This post provides an explanation of PSRBs’ interactions with the UK higher education system in respect of quality and standards, and their role in the new quality assurance arrangements from 2016/17 onwards.
‘PSRB’ stands for Professional, Statutory and Regulatory Body; a catch-all term for organisations that accredit or recognise higher education courses against set criteria, with many setting standards for entry into a profession and regulating these standards in the public interest. Universities will, by and large, want to gain accreditation for their courses wherever possible in order to increase their status and appeal to applicants; however, there can be a tension between the PSRB’s requirements and the University’s own internal quality assurance processes (which are in term informed by sector standards and expectations).
There are a significant number of PSRBs relevant to the HE sector, all of whom have their own approaches to setting and maintaining standards or conferring professional body membership status. According to a database developed by the Higher Education Better Regulation Group (HEBRG) in 2011 there were approximately 130 PSRBs actively engaging with higher education (HEBRG, 2011, 15). This figure has now risen to 175 individual PSRBs, as recorded on HESA’s Accreditation Information Table used for Key Information Sets.
Professional bodies are typically concerned with entry into a profession and supporting its members once they are in that profession. Regulatory/statutory bodies have a public interest function and will have rigorous minimum standards that any higher education institution must adhere to in order to gain and maintain accreditation status, allowing them to award protected titles. They may have their powers granted by Parliament and they may publish a register of practitioners in the public interest. Some examples are as follows:
- many PSRBs relate to the health professions such as the General Medical Council (GMC), Health and Care Professions Council (HCPC) and the Nursing and Midwifery Council (NMC). They set standards for the practice of the discipline; act as a gatekeeper to the profession by maintaining a list of members to have achieved these standards; and assess individual providers to ensure that they are delivering courses to the standards. For graduates of accredited courses their registration status may be time limited and subject to conditions such as maintenance of continued professional development (CPD).
- some PSRBs control ‘protected titles‘ (e.g. Social Worker) and may not have any other role in designating curriculum content; these are professional titles protected by law and any practitioner must be registered with the relevant professional body, thereby ensuring they have completed a course or training programme. These titles may take the form of a Licence to Practise (mandatory for professions such as being a doctor) and Chartered Status (providing a certain status but not mandatory).
- there are examples of PSRBs allowing exemptions from professional exams for those who have completed recognised courses, such as the Chartered Institute of Management Accountants (CIMA) for examinations in financial accounting.
- a large proportion of professional bodies are concerned with the monitoring and review of higher education courses to ensure that academic standards of graduates in a particular discipline meet certain standards (e.g. Geological Society of London).
- membership of professional bodies may be attached to accreditation of courses, such as the Institution of Environmental Sciences (IES) and the Chartered Society of Forensic Science.
PSRBs and quality and standards
Universities will typically view PSRB requirements as an additional layer of external regulation to consider and accommodate where possible in the design and operation of its courses. Professional bodies have a different outlook in relation to quality assurance concerned with professional standards (a compliance culture), whereas universities operate under a broader remit concerning subject knowledge and skills (academic standards), although this is increasingly aligned with the employability agenda. In addition, the wide range of PSRBs means that no single approach can be taken and processes cannot automatically be aligned.
For example, a University’s academic regulations may allow students to carry failed assessments within a certain tolerance threshold, providing that the overall module mark is above the pass mark. A PSRB in a highly regulated environment may require each and every individual assessment to be passed in order, for example, to demonstrate clinical competency. The University would typically deal with this as an exception to its standard regulations.
The main reference point for university quality assurance is the UK Quality Code, maintained by the QAA. It includes the following statement about PSRBs:
The PSRB is responsible for the standards of the professional certification… Where degree-awarding bodies choose to offer programmes which fulfil the requirements of a PSRB, the relevant PSRB will influence the design of academic programmes, and may even influence the approval, monitoring and review of programmes. However, the responsibility for the academic standards remains with the degree-awarding body which is awarding the academic qualification. (QAA, 2017, 6)
There are regular calls for greater coordination and alignment between the requirements of PSRBs and universities (both internal and external quality review activities). Such calls are reflected in the HEBRG report ‘Professional, statutory and regulatory bodies: an exploration of their engagement with higher education’, which provides context to the relationship between PSRBs and higher education, and was written prior to the design of the new quality assessment structures. Aside from noting the types and variety of PSRB, the report from 2011 made a number of recommendations including:
- improving the consistency and understanding of terminology;
- enhancing engagement between PSRBs and sector bodies such as QAA and HESA;
- increasing ‘regulatory efficiency’ for HEIs and PSRBs.
