ENQA highlights risk of UK nations divergence on quality assurance

The good news first – the QAA has passed its quinquennial inspection, and is compliant with the standards and guidelines for quality assurance in the European higher education area (ESG).

The agency itself highlights specific commendations on the way students are involved in university and college review processes, and on the way it has worked to ensure its independence from government. Lest you think this is all a bit of a whitewash, there’s areas flagged for improvement (“partial compliance”) too – specifically:

• A clearer plan for thematic analysis – drawing together the findings from the various review activities the QAA carries out to benefit the sector. ENQA did note that QAA does this well in Scotland
• A plan to ensure the consistency of outcomes – QAA is unique in Europe in leaving the final decision on reviews to the review panel rather than moderating recommendations centrally. QAA manages this by providing detailed guidance to panels, but ENQA reckons there needs to be a loop through the QAA management structure as well.

It’s a good showing in all. Back in June 2022 the QAA’s ENQA registration was suspended out of cycle following concerns with work carried out as the Designated Quality Body in England. At that point the concerns were that students were not involved on review panels, and reviews were not being routinely published on completion. QAA had to demit as DQB (something that was formalised on 31 March 2023) in order to re-register.

Told like that, this all seems like a very simple problem to solve – to go along with the rest of the world and include students (as experts in their own experience) as reviewers, and to publish reviews in the interest of transparency. This, however, was apparently not an option – and the Office for Students was willing to insist on non-compliance to the detriment of the wider UK sector. Fans of the minutiae of regulation in England will be aware how this situation quickly degenerated into farce, with the resultant regulatory bickering failing to impress the House of Lords Industry and Regulators Committee.

Noting that the QAA needed international compliance to do the work it does in Wales, Scotland, Northern Ireland, and elsewhere – ENQA has a take on all this too as an “additional observation”.

The fact that England has taken a different direction from the rest of the UK could create confusion internationally and might also impact QAA’s international operations, depending on which institution takes on DQB responsibilities in the future

It laments the fragmentation of Quality Code driven agreement on quality and standards across the four UK sectors, and notes the risks involved:

This review and especially the site visit made it very clear how the four UK nations are drifting apart policy-wise, mainly with England moving in a different direction from the rest of the nations. Wales, Scotland and Northern Ireland have the opportunity to connect with each other, work together and share best practice, such as through the enhanced review approach. This will challenge the ambitions of QAA to reach more convergence on the UK level and have effects on the perception of higher education in/from the UK as a whole

But it also makes a gesture towards one of OfS’ stated concerns – that being a membership organisation (which “has an important role to play in disseminating good practices, organising discourses and exchange and providing support and solutions to the higher education sector”) and that reviewing organisations that fund you in this way is “a balancing act”.

To be clear, there’s never been any suggestion that QAA reviews are easier for fee-paying members. And the whole situation has basically been foisted on the QAA by the 2017 Higher Education and Research Act (which mandated a subscription only to cover DQB activity, meaning other revenue streams needed to be found to support the valuable UK-wide work QAA does on stuff like the subject benchmark statements). But we are, it is said, where we are – with the QAA now needing to identify more income streams to fill the income gap of around 20 per cent that demiting from the role in England has left.