A Manifesto for Higher Education

My heart warmed to Des Freedman when I read that he hoped to 'inspire debate in staff rooms, offices and tutorials'. Perhaps at Goldsmiths they still have staff rooms and tutorials, but in the rest of the sector even the office (at least the sole-occupant office in which one could have a good debate without unduly disturbing one's colleagues) is well on the way out. We dour (and, of course, bloated) roundhead administrators like to have a Wrong and Romantic cavalier come along to lighten our lives every now and again

But the mainfesto itself was a terrible disappointment. A certain level of flabbiness is inevitable in these kinds of things, but when you can't even achieve precision in what you want abolished ('Scrapping of the National Student Survey and other forms of evaluation which perpetuate cultures of ‘customer satisfaction’ and quality control') then there isn't much hope for your positive programme. And if you are going to be Romantic in your wrongness, it also helps if fewer than half of your demands are for people to give you more money and better benefits.

Administrative bloat in universities

Via Matthew Yglesias, I've read Benjamin Ginsberg's shorter-version diatribe about the bloated administrative costs of US universities. Ginsberg has already upset Paul Greatrix by publishing an extract from his book in the Chronicle of Higher Education.

I think Yglesias' main point is a sharp one. Ginsberg seems to assume that the purpose of universities is to spend money on their professors (UK: academics). But universities respond to their incentives and the 'best' and 'most succesful' universities are usually judged to be those with the best-qualified entrants. Even in Yglesias' alternate reality where universities are judged by their success in supporting student learning, of course, it is less than obvious that student learning is maximised by increasing investment in professors (academics) at the expense of, say, IT and library staff, or student services professionals.

I'm less inclined to echo Yglesias' praise of the Ginsberg piece. On the contrary, with its leaden sarcasm, blinding non-sequiturs, and spectacularly tendentious use of anecdote (some university administrators have been guilty of fraud, therefore university administration is a fraudulent activity?) I think it is pretty shocking that a professor at a world-famous institution such as Johns Hopkins could have written such a thing. Administrative bloat is a real issue, and deserves much better treatment than this.

New members of the HEFCE Board

Three new members have joined the HEFCE Board. Two of them have NHS backgrounds and the third a private business background. Sir Alan Langlands, the HEFCE Chief Exec, also has an NHS background, so this significantly strengthens that voice on the HEFCE Board.

In one sense, this isn't surprising. HEFCE has a great deal of money tied up in training medics and other health professionals, and in undertaking health research in universities. The NHS too has a great deal of resource tied up in providing clinical placements to universities so there has always been a strong need for co-ordination. The person spec for these Board positions identified health sector experience as one of the key selection criteria.

What is more interesting is that BIS seems to have missed an opportunity to strengthen the Board with respect to its new role regulating the private sector in HE. This is an area where HEFCE's existing corporate culture and existing staff can expect to be challenged by the demands of the post-White Paper environment. Bringing in experience at Board level from another BIS quango with more relevant experience - maybe the OFT - would have seemed like an obvious move.

Restrictions on AAB equivalent qualifications 'may not be legal'

Reading my Higher, I see that they have caught up with the views I expressed nearly three months ago, and reported that the application of the AAB+ policy may result in unlawful discrimination. What the Higher still doesn't communicate very clearly, though, is that it is difficult to amend the policy to meet this problem. Even if HEFCE could devise a pan-European AAB+ equivalency matrix (which would hardly be straightforward in the time allowed - we are talking about Christmas 2011) the HESA codes do not exist to report qualifications such as the Arbitur to the level of detail required. If you haven't got the data, you can't operate the policy.

Of course if HEFCE had ample time, we could create new HESA codes, require institutions to amend their data collection systems to meet the new requirement and start collecting the data they want for the policy they have. But if you announced those codes now, institutions could use them for 2012 entry at the earliest. The resulting data would be reported to HESA in October 2013 and HEFCE could use it to inform student number caps for 2014/15. I don't think that is Mr Willetts' timetable.

David Willetts lobbying universities

David Willetts has written to a number of universities to lobby for the admission of his constituents. This strikes me as highly irregular in every possible way.

Firstly, the universities are autonomous charities not Government departments ultimately answerable to Parliament. Any MP has as much business writing on behalf of constituents to his(her) local university  as he(she) does writing to the local Rotary club.  Second, the admission of students is explicitly protected by law from political interference, so this is a particularly inappropriate matter on which to lobby. And thirdly it cannot be right for a Minister to act as a constituency MP within his(her) own departmental area as if he or she held no Ministerial responsibility. Ministers must avoid even the appearance of impropriety.  

Finally, how could this have done any good? There is no way a university could lawfully take account of the ministers' letter in its admissions process so there is no way that the constituents could have been benefitted without breaking the law.

