Recommendations & Conclusions
10 items
3
Recommendation
Eighth Report - Financial sustainabilit…
Accepted
Protections for students, in the event of providers facing financial distress, are not strong enough. The OfS requires providers to have a student protection plan in place to address the risk of continuity of study for its students, but it has identified common weaknesses in them – including over-optimism about …
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Protections for students, in the event of providers facing financial distress, are not strong enough. The OfS requires providers to have a student protection plan in place to address the risk of continuity of study for its students, but it has identified common weaknesses in them – including over-optimism about risks and weak refund and compensation policies. When initially registering providers, the OfS approved a number of student protection plans that it considered inadequate, so as not to delay registrations. During the pandemic, it found that it needed greater powers to intervene more quickly, and introduced a new condition of registration from April 2021 allowing it to issue directions to universities it considers at material risk of failure. However, the process of implementing a student protection plan, which the OfS described to us, appears to be reactive. Recommendation: The OfS should prioritise ensuring that all providers’ published student protection plans are fit for purpose and sufficiently clear for students to make confident, well-informed decisions about the protections universities are promising them.
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Government response AI summary
The government agrees that the OfS should prioritize ensuring that all providers’ published student protection plans are fit for purpose and sufficiently clear, highlighting the OfS's risk-based approach, the introduction of Registration condition C4, and intentions to begin discussions with the sector to update and …
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HM Treasury
5
Recommendation
Eighth Report - Financial sustainabilit…
Accepted
Student satisfaction with the value for money of their courses is at a worryingly low level. One of the OfS’s four regulatory objectives is that students receive value for money. OfS says that students should receive the academic experience they were promised by their provider and their interests as consumers …
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Student satisfaction with the value for money of their courses is at a worryingly low level. One of the OfS’s four regulatory objectives is that students receive value for money. OfS says that students should receive the academic experience they were promised by their provider and their interests as consumers should be protected before, during and after their studies. Overall student satisfaction has been consistently over 80%, but fell to 75% in the pandemic- one of the main contributing factors being dissatisfaction with learning resources required by lockdown restrictions. The proportion of students who thought their course was value for money is much lower and dropped from 38% in 2020 to 33% in 2021, with more than half saying it was not value for money. The OfS acknowledges that students’ view that they are not getting value for money is a cause for concern. The OfS believes that quality of provision is central to how students regard value for money, and asserts that quality is one of its top three concerns. The OfS says that it is looking at quality issues closely and that working with the universities to ensure that, even on oversubscribed courses, quality remains good. Recommendation: The Department and the OfS should set out what action the OfS is taking to improve students’ satisfaction with value for money, including the OfS’s assessment of the impact of hybrid teaching on students’ experience and what progress has been made in addressing the causes of dissatisfaction.
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Government response AI summary
The OfS is introducing an enhanced quality regulatory regime including student outcome thresholds and new registration conditions covering students’ academic experience; it is also considering how it measures value for money and is reviewing blended learning.
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HM Treasury
8
Recommendation
Eighth Report - Financial sustainabilit…
Accepted
We asked the OfS whether satisfaction rates among students had changed as a result of the pandemic, and what the impact of hybrid learning had been on students. The OfS told us that, following the widespread use of online provision during the COVID-19 pandemic, it was undertaking work to better …
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We asked the OfS whether satisfaction rates among students had changed as a result of the pandemic, and what the impact of hybrid learning had been on students. The OfS told us that, following the widespread use of online provision during the COVID-19 pandemic, it was undertaking work to better understand the impact of hybrid provision—a mix of face-to-face and online provision—on students, what is going on in the sector and what ‘good’ looks like. It noted that while there might be some lag in identifying trends through the National Student Survey, its work on hybrid provision would give it evidence “that is much more real-time”. It expected this work to be completed by summer 2022.16
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Government response AI summary
The government agrees to improve the quality of higher education provision and ensure students are satisfied with value for money, with the OfS introducing an enhanced quality regulatory regime and reviewing blended learning, with a target implementation date of Autumn 2022.
