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The ABCs of APPs

This blog has been written by Dr Richard Boffey, Head of London Higher’s AccessHE division.

Through its widening participation division, AccessHE, London Higher has an important role to play in supporting our members in adapting to changes in how equality of opportunity in English higher education is regulated. This function has become all the more important in recent years following the Office for Students’ (OfS) introduction of a new regulatory framework for access and participation in 2022-23. 

The so-called Equality of Opportunity Risk Register (EORR) sitting at the heart of this change in regulatory approach is intended as a point of orientation for HE providers as they develop new Access and Participation Plans (APPs). The risks in the register span the student lifecycle and touch on themes such as knowledge and skills prior to entering HE, academic support in HE, and progression into graduate work. Providers must give regard to EORR risks in their APPs and set out how they will mitigate these for the student groups most likely to be affected. A small number of ‘wave 1’ plans have already been approved by the OfS, with most plans – and, crucially, virtually all plans from London HEIs – to follow in ‘wave 2’, in summer 2024. 

London’s higher education sector is therefore hard at work in developing bold and ambitious access and participation commitments. But what does ‘bold and ambitious’ look like with respect to an access and participation plan? And how can we enshrine meaningful collaboration in the plans that are currently being developed? To help our members answer these questions, London Higher’s AccessHE division ran a workshop in October that provided a space for our members to discuss and share approaches to the crafting of APPs. We were joined by the OfS’ APP team to hear first-hand from the regulator about their expectations for plans. 

The session crystallised a number of common areas of concern and challenge but also opportunity. These are themes that London Higher members will be grappling with over the coming period but apply equally to all institutions preparing APPs as part of wave 2, whether they are in London or not. This blog summarises three priority considerations for London and for the HE sector at large. 

Firstly, providers should not feel straitjacketed by the EORR. Many of the questions our members had coming into the session – questions which are echoed across the sector – related to how best to frame a plan around the EORR risks. How many risks should be addressed? How is a risk-based approach best reconciled to the data available to providers, which may often say less about emerging equality of opportunity risks to an individual and more about visible (historic) equality of opportunity gaps at a group level? There were some concerns that the EORR could prove awkward to work with, as the 12 risks it contains do not neatly map onto internal university structures nor onto the ways in which institutions report on and manage their widening participation.  

But our discussion, which included some wave 1 providers with experience of the APP approval process, helped to illustrate there is no one ‘right’ approach to using the EORR. An APP can be written around discrete risks, but if it makes more sense to take a different approach – for instance, structuring a plan around a pre-existing institutional strategy – then providers should feel able to pursue that. The EORR is, ultimately, one of several tools available in the drafting of APPs, not the only tool. 

Secondly, providers would be well advised to consider how the micro and macro levels of their APPs relate to one another. Our workshop identified possible tensions here, for example when it comes to evaluation. The OfS asks providers to submit evaluation strategies as part of their APPs, with measurable objectives at both a strategic and an intervention level. But as our members discerned, an overarching strategic objective in a given area may not necessarily use the same indicator for measuring impact as the projects sitting within it. Weaving groups of projects together into a coherent APP narrative is therefore easier said than done and is an area in which providers would benefit from greater peer support and guidance. 

Finally, there is obvious appetite for collaboration between providers in setting access and participation plans, but there are some barriers standing in the way of this. Judging by discussion at our workshop, these relate in the main to financial constraints and the logistical complexity of setting up partnerships. The OfS can of course only do so much to influence internal decisions within providers about access and participation spend, but if stretched budgets are causing institutions to think twice about undertaking joint projects with collaborative targets on the grounds of risk, then it is only right to ask whether the right incentives for collaboration are in place across the sector. 

These are just three of the many themes surfacing as the sector gears up for wave 2 of APP submissions. We intend to continue discussions with the London Higher membership – not least at our upcoming AccessHE Conference on 30 November – as the development of plans is a far from straightforward process. The more that process can entail dialogue and discussion with peers across the sector, the better.     

You can sign up for the AccessHE Conference, Collaboration Matters, taking place at the University of East London on 30 November, via Eventbrite.