London Higher has today, 10 November 2022, submitted its response to the Office for Students (OfS) consultation on a new approach to regulating access and participation in English higher education (HE). The submission has been informed and shaped by 36 of our HE provider members, who shared their views on the consultation and its underlying proposals with us at an online roundtable event on 20 October 2022.
The consultation marks an important inflection point in the HE sector’s access and participation work, refocusing it around key ‘risks to equality of opportunity in higher education’ identified by the OfS via an Equality of Opportunity Risk Register (EORR).
The consultation could pave the way for a genuine step-change in rates of progression to HE, and success in it, for students from widening access backgrounds. However, it is imperative that the OfS provides more detail on how proposals such as the EORR, or partnering in new ways with schools to raise pre-16 attainment, will work in practice.
London, with its dense school landscape and unique set of equality risk factors (set out in London Higher’s recent briefing), will make the process of developing new Access and Participation Plans that deliver on the consultation’s core proposals especially complex. It is therefore all the more important that the OfS clearly communicates its expectations of providers.
We now call on the OfS to:
- Publish a draft version of the EORR as soon as possible, so that providers can understand the likely risks they will have to address in their APPs;
- Clarify its process for prioritizing risks. The consultation refers to provider-level, sector-level, geographic/regional risks, and emerging risks, but gives no indication as to what balance of commitments it expects to see in APPs when it comes to addressing these differing levels of risk. If this is a decision for providers themselves, the OfS should make that clear;
- Confirm continued funding of the Uni Connect programme to enable it to provide the strategic, England-wide infrastructure that is needed for the sector to effectively contribute to raising pre-16 attainment in schools. Uni Connect partnerships have over five years of experience in building relationships with schools and identifying ‘cold spots’ in school-HE collaboration. Losing this expertise would not just make impossible any meaningful intervention by HE in school standards; it would mean the entire next APP cycle will be spent trying to recover lost capacity. This is entirely at odds with the OfS’ ambitions for raising attainment.
With providers set to commence work on APPs in a matter of months, the OfS must urgently provide direction and clarification to the sector. Otherwise, the period 2024-28 risks becoming a missed opportunity for the ‘new approach’ to access and participation to deliver meaningful change.
Read our full response to the consultation on our website.