TEF Green Paper response - Reading University Students' Union

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice - Consultation You can reply to this consultation online at: https://bisgovuk.citizenspace.com/he/fulfilling-our-potential A copy of this response form is available at: https://www.gov.uk/government/consultations/higher-education-teachingexcellence-social-mobility-and-student-choice The Department may, in accordance with the Code of Practice on Access to Government Information, make available, on public request, individual responses.

The closing date for this consultation is 15/01/2016

Name: Niall Hamilton Organisation (if applicable): Reading University Students’ Union Address: Reading University Students’ Union Whiteknights Campus Reading Berkshire RG6 6AZ Email Address: educationofficer@reading.ac.uk

Please return completed forms to: Alison Haines Higher Education Directorate Department for Business, Innovation and Skills Level 1, 2 St Paul’s Place 125 Norfolk Street Sheffield S1 2FJ email:

consultation.he@bis.gsi.gov.uk

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Please tick the box that best describes you as a respondent to this consultation.

Alternative higher education provider (with designated courses) Alternative higher education provider (no designated courses) Awarding organisation Business/Employer Central government Charity or social enterprise Further Education College Higher Education Institution Individual (Please describe any particular relevant interest; parent, student, teaching staff etc.)

Legal representative Local Government Professional Body Representative Body Research Council Trade union or staff association X

Other (please describe) Students’ Union

Public sector equality duty Question 1: a) What are your views on the potential equality impacts of the proposals and other plans in this consultation?

RUSU believes that there are many proposals in this paper that will have a

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

hugely detrimental effect on a number of student groups. Linking the TEF to an increase in tuition fees will have a negative effect on the access students from poorer backgrounds have to Higher Education. With more and more of our students finding debt one to be one of their largest concerns while at university, we believe increasing the £9,000 threshold will result in even fewer working class students‟ to pursue academia. We already know that poorer students are more likely to commute to university and pursue shorter courses to avoid debt. Limiting options for these students is the opposite of equality. It‟s also been seen that student parents, BME students and Muslim students are even more deterred from pursuing higher education due to debt.

RUSU also believes that an increase in tuition fees under the term „excellence‟ will cause working class students to no longer strive for excellence, fostering a culture that excellence is derived from how much you can afford to pay. Removal of maintenance grants and the cutting of the DSA alongside increasing tuition fees will extend the barriers equality act protected groups face. RUSU strongly believes that the TEF and tuition fees need to be separated if we are to move towards a higher education system with more equality.

Addressing the proposals of the TEF link strongly to employment metrics; RUSU believes teaching excellence should not be measured using employment data in relation to particular graduate salaries. With pay gaps already existing in society for women, BME and disabled people, Higher Education Institutions that champion and support these students will be punished. This proposal will only result in promoting institutions that already have high employment figures, causing their employment to get pushed higher and other instructions to fall. This will cause a rift between WP universities for which there are little opportunities for them to bridge.

RUSU strongly believes employment data has no place in the measure of Teaching Excellence. It should be removed to ensure women, BME and disabled students are not unfairly penalised in accessing Higher Education.

While we are receptive to the outlined proposals surrounding provider exit and student protection, we have concerns that this still is not enough.

Some students will not have the option to change universities due to circumstantial factors. This will, again, disproportionately affect disabled, BME and parent students.

b) Are there any equality impacts that we have not considered? ☒ Yes

☐ No

Please provide any further relevant evidence.

☐ Not sure

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

We believe that the government needs to consider the needs of LGBT+, religious, parent, pregnant, part-time and mature students more fully. The fact that these students have not been mentioned is extremely worrying and shows the government‟s idea of what student populations look like to be grossly misrepresentative. These students already face various barriers to education. They also have differing ideas as to what excellent teaching may look like and are worthy of consultation. We also believe when looking at equality the government should be proactive in supporting diverse lecturers.

More diverse academic teams will create a more diverse learning experience, thus improving equality.

Teaching Excellence Framework (TEF) (Part A: Chapters 1-3) Question 2: How can information from the TEF be used to better inform student and employer decision making? Please quantify these benefits as far as you can.

RUSU believes there are already many available resources that inform student choice and allow prospective students an informed choice when applying to university; newspaper league tables, Unistats, the NSS, Open Days, university fairs and UCAS. The TEF will not add anything that isn‟t already readily available.

We also believe it is naive to assume that every student would engage with the TEF in the same way. Not every student attends university for the same reason and certain elements of a university education appeal to different students in different ways. Students from varying social backgrounds will also engage with the TEF in varying ways.

We also believe that students are generally more focused on their course league tables over institutional league tables; differentiation of the TEF will be uninteresting to students until it can be compared at departmental levels.

