TEF and the government’s PGT blind spot

The Higher Education Green Paper, Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice (Link) has received a significant amount of coverage and I would refer readers to the Wonkhe site for an excellent range of articles. What has struck me about the Green Paper the most is how the thinking outlined in the paper, including the proposals for the TEF in their current green state and the behaviour changes in universities that they’re aimed at effecting, is so plainly focused on undergraduates.

Of course this comes as no surprise if you take the view that the primary purpose of the TEF is to create a differentiated fee regime, with undergraduate (Home/EU) fees one of the principal levers available to the government to influence universities.

At HEFCE’s annual meeting on Thursday Quintin McKellar, Vice-Chancellor of the University Hertfordshire was quoted by Aaron Porter as saying “isn’t it curious that the Green Paper seeks to fix items not broken. But doesn’t address PT & PG which are” Link.

The only reference to postgraduates in the 105-page document is the signal that ‘In time, we would also like [the] TEF to be open to all levels in the Framework for Higher Education Qualifications (undergraduate and taught postgraduate). We are exploring the implications of this further, and some of these proposals may only be brought forward with legislative change.’ (BIS, 21)

The problem the government has is that not only are the existing metrics focused on undergraduates but the rhetoric and incentives outlined in the Green Paper are as well. It is difficult to see what steps they may take to include taught postgraduate provision in future iterations of the TEF.


The Green Paper notes that the ‘criteria and metrics used for [the] TEF will develop over time’ and that this would be ‘the subject of a technical consultation in 2016’ (BIS, 23). Three proposed common metrics are cited, though, which are illustrative:

  1. Employment/destination from the Destination of Leavers from Higher Education (DLHE) survey (this does cover all levels of study)
  2. Retention/continuation from HESA UK Performance Indicators (this looks at first degree students)
  3. Student satisfaction in the NSS (final year undergraduates only)

DLHE, although not without its flaws, is readily available as a source of data for postgraduates with just under a quarter of survey responses in 2013/14 made by postgraduate leavers[1]. This is the one measure that could be used immediately. A retention measure for item 2 would require an extension of the non-continuation status collection to cover postgraduate courses; however the rhetoric in Chapter 4 of the Green Paper only speaks of those ‘entering higher education’ (‘an ambition to doubling the proportion of people from disadvantaged backgrounds entering higher education by the end of this Parliament from 2009 levels.’ (BIS, 36)). Furthermore, the actions taken or proposed by the government are undergraduate-specific: e.g. lifting the student number cap (for undergraduate recruitment) and UCAS being asked to look into implementing a ‘name blind’ application process from September 2017. (NB: despite it’s wish to corner the postgraduate market, UCAS operates primarily in the undergraduate admissions application process and postgraduate applications are usually made directly to institutions)

The NSS is of course undergraduate only and its postgraduate counterpart, PTES, is an optional survey. The nature of PTES may be attractive to the TEF designers considering metrics for postgraduate study nonetheless, as it delves a little deeper into areas such as engagement with studies, skills development and teaching and learning by asking questions like: ‘The course is intellectually stimulating’ and ‘As a result of the course I am more confident about independent learning’. With NSS 2.0 expected to include questions on enhancement, might PTES, a survey based on similar enhancement surveys used in other countries, become mandatory?


Here I’m included both the carrot and stick incentives.

There are to be pre-conditions for participation in the TEF, including observing the Competition and Markets Authority (CMA)’s published guidance on obligations under consumer law (BIS, 27). This guidance is aimed at undergraduate students, not postgraduates: ‘Consumer protection law will generally apply to the relationship between HE providers and prospective and current undergraduate students’ (CMA, 3), which means it is likely to affect institutions’ practices relating to undergraduates provision first and foremost.

Although not a pre-requisite, the Green Paper includes a strong push for Grade Point Average as an alternative to the current degree classification system. This is the government’s attempt to answer employers’ calls for a results system that enables them to differentiate job applicants more easily. There is no mention of postgraduate qualifications or grading systems here, which may in part be due to the more specialist nature of PGT courses and smaller student numbers lessening the need for change from an employer’s perspective.

Finally, as I’ve mentioned, the primary incentive for universities is the opportunity to raise undergraduate (Home/EU) fees in line with inflation. Postgraduate course fees are unregulated with universities free to charge what they want. According to government figures published in a consultation on Support for Postgraduate Study (link), the mean average fee for a PGT course is £8,010 and the median average is £6,061 (the difference may indicate that a few significantly high course fees are dragging the mean upwards). This government consultation from March 2015 indicated that an income contingent loans system would be introduced and details on this are likely in the forthcoming Autumn Statement. The document says that “The Government does not intend to use the introduction of this loan to increase regulation on the higher education sector, and wishes to keep the introduction of new regulation to a minimum”. Although this was published by the previous government and Universities Minister and cannot therefore be held-up as a definitive statement, it is unlikely that there will be regulatory intervention in the area of postgraduate fees.

My scepticism then about opening up the TEF to include postgraduate study is because the incentives for universities (as conceived by the government) are not there and the regulatory architecture is missing. The only hint of a possibility that this may change is in the statement containing the single reference to taught postgraduate, with further exploratory work possibly leading to legislative change.

[1] Source: HESA data https://www.hesa.ac.uk/sfr217 (see Table 2)


Competition & Markets Authority (CMA) (2015) Advice for higher education providers and undergraduate students – Information on your consumer law obligations/rights [online] Available at: https://www.gov.uk/government/collections/higher-education-consumer-law-advice-for-providers-and-students [Accessed 28 September 2015]

Department for Business, Innovation & Skills (BIS) (2015) Fulfilling our potential: Teaching Excellence, Social Mobility and Student Choice [online] Available at: https://www.gov.uk/government/collections/higher-education-consumer-law-advice-for-providers-and-students [Accessed 16 November 2015]


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