London Higher members have submitted the following response to the OfS consultation on regulating quality and standards in higher education 

“As a member of London Higher, the representative body for the diversity of London HE, we have numerous concerns about this consultation which are shared across the membership:

The proposed approach of this consultation, by not considering benchmarking or contextualising minimum or threshold metrics of quality and standards, risks reversing progress made in increasing access and participation for underrepresented student groups and there is a distinct risk that students from the most disadvantaged areas of London, and London’s diverse BAME communities, will be denied the opportunity of engaging in life-changing higher education opportunities.

London possesses some serious sub-regional educational inequalities that are not obvious when looking at London as a whole and we fear, under the proposed approach, that students may be denied the opportunity to study the subjects they want at the institutions of their choice. As institutions committed to opening up opportunities for London’s diverse population, we recognise the importance of retaining a varied higher education offering and believe providers should be adequately supported to continue providing opportunities and support which meet the needs of individuals.

Furthermore, by utilising the metrics chosen, the Office for Students is failing to include the student voice. There are a myriad of reasons why a learner might choose to engage in high level study and not all will have the aspiration for, or measure their success by, reaching a certain salary threshold or moving into professional employment.

We are also concerned that the proposed approach comes alarmingly close to undermining the institutional autonomy relating to standards, as enshrined in the HERA (2017), which rightly limits the powers the OfS may exercise in this space. HERA makes clear that when a Quality Body (as defined by the Act) has been designated, it is this body that should be responsible for the setting and assessment of eligible standards in higher education in England (stated in Section 27, paragraphs 2 and 3). As the QAA is the designated Quality Body under the HERA, we query the necessity for the OfS to consult with the sector before having consulted with the QAA.

Moreover, this proposal risks causing additional complications for emerging educational trends, such as how metrics would be applied to short courses or micro-credentials. With an increasing need for citizens to engage in lifelong learning, higher education institutions will develop flexible, bite-sized learning solutions to meet citizens’ upskilling needs. The risk of applying broad-brushed, absolute metrics is that they would not be adequately designed to apply to these offerings.

Finally, the timing of this consultation places undue pressure on university staff at a time when we are taking extraordinary steps to support students navigating the complexities of this pandemic and the pressures it puts on their mental health and wellbeing. Higher education institutions across London are particularly stretched at present, given their large communities of commuting students, traditionally underrepresented students and international students, who all require increased levels of support. So, any time spent on responding to this consultation ultimately detracts resource away from prioritising students’ needs.

We therefore implore you to reconsider this proposal.”