RUSU believes that the TEF should not be focused around employer decision making but should be designed with the sole intention of benefitting students and informing their decisions. Employers will still benefit from the implementation of the TEF when making recruitment decisions, but the design of the TEF should not have employer benefit as its focal point.

We would also like to question how the TEF will create engagement with international students. We feel not enough has been done to ensure they can engage with the framework.

Question 3: Do you agree that the ambition for TEF should be that it is open to all HE providers, all disciplines, all modes of delivery and all levels? ☐ Yes

☐ No

Please give reasons for your answers.

☒ Not sure

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

RUSU believes that teaching quality is important at all levels of education.

However, it‟s important that the metrics employed for measuring each degree should be differentiated to reflect how that discipline operates. For example, it would be unfair to measure an MPharm Pharmacy course in the same way that you would a BA (Hons) Fine Art Degree. We would like to see more done to show differentiation between degrees.

We would also like to highlight the number of students that will not be represented in the TEF. Transnational education students will not be able to influence a TEF score as they don‟t partake in NSS or DLHE. RUSU strongly supports an increase in transnational education and believes the TEF will cause a reduction in institutions participating in this type of activity. Why waste money educating students at a high quality when they won‟t be able to increase your TEF score?

Question 4: Where relevant, should an approved Access Agreement be a prerequisite for a TEF award? What other mechanism might be used for different types of providers?

Yes. RUSU believes that Access Agreements have been proven to be an excellent tool for institutions to improve access. We believe that is essential that the TEF includes this as a pre-requisite. Higher Education should be open to anyone who is able to achieve and desires to do so. We support the government‟s commitment to widening participation and improving access to higher education.

Question 5: Do you agree with the proposals on: a) what would constitute a ‘successful’ QA review ☐ Yes

☐ No

☐ Not sure

b) the incentives that should be open to alternative providers for the first year of the TEF ☐ Yes

☒ No

☐ Not sure

c) the proposal to move to differentiated levels of TEF from year two? ☐ Yes

☒ No

☐ Not sure

Please give reasons for your answer.

We believe that institutions will participate in the TEF regardless of financial incentives due to the pure reputational incentive.

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Whilst we understand that the TEF is a pointless activity if it can‟t be used to make differentiations between institutions, we object to the creation of a link between TEF scores and tuition fees.

RUSU believes that differentiating levels of TEF, and using this as a tool for employers, means the TEF will become self-fulfilling prophecy. If one of the metrics of the TEF is employment, and employers are only going to select graduates from higher TEF levels, it will just reaffirm those institutions in the higher levels of TEF. It will cause a gap to form between highly employable institutions and others; a gap which will increase in size as TEF becomes common practice.

Question 6: Do you agree with the proposed approach to TEF assessments on Timing? ☐ Yes

☐ No

☒ Not sure

Assessment panels? ☐ Yes

☒ No

☐ Not sure

☐ No

☒ Not sure

and process? ☐ Yes

Please give reasons for your answer.

We believe that the proposal for the TEF to be implemented quickly demonstrates the government rushing this paper through without having thought about potential consequences. We believe that this will damage the effectiveness and robust nature of the TEF. We also believe that assessment panels must include students. We believe that partnerships between academics and students are vital to maintain the integrity of the process. We strongly object to employers sitting on these panels.

We believe that the compliance of consumer law is important but should be dealt with by a panel that is more qualified to deal with this process.

We agree with our institution that the government needs to publish a transparent and detailed process report to show standardisation across the sector.

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Question 7: How can we minimise any administrative burdens on institutions?

Please provide any evidence relating to the potential administrative costs and benefits to institutions of the proposals set out in this document.

RUSU believe that when dealing with such a transformative change to Higher Education we should not be thinking about this as a priority. If we are going to implement the TEF we are going to need it to be fit for purpose, not rely on poor metrics and not be striving for minimisation of burdens. This conversation should happen later.

Question 8: Do you agree with the proposed approach to differentiation and award as TEF develops over time? ☐ Yes

☒ No

☐ Not sure

Please give reasons for your answer.

RUSU believes the metrics suggested will not provide the “clear and robust differentiation within institutions as it develops over time” They will only serve to create a blurred idea of what constitutes “excellence” amongst students, employers and academics. We do believe that the TEF will not offer enough information to students or employers that will allow them to make informed decisions but in fact do the opposite. The TEF will standardise the education sector and will completely stifle excellence and creativity.

