This post is part of an ongoing series where I intend to develop my full personal (not institutional) response to the HE Green Paper. Comments are welcome to refine this.
The Green Paper asks (as question 6):
Do you agree with the proposed approach, including timing, assessment panels and process? Please give reasons for your answer
I have several concerns about the proposed approach, timings, panels and processes.
The Green Paper states that “The TEF needs to be simple in its processes, but robust in its judgements”. This makes an underlying assumption that robust judgements of a complex ecosystem can be made through simple processes. In fact, this is challenging since as the Paper notes, “because there is no single direct measure of teaching excellence, we will need to rely on proxy information”. At the same time, Green Paper explicitly says that the challenge that has faced league tables in appraising teaching is that “there have only been imperfect proxy measures to date”. Once again, I highlight that the Green Paper does not contain the necessary information for us to respond properly to its processes and I reiterate the call that another consultation be held after the technical consultation has been completed.
This then feeds into issues of timing. Other parts of the Green Paper propose an accelerated entry pathway for alternative providers of three years. Yet here the award is proposed to be for a five-year period. This seems a strange mis-alignment in determining an acceptable period over which institutions must demonstrate their worth.
The rolling cycle of assessment poses challenges of comparability. As a purely metrics-based approach will be impossible, an element of subjective judgement must also enter into the equation. The Green Paper contains no information on how this process is to normalized/standardized to ensure cross-institutional comparability.
Given the focus on student choice and competitiveness driving down costs, it is also contradictory that to “anticipate that institutions would be expected to bear the cost of the TEF assessment process”. This, essentially, will be funded by students’ fees, wasting valuable money that could be put into enhancing education. There may also be situations where smaller, or even alternative, providers do not have the resources to submit a TEF application. Considering that TEF is a top-down, centralised and (in all but name) mandated system of audit, it is fairly obscene to propose that those subject to its judgements (and who may actually be penalised by its results) should be expected to fund it. If government wants to audit and control teaching provision at universities, it should contribute to it financially, which barely happens since the erosion of the teaching grant. As the Paper itself acknowledges, “the income of nearly all of these providers is no longer principally from direct grant”. As it stands, this is asking a sector to pay for its own regulation.
With respect to the panel process, I have some significant concerns. The inclusion of “employer/professional representatives” is curious because why should employers or professional representatives know anything about teaching? The only rationale for their inclusion can be to ensure that industry can have a say in university teaching. But why should “employers” have more of a say than anyone else who pays taxes? What about interested laypeople? This is clearly a politically motivated decision that renders the assertion that “TEF assessments will be independent from Government” meaningless.
I am also unclear on the proposed timings of the convening of panels. The Paper states that “In time, it is envisaged that panels will be convened for each discipline”. Is it the case, then, that subject-specific panels will not be implemented early on in the process? Again, this leads me to believe that the whole process is far too rushed. How could a physics expert appraise teaching in drama?