Question 1: What do effective regions for collaboration on equality of opportunity look like?
As an organisation with a longstanding role driving regional collaboration, especially in access and participation, London Higher is pleased to have the opportunity to respond to this call for evidence. We have engaged well in excess of 5000 young Londoners in intensive outreach programmes that are co-delivered with our higher education provider membership, including via dedicated programmes for some of the city’s most vulnerable groups such as care leavers, pupils outside of mainstream education, and Londoners who are at risk of becoming NEET. The work has resulted in improvements to predicted GCSEs, increased rates of HE progression, and more positive engagement with education overall. We therefore have a good understanding of what constitutes effective regional collaboration and suggest in our responses below how this could be embedded in regional access partnerships from 2026 onwards (including setting out how we can be a positive contributor to these).
1.1 Which existing regional structures does your organisation engage with most? (e.g. local authorities, combined authorities etc.)
In London Higher’s role co-delivering London Uni Connect, we engage extensively with local authorities across the capital, especially in the targeting of collaborative outreach activities and the provision of information, advice and guidance (IAG). This is especially the case in local authorities that have well-developed relationships with school leadership teams (and therefore a good understanding of local HE outreach needs) and/or that convene networks for careers advisers in their area.
At a strategic level – for instance in ensuring we take a whole-lifecycle approach to the design of outreach activities that connects with regional skills needs and labour market opportunities – we engage with the GLA and with sub-regional partnerships in London.
We have found it especially beneficial to work with other pan-London organisations such as the Association of London Directors of Children’s Services (hosted by London Councils) and their regional improvement and innovation alliance, as well as with the pan-London Children in Care Council, on the design of targeted interventions we have developed for care-experienced young Londoners.
The higher education providers in the London Higher membership for their part work very closely with local authorities on widening access initiatives. Some prioritise work in and with single boroughs whereas others report engaging with clusters of local authorities. It is important to stress that they also collaborate with supra-regional networks, for instance discipline-based, learner group-based and tariff group-specific collaborative partnerships. Regional collaboration is therefore common to all our members, but it is by no means the sole lens through which they develop and deliver collaborative outreach.
1.2 What are the opportunities for your organisation if working in defined regions to improve access to higher education?
Given that London Higher is a pan-regional sector body, it is self-evidently in our interest to widen access at a regional level, given all of our members stand to benefit. From our own experience delivering London-wide collaborative outreach over more than 15 years, including co-delivering the London arm of the most recent three national collaborative outreach programmes, we can attest first-hand to the benefits of this approach with respect to efficiency gains and increased impact. Working at a regional level can also raise profile as it allows HE providers to speak in one voice to policymakers, local stakeholders and target audiences.
There are unique and deep-seated access challenges facing the London region that a RAP (led jointly by London Higher) could meaningfully address. These include the relatively low levels of awareness of options locally for young and adult Londoners, and the complexity associated with navigating the system in the region. In a region with high relative levels of HE participation overall but significant, though hyper-localised access gaps, a highly targeted approach is needed. This is if anything compounded by the high number of providers in the region – although Londoners live in closer proximity to HE providers than may be the case in other regions, the current approach to targeting, combined with the high number of providers, results in clustering of activities around particular schools/areas, creating both hot spots (which bring their own risks of overwhelm for schools) and cold spots. These are issues that providers cannot solve individually – nor should they be expected to – whereas a regionally coordinated approach holds considerable promise.
Our members have also pointed out several opportunities, as they see them, in working with a regional access partnership (RAP), namely:
- It would build capacity for deeper and more meaningful local collaboration, as partnerships can be developed on the basis of ‘on the ground’ regional intelligence that is gathered and disseminated by the RAP. The London Uni Connect partnership has sketched out a high-level Equality of Opportunity Risk Register for London in its submission to this call for evidence. Producing and maintaining a register of this kind would be a productive role for the London RAP as it would enable HE providers in the region to prioritise their access work on the basis of its likely impact in mitigating the most pressing equality of opportunity risks;
- Relatedly, it would build the evidence base for ‘what works’ in widening access regionally, if the RAPs (as is envisaged in the call for evidence) take on a role in embedding evaluation insights across their regions;
- It would create efficiencies of scale in some areas. An example is transition to HE support. Where clusters of providers in a region are each recruiting a similar profile of student in numbers that would not, individually, justify targeted interventions such as community-building activities, the support could be pooled;
- It would mitigate against a ‘one size fits all’ approach to collaboration that disadvantages small-specialist providers with more limited capacity. The regional ‘connector’ role envisaged for the RAPs would leave them well positioned to identify roles within collaborative initiatives that play to providers’ strengths and are proportionate to their size and resources;
- It would free up time and resource in some areas where it is envisaged the RAPs will offer outreach or IAG support across a region, allowing providers to discontinue these activities.
