Reading between the lines: changes to external reference points

Higher education has rarely known a steady state but the current uncertainty regarding the regulatory landscape is significant.

In this blog post I am considering possible changes to the external reference points used for quality assurance, based on what is said and left unsaid in both the Green Paper and HEFCE’s proposals for a ‘Revised operating model for quality assessment’. Taking both documents on face value there is to be a dismantling of some key pillars of the ‘academic infrastructure’ and a greater reliance placed on other forms of regulation. This, principally, means a diminished role for the UK Quality Code, which “sets out the Expectations that all UK higher education providers are required to meet”. It has several stated purposes including “to safeguard the academic standards of UK higher education”.

HEFCE, who say that their proposed new approach “is underpinned by the view that ‘quality’ is an inescapable part of an overall approach to regulation”, (source: ‘HEFCE report: Revised operating model for quality assessment‘, point 9.) make the following statements in their proposals regarding the Quality Code:

…baseline regulatory requirements will include the following elements: … b. Specific elements of the current UK-wide Quality Code (HEFCE, 2016: 5)

We are discussing with the sector representative bodies how [the baseline regulatory requirements] could be developed as the governance mechanism for determining the ongoing development of the Quality Code, as an important and shared UK-wide reference point. (HEFCE, 2016: 16)

These statements give the impression that the code will be retained and subject to renewal. However, a subsequent statement in the document paints a different picture:

In England, Wales and Northern Ireland we expect to include the ‘Expectations’ of the Quality Code as an element of the baseline regulatory requirements. We do not wish to continue to use the ‘Indicators’ of the code, as many respondents to the June 2015 consultation believed that these detailed elements prompted an unhelpfully burdensome and formulaic approach to review by both providers and review teams (HEFCE, 2016: 16)

Many people would not mourn the loss of the Quality Code for this reason. The QAA, which perhaps in previous years would have robustly defended its approach, has more recently recognised a shift in the sector’s view with their response to the Green Paper advocating “A revised, improved and simplified Quality Code, which evolves with UK higher education, should remain owned by the sector and maintained by QAA.” Its potential downgrading by HEFCE to a list of Expectations would, however mean the loss of some important details and safeguards. An example from Part B, Chapter 7 on External Examining:

The Expectation and, on the face of it, all that would be retained is:

Higher education providers make scrupulous use of external examiners.

The indicators in this chapter that may be ‘unhelpfully burdensome’ include the remit of the role, the person specification, details about what constitutes a conflict of interest, limits on the duration of appointment, the necessity to provide information to students and what to do when external examiners have a concern.

As HEFCE is looking to further strengthen the role of external examiners, in particular their part in maintaining academic standards, then it is hard to believe that these details will be discarded and I would expect a similar list would need to be re-created in time to help define the role.

This isn’t to say that the Quality Code shouldn’t be refined or replaced and that although the Introduction to the Code states that it shouldn’t be used as a checklist, this has been the reality for some institutional reviews. In conflating all types of regulation into one process however, there is a ‘baby-out-with-the-bath water’ type of risk and I would also suggest that many aspects would have to be re-created in another form.

The Government’s Green Paper meanwhile, ‘Fulfilling our potential: teaching excellence, social mobility and student choice’ uses similar rhetoric to HEFCE, such as this statement in a section titled ‘Simplifying the higher education architecture’:

“Reduce the regulatory and administrative cost and burden, adopting a risk-based approach while improving accountability to students” (BIS, 2016: 57).

The Government intends to achieve this via the consolidation of powers in one regulator, the Office for Students (OfS), although the details in the document are sketchy: – “OfS would be required to publish a risk based regulatory framework limiting monitoring for low risk providers”. (BIS, 2016: 60)

Both documents are silent on some other external reference points, for example the Subject Benchmark Statements and Qualification Characteristics. Although both documents are also ‘green’ with many details still to be worked-out this is a valid point due to the comments quoted above about the Quality Code and also the retention of one specific aspect, the FHEQs, as stated in the HEFCE proposals: “We will continue to use the Framework for Higher Education Qualifications as a clear written expression of academic output standards.” (HEFCE, 2016: 7)

The potential loss or diminishing role for the external reference points will mean a more prominent role for other types of regulation. As commented by Smita Jamdar at the QAA conference 2016, the HE sector needs to think about “the regulatory landscape and how its relationship with the regulators is likely to change. Here the change is likely to be most keenly felt by what is commonly described as the traditional sector, which has long had the relative luxury of co-regulation.” (Jamdar, 2016: 3-4) It is certainly the case that market interventionists the CMA have a much more prominent place in the TEF and HEFCE proposals than does the Quality Code.


Higher Education Funding Council of England (HEFCE) (2016) Revised operating model for quality assessment [online]. Available at:,2014/Content/Pubs/2016/201603/HEFCE2016_03.pdf [Accessed 27 April 2016]

Department for Business, Innovation & Skills (BIS) (2016) Fulfilling our potential: Teaching Excellence, Social Mobility and Student Choice [online] Available at: [Accessed 27 April 2016]

JAMDAR, S. 2016. The top five things higher education should think about. QAA Annual Conference, 14 April 2016, University of Birmingham. Available at:) [Accessed 27 April 2016]

Quality Assurance Agency (QAA) UK Quality Code for Higher Education [online] Available at: [Accessed 26 April 2016]

Quality Assurance Agency (QAA) Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice – QAA’s Response [online] Available at: [Accessed 24 April 2016]


2 thoughts on “Reading between the lines: changes to external reference points

  1. Pingback: Updates from the ARC Quality network and QAA Quality Matters (December 2016) | Exit Velocity

  2. Pingback: Finding a new chapter and verse | Exit Velocity

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