To begin with, not every student looks at a university education in the same way. There is no uniform process that students undertake when selecting a university. Some may attend open days; some may rate opportunities on campus highly, others may make decisions based on course content. This variety cannot be easily represented through TEF and will not be shown using the currently proposed metrics. Different students will interpret TEF results in different ways and will not be able to look critically at the TEF as it uses processes that students applying for their first undergraduate will not be accustomed to. Only students with access to professional advice or with relations that have gone through the system will stand a chance of understanding the TEF. Students from WP groups who may not have that privilege will make even less informed decisions.

Question 9: Do you agree with the proposed approach to incentives for the different types of provider? ☐ Yes

☒ No

Please give reasons for your answer.

☐ Not sure

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

We understand an increase in nominal fees from £9,000 to £12,000 won‟t change how much students will pay back unless they are earning over £100,000. However, that is only if the method of payback remains the same.

However we are aware that the method of pay back is open to change. We have already seen this with students who started university in 2012. While entering University with the expectation that they will pay back the loans in a specific way, we‟ve seen a change. This demonstrates the fluidity of how students will be expected to pay back their tuition loans. With the proposal of increased tuition we will need to see a robust proposal which lays out how repayment will take place after graduation.

We also believe that the differentiation of fees compared to „Teaching Quality‟ will only succeed in increasing the elitism of universities. Students from WP backgrounds will be less likely to go to top universities under the expectation of having to pay more back. We believe this will restrict access to Russell Group universities for a number of students from working class backgrounds.

Students will only see this at face value; they will sacrifice a place at a better university for the opportunity of getting a „cheaper‟ degree. This matched with employers looking at TEF ranking will see students from working class backgrounds becoming less employable whilst richer students will benefit from better employment opportunities.

Differentiating fees goes completely against the narrative of widening participation in higher education present in this Green Paper.

Question 10: Do you agree with the focus on teaching quality, learning environment, student outcomes and learning gain? ☒ Yes

☐ No

☐ Not sure

Please give reasons for your answer.

RUSU agrees that these are good measures of quality of teaching; however we believe that the TEF will drive focus away from improvement of these. Using HEFCE funded research the NUS did; the comprehensive Guide to Learning & Teaching, we believe the following metrics cover what excellent teaching encompasses: Excellent teaching happens at disciplinary level, but institutions are responsible for creating an environment in which it can thrive.

Excellent teaching is inclusive enables all students to learn and be successful.

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Excellent teaching is a narrow frame, what students care about is excellent learning – which includes teaching, independent study, assessment and a physical and intellectual environment that stimulates this.

Excellent teaching is enabled and supported to take risks and to innovate Excellent teaching happens in a team – drawing on knowledge and expertise of a wide range of people, including students.

RUSU believes that teaching quality should take into account student‟s opinions. RUSU also believes that the NSS should not be used as the only option for students to voice opinions on quality of teaching. We believe that the NSS is not an accurate representation of a student‟s time at university and that three or more years of Teaching and Learning cannot be summarised with any sense of accuracy within a 23 question survey.

RUSU supports the focus of more training of HE academics in quality teaching, although we question the treatment of postgraduate research students and the availability of training for them. How will they be supported and encouraged to teach?

Although RUSU appreciates employment is a huge part of why students come to university, we disagree this should be considered a measure of quality of teaching. We believe too many external factors effect employment after graduation. The term „it‟s not who you know but what you know‟ springs to mind. Factors such as the student‟s background, social capital, socioeconomic history and even location can alter this data. We also acknowledge that this will cause disproportionate harm to those studying Arts and Humanities degrees, which historically have a lower graduate employment rate than other vocational degrees.

RUSU supports the focus of „learning gain‟ as a measure of Teaching Excellence and our Education and Welfare Officers are working with the University in developing suitable measures of this concept.

Question 11: Do you agree with the proposed approach to the evidence used to make TEF assessments - common metrics derived from the national databases supported by evidence from the provider? ☐ Yes

☒ No

☐ Not sure

Please give reasons for your answer.

We do not believe student outcomes should be a monitor of Teaching Excellence. There are far too many variant factors involved in student employment post-university. We do however believe how employable a student is should be taken into account and perhaps should be monitored.

This should be done through measuring the number of opportunities that students have whilst at university. Monitor the output and engagement of

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

careers services, the number of volunteering opportunities, the number of placements students can take and the opportunities universities provide for their students to study abroad.

This data also doesn‟t take into account how satisfied students are with their graduate jobs. The current metrics do not take into account how relevant the employment is to their degree, whether a student came to university to get a job or because they were interested in learning about a particular discipline.

This data will have a negatively disproportionate impact on students in the Arts and Humanities, where their jobs are perhaps not directly linked to their degree or a career.

