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 in Question 15:
a) Do you agree with the proposed risk-based approach to eligibility for DAPs and university title? Please give reasons for your answer.
b) What are your views on the options identified for validation of courses delivered by providers who do not hold DAPs
Provisional answer to part a:
I do not agree with the proposed routes to accelerated eligibility for DAPs and university title as these are likely to cause substantial reputational damage to the UK HE sector and to students at such institutions. The reason that DAPs and Titles are awarded on a permanent basis after a substantial number of hurdles is twofold:
In order to ensure that only high-quality entities are ever allowed to use the title, thereby ensuring its credibility.
In order to protect students. The withdrawal of DAPs in the years after students have graduated is likely to significantly demean their qualification in the eyes of employers. This will result in substantial reputational damage to these students.
The correct approach is, instead, to ensure that only stable, long-term, high-quality providers can access DAPs and university title. If a duly certified provider fails QA it should be subject to rigorous review to ensure that its standards are brought back up.
Provisional answer to part b:
The Green Paper does not consider that the reason that some existing institutions may not wish to validate new providers is that the new entrants are low quality and reputationally damaging. In fact, the Paper seems to assume that the only motivation that an existing institution might have for not participating in a validation exercise is an anti-competitive bent (“incumbency interest”). This could not be further from the truth. Universities validate each other at present, even though they have been forced to compete for students. Institutions are more worried about validating providers who then turn out to be malicious or fraudulent actors.
With respect to the specific options:
New legislation to allow “the Office for Students” to “itself take on a validation role, perhaps delivered through another body under contract” sounds as though it may be a deeply un-competitive process in itself. If the current complaint is that existing universities won’t validate, there are very few entities who would fulfill that contract and it leads me to wonder if this is, in fact, a closed contract for Pearson.
“With new legislation, Government could give DAPs to non-teaching bodies, with no incumbency interest, in order to widen options for validation”. This goes against the very principles of higher education based on a link between teaching and research. Without expert peer guidance, such non-teaching bodies will be merely standardised tests and will demean the title of HE. It will, instead, be just a continuation of school.
“With or without legislation, Government could approve, endorse or even contract existing bodies with their own DAPs to operate as central validating bodies, on condition that they sign up to a validation approach which explicitly promotes competition, diversity and innovation”. This last clause notwithstanding, this carries substantial risks of empowering a subset of institutions to act as kingmakers.