Consultation
Published 12 December 2024
Consultation on OfS strategy for 2025 to 2030
Published 12 December 2024
Annex A: Further information on our proposals
- We set out our proposed strategy for the OfS from 2025 to 2030 above.
- Our proposed strategy is grounded in the current context and reflects the challenges and opportunities we anticipate that institutions and students will encounter in the coming years. This section describes some of the features of the current context which are pertinent to our strategic choices. These include the funding environment, technological change, cost of living pressures and changing labour market patterns.
- In place of the ‘mission’ included in our previous strategy, we propose a re-articulated purpose that more clearly sets out priority areas of work for the next strategy period. This remains aligned with the OfS’s functions set out in HERA.
- We propose three priority areas to help us focus our regulatory activity where we can most effectively serve the interests of students. These are quality, the wider student interest, and sector resilience.
- Equality of opportunity remains a priority for the OfS and is integral to everything we do. To reflect this, we have integrated work to promote equality of opportunity throughout priority areas, rather than constructing equality of opportunity as a standalone priority area or goal. We believe this approach will ensure equality of opportunity objectives shape our work in the round and mitigate the risk that work to promote equality of opportunity becomes isolated and detached from core activity.
- In proposing to focus our activities in these areas, we have had regard to our general duties under section 2 of HERA. In particular we have had regard to: (1) the need to promote quality and greater choice and opportunities for students (under section 2(1)(b)); (2) the need to promote equality of opportunity in connection with access to and participation in higher education (under section 2(1)(e)); and (3) the duty to monitor and report on financial sustainability (under section 68). In addition, we have noted that HERA requires the OfS to have in place a mandatory access and participation plan condition for certain institutions (section 12) and that it identifies quality and standards as an area we may in particular regulate using our conditions (section 13). HERA further sets out our duties and powers, and other provisions, in respect of quality and standards (sections 23 to 28) and access and participation (sections 29 to 37).
- In developing this strategy, we conducted a programme of engagement and insight gathering to help us understand the student interest. We heard that a quality education is core to what students want and expect from higher education. While most provision in the higher education sector in England is already excellent, this is not universal, and where quality falls short the risk to students can be significant. For example, students who do not benefit from high quality provision are less likely to complete their course and progress to graduate level employment. These risks are exacerbated by the financial challenges much of the higher education sector will face in the coming years, which are likely to require institutions to make difficult decisions about their offer to students. We believe that in this context, working with the sector to protect the right of all students from all backgrounds to a high quality education is especially important.
- We also heard that students’ expectations of higher education extend beyond their academic experiences and outcomes. Their wider experiences of higher education are affected by the way they are treated by their institutions and the non-academic services and support they have access to. Our proposed strategy seeks to promote positive experiences for students through a focus both on the contractual relationship between students and institutions and the non-academic features of higher education that shape a students’ ability to benefit from higher education.
- Beyond activity designed to improve the contractual relationship between students and institutions, we propose exploratory activity to help us understand the extent to which students’ reasonable expectations of higher education are being met. We believe that students’ reasonable expectations reflect their contractual entitlements, the informal promises and impressions communicated by institutions, and wider, societal expectations of what higher education should deliver.
- Evidence suggests that the wider student experience is becoming more challenging and that disadvantaged students and students from underrepresented groups feel these challenges most acutely. In our proposed strategy, we identify accommodation, mental health, harassment and sexual misconduct, and cost of living pressures as features of higher education which are pertinent to the wider student interest. This list reflects what we heard during pre-consultation engagement but does not represent a definitive set of priorities.
- Our proposed strategy sets out an approach to exploring some of the ways we might serve the wider student interest in these areas, including ways that do not require direct regulation. There may also be times when we take direct regulatory action, where possible and appropriate (for example, in relation to harassment and sexual misconduct).
- OfS analysis and engagement with sector representatives has made clear that the resilience of the higher education sector will be tested over the next strategy period. ‘Sector resilience’, our third priority area, is a prerequisite to delivering high quality higher education and positive wider experiences for students. Within this priority area we consider financial sustainability and effective management and governance.
