Blended learning and OfS Regulation

This theme links to the aspect of condition B1 that relates to whether a higher education course is ‘effectively delivered’.

We do not specify how a provider should articulate its blend of online and face-to-face learning (provided it is clear to students, see 'Communicating the reasons for the blend to students') or how decision-making about these matters should be delegated within a provider. We would make judgements about compliance with our quality conditions based on whether a provider’s approach to blended learning results in a course that is ‘effectively delivered’.

The panel identified courses that delivered a blended academic experience that was confusing or difficult to manage for students, for example through staff not being fully aware of the simultaneous demands on students’ time across multiple modules. We would be likely to have compliance concerns in relation to condition B1 if a lack of coordination between modules on a course meant there was not an appropriate balance between delivery methods, leading to the course not being ‘effectively delivered’.

We would also be likely to have compliance concerns if teaching activities were moved online to meet a fixed blend ratio for a course, rather than using the most appropriate delivery methods for the material being taught. If decisions were not being made for sound pedagogical reasons, this could lead to concerns about whether a course is ‘effectively delivered’.

Students at one provider reported concerns with the high volume of recorded lectures with which they had to engage each week. They commented that this quantity of learning would have been unlikely to fit into a fully face-to-face timetable and that it was easy to fall behind. The blend they received was heavily influenced by module choice, and students felt that the provider had not acknowledged these challenges. The review panel took the view that there was a lack of coherence at course level. If this meant that the course was not being ‘effectively delivered’, we would be likely to have compliance concerns in relation to condition B1.

This theme links to the aspects of condition B1 that relate to whether a higher education course is ‘coherent’ and ‘effectively delivered’. It also links to the aspect of condition B2 that relates to whether a cohort of students is receiving appropriate resources.

Where a provider’s decisions about its delivery of higher education are driven principally by capacity or cost of delivery and are not based on considerations of the quality of the provision, this is likely to be relevant to a provider’s compliance with a number of conditions of registration, including those relating to quality, standards and financial viability and sustainability.

We are likely to have compliance concerns in relation to condition B1 if factors such as limited physical learning resources, including in-person teaching facilities, drive decisions about how a course is delivered. If a course is re-timetabled because there is not appropriate access to the in-person teaching spaces that certain subjects or skills require and, as a consequence, that course is no longer taught in an appropriate order, this may indicate that the course is not coherent. If decisions about how teaching is delivered do not take sufficient account of sound pedagogical considerations, we may conclude that the course is not effectively delivered. Either finding would indicate that students on the course are not likely to be receiving a high quality academic experience.

We are likely to have compliance concerns in relation to condition B2 if a cohort of students appears not to receive access to appropriate physical resources sufficient for the purpose of ensuring a high quality academic experience or success in and beyond higher education. This would be particularly likely if there is evidence that the absence of physical resources is linked to pressures driven by, for example, increases in student recruitment. This is likely to raise compliance concerns because it may indicate that a provider has not taken reasonable steps to mitigate those pressures on resources (for example, by restricting student recruitment such that physical teaching resources are available at appropriate times and on an appropriate scale).

The panel found that increased student numbers and space constraints at a provider appeared to lead to a whole day of online learning being regularly scheduled for students on its medicine course that had previously been in-person, despite the removal of government restrictions on face-to-face teaching. Some students the panel spoke to regretted that this teaching was not delivered in-person as it had been before the coronavirus pandemic.

The panel also observed at a different provider that a decision to retain recorded versions of online lectures as part of its delivery of multiple courses partly related to overcrowding on a campus. The overcrowding resulted from unexpected numbers of students meeting entry tariffs in 2021 after receiving centre-assessed grades. The panel found that this contradicted assertions by other staff at the provider that decisions about the blend were driven by discipline-based academics making decisions about which blend was most appropriate in their subject context.

The scenarios set out above would both be likely to raise compliance concerns with condition B1, if evidence suggested that factors such as limitations in the availability of physical learning resources were the principal drivers for decisions to deliver aspects of a course online.

In addition, both scenarios would be likely to raise compliance concerns with condition B2 if the delivery of aspects of courses online led to students not being able to access the physical facilities or resources necessary to ensure a high quality academic experience and/or success in and beyond higher education.

The information given to prospective and registered students about their course, including marketing and web-based information, is covered by regulatory requirements relating to consumer and student protection. While consumer protection matters were not the focus of this review, we consider it appropriate to expand on this point further given its importance to students.