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HM Treasury
9
Conclusion
Eighth Report - Financial sustainabilit…
Accepted
To create and maintain its regulatory independence, and seeking to minimise regulatory burden, the OfS does not maintain close ongoing contact with individual providers it considers at low risk. The OfS explained that it collected “a basic core from every registered university and college” but beyond this it considered its …
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To create and maintain its regulatory independence, and seeking to minimise regulatory burden, the OfS does not maintain close ongoing contact with individual providers it considers at low risk. The OfS explained that it collected “a basic core from every registered university and college” but beyond this it considered its approach was “proportionate to the particular circumstances they face”.17 The National Audit Office reported that the sector bodies and providers it had spoken to told it that, because the OfS had not routinely spoken to most providers, they were not confident that the OfS had all the information it needed to contextualise the financial data it collects. The OfS asserted that it did not recognise that criticism in relation to financial data, as opposed to information about quality. It accepted that there were issues around the burden on providers of collecting this data, and that it was doing a lot of work on that, but that “in terms of us needing this core data, the case is unequivocal”.18 The Department’s oversight of the OfS’s performance
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Government response AI summary
The government agrees with the committee's observation but states that the OfS already ensures robust protections through a risk-based approach and a new registration condition (C4) introduced in April 2021, which strengthens providers' plans to protect students.
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HM Treasury
11
Recommendation
Eighth Report - Financial sustainabilit…
Accepted
The National Audit Office reported that the OfS does not yet have a complete and transparent set of performance measures to demonstrate its own performance as a regulator.21 Of the 26 performance indicators the OfS sets out on its website, eight are still in development or have incomplete performance information …
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The National Audit Office reported that the OfS does not yet have a complete and transparent set of performance measures to demonstrate its own performance as a regulator.21 Of the 26 performance indicators the OfS sets out on its website, eight are still in development or have incomplete performance information and a further 11 indicators do not yet have associated targets. We asked the Department how it was able to hold the OfS to account without the management information that such a set of measures would provide. The Department and the OfS recognised that development of the indicators had 15 Qq 72–78 16 Q 33–35, 42–43 17 Q 55 18 Q 55; C&AG’s Report, paras 3.5–3.6 19 C&AG’s Report, para 1.8 20 Qq 45, 50; C&AG’s Report, paras 3.5, 3.25 21 C&AG’s Report, para 16 Financial sustainability of the higher education sector in England 11 not been a priority during the COVID-19 pandemic, but told us that it was not something they were complacent about. They told us that the measures would be reviewed in line with the OfS’s new strategy and would be in a better place by summer 2022.22
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Government response AI summary
The government agrees to work with the OfS to establish a complete set of robust, published performance measures and targets, including structured feedback from providers, to hold the OfS to account for its effectiveness, with a target implementation date of September 2022.
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HM Treasury
12
Recommendation
Eighth Report - Financial sustainabilit…
Accepted
The OfS assured us that it consulted widely on changes to its regulatory framework and holds meetings and workshops with stakeholder groups. However, there is no routine way in which it captures structured stakeholder feedback through which it can gather the views of regulated bodies on its own performance. It …
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The OfS assured us that it consulted widely on changes to its regulatory framework and holds meetings and workshops with stakeholder groups. However, there is no routine way in which it captures structured stakeholder feedback through which it can gather the views of regulated bodies on its own performance. It told us that it planned to ask for more systematic feedback through a survey, which will provide comparable data against which it can benchmark itself each year.23 Providers’ financial dependence on overseas students’ tuition fees
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Government response AI summary
The OfS is in the process of concluding the review of its key performance measures, with a view to these being published by September 2022 and the Department for Education is working with the OfS to agree an aligned suite of internal performance measures which …
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HM Treasury
13
Recommendation
Eighth Report - Financial sustainabilit…
Accepted
Publicly funded teaching and research make a loss across the sector once the full economic costs of those activities are taken into account. Providers’ financial viability depends on subsidising these activities from the surplus generated by non-publicly funded teaching – primarily fees from overseas students.24 The Department told us that …
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Publicly funded teaching and research make a loss across the sector once the full economic costs of those activities are taken into account. Providers’ financial viability depends on subsidising these activities from the surplus generated by non-publicly funded teaching – primarily fees from overseas students.24 The Department told us that this was a very competitive market, and estimated that international students contributed some £17 billion to GDP.25
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Government response AI summary
The government agrees to set out the risks to achieving continued forecast growth in overseas student numbers and explain how it is mitigating those risks, noting the importance of the International Education Strategy (IES) and diversification of international student recruitment.
