The OfS’ decision to launch a consultation on proposals to raise the bar on quality and standards in higher education is welcome. However, we’re concerned that oversights in OfS’s preferred metrics to measure the quality of a course may put those pursuing higher education vocationally or via flexible or lifelong learning at a disadvantage.

Outlined below are some of the ways in which we believe the OfS’ proposals can be improved.

Defining quality and standards in higher education

We agree, in principle, with the proposed definition of quality and standards. However, further consideration needs to be given to their proposed use and applicability. For example, we take issue with the specific focus on “progress to managerial and professional employment”. It is not clear what exactly this means, how these terms will be defined, and what will happen to those taking high-quality higher education courses that do not lead to professional and managerial jobs.

Student progression to such roles is affected by so many factors and we fear that such a metric may unintentionally reduce access to certain courses.

Assessing student outcomes

We query the baseline metric of assessing students’ outcomes based on them gaining ‘managerial and professional jobs’ after leaving education (11c). There are several reasons we do not support the proposed use of this metric in assessments:

• It may disadvantage students who take courses which do not immediately equip them for professional or managerial roles upon graduation. Whilst we support the delivery of effective pathways, care should be given not to reduce access for students to alternative courses with different outcome objectives beyond professional/managerial employment.
• Students’ progression to such positions is subject to several other factors beyond their attainment at higher education. 
• It’s unclear how this metric would impact those pursuing self-employment, as well as international students. 
• To ensure as seamless transferability as possible, we believe metrics should be as easily understood and measurable as possible between employers and higher education establishments.

Defined path of three to four years study

We are concerned that the consultation assumes that the average student has a defined path of three to four years study. We believe this impact negatively on those accessing higher education via lifelong learning, flexible learning or apprenticeships.

Proportional regulation of quality and standards

There are several areas within the proposals that may create new regulatory requirements on providers, such as a revision of the Teaching Excellence Framework and the National Student Survey. In order to fully understand how the proposals impact on the proportionality of regulations on providers, greater clarity on these points is needed.