Condition C1 requires a registered provider to demonstrate that in developing and implementing its policies, procedures and terms and conditions, it has given due regard to relevant guidance about how to comply with consumer protection law. For the purposes of the condition, ‘relevant guidance’ means the Competition and Markets Authority’s (CMA) publication ‘UK higher education providers – advice on consumer protection law’. The CMA guidance states the following:

‘The [Consumer Protection Regulations] make it unlawful to mislead students by failing to give them the information they need to make an informed decision, such as about what and where to study. This is called material information. Material information does not necessarily include all of the information that might potentially be of interest to a student but is the information the student needs to make an informed decision…’²

The CMA guidance then specifies that the type of course-related information that is material information under the Consumer Protection Regulations is likely to include the following:

‘…Information about the composition of the course and how it will be delivered, and the balance between the various elements, such as the number and type of contact hours that students can expect (for example lectures, seminars, work placements, feedback on assignments), the expected workload of students (for example the expected self-study time), and details about the general level of experience or status of the staff involved in delivering the different elements of the course;…

…location of study or possible locations, which should also include the likely or possible location of any work placement to be undertaken (where known);’

In addition to the consumer protection issues referred to above, this theme links to the aspect of condition B1 that relates to whether a higher education course is ‘effectively delivered’.

Providers should consider whether their marketing and recruitment information is clear and provides sufficient detail about how courses will be delivered.

If a provider cannot show that it has given due regard to relevant guidance about how to comply with consumer protection law in developing and publishing information for prospective students about a course, or there is otherwise evidence that suggests it is not complying with consumer protection law, we are likely to have compliance concerns in relation to condition C1. Providers are always required to comply with consumer protection law.

We are likely to have compliance concerns in relation to condition B1 if a provider does not communicate to current or prospective students information about the extent to which a course will be delivered through a blended approach. This might suggest that the design, delivery or management of that course is weak. This in turn would be likely to raise compliance concerns because it would indicate an increased likelihood that the course would not be considered effectively delivered.

The panel found one course at a provider that offered students a choice between a face-to-face or blended approach to course delivery. Where a provider has decided to offer a course in this way and ensured students are provided with the material information necessary to enable an informed choice, this would be unlikely to raise compliance concerns with condition C1.

Such an approach, in itself, is also unlikely to raise compliance concerns with relevant elements of condition B1 because it does not raise concerns about the design, delivery or management of the course, giving no reason to suppose that the choice offered to students means that the course would not be effectively delivered.

This theme links to the aspect of condition B2 that relates to whether a cohort of students receives sufficient resources, including ‘physical and digital learning resources’ as appropriate to the content and delivery of the higher education course.

Where a course is delivered through a blended approach with a significant quantity of digitally delivered teaching, or requiring the use of digital learning resources, the cohort of students on that course is unlikely to have a high quality academic experience if students are not able to access and engage effectively with digital learning.

Such resources as described in in this section are likely to fit within the definition of ‘physical and digital learning resources’ in condition B2. We have specified in the guidance that underpins condition B2 that having consistent access to an appropriate place to study is an example of digital learning resources for the purposes of that condition.³ Such facilities also clearly correspond to the ‘physical locations’ element of the definition of physical and digital learning resources.

We are likely to have compliance concerns in relation to condition B2 if a provider requires students to spend a significant proportion of their time engaging with digital learning, without ensuring access to appropriate physical spaces to allow them to do so.

At one provider, students (citing overcrowding on campus) reported struggling to find space to study or to join online lectures. Some students felt that this issue was compounded by an increasing quantity of online lectures. One student suggested that a traditional campus-based teaching calendar would not be able to accommodate the number of lectures that were produced.

We would be likely to have compliance concerns in relation to condition B2, if, because of a lack of suitable facilities on campus, a cohort of students could not participate in online learning or study at appropriate times relevant to the delivery of their course.

This theme links to the aspect of condition B2 that relates to whether each cohort of students receives ‘physical and digital learning resources’ as appropriate to the content and delivery of their higher education course. It also links to the aspect of condition B2 that relates to whether students receive sufficient academic ‘support’.

As discussed above in the section on ‘On-campus teaching and learning’, students are unlikely to receive a high quality academic experience on a blended learning course if they cannot appropriately access digital learning resources.

The definition of ‘physical and digital learning resources’ in condition B2 includes ‘iii. The resources needed for digital learning and teaching, for example, hardware and software, and technical infrastructure’. Similarly, ‘support’ includes ‘ii. support needed to underpin successful physical and digital learning and teaching’.

Consequently, we are likely to have compliance concerns in relation to condition B2 if students do not have access to sufficient hardware and infrastructure to access digital content as part of a blended course. We would also be likely to have compliance concerns in relation to condition B2 if students do not receive sufficient support to develop the skills to engage with digital learning effectively and therefore do not receive a high quality academic experience.