- These priority areas connect to our primary regulatory objectives in the following ways. This is a non-exhaustive list.
- Objective 1 – Promoting high quality higher education and equality of opportunity will support students from all backgrounds to access, succeed in and progress from higher education.
- Objective 2 – Promoting high quality higher education while prioritising the wider student interest will enable more students to receive – and benefit from – quality academic experiences.
- Objective 3 – As a result of promoting high quality higher education and enabling more students to engage and benefit from this, more students will progress into further study or employment.
- Objective 4 – Promoting sector resilience will support the ability of higher education providers to deliver high quality academic experiences and positive wider experiences, leading to positive outcomes and value for money for students.
- Within priority areas, we set out our goals for this strategy period. These goals are the specific outcomes we will seek to achieve from 2025 to 2030. Across goals, we will work with students, institutions, government and other partners as necessary to achieve our aims.
- In the category of quality, we propose two goals. The first is to ensure that ‘students receive a high quality education that has a significant and enduring positive impact on their lives and careers, delivered by institutions that continue to improve the quality of their courses.’ This conveys our strategic focus on continuous improvement as the most effective means of ensuring the greatest number of students, from all backgrounds, benefit from high quality higher education. It signals our commitment to ensuring students benefit from quality academic experiences while they study and continue to derive value from their experiences of higher education into the future.
- The second is to ensure that ‘prospective students have a range of high quality options and are well equipped to exercise informed choice about what, when, where and how they study.’ This advances equality of opportunity because innovative and flexible provision, together with diversity of choice, enables students to choose and access higher education that meets their needs. It signals our commitment to supporting innovative approaches and fostering a dynamic sector that adapts as the wider environment and students’ needs change.
- To support delivery of this strategic goal we commit to ensuring our regulatory tests are appropriately calibrated to protect students and taxpayers while facilitating efficient entry to the regulated sector for high quality institutions. In activity described under strategic goal six, we commit to ensuring that initial and ongoing regulatory tests are appropriately calibrated to protect students and taxpayers, recognising the level of risk inherent in different business models. In both cases, our commitment is to ensure that our regulation enables innovation without exposing students and taxpayers to risks arising from low quality or unsustainable provision.
- In the category of the wider student interest, we propose two goals. The first is to work with institutions and students to ensure that ‘students receive the higher education experiences they were promised.’ This recognises the importance of students’ rights as consumers and identifies consumer rights as a mechanism for improving students’ experiences of higher education, both academically and more broadly.
- The second is to work with institutions and students to ensure that ‘students benefit from rich and rewarding wider environments that help them to make the most of their time in higher education.’ This recognises that experiences beyond the classroom can have a significant effect on students’ ability to engage with and benefit from higher education. It will help advance equality of opportunity by drawing attention to the importance of promoting environments that support all students to succeed.
- In the category of sector resilience, we propose two goals. The first is to work with institutions, government and others to ensure that ‘a financially resilient sector delivers high quality higher education and student choice in the context of constrained finances.’ This recognises that the financial challenges many higher education institutions are facing will interact with the student interest in a range of ways. Market exits not only compromise the experiences of directly affected students but also erode student choice, while financial challenges are also likely to affect the courses institutions offer and how provision is delivered. This goal therefore recognises that a financially resilient sector is a prerequisite to high quality higher education and positive wider experiences for all students.
- The second is to work with institutions, government and others to ensure that ‘effectively governed institutions successfully navigate an environment of increased financial and strategic risk, enabling students to reap the benefits of higher education while giving taxpayers confidence that public funding is used appropriately.’ This identifies the importance of effective management and governance as a means of minimising institutions’ exposure to financial risk in a challenging environment. By ensuring institutions are equipped to manage financial risks and other risks that may emerge, our approach will protect students’ interests and ensure the appropriate use of public funds.
