Regulation should be more independent, not less

Originally published on wonkhe

I worked at NUS for over a decade, during which we waged a sort of war on the process types that believed that student representation was all about systems and committees and surveys and literally re-presenting the (often abhorrent) views of students.

“Representation must never be seen as an end in itself”, said the quote from 70s NUS President Digby Jacks framed on the wall. “Too many union officers see it as a question of communication and merely sitting on the appropriate committee. The purpose of representation is to secure educational and social change”. Hold power to account. Don’t become it.

So imagine my surprise and horror when, towards the end of my time at NUS, an army of student officers emerged that were so in love with quality assurance frameworks that they made badges that said “Quality Geeks”. This sinister tribe were like quality code zombies, another ‘tail wagging the dog’ moment in the history of students’ unions, all because the sector has never quite been able to bring itself to love SUs for what they are.

Instead it’s preferred to require them to jump on board a series of educational bandwagons to justify funding, like the ‘key skills’ student development boom of the 80s and 90s, the citizenship and community contributions of the 90s and 00s and in the last decade or so, student engagement in quality. 

But rumours of what’s coming in the HEFCE review of quality have caused me to reassess somewhat. I think I was wrong. I think the escapades of students and students’ unions in their interactions with quality and student written submissions and institutional reviews have been an extraordinary force for good. I think the cycles and rhythms and the externality of the whole thing serve students well – the way it exposes poor attitudes and practices within institutions in the run up to audit is powerful, because the quality code and its enforcers represent, embody and describe a way to run and operate HE that is inherently in the interests of those that fund it. 

The gleeful reactions of some in the sector to the idea that the QAA might go away tell their own story. I get that someone with a clipboard might be asking difficult questions, but is it really all that bad? Exactly which part of the quality code should be optional? Which chapter should we ignore based on one’s distinctive mission? Which element is bureaucracy gone mad? Students and the taxpayers that subside them need and deserve a regulator – someone less ‘of’ the sector, not more – that starts from the position that sometimes the way to defend a system is to attack its weakest parts, both within and across institutions. 

Could HEFCE do it itself? Maybe. It would require a monumental cultural shift that it’s hard to imagine, and the rumoured plans seem to involve HEFCE as a direct player not because it would be wise or effective, but because it would be much less expensive. The problem is that if you believe the fantasy that you can do effective and internationally renowned quality assurance on little or no money, we might ask: why has the funding council been wasting students’ cash on the QAA all these years? And why, having demonstrated such poor judgement on the issue, would we now allow them to be in charge of doing things itself?

But perhaps the most terrifying of the rumoured suggestions is the central one – that university governing bodies will be made more explicitly accountable for their own institutions’ quality. Anyone that’s been near a meeting of their university governors will know just how doomed this proposal is to fail. They may be hopelessly male, pale and stale but they’re usually successful people – often nice, skilled and talented types that can nod and wink to make sure a place is run well whilst retaining its standing and reputation. 

It’s precisely this that means they’d make terrible regulators – not least because to be the sort of person that becomes a university governor, one needs to be the sort of person that benefits least from HE regulation. You likely went to university before the QAA was invented, you probably dislike regulation in your own sector, you can only understand HE through the optic of your own experience, you did pretty well out of it, and to the extent to which the university failed you, it probably never did you any harm. In your day, you adapted to the university, not the other way around. 

Lord Hutton’s report into the failings at the BBC over David Kelly put the final nail into the coffin of the BBC’s Governing Body, highlighting the deep contradictions of any system which involved governors’ role as being both champions and regulators – and for good reason. That failure of the dual role infects HEFCE and even the current incarnation of the QAA to some extent, when what’s needed within and across institutions is strong, independent regulation that operates in the student interest. I hope that someone will realise this before it’s too late.


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