Provision of laptop loans or bursaries may be one of many appropriate ways to provide students with access to digital content. However, the existence of such schemes on their own may not be sufficient to satisfy the requirements of condition B2 if, for example, relevant students are not aware of them. Providing access to learning technologists and digital skills training are likely to be appropriate ways of providing ‘support’ to students on blended courses.

We would take these examples of practice into consideration as part of any assessment of a provider’s compliance with condition B2. Providers should satisfy themselves that they have taken all reasonable steps to provide sufficient ‘physical and digital learning resources’ and ‘support’ to ensure each cohort of students’ high quality experience on blended courses.

This theme links to the aspect of condition B2 that relates to whether a cohort of students receives resources and support which are sufficient for the purpose of ensuring a high quality academic experience for those students; and those students succeed in and beyond higher education.

The use of the term ‘cohort of students’ in the requirement of condition B2 places a particular emphasis on the needs of the group as a whole, and on the steps that may be considered reasonable to ensure that the group’s needs are met.

We agree with the review panel that providers must actively consider the particular resource and support needs of a cohort of students to ensure students have a high quality academic experience and achieve success. A provider that has failed to consider this properly and take all reasonable steps is likely to cause compliance concerns in relation to condition B2.

Our expectation is that the number and nature of the steps that need to be taken (to ensure sufficient resources and support) are likely to be more significant when the academic needs of a cohort are greater. A cohort of students that has a range of academic needs will likely result in a provider needing to take more, or more substantial, steps to ensure sufficient resources and support are available to students.

Academic needs may be linked to some students’ protected characteristics or socio-economic backgrounds. For example, we have previously specified in the guidance that underpins condition B2 that academic support includes mentor support that disabled students may require to support their learning.⁴ Similarly, a provider responding to a cohort of students who have caring responsibilities, by making high quality digital learning resources available to them, could be an appropriate means of supporting their particular academic needs.

Condition B2 requires a provider to take all reasonable steps to ensure sufficient resources and support for each cohort of students. In addition to our regulatory requirements, all providers must meet their legal obligations to make reasonable adjustments for a disabled student. For the purpose of condition B2, any reasonable adjustments made to the delivery of a course for an individual student should not have a detrimental effect on the academic experience of the whole cohort.

The panel observed on one course that students are offered a choice at the start of their course between fully online and blended delivery, with provision made for students to change pathway mid-course. In this instance, the panel’s view was that when a course did not require specialist spaces or equipment, this approach would work well for a wide range of students’ needs. In contrast, the panel found that students on other courses reported poor experiences of live lectures being dual-cast, as well as staff commenting that they found hybrid delivery – where some students study in-person and others online at the same time – did not work well in their teaching contexts.

The two scenarios above illustrate how adjusting the delivery approach for a course can have a different effect in different contexts. If a provider decided that making available online or blended delivery was not appropriate for a particular course, for example because of the extent or nature of student participation and engagement required by the subject matter of the course, this by itself would be unlikely to raise compliance concerns in relation to condition B2. This could be the case even where the preferences of individual students could have been more fully met by offering a choice of delivery methods.

This theme links to the aspects of condition B1 that relate to whether a higher education course is ‘up-to-date’ and requires students to develop ‘relevant skills’.

We may consider a guest speaker programme, delivered using digital technology, to be relevant to condition B1 where we consider it forms part of a course. This may mean that a course is more likely to be ‘up-to-date’ or delivering other ‘relevant skills’, because guest speakers can contribute course content which incorporates recent developments in a subject area, research, or professional and industrial practice. However, this may not, on its own, compensate for other elements of a course that are not up-to-date.

We are unlikely to consider the absence of an external speaker programme, by itself, as indicating an increased likelihood that a course is not up-to-date or delivering other relevant skills, as these requirements could be met through other means.

A course lead for a performing arts course described how the option of delivering guest speaker sessions online, originally made necessary by pandemic restrictions, had allowed the programme to expand. The reduced time commitment and need for travel had made it easier to book guests for online Q&A and careers sessions and, as a result, students had access to relevant figures from industry to discuss career development. The course lead reported that student engagement with this programme was high.

This example reflected an improvement to the course that was valued by students. However, it is unlikely that we would consider this series of Q&A sessions on its own as evidence that a course is up-to-date or delivering relevant skills. If the guest lectures were clearly part of a course, they would be taken into account as part of our assessment of the course as a whole.

This theme is linked to the aspect of condition B1 that relates to whether each higher education course is up-to-date. The theme is also linked to the aspect of condition B2 that relates to whether each cohort of students receives sufficient resources, including ‘physical and digital learning resources’ as appropriate to the content and delivery of the higher education course.