Its difficult to avoid the conclusion that Willetts was either wholly ignorant of the principles which ought to govern his (and the universities') conduct, or wholly reckless of the consequences when he wrote those letters, and 'wholly reckless of the consequences' are not comforting words to write about a powerful man.

Headline writing

So the headline says a fifth of graduate workers earn less than school-leavers, but the story says:

Analysis shows the median hourly pay for employees educated up to around GCSE or equivalent level was £8.68, for those at A-level or equivalent £10, up to higher education but below degree level £12.60, and for those with a degree £16.10.

Have I mentioned before that I don't understand news values?

More about HEFCE's approach to deregulation

I posted on Friday about HEFCE's new approach to working with institutions on their data returns. Essentially, they are shifting from an approach where we report data to them, and they audit it if it looks suspicious towards an approach where they will review our draft data as soon as we begin to test it (which we traditionally do using the online tools HESA provide), and commence an informal audit process straight away if they see cause for concern. There is also a shift away from the idea that HEFCE works through bodies such as HESA (and the QAA is another such) which are - in theory at least - owned by the sector towards the direct management of the sector by HEFCE.

In this first phase there are three specific areas where HEFCE are directing their attention:
·       Entry qualifications and the student number control
·       Research degree student numbers
·       Numbers that may inform WP and TESS allocations.



The first of these relates to the AAB numbers in the White Paper. HEFCE will be setting student number caps for non-AAB students recruited in 2012/13 on the basis of numbers of non-AAB students reported by institutions in 2010/11. These data are due to be reported by institutions to HESA in October 2011 and then by HESA to HEFCE (following various checking processes) probably in early December 2011. This means that the earliest HEFCE could provide student number caps to the institutions would be January 2012. The UCAS deadline is 15 January, so there clearly isn't that much slack in this system.

HEFCE's problem with the AABs is that historically, the quality of entry qualifications data for mature and non-traditional students is poor. See this spreadsheet for evidence of that. Now in October 2011, institutions will have a strong incentive to under-report their AABs in order to maximise their capped numbers (then in 2012 they will fully report, so that the AABs do not count against the cap), so HEFCE could use old and poor quality data, or they could use new data where cheating has been incentivised. They have chosen to use the newest data possible which, because of the established timetable, creates major risks for them. They then manage those risks by unprecedentedly early intervention in institutions data returns.

The next two bullets show how quickly we have slid down the slippery slope this represents. For research degree student numbers, HEFCE have recently decided to do away with the separate Research Activity Survey return and just rely on the HESA data. This was their own decision, allegedly to reduce burden on institutions, but now that they are looking at the HESA data anyway, they may as well check that we are getting this one 'right'. With the WP(widening participation) and TESS(teaching enhancement and student success - also effectively widening participation) allocations there isn't even any change of policy of data use this year.

HEFCE will argue that the earlier they spot a problem, the less cost and trouble to put it right, and of course this is true. But equally, shifting from the periodic audit we have at the moment to continuous audit of live data is going to create cost and trouble.


What I think will be interesting will be to see how this more interventionist HEFCE that is emerging will relate to the private providers it will have to regulate in future. Will private providers be as submissive as the existing institutions are? Unlike the universities, who still have funding to lose, HEFCE will have weaker control over the private providers. I see more cost and more trouble down the line.

Deregulation in action

HESA and HEFCE recently sent all institutions the following guidance:

Changes to validation and data checking arrangements

We are writing to you to set out details of changes to validation and HEFCE’s involvement in data quality work during the current student collection cycle. The primary responsibility for data quality remains with institutions and heads of institutions will still be required to sign off that the data are fit for purpose.

HEFCE are increasingly using HESA data to drive funding allocations and allocate student number controls. In particular the following HEFCE publications have signalled changes in the way HESA data will be used:

·       HEFCE circular 2011/20 ‘Teaching funding and student number controls: Consultation on changes to be implemented in 2012-13’

·       HEFCE circular letter 19/2011 ‘Discontinuation of the Research Activity Survey and future arrangements for data collection’.

In addition paragraph 7 of HEFCE circular letter 21/2011 ‘HESA funding and monitoring data 2010-11: web facility’ states that HEFCE may not in future incorporate post collection amendments into its funding allocations. This change means that it is now more important than ever that the data submitted to the HESA collections are correct. In order to support this, HEFCE also made it clear in paragraph 20 of circular letter 21/2011 that they would increasingly scrutinise institutions’ outputs from the IRIS system during the data collection period. HEFCE do not intend to scrutinise the outputs produced via their web-facility or through IRIS as the result of a test commit as they recognise that institutions often use these systems with partial data. HEFCE will scrutinise data from the IRIS system for both ‘committed’ and ‘Commit passed, HIN failed’ statuses in three areas:

·       Entry qualifications and the student number control

·       Research degree student numbers

·       Numbers that may inform WP and TESS allocations.