Some of these recommendations were taken-up by QAA in their review methodologies. For example, the handbook for institutional review (2015) stated that ‘Review teams will … explore how accurately information about accredited status is conveyed to students’ – the standardisation of statements relating to individual PSRB accreditations as published on the unistats website and collated via Key Information Sets was aimed at addressing the first recommendation – and ‘review teams will explore how accreditation requirements are taken into account in the setting and maintaining of standards and the quality assurance of programmes.’ (QAA, 2015, 31)
The new Quality Assessment arrangements
In 2015, HEFCE instigated a review of sector-wide quality assessment arrangements. The summary of responses to the consultation on the proposed new approach included the following statement:
348. There was an appetite for a more coordinated approach to quality assessment among some stakeholders. It was felt that if different bodies worked more closely together, with more clearly defined and distinct roles, it would make the system more coherent, and easier for different stakeholders to understand and navigate. ‘Rationalisation and streamlining of areas of perceived overlap and/or duplication in the activities of national sector bodies (e.g. the enhancement functions undertaken by QAA, HEA, Leadership Foundation of Higher Education [LFHE]; improved coordination of data and information collection, sharing and reporting between PSRBs and quality assurance bodies) would be welcomed.’ HEI, England (HEFCE, 2015, 87, my italics)
HEFCE published its ‘Revised Model for Quality Assessment’ in March 2016. This envisaged a role for PSRBs in the ‘calibration of academic output standards’, i.e. to ensure greater comparability of standards across the sector, which is being taken forward through pilot activities at the subject level, and is aimed at addressing the HEA’s reservations ‘about the effectiveness of the external examining system in safeguarding academic standards and assuring their reasonable comparability’. (HEFCE, 2016a, 35) It is unclear as yet what this pilot activity will generate.
Other PSRB involvement is less well defined and subject to the publication of further details about the various aspects of the new quality arrangements. HEFCE is interested not only in the role PSRBs may have in setting and maintaining standards at the sector level but also in the outcome of individual accreditation visits to institutions as part of their ‘intelligence gathering’ on providers within Annual Provider Review (APR): ‘We will supplement our intelligence about providers by establishing effective ways to capture the views of its students and any outcomes of PSRB activities’ (HEFCE, 2016a, 24).
Despite this, the document setting out how the APR process will operate in 2016/17 does not mention PSRB activities and only includes broad statements about HEFCE making use of its ‘understanding of the HE sector and the strategies and plans of individual providers’ (HEFCE, 2016b, 8) when formulating its initial judgements. It can therefore be assumed that HEFCE is still working-out how to incorporate PSRB activities in its process; balancing the aim of avoiding requiring institutions to submit additional evidence with finding a way of tapping into the potentially illuminating findings of PSRBs from their own review activities. Institutions may anticipate this by following the guidance put out by the Committee of University Chairs (CUC) in its Illustrative Practice Note no.3 on Academic Governance, namely by ensuring that its governing body is informed of the outcomes of PSRB accreditation visits as part of the evidence it needs to ‘submit on an annual basis assurance on the quality and standards of its HE provision’ (CUC, 2017, 3). (although this is outwith HEFCE’s own ‘intelligence gathering’)
A further area of PSRB involvement in the new quality arrangements is in the ‘one-off verification process’ contracted to QAA. This seeks to assure HEFCE (and the sector) of each provider’s own internal review processes, albeit that, as a one-off process, it will only capture the efficacy of such internal processes at a particular moment in time. As above, this process will undergo piloting during 2016/17 with full roll-out in 2017/18. In the Revised operating model it was suggested that the specification for the process will include a set of requirements that will seek to establish whether institutions’ internal review processes (amongst other aspects) ‘include employer or alumni or PSRB representation’ (HEFCE, 2016a, 22). It is not yet clear whether there will be any attention placed upon this in the process as operated by QAA.
In summary then, there have been the usual hints of closer alignment of PSRB and sector assurance requirements with a view to lightening the regulatory burden; however, operationalising this appears somewhat vague at present and no step change in aligning the scrutiny requirements of PSRBs and universities is expected. Universities are likely to continue to engage proactively with PSRBs and take a close look at the findings of their reviews.
Committee of University Chairs (CUC) (2017) Illustrative Practice Note 3: Academic Governance [online]. Available at: http://www.universitychairs.ac.uk/wp-content/uploads/2017/01/CUC-IPN3-Academic-Governance-Jan-17.pdf [Accessed 23 February 2017]
Higher Education Better Regulation Group (HEBRG) (2011) Professional, statutory and regulatory bodies: an exploration of their engagement with higher education [online]. Available at: http://www.universitiesuk.ac.uk/policy-and-analysis/reports/Pages/hebrg-professional-bodies.aspx [Accessed 23 February 2017]
Higher Education Funding Council of England (HEFCE) (2016a) Revised operating model for quality assessment [online]. Available at: http://www.hefce.ac.uk/media/HEFCE,2014/Content/Pubs/2016/201603/HEFCE2016_03.pdf [Accessed 20 January 2017]
HEFCE (2016b) Annual Provider Review [online]. Available at: http://www.hefce.ac.uk/media/HEFCE,2014/Content/Pubs/2016/201629/HEFCE2016_29.pdf [Accessed 23 February 2017]
HEFCE (2015) The future of quality assessment in higher education: Analysis of responses to Phase 1 of the quality assessment review (June 2015) Report to the Quality Assessment Review Steering Group by MRUK Research [online]. Available at: http://www.hefce.ac.uk/media/HEFCE,2014/Content/Pubs/Independentresearch/2015/The,future,of,QA,in,HE/2015_futureqainhe.pdf [Accessed 23 February 2017]
Quality Assurance Agency (QAA) (2017) UK Quality Code for Higher Education Part A: Setting and Maintaining Academic Standards [online]. Available at: http://www.qaa.ac.uk/assuring-standards-and-quality/the-quality-code/quality-code-part-a [Accessed 23 February 2017]
QAA (2015) Higher Education Review: A handbook for universities and colleges with access to funding from HEFCE or DEL undergoing review in 2015-16 [online]. Available at: http://www.qaa.ac.uk/en/Publications/Documents/HER-handbook-15.pdf [Accessed 23 February 2017]