1.3 What should the regional groupings be called? (e.g. Regional access partnerships, Equality of opportunity partnerships etc.)
We are supportive of the groupings being called regional access partnerships.
Question 2: What are your thoughts on the proposed regions?
2.1 What are the barriers for your organisation to working in the defined regions to improve access to higher education?
The main barriers to regional access coordination identified by our members are:
- Agreeing common target groups, given that institutions in London use a wide range of targeting metrics (IMD, ACORN, POLAR/TUNDRA, FSM, ABCS);
- Coordinating efforts to engage cold spots. Under-served groups and areas in the capital are highly localised and this can result in an uneven spread of activity across London, with some schools being overwhelmed with offers of support. The RAP can play an important corrective role here, but the density of HE providers in the London region and the geographical spread of institutions means concentration of activity in certain areas is unavoidable.
- The low number of access targets included in current APPs regionally. This is not to say that providers in London are not committed to delivering access initiatives (including collaboratively); rather that, if the sole purpose of the RAPs is to drive coordination around formal APP targets, many providers would have no formal mechanism for engaging with the London RAP. Alternatively, if the function of the RAPs is instead – or in addition – to improve the coordination of wider contributions to HE access, for instance through attainment-raising work, consideration must be given to the fact that providers have differing levels of resource to contribute and therefore any collaboration must be proportionate as well as playing to providers’ strengths. It would be advantageous for the OfS to introduce flexibility in the regulatory framework here, permitting a risks-based approach (as applies to the regulation of quality and outcomes across the sector) to minimise regulatory burden. This would be in line with the OfS’ own promise to make use of the ‘sandbox of regulation’ more broadly to facilitate innovative approaches to access and participation.
- Potential tension between regionally-focussed activity and existing collaborative partnerships. Small-specialist providers in our membership, especially those who support distinct access pathways (e.g. into performance-based disciplines or into medical/veterinary science), already collaborate with a partner network specific to these pathways and therefore may not be able to contribute much to regional efforts if these are not in some way complementary to the existing work. For this reason, we also advocate the OfS using as broad a definition of collaboration as possible in how it defines and monitors collaborative access activity, so that a wide range of contributions outside of co-delivery of projects (such as providing venue space, academic expertise or equivalent) can be captured as positive examples of collaboration.
2.2 Should the Greater London region be broken down further? What should the areas in London be?
We are strongly in favour of retaining the proposed Greater London region. The current London Uni Connect partnership is a confederated structure, which has the advantage of retaining local expertise and networks without adding additional administrative costs. It also provides a single point of contact for the devolved administration and other external partners.
Many of our members recruit high numbers of commuter students and target commuter students via their access work. At the same time, this is a group that is likely to experience risks to equality of access to higher education. Given the high levels of in-region mobility of these students it would be helpful to formulate regional approaches to supporting them.
The only other established administrative structures in London are the four sub-regional partnerships, however these do not map neatly onto our members’ existing local partnerships. In any case, for the reasons we have outlined above, we feel it is neither practical nor desirable to break down the London region further.
2.3 Which region would your organisation fit well in and why? Does this differ from the proposals?
Our members are broadly comfortable with the suggested allocations in the proposed regional structures, however they stressed to us that boundaries between the Greater London RAP (region 13) and regions 9, 10, 11 and 14 are porous. Several of our members have campuses in both London and another region (e.g. the Royal Veterinary College’s Hertfordshire campus; the University of Greenwich’s Medway campus) or, in the case of Royal Holloway, University of London, straddle two regions in their outreach work.
Question 3: How could a region best collaborate to improve equality of opportunity in access to higher education?
