) does not even have official status as a sector recognised standard. The official line from the regulator is:
providers may still choose to refer to the UK Quality Code if they find it helpful but should be aware that following the Code will not guarantee compliance with the OfS’s requirements. In particular, providers should note that there are likely to be some parts of the Code which would lead to practice that we would consider non-compliant with our regulatory requirements.
The justification here was OfS’ perception that providers had previously “gold-plated” quality assurance structures and mechanisms, and that a less prescriptive approach would allow for both a reduction of burden and the prospect of innovation. Hold that thought.
What’s new?
It’s an iteration rather than an evolution of the version presented for initial feedback at the back end of last year, but do not be fooled – this still represents a big shift from the 2018 state of the art (as tweaked in 2023). The doubling down on student participation and the explicit links between assurance and enhancement remain – the “key practices”, as expanded and refined, still remain a useful primer – for newer providers in particular – that offers support for the development of emerging processes without reaching the point of expectation.
The latest round of feedback has seen the sector get to grips with the trend towards the fashionable conceptualisation of higher education as a part of a wider tertiary sector, and to seek guidance on new perceived threats to academic integrity such as the use of large language models (LLMs, here described as “Generative AI” feature under principle 11). There’s been a pleasing addition of detail to principle 8, covering the risks of partnership arrangements. On a more textual level there’s been refinements on sections on external expertise and flexible delivery, alongside a simplification of some of the language in a quest to make things as usable and inclusive as possible.
Jargon is often an issue in quality assurance – so the addition of a glossary is welcome. We even get a definition of quality:
Quality – refers to how well providers support students to consistently achieve positive outcomes in learning, personal development and career advancement, while meeting the reasonable expectations of those students, employers, government and society in general.
Alongside a definition of standards:
Standards/academic standards – these are the standards that degree-awarding bodies set and maintain for the award of academic credit or qualifications. Degree-awarding bodies are responsible for defining their own academic standards by setting the pass marks and determining the grading/marking schemes and any criteria for classification of qualifications that differentiate between levels of student achievement above and below the threshold academic standards. These individual standards align to national qualifications and credit frameworks and/or The Framework of Qualifications for the European Higher Education Area.
Quality beyond designation
If you are based in England you may be forgiven for wondering what all this means for you. Since QAA walked away from a notably toxic relationship (and the Office for Students memorably threw toys out of the pram) there’s not been a statutory role for the QAA – something that has alarmed the House of Lords Industry and Regulators Committee:
the circumstances of the QAA’s de-designation remain unclear and contested, and the difficulties we faced in getting a clear account of these issues is a problem in and of itself.
The most charitable read of all this is that OfS has been trying to reset quality assurance expectations. It has thus far carried out a range of quality assurance assessments, including eight with published reports, of which four noted issues that may require regulatory insight.
Findings include issues with staff and other resourcing (principle 3 of the new code), monitoring and understanding engagement and continuation data (principles 4 and 5), identifying and acting on student support needs (principle 10), partnership activity (principle 8), consistency of rules and requirements (principle 5), and assessment and feedback (principle 11). I don’t want to labour the point, but had the providers in question been compliant with the Quality Code, these issues would not have been present.
The “I’ll know it when I see it” approach to quality assurance guidance, where general statements about freedom and innovation are leavened with incomprehensibly direct interventions (spelling and punctuation!) that make it feel like the regulator has been under pressure to act, have manifested as a significant step backwards for the sector in England. Bluntly put, we did not see these kinds of issues in mainstream providers pre-2017, and it is not clear that similar issues are absent at more “prestigious” providers with better outcomes metrics.
The regulator may want to treat universities as black boxes that produce employable graduates. But the real work of quality assurance is the inside of the sausage machine – and the Code (alongside updated guidance and stuff like the subject benchmark statements) represents the sector’s own understanding of what is required at this level of detail. Ignore it at your peril.
