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.