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HM Treasury
22
Conclusion
Eighth Report - Financial sustainabilit…
Accepted
The OfS told us that one of the things it became very aware of during the early days of the pandemic was that it did not have the tools needed to intervene quickly if facing a provider failure. It said that, because addressing that issue was urgent, in early 2020 …
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The OfS told us that one of the things it became very aware of during the early days of the pandemic was that it did not have the tools needed to intervene quickly if facing a provider failure. It said that, because addressing that issue was urgent, in early 2020 it consulted quickly and introduced a new regulatory condition, effective from 1 April 2021, which enables it to impose directions on providers it considers at material risk of failure. The OfS described to us examples of the sort of directions it might make, including: requiring a provider to specify what it was doing to protect students’ interests; ensuring that students could transfer to a different institution to complete their studies; complete their intended course of study, or complete their current academic year or term and receive an exit award or credit to recognise their achievements with sufficient evidence retained to enable students to demonstrate the credit they had secured; and ensuring that complaints processes and a compensation scheme were in place.42
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Government response AI summary
The government agrees with the Committee’s recommendation and the OfS focus has been ensuring that protections are as robust as possible in those providers which might face financial distress.
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HM Treasury
24
Conclusion
Eighth Report - Financial sustainabilit…
Accepted
The results of the National Student Survey show that overall student satisfaction was stable at 82–83% between 2017 and 2020, falling to 75% in 2021.44 The OfS measures students’ perception of value for money in a separate survey, which, unlike the National Student Survey, is not restricted to final-year undergraduates. …
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The results of the National Student Survey show that overall student satisfaction was stable at 82–83% between 2017 and 2020, falling to 75% in 2021.44 The OfS measures students’ perception of value for money in a separate survey, which, unlike the National Student Survey, is not restricted to final-year undergraduates. In this survey, the proportion of then-current undergraduates saying that university offered good value for money fell from 38% in 2020 to 33% in 2021, and the proportion saying it did not rose from 48% to 54%.45 We asked the OfS whether it was concerned by these figures. The OfS told us that value for money is one of its four regulatory priorities. It agreed that the proportion of students thinking that their course was value for money was a very low figure and “absolutely” a cause for concern. The OfS assured us that it saw tackling the situation as a priority. It explained that a lot of the OfS’s work would be looking to reverse that, primarily by addressing issues of quality, where students think they are not getting the quality that they deserve.46
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Government response AI summary
The government agrees with the Committee’s recommendation, with the OfS introducing an enhanced quality regulatory regime to tackle the pockets of low-quality provision.
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HM Treasury
26
Conclusion
Eighth Report - Financial sustainabilit…
Accepted
The OfS suggested to us that students’ satisfaction with their courses and assessments of value for money were also related to their perceptions of what they were getting for the tuition fee. During the pandemic, there were calls for higher education providers to refund a proportion of tuition fees in …
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The OfS suggested to us that students’ satisfaction with their courses and assessments of value for money were also related to their perceptions of what they were getting for the tuition fee. During the pandemic, there were calls for higher education providers to refund a proportion of tuition fees in recognition of the shift to online learning required by lockdown restrictions, and restricted access to laboratories, libraries and other learning resources. Student satisfaction with learning resources had the greatest fall of factors measured between 2020 and 2021. The government’s position was that students ordinarily should not expect any fee refund if they were receiving adequate online learning and support. The government did not define what it meant by ‘adequate’, and students were not consulted on this decision nor on how it affected the value for money they were getting. The NAO found that it was likely, however, that the government’s position reduced financial stress on providers.49 44 Q 69; C&AG’s Report, para 4.7 45 Qq 33, 69, 71; C&AG’s Report, para 4.8 46 Qq 69, 71 47 Qq 29, 70, 83; C&AG’s Report, para 4.8 48 Qq 69, 83, 95 49 Q69; C&AG’s Report, paras 4.19–4.20 and Figure 11 16 Financial sustainability of the higher education sector in England
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Government response AI summary
The OfS is introducing an enhanced quality regulatory regime including student outcome thresholds and new registration conditions covering students’ academic experience; it is also considering how it measures value for money and is reviewing blended learning.
Read full response →
HM Treasury