Where HEFCE have queries on any of these areas they will raise these directly with institutions. HEFCE recognises that data submitted to HESA goes through a cycle of quality enhancement meaning that there are often significant changes to data between initial commit and final sign-off. While HEFCE will compare data between submissions in order to ensure data quality is improved or maintained HEFCE do not intend to retain copies of submissions beyond the collection cycle or use them in any audit work. HEFCE do not intend to retain copies of submissions beyond the collection cycle or use knowledge gained through the in-cycle checking to inform future audit work. We encourage institutions to continue to interact with HESA’s data collection systems in the same way as in previous years to ensure that the final data are submitted on time and are of the highest quality. HEFCE expect to be able to provide further details of the process for data scrutiny during September.

In addition to the scrutiny that HEFCE will be applying to these data, HEFCE have also asked HESA to enhance the validation of qualification on entry information as these data are likely to be critical in setting the student number control for 2012-13. Details of the enhanced validation are given in annex A. HESA expects to implement these new checks in August. HEFCE plan to announce provisional student number control limits for 2012-13 in January 2012 to help institutions to plan their recruitment. Therefore, there will be no opportunity to further correct, or enhance, data between final submission of files on 31 October 2011 and the setting of provisional control numbers. The enhanced validation and checking will focus on ensuring that the qualification on entry data are complete, as missing data are likely to have a material impact on HEFCE’s ability to control overall student numbers.

By giving notice now of the detail of these changes to validation and data checking arrangements it is expected that the existing HESA student record data collection schedule will be maintained.

 If that is mostly Greek to you, what it means in practice is that HEFCE will now be monitoring our early drafts of data submissions to see what they can learn from them, and potentially intervening if they see something that makes them concerned and/or suspicious. Those of us who work in this area are exceedingly busy right now preparing for the initial data return in September - this kind of work doesn't even stop for Clearing.

In the past, we have used HESA's validation tools to check and improve our data. This means we don't have to have the same functionality as part of our own student record systems, and therefore it saves us cost and effort.

If HEFCE are looking at our draft data - even though I am sure they wish only to be helpful to institutions - we will be obliged to develop ways of emulating the HESA functionality without putting our draft data anywhere where HEFCE might see it. After all, policies change, data are not always used for the purposes for which they were collected, millions of pounds are at stake and HEFCE have been carefully only to specify their 'intentions' not to limit what they might ultimately do with these draft data. Right here you can see additional costs coming down the line for institutions as a result of the White Paper, and HEFCE taking ever more control of the sector.

Morrisons and the University of Bradford

According to the Guardian, Morrisons is planning to fund 1,000 students onto a retail studies degree. They already have 20 students a year on BSc Business and management at the University of Bradford, although there is a link on their recruitment site currently telling me that no vacancies are available on this programme.

The funding level in the Guardian story - £4,000 per head - makes no sense to me as a full-fee level even for a Foundation Degree. However Bradford had a significant award from HEFCE's co-funded employer engagement programme and the project website lists the previous Morrisons programme as one of their success stories. HEFCE would be allocating about £1,500 per Price Group D co-funded FTE in business. I don't have the details to hand, but 2011-12 is likely to be their last opportunity to fill places funded through this route, so a knock-down price might be better than giving the grant money back to HEFCE. If the places are filled in 2011/12, then HEFCE funding will continue to flow for the next few years under the planned transitional arrangements. It is therefore possibke that Morrisons managed to get this outstanding deal because Bradford were under time pressure to reach any kind of deal at all.

So rather than the shape of things to come, I think we may be seeing the last gasp of the previous Government's policy approach playing out here.

Foundation Degree Awarding Powers for FE Colleges

Degree awarding powers come in three flavours - taught degrees (TDAP), research degrees (RDAP) and Foundation Degrees (FDAP - in effect, a subset of taught degrees). The Higher reports that two colleges have now been awarded FDAP.

I have limited direct experience of the FE sector, having worked in HE institutions that received LSC funding in previous roles. From my perspective there seem to be two broad classes of FE Colleges which want to develop and grow major HE operations. Of these, the clearest and most straightforward are the specialist institutions - primarily in Art & Design. A steady trickle of specialist FE Colleges makes the transition into the HE sector by growing their HE activity until it is more than half the total. At least one of these, the Surrey Institute of Art & Design, is now a university in its own right. The reasons for growing the HE activity are not hard to seek - HE is better funded than FE - and the additional step into the HE sector also makes very clear sense - HEFCE, with its tradition of hands-off respect for institutional management and (at least up to now) its block grant funding principle, is clearly a much better body to work for than ever the LSC was. Reading the HEFCE Board papers will show you that these transitions are still continuing.