The re-use of lecture recordings, particularly for core course content that remains similar year-on-year, would, in itself, be unlikely to cause compliance concerns. This is because re-using high quality lecture recordings from previous years could support improvements in the academic experience, as the time of teaching staff may be freed up for other beneficial engagement with students.

However, there is a risk that lecture recordings are not up-to-date when they are re-used, for example, because they can include course content that no longer reflects the curriculum design. The re-use of lecture recordings would be likely to raise compliance concerns in relation to condition B1 if the re-used lectures are not up-to-date, which could be because they are not appropriately informed by subject matter developments, research, industrial and professional developments, or developments in teaching and learning.

The re-use of lecture recordings may also result in students being provided with lectures which include incorrect administrative information, such as previous years’ course deadlines or timetables. This can create confusion for students and impede their learning. The re-use of lecture recordings would be likely to raise compliance concerns in relation to condition B2 if the extent of incorrect and confusing administrative information they contained meant that they could not be considered adequate and deployed effectively to meet the needs of students.

A number of providers had provider- or course-level policies about the ownership, storage and reuse of lecture recordings. The panel’s view was that, where such policies were absent, students experienced variable and inconsistent approaches to lecture recordings, and what they received depended on the decisions of individual teaching staff.

We do not require providers to adopt particular policies or procedures regarding lecture capture, storage and reuse. Providers should ensure that, where lecture recordings are re-used, they remain up-to-date and do not contain inaccurate administrative information such that they are no longer adequate and deployed effectively to meet the cohort’s needs.

The theme is linked to the aspect of condition B2 that relates to whether each cohort of students receives sufficient resources, including ‘physical and digital learning resources’ as appropriate to the content and delivery of the higher education course.

Poorly produced online lectures can affect students’ academic experience. They may lead to students missing important course content or administrative information relating to their course, particularly where audio or video are poorly recorded. They may also make it difficult for students to interact fully with teaching sessions, especially those that are unduly long.

Poorly produced online lecture recordings would be likely to raise compliance concerns in relation to condition B2 if students were receiving resources that were not adequate or not deployed effectively to meet students’ academic needs.

At two providers, students reported that they missed course content because information written on whiteboards was not visible in lecture recordings, and teaching sessions were so long that they struggled to interact fully for the session’s duration. At one of these providers, students reported that audio was poor and that they were unable to hear parts of the session.

At one provider, students stated that when lectures were broadcast live (rather than pre-recorded), there were frequent technical issues which meant they missed content and found it difficult to interact with these lectures.

These examples would be likely to cause compliance concerns in relation to condition B2, as they indicate that a provider is providing poor quality resources which are not meeting the needs of the cohort of students.

This theme links to the aspect of condition B2 that relates to whether each cohort of students receive sufficient resources. Resources includes a staff team that is ‘appropriately qualified’.

As the panel has highlighted, a lack of digital skills among staff can lead to poor quality online teaching, which may be connected with a number of themes discussed elsewhere in this report, for example, in the sections on ‘quality of online lectures’ and ‘feedback on learning progress in online settings’.

Failure of a provider to ensure a staff team has appropriate digital skills may give rise to compliance concerns. For courses employing blended learning approaches, proficiency in the digital tools used is a necessary skill for teaching staff to be able to deliver a course effectively. We may therefore consider that staff lacking digital skills are not appropriately qualified. We would be likely to have compliance concerns in relation to condition B2 if a provider is not taking all reasonable steps to ensure its staff team was appropriately qualified, with sufficient digital skills to effectively deliver courses employing blended learning approaches.

One provider had employed and offered training to a significant number of students to provide digital support to students and staff. Staff at this provider spoke positively of the impact this approach had on their digital skills.

On a performing arts course, the panel described digital developments in the creative arts sector (such as headphone theatre and livestream theatre) which had been integrated into a course, with dedicated technical teams to support teaching staff’s ability to teach up-to-date digital approaches.

If a provider were taking these approaches to upskill staff and those approaches were effective in practice, we would be unlikely to have compliance concerns with condition B2 in relation to staff’s digital skills, as we would be likely to consider that the provider had taken some steps to ensure its staff team was appropriately qualified.

This theme links to the aspect of condition B1 that relates to whether each higher education course is ‘effectively delivered’. It also links to the aspect of condition B2 that relates to whether each cohort of students receives sufficient support.

Students reported that, in some instances, online teaching was connected with limited dialogue with, and reduced small-scale feedback from, teaching staff. Both students and staff reported that there are certain elements of courses which require dialogue and small-scale feedback to be effectively delivered (see the 'case study' section below for an example). We would be likely to have compliance concerns in relation to condition B1 if delivery methods did not facilitate feedback for students appropriate to the content of a course.

