Among the policies slated for Rishi Sunak’s latest relaunch (which include the absolutely superb idea of scrapping A levels in favour of an English Baccalaureate ) we find the re-appearance of an old favourite: a “crackdown on low-grade degrees“.

This is a favoured hobbyhorse of the PM, first appearing as a possible vote-winner in the leadership contest he lost to Liz Truss in the summer of 2022, despite already being government (and Office for Students policy) having been announced several times, most recently in May 2022. It then re-emerged in July 2023, spooking the sector with the idea of student number controls before turning out to be a restatement of paragraph 175(b) of the regulatory framework – powers that not only already existed but that had already been used four times by the Office for Students.

Rishi clearly believes such policies are both popular and achievable, even though when you press him on the detail he just tails off murmuring about “earning potential“. On the more practical implementation points, meaningfully identifying “low grade” courses is a huge stumbling block – for a start there is very little meaningful data on courses themselves, meaning we usually end up talking about quite wide subject areas involving numerous courses. It is also quite difficult to spot subject areas in providers that are just plain bad using data, your set will also include subjects at providers frequently taken by people with disadvantaged backgrounds (prior disadvantage still has a huge impact on continuation and progression, despite the fervent wishes of the Social Mobility Council) or that lead into low paid public sector jobs or jobs incorrectly classified as low-skilled.

All this is a shame because there are poor quality courses in our higher education system, but our regulator is uniquely poorly suited to dealing with them.

We are, supposedly, going to get some data on franchised courses at some point, as a prelude to regulatory action – but (although franchised provision is as diverse as any other mode) we know there are some unregistered providers offering what appears to be a very low quality product. This is something that should be dealt with by the providers the course is franchised from, but such is the need for income among these providers it appears issues may be being overlooked. Certainly it doesn’t help that regulatory investigations seem not to be focused on such provision, and – indeed – providers can choose whether or not franchised provision can be included in the TEF.

Likewise, it is clear that there are some subject areas in some providers that have grown recruitment to such an extent that there are no longer sufficient staff or resources to offer students a high quality student experience. We usually see this in two ways, declining National Student Survey scores in larger departments, and attempts to limit recruitment growth at better-off providers. Sadly, we have a system that requires universities and colleges to grow student numbers (and thus fee income) just to retain enough real-terms resources to cover costs. Until another way to drive provider income is found quality is going to fall – whatever waste may have existed in the system in 2012 is long gone in 2023, with rounds of restructuring in the late 2010s overlaid with the cuts needed during the pandemic.

In both cases, early knowledge is essential for action that would benefit current students. Students themselves are best placed to offer data here, but OfS has systematically devalued the student voice since inception – the student panel and student board members have been put under political and ideological pressure, and plans to expand the NSS beyond third-year undergraduates (to postgraduates, and other years of study) have seemingly stalled. While OfS is committed to keeping an eye on output data, the use of lagging indicators like continuation, completion, and progression mean that we can’t see poor quality provision directly, only the effect it has had on a cohort of students some years later.

If Sunak generally wants to crack down on low-quality provision, he needs to start with regulatory reform – the recommendations of the Industry and Regulators Committee offer some cover here. And as outputs-based regulation will be even worse for LLE-style short courses than it is for traditional degrees, we need to move quickly.