The two institutions gaining FDAP are quite different, as they are large (in the case of NCG very large) generalist FE colleges. Other Colleges seeking FDAP that I know of, such as Havering, also fit this mould. Here there seems little chance that HE can ever be the majority activity: at Havering it is about 1,000 students out of 7,000, at NCG 3,500 out of 40,000 (and NCG is growing at the FE end), and at New College Durham it is 16% (about 1,800 out of 11,500 learners). Havering primarily has validation through the Open University, New College Durham (I think) through Leeds and Sunderland, and NCP don't seem too keen to publish their partner names, but do mention UCLan in their annual report. Newcastle College (a subsidiary of NCG) has £11,089,410 of direct HEFCE funding in 2011-12, Havering £4,351,560 and Durham £3,725,762 (which, incidentally, is just outside the top ten for HEFCE funding of FE colleges). In other words none of them is in any sense in a 'Feudal' relationship with a local university, at least as far as I can see.

Whilst Framwellgate Moor lacks a pre-existing vocational HE provider, you could hardly say the same for either Newcastle or east London. So seeking FDAP can't necessarily be taken to be either an attempt to fill a market gap or part of a strategy of institutional transformation (as in the case of the specialist colleges). I understand it as part of a strategy to protect an established revenue stream in a relatively small group of FE Colleges.

Fraud in the HE sector

I was reading this report on fraud prevention in the HE sector on the train into work this morning. It suggests that up to £1 billion could be lost to UKHE through fraud each year, and that institutions typically have limited technical capability and a weak culture of fraud prevention. The Higher covered it here, and Paul Greatrix has some rather sniffy comment here (which kind of demonstrates what they were saying about a weak culture of fraud prevention, given that Paul is a very senior manager at a very large and prestigious university, and therefore represents the absolute cutting edge in HE management thinking).

There are obvious reasons to be sniffy. The report is a pretty basic piece of work unashamedly produced by anti-fraud professionals to drum up business. Even they don't really believe the £1 billion figure - notice how it is prominent in the press release, but not actually in the report at all...

But considered as an upper bound, I don't find the figure particularly incredible. I've now worked in four institutions, and come across fraudulent practices in all of them. If you look not just at departmental administrators dipping their fingers in the petty cash, but also at student loan fraud, research grants, fraudulent data returns to HEFCE, and all the other kinds of fraud out there then you can see that the number will start to add up. Then there are those more questionable things - I've personally seen many examples of university (middle and senior) managers procuring goods and services from their friends and business contacts without even the most basic market testing required by Financial Regulations. I've no reason to think that there was out-and-out corruption involved, but sometimes the excessive price paid does make you wonder.

Of course not all these frauds cost individual universities money - and some may even gain money for the institutions that don't get caught. You can see why it is hard for institutional leaders to have a really strong anti-fraud approach when they are more-or-less consciously cheating HEFCE on their data returns.

Things have improved. When I worked at HEFCE, we always ascribed financial irregularities on the part of institutions to incompetence, whatever the evidence might indicate to the contrary. That isn't the case any longer and HEFCE at least now undertakes more rigorous audit. Still, I think there is a lot of room to improve. If I were a senior leader, I would stick my hand in my pocket for the £4,450 (plus VAT) for my fraud resilience check - at least after I had tested this price against the market, I would.

Financial Health of the Higher Education Sector

HEFCE's recent publication reporting on institution's financial forecasts has been rather misreported, it seems to me. The Higher leads with 'sector braces for fall in numbers', the Guardian with 'half of universities predict student numbers will fall'. These stories show naivety (whether feigned or real) about how these projections are prepared, and what their purpose is. As I have spent many years working with colleagues in Finance (primarily) on annual accountability returns, I'd like to provide a slightly different perspective.

Incentives for AAB applicants

I don't really understand news values. The idea that students with AAB grades might get financial incentives to attend certain universities is all over the web and papers today (see here, here, here,  here and here, just for example) although this was clearly and centrally part of the White Paper from the start. Government wants institutions to compete for these applicants, and it is natural that some will compete on service and others on price.

What is sufficiently interesting is the identity of the institutions identified as competing on price. I've seen references to Kent and Essex. If you look at the HEFCE data, then Kent has 10% AAB students, and Essex 8% (looking at UK-domiciled only, for convenience). As AAB entrants are a relatively small proportion of their intake, giving discounts may not be financially crippling for them, whereas for institutions higher up the scale (say SOAS at 57% AAB), substantial discounts might be unaffordable. I find it quite startling that institutions like Essex and Kent now seem to find themselves below the squeezed middle, and able to play for growth in their AAB numbers in consequence.