The regional access partnerships programme must be set up in a way that works for all regions. This means creating a national framework in place that allows for a high degree of regional variation in how partnerships choose to address access-stage equality of opportunity risks in their area. In this respect, we welcome the proposal that all RAPs focus on the core aspects of IAG provision, acting as a regional ‘connector’, and delivering early, persistent and consistent engagement with the highest-priority groups regionally, with discretion to shape the precise spread of, and approach to, these activities according to local need.
Within London specifically, the collaborative infrastructure will be serving a region characterized by high overall levels of HE participation alongside high levels of inequality in HE access between groups and places within the capital. It will also need to mobilise collaboration between a very high number of schools, colleges and HE providers – much more so than in any other proposed region. This means, of the three proposed outputs, the connector role is perhaps most significant as we can expect higher levels of fragmentation and duplication in provider-level outreach work and a weaker alignment to regional economic needs than in other regions. Our members have stressed to us the value a RAP in London would have for them in ‘decluttering’ the outreach landscape – that is, focusing on streamlining existing work as opposed to creating many new collaborative delivery obligations for HEIs in the region.
3.1 How could regional partnerships be governed or organised?
We recommend introducing greater flexibility into the current organisational model for Uni Connect, in which partnerships must be led by a single HE provider. There would be considerable advantages, given the size of the proposed regions, to a consortium or multi-partner approach, in which an HE provider serves as one of the partnership leads alongside another place-based organisation with an active role in supporting collaborative access work in that area. This might be a sector body or other regional partner. This would preserve sector ownership of the programme, whilst also embedding partnerships in relevant regional networks and improving alignment with mayoral/combined authorities, councils, schools and colleges.
In London, we are uniquely placed to play this role. As the HE membership body for the region, with a pan-London remit and strong ties with local government and schools across the capital, our involvement in leading the RAP here would ensure city-wide buy-in from key partners both in and adjacent to London HE. The same would apply in other proposed regions such as the North East (Universities for North East England), and East and North Yorkshire and Lincolnshire/West and South Yorkshire (Yorkshire Universities).
It would also be beneficial to retain elements of the ‘hub and spoke’ models in place across some of the current Uni Connect partnerships. In London, the confederated model we utilize currently allows for wide geographical coverage of a very large region whilst delegating responsibility for certain areas of work – for instance, relationships with schools in specific sub-regions, and partnerships with FE and sixth form colleges, to network partners with the requisite local knowledge and expertise.
3.2 How could regional partnerships work together to identify the best ways to target their effort?
It is important that the mechanism used for identifying regional priorities is agile and low-burden for providers to access, so that partnerships are able to continually refine their approach and respond to equality of opportunity risks that are, by their nature, fluid. London Uni Connect and London Higher already play a convening role in the capital, facilitating decision making through dedicated, pan-regional special interest groups and communities of practice, and this model would lend itself well to the RAP.
In London, we therefore recommend close coordination with the GLA, the London Careers Hubs and local authorities, in line with London Uni Connect’s current approach, but also more integrated working between the RAP and London Higher. This would serve to platform the RAP’s work with external stakeholders, coordinate more effectively with HE providers at all levels, and support with the targeting and directing of work towards systematically under-served groups.
In the London context particularly, the RAP must ‘declutter’ the existing collaborative outreach landscape through its role identifying cold spots and duplication of effort. This means a highly selective and strategic approach to delivering new projects and a focus on rolling intelligence-sharing between the RAP and the region’s HE providers.
3.3 How could each region be coordinated or led?
We recommend that the OfS permits a dual-leadership model for the RAPs, in which an HE provider and sector-aligned body, like London Higher in London’s case, jointly provide strategic oversight and coordination (provided this is also endorsed by other providers in the region).
Question 4: One option for leadership and coordination would be working with an independent regional coordinator identified by the OfS to facilitate collaboration in each region. What are your thoughts on this approach?
It is unclear what this proposal would mean in practice, however we are of the view that facilitating collaboration should be a core function of the RAPs themselves, and as such, additional independent coordination would not be necessary.
If, as we have suggested in our response to Q3, the RAPs could be led jointly (where appropriate) by an HE provider and another organisation with a regional remit, like London Higher in London, this would ensure an impartial and inclusive approach to collaboration. Including consultation with the relevant RAP(s) in future regulatory guidance on the preparation of Access and Participation Plans would also drive up regional collaboration.
