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.