- Our proposals are intended to benefit students by promoting and protecting high quality higher education while also serving the wider student interest and supporting a resilient sector that is equipped to deliver high quality higher education now and in the longer term. Our focus on continuous improvement in the quality of higher education will benefit students at a wide range of higher education institutions, studying on a wide range of courses. Our commitment to protecting students from provision that falls below the requirements set out in our conditions of registration will benefit those studying at the small number of institutions with unacceptably weak performance. It will also benefit prospective students who will be protected from provision that fails to adhere to our regulatory requirements.
- Our proposals are intended to help the institutions we regulate to improve their own performance, including by extending the reach of our regulatory activity beyond institutions in breach – or potential breach – of our minimum requirements. By communicating more routinely on features of quality provision, we will support institutions’ understanding of quality and contribute to a culture of continuous improvement. We will use a quality risk register to support our strategic goals which relate to quality and provide a clear and publicly evidenced basis for regulatory action, supported by input from students and the sector, helping institutions to understand, anticipate and mitigate areas of concern. The small number of institutions with unacceptably weak performance will be the focus of enforcement activity.
- We expect our proposals to benefit society as a whole in a range of ways. They will support a higher education system equipped to cultivate the skills the country needs and increase employer confidence in the value of English higher education qualifications. High quality higher education will be accessible to more people, and students from all backgrounds will be better able to engage with and benefit from high quality higher education, supporting a more equal society which makes better use of untapped talent and latent potential. The supply of skilled graduates will support local and national economies alike, while the ‘public goods’ associated with high quality higher education will accrue to a wide range of individuals and communities. Public goods include economic growth, a more equal society and greater knowledge and understanding.
- Strategy documents reflect a series of choices that articulate an organisation’s priorities. As such, many alternatives to the approach proposed in our strategy are possible. It would not be instructive to seek to identify all of those here.
- In developing our proposed strategy, we considered extending the existing strategy or having no strategy for the next five years. In our view, neither would be a credible course of action. Both bring similar, marginal benefits: there would be no new information for stakeholders, including OfS staff, to spend time and effort understanding; and in the case of extending the existing strategy, there would be greater stability in the system as the regulator would operate in the same way.
- However, significant changes pertinent to the way that higher education operates mean the benefits of continuity would be limited. It is our view that the merits of a new strategy, developed in response to the challenges facing students and institutions today, outweigh the benefits of continuity. Furthermore, by keeping the same regulatory objectives, we balance the need for stability with the need to respond to a changing context that brings new opportunities and risks. The brevity of the strategy document will limit the time and effort stakeholders are required to put into understanding our proposed approach.
- We also considered extending the approach to baseline regulation articulated in our current strategy. Again, this would have the benefit of providing greater continuity for institutions. Focusing on the regulatory baseline, however, would mean focusing resource on a small number of institutions with unacceptably weak performance. We believe this was the right approach as we established ourselves as a regulator. Now, and in the context of difficult headwinds for the sector as a whole, we believe that a broader approach that drives continuous improvement above our minimum requirements will maximise the positive benefits of regulation, benefiting a greater number of students.
- Subject to consultation responses, we have therefore provisionally discounted these alternatives as credible options.
- Throughout the consultation period we will create engagement opportunities for students, sector staff and sector representative groups, ensuring a wide range of views shape our finalised strategy.
- We will take into account consultation responses and engagement outcomes when finalising our strategy. We will also take into account any other developments that may impact the efficacy of our proposals. We intend to publish the strategy in spring 2025.
- Our proposed strategy covers the period from 2025 to 2030, deviating from past strategies that cover periods of three years. This is intended to provide greater stability and a clearer sense of direction to the sector over a period of change.
- Each year of the strategy period, we will set out our planned activity in an annual business plan. Delivery of our strategy is subject to a sustainable resourcing model being in place for the OfS through the strategy period.
- In the coming months we will set out in more detail how we plan to take forward our strategic goals. For example, in early 2025 we will begin to discuss with students and institutions how our new integrated quality model should take shape. We will explain how we plan to secure the more real-time data a modern, agile regulator needs to be effective. And we will publish proposals for reforming the approach we take to registering new institutions, smoothing the pathway into the regulated system for those that will offer high quality and innovative education to students.
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