Question 5: What support would be required for your organisation to work collaboratively across a defined region to improve equality of opportunity in access to higher education?
5.1 How best could the OfS support collaboration?
In our view it will be necessary for the OfS to incentivise collaboration. This is because of financial and resource constraints across the HE sector, meaning that providers are less likely to enter into collaborative agreements (which by their nature carry greater risks).
Incentives could be financial (though we recognise offering this will be challenging in the current financial environment), or regulatory, for instance introducing a lighter-touch, risks-based approach to regulation of collaborative access work. Another possible approach would be to require RAPs, as opposed to HE providers, to evaluate collaborative APP projects and report on progress to the OfS, reducing the reporting burden and evaluation spend on the part of providers.
There is an established precedent for Uni Connect partnerships co-funding priority collaborative outreach initiatives, and whilst this could be continued by the RAPs in a limited capacity, the number of providers in the London region means demand would inevitably outweigh supply. It could be more fruitful to task RAPs with securing additional funding for collaborative activities from sources such as business and local/regional government. Corporate CSR funding, regional R&D funding allocations such as the Local Innovation Partnerships Fund, and the Adult Education Budget (where it is devolved, and where local flexibilities exist) all represent viable funding streams that would have the added benefit of incentivising bidders for collaborative access project support to develop their projects around local skills and economic growth priorities. London Higher has experience of doing this in our current role in the London Uni Connect partnership, having secured funding from local councils, charitable associations and grassroots funders for outreach initiatives.
London Higher has noted the proposals in the recent spending review to increase funding flows to skills and equalities work in the HE sector through a levy on international student fees. This is a funding mechanism that we would wish to see the OfS rule out at the earliest possible opportunity. Seeking to create financial headroom in this area by destabilising the sector’s finances in another is a zero-sum logic that we oppose in the strongest possible terms.
5.2 What structures would need to be preserved or in place for your organisation to collaborate effectively?
The 29 current Uni Connect partnerships have developed considerable expertise and regional infrastructure over the duration of the programme. We recommend that the OfS gives further consideration to how this can be retained and built on by the RAPs. Standing up a network of regional partnerships requires enormous time investment, and it would hinder the ability of the RAPs to deliver on their stated aims if this process had to be repeated in its entirety. The OfS may wish to explore how the tendering process for the RAPs can encourage the active involvement of current Uni Connect partnerships in any future England-wide collaborative outreach programme.
Question 6: What are your views on addressing regional risks to equality of opportunity in your access and participation plan?
6.1 What would it look like to include regional collaboration on access in your APP?
As we have outlined in our response to Q1, a straightforward mechanism through which providers could demonstrate collaborative regional commitments in their APPs would be through giving regard to a regional Equality of Opportunity Risk Register, as the London Uni Connect partnership has proposed in its submission to this call for evidence.
The advantage of this approach would be that it is provider-led, in that it would ask institutions to give regard to the regional EORR in assessing equality risks in their own setting. Providers would likewise retain the discretion to set out risk mitigation strategies that are proportionate to their size, strengths and resources.
6.2 What are your views on APP submissions to the OfS being done in waves according to region?
We agree in principle with this proposal, though as we have noted in our answer to Q2, there are existing collaborations in place that span multiple regions. It will be important not to destabilise these (especially where they are delivering impact) by making changes to submission timeframes.
6.3 What are your views on shared accountability for collaborative targets or delivery of other collaborative provisions in APPs? How could this be managed?
We refer here to our answer to Q5. We recommend an approach that shares accountability for collaborative initiatives across providers and the relevant RAP(s), for instance by restricting any regulation of providers to the monitoring of financial/resourcing commitments and tasking RAPs with evaluation.
Question 7: What are your views on a regional coordinator identified by the OfS providing feedback to us on levels of collaboration reflected in APPs?
We agree with the principle of monitoring levels of collaboration but suggest the RAPs themselves are best placed to do this. If the OfS were to develop a standard reporting structure and outcomes framework for use nationally, building on the theory of change that has already been developed, then it would be possible to form evidence-based views on the performance of the programme nationally (and of the relative performance of regional partnerships) even allowing for a high degree of differentiation between regional operating models, processes and activities.