Moving on to student satisfaction; we believe the NSS alone is not an accurate measure of a student experience. Condensing three or more years of study into nine teaching and learning questions (which can be filled out rapidly) does not result in accurate data. We believe there needs to be, at the minimum, a measure of satisfaction for every year of study. This will allow a far better insight into how students see teaching quality. The student voice should be one of the loudest in this process. This will be what prospective students will really want to know before applying to university. We are also worried with regards to how easily this data can be manipulated by institutions.

Relying on this data we believe will lead to institutions seeking out „quick wins‟ to increase their NSS scores in the short-term. Higher Education should be seen under a far longer term scope. Linking this to TEF will only increase this culture.

Social mobility and widening participation (Part A: Chapter 4) Question 12: a) Do you agree with the proposals to further improve access and success for students from disadvantaged backgrounds and black and minority ethnic (BME) backgrounds? ☒ Yes

☐ No

☐ Not sure

Please give reasons for your answer.

We also believe some more work could be done at an earlier stage in education. But we are satisfied that the government is taking BME attainment gaps seriously.

b) Do you agree that the Office for Students should have the power to set targets where providers are failing to make progress? ☐ Yes

☐ No

☒ Not sure

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Please give reasons for your answer.

c) What other groups or measures should the Government consider?

Monitor the progression, attrition and attainment of LGBT+, women, disabled, mature, international, part-time and parent students. These are all groups that face barriers to the current way Higher Education is run, through non-diverse curriculums, lack of representation and support within universities.

Question 13: a) What potential benefits for decision and policy making in relation to improving access might arise from additional data being available?

RUSU does not support the proposal of sharing data collected about students without the explicit consent of students, and without full transparency of what this data will be used for.

b) What additional administrative burdens might this place on organisations? If additional costs are expected to be associated with this, please quantify them.

Opening up the sector to new providers (Part B: Chapter 1) Question 14: Do you agree with the proposed single route into the higher education sector? ☐ Yes

☐ No

☐ Not sure

Please give reasons for your answer, including information quantifying how the potential cost of entry would change as a result of these proposals.

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Question 15: a) Do you agree with the proposed risk-based approach to eligibility for degree awarding powers (DAPs) and university title? ☐ Yes

☐ No

☐ Not sure

Please give reasons for your answer.

b) What are your views on the options identified for validation of courses delivered by providers who do not hold DAPs?

Question 16: Do you agree with the proposed immediate actions intended to speed up entry? ☐ Yes

☐ No

☐ Not sure

Please give reasons for your answer.

Provider exit and student protection (Part B: Chapter 2) Question 17: Do you agree with the proposal to introduce a requirement for all providers to have contingency arrangements to support students in the event that their course cannot be completed? ☒ Yes

☐ No

☐ Not sure

Please give reasons for your answer, including evidence on the costs and benefits associated with having a contingency plan in place? Please quantify these costs where possible.

RUSU strongly supports the proposal that providers must have rigorous contingency arrangements to support students over courses that cannot be

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

completed. Students need to be secure in their learning environment, achieved through factors such as: academic and welfare support, having secure accommodation and being made to feel welcome and included. Therefore having appropriate mechanisms in place to protect these students when they cannot complete their course is of paramount importance.

There needs to be fair and accessible policies and practices governing course closure and changes. Students need to be made aware of the options available to them when course changes occur and they must be informed in plenty of time. Students who undergo significant change need to be put at ease that the provision for them will remain satisfactory. Students from widening participation backgrounds will also be disproportionately affected by course changes; in particular students with caring responsibilities, as they will not be able to transfer courses as easily.

It is imperative that the Students‟ Union is involved with any course changes and the subsequent consultation with students over these changes. Together with the University, the Students‟ Union has a duty of care for these students, especially as their circumstances are more unique and potentially harmful to their student experience. Therefore, it is crucial that student wellbeing remains at the heart of any changes that occur to courses and will be supported by consistent contingency plans implemented by the University.

Simplifying the higher education architecture (Part C) Question 18: a) Do you agree with the proposed changes to the higher education architecture? ☐ Yes

☐ No

☒ Not sure

Please give reasons for your answer.

While we believe the merger of OFFA and HEFCE into OfS will benefit students, RUSU is sceptical of how the OfS will represent students. We question how an office for students can exist without the input of students.

We would recommend collaboration with NUS or other student representative bodies in the decision making aspects of OfS from the start.

b) To what extent should the Office for Students (OfS) have the power to contract out its functions to separate bodies? ☐ Fully

☐ Partially

☐ Not at all

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

c) If you agree, which functions should the OfS be able to contract out?

d) What are your views on the proposed options for allocating Teaching Grant?

