Article previously published in May 2022, by Jana Moehren (Quality Assurance and Compliance Advisor)
What is happening?
In the last blog in November 2021 about changes to the external quality assurance of higher education in England, the conditions for registration of the regulator for Higher Education in England, the Office for Students (OfS) were introduced.
As a reminder, since 2018, the OfS regulates higher education for English providers which must comply with seven conditions of registration. Changes have now been made to the B conditions which regulate the minimum requirements for quality, standards and student outcomes that courses have to comply with. Since 1 May 2022, most of these B conditions are now in place and institutions are expected to comply with all of them from then on. In fact, the OfS have just announced that they have launched the first investigations into whether business and management courses at eight institutions comply with the new conditions.
So, what are the changes?
There are six B conditions that set out the minimum baseline requirements for existing providers. They cover all types of higher education from level 4-8, no matter the form or location of delivery, nor the type of student (for example, international students, part-time students, distance-learning students, apprentices, research students). The conditions also are applied to courses for students who are awarded degrees by Kent, but are neither registered nor taught here, for example students at validated institutions.
Conditions B1, B2, B4 and B5 are now in force. The OfS is expected to publish the final version of condition B3 in June. Some of the requirements are new, some strengthen an expectation previously expressed by the OfS.
The main areas of change are:
B1 Academic experience
This condition set out the expectation for courses: they have to be is up to date, challenging, coherent and effectively delivered. We will need to be able to evidence that course design meets these expectations in course approvals and amendments, and monitor this consistently.
Another new expectation is that all students achieve sufficient English language skills, and that these skills are adequately assessed. All courses need to be reviewed to ensure they comply with this expectation and include English language skills and assessment. For example, students will need to be penalised for poor grammar or spelling. There are, of course, exceptions where adjustments need to be made to comply with the Equality Act 2010, but these exceptions are to be very limited in scope. The only other exception to this requirement is when courses aim at teaching a language than English, for example language courses. In practice, this means that we will need to review all of our degrees and ensure that English language proficiency is captured and assessed.
B2 Resources, support and student engagement
This condition sets out expectations for staff resources, physical and digital resources. For all courses, we have to ensure that we have sufficient, and sufficiently qualified, staff. The university will also have to ensure that all necessary resources, such as hardware and software, or for example quiet places to study, are available to all students. In practice, this will mean that in course design, approval and when amending courses, we need to evidence that all of these expectations will be met. Condition B2 also defines the support that students should receive, specifically non-academic support. For example, student support should be based on and tailored to the prior attainment of a cohort of student – so where there is a greater need of students, the university should provide more support. Student engagement in quality assurance at all levels is also part of this condition. It strengthens the expectation for effective student engagement and contribution of students, individually and as a group, to university governance and quality assurance. The university will have to consider if the current ways of engaging students are sufficient and effective.
B4 Assessment and awards
The condition contains an expectation that students are assessed effectively and reliably, and that academic regulation ensure that awards are credible. We will need to ensure that assessments actually assess what they intend to check . This will include an assessment of grammar, spelling and punctuation in the use of English. We also need to evidence that assessments are designed to avoid opportunities for academic misconduct. Systematic feedback to students before the final assessment also needs to be ensure for all modules. To ensure compliance with this condition, we will need to set out our expectations for assessment and assessment design and ensure that they allow for a consistent awarding of degrees at the right standards (which are defined below in condition B5). Part of this assurance will be through external expertise.
B5 Sector-recognised standards
The sector-recognised standards are clearly defined by the OfS and include qualification level descriptors which are already incorporated into our Credit Framework. A new part of the sector-recognised standards are classification descriptors for level 6. They set out the knowledge, skills and competences that students should have acquired when achieving different grades from fail up to first. In practice, this means that our grading criteria for level 6 must be aligned with the classification descriptors. A recent review has found that our grading criteria do not consistently specify the appropriate classifications. By not doing so, we risk contribution to grade inflation – this is what the OfS understands to be a higher number of upper second and first class degrees awarded by an institution than they would have expected, and where these awards are not explained by certain student-based criteria. Finally, it is worth noting that while there are numerical thresholds for condition B3, there are no quantitative indicators for any of the other requirements in the conditions, so the university will have to insure itself at all times that there is no risk in breaching any of them.
What about the other conditions?
A consultation on condition B3 has concluded and we are waiting for the final result. Essentially, B3 defines thresholds which institutions must meet for student continuation, completion and progression. This table shows the expected minimum outcomes for different types of courses.
B6 is the condition that specifies participation in the Teaching Excellence Framework (TEF). This has also been subject to consultation, but we will need to make a submission to TEF in early 2023. TEF measures excellence beyond and above the minimum requirements defined by the other conditions. In quality assurance terms this means that we have to ensure that our processes and procedures enable continuous enhancement.
What is Kent doing to comply with the new conditions?
We have identified five main priorities to amend and add to our current regulations by the beginning of the next academic year to ensure that Kent continues to meet the conditions of registrations. In the first instance, English language assessment and level 6 classification descriptors will have to be consistently implemented. Additionally, over the summer a dedicated task & finish group of academics and professional services staff, we will look at our Code of Practice and our procedures for assessment and feedback, course and module approval, course and module amendments and monitoring and periodic reviews.
If you would like to contribute to the QA Blog or get involved in this ongoing policy work, please get in touch with a member of the QA team via QACO@kent.ac.uk.