Option 1: BIS Ministers set strategic priorities and BIS officials determine formula. ☐ Agree

☒ Disagree

☐ Not sure

Option 2: BIS Minister sets strategic priorities and allocation responsibilities divested to OfS ☐ Agree

☒ Disagree

☐ Not sure

Please give reasons for your answer, We disagree with the centralisation of this procedure and that it should not be led by government at such a close level. OfS should have the power to set targets without the constant intervention of government.

Question 19: Do you agree with the proposal for a single, transparent and light touch regulatory framework for every higher education provider? ☐ Yes

☐ No

☐ Not sure

Please give reasons for your answer, including how the proposed framework would change the burden on providers. Please quantify the benefits and/or costs where possible.

RUSU believes this question is far too vague for us to respond.

Question 20: What steps could be taken to increase the transparency of student unions and strengthen unions’ accountability to their student members?

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

RUSU welcomes the reference to the importance of Students‟ Unions in this Green Paper. Students‟ Unions are vital to consider in any changes made to Higher Education.

The core of Students‟ Unions is the ethos that we are run „by students for students‟. This is a powerful narrative and we make sure it is present throughout all the work we do. We hold regular consultations with students in regards to academic and welfare related issues, we provide opportunities for students as an autonomous body, we support and represent our membership and we make sure that we are accountable and transparent in all of our processes.

Our governance is determined in democratic elections open to all students, and we provide numerous opportunities for students to both determine and scrutinise our work and priorities as a Union. Our governance is accountable to students through all student meetings, scrutiny panels and constant, open conversations between elected representatives and students.

Change within students‟ unions must carry on coming from the student membership, not external pressures. We implore the government to be more specific in who should carry out the „steps‟ referenced in the question. To maintain the integrity of our work it must always come from our membership, not the government.

Question 21: a) Do you agree with the proposed duties and powers of the Office for Students? ☒ Yes

☐ No

☐ Not sure

Please give reasons for your answer.

RUSU believes that autonomy is key, and decentralisation of control is vital for the success of OfS. We hope the merger does not however reduce the important focus HEFCE puts onto research into Higher Education. We believe that postgraduate students must also be considered when setting targets. In light of PG loans being passed, we believe protection of PG fees against disproportionate inflation is important.

b) Do you agree with the proposed subscription funding model? ☐ Yes

☐ No

Please give reasons for your answer.

☐ Not sure

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Question 22: a) Do you agree with the proposed powers for OfS and the Secretary of State to manage risk? ☐ Yes

☐ No

☐ Not sure

Please give reasons for your answer.

b) What safeguards for providers should be considered to limit the use of such powers?

Question 23: Do you agree with the proposed deregulatory measures? ☐ Yes

☐ No

☐ Not sure

Please give reasons for your answer, including how the proposals would change the burden on providers. Please quantify the benefits and/or costs where possible.

Reducing complexity and bureaucracy in research funding (Part D) Question 24: In light of the proposed changes to the institutional framework for higher education, and the forthcoming Nurse Review, what are your views on the future design of the institutional research landscape?

Question 25: a) What safeguards would you want to see in place in the event that dual funding was operated within a single organisation?

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

b) Would you favour a degree of hypothecation to ensure that dual funding streams, along with their distinctive characteristics, could not be changed by that organisation? ☐ Yes

☐ No

☐ Not sure

Please give reasons for your answer

Question 26: What are the benefits of the REF to a) your institution and b) to the wider sector? How can we ensure they are preserved?

Question 27: How would you suggest the burden of REF exercises is reduced?

Question 28: How could the data infrastructure underpinning research information management be improved?

Do you have any other comments that might aid the consultation process as a whole?

Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice

Please use this space for any general comments that you may have, comments on the layout of this consultation would also be welcomed.

Fundamentally the metrics being currently proposed for the TEF are not fit for purpose. The TEF will not monitor teaching excellence and will be too easily manipulated.

Furthermore the linking of tuition fees to the TEF will only cause an elitist movement though out academia cutting out and alienating huge numbers of young people from study. Students are not products for the government to sell to employers. Students are not a unified consumer. Further marketization of higher education will only stifle the academic excellence this country is known for.

We are grateful the government has sort out comprehensive consultation before rushing this through and hope all responses are treated equally.

Thank you for your views on this consultation.

Thank you for taking the time to let us have your views. We do not intend to acknowledge receipt of individual responses unless you tick the box below.

Please acknowledge this reply ☒ At BIS we carry out our research on many different topics and consultations. As your views are valuable to us, would it be okay if we were to contact you again from time to time either for research or to send through consultation documents? ☒Yes BIS/15/623/RF

� No