Students reported that issues with the timeliness and quality of feedback during online teaching could make it more difficult to fully engage with their course and understand course content. Condition B2 requires a provider to take steps to ensure that students receive support to facilitate a high quality academic experience. We would be likely to have compliance concerns in relation to condition B2 if a provider were not offering timely and effective support appropriate to a course and if students were struggling to interact fully with physical or digital learning and teaching as a result.

We take the view that providing appropriate feedback and support is certainly possible in an online teaching environment. Providers should consider how they can provide students with appropriate feedback and support so that they receive a high quality academic experience both in-person and online. The case study example below illustrates how one provider has been able to improve feedback and support for students when adopting blended learning approaches.

Students at one provider said that online delivery caused issues with timely and effective feedback on the mathematical elements of their course. They said that chat functions on video calls did not enable students to write or annotate complex formulas, and that email responses to queries were too slow to be helpful. We would be likely to have compliance concerns in relation to condition B1 in this instance, as delivery methods may not be appropriate for the course content, causing students to miss appropriate feedback, which suggests that the provider may not be delivering the course effectively.

Students at one provider said that during the coronavirus pandemic, teaching staff increased contact through email and set up informal virtual meetings to discuss student work-related concerns, and that this practice had now become common. Students reported that this had improved communication and helped them resolve issues quickly and effectively. This illustrates one way in which teaching staff can create new routes or improve current routes for providing feedback to students, as part of online learning and teaching. We would be unlikely to have compliance concerns in relation to condition B1 if a provider had taken steps such as this to ensure students receive sufficient support to facilitate effective learning and teaching.

This theme links to the aspect of condition B1 that relates to whether a course is ‘effectively delivered’. It also relates to the aspect of condition B2 that related to whether students receive appropriate support.

We do not currently set specific quantitative requirements for students’ attendance or engagement with their course, although we note that the Student Loans Company has expectations in this area. However, we agree with the panel that low attendance and engagement may be cause for compliance concerns in relation to conditions B1 and B2. It is important to distinguish between occasional short-term attendance issues (for example due to student illness) and broader issues which are likely to affect students’ academic experience and cause compliance concerns.

Low attendance and engagement may be an indication that a course is not effectively delivered, meaning that it does not contain an appropriate balance between delivery methods or between directed and independent work. Students who do not attend or engage are likely to be missing learning. We would be likely to have compliance concerns in relation to condition B1 if we see low attendance and engagement and judge this to suggest ineffective design and delivery of a course.

Many prospective and current students have had a challenging academic experience due to the coronavirus pandemic. Staff and students reported that this has led to a skills deficit, with more students struggling to participate effectively in the face-to-face elements of their course. Condition B2 requires a provider to take steps to ensure students receive sufficient support which is appropriate to their academic needs. Following the pandemic many students may, for example, need support engaging with face-to-face teaching. We would be likely to have compliance concerns in relation to condition B2 if a provider were not taking steps to offer appropriate support to students to facilitate successful learning, informed by consideration of a cohort’s academic needs.

The panel found one course for which students reported attendance rates below 50 per cent for in-person elements of the course, and that many students had left the course. One student on this course said:

‘About February, March, a lot of the students became disinterested. And they lost their motivation to actually do the proper work. Maybe 10-15 students at a time within those tutorials, which from a student body which was [a much larger number], that's not exactly enough.⁶ ... Whether it was the fact that the university struggled at the beginning of the year or whether it was just some stress post-pandemic, we don't know […] The motivation wasn't just within this course.’

This particular course was providing a significant amount of online teaching. Students said that this had led to an increased emphasis on theory-based learning as opposed to the practical elements which took place in laboratories, and that this had resulted in less interaction with academic staff.

‘And another problem with online learning as such is that once you get down into more difficult calculations or equations, sometimes you need the lecture[r] to be there with you to actually guide you through.’

This case study suggests that decisions about the delivery method for a course can be linked to low attendance and non-continuation. We would be likely to have compliance concerns in relation to condition B1 in this case as low attendance and increased non-continuation suggest that a course is not effectively designed and delivered. In this case, we would be likely to consider that the course was not effectively delivered because of an inappropriate balance between delivery methods and between directed and independent study. However, there are other factors that could indicate that a course is not effectively delivered in the manner which it is taught, supervised and assessed.

In addition, this example raises questions about whether students are adequately supported by their provider. A sustained period of low attendance on this course should have signalled to the provider that the academic needs of students may not have been adequately met. We would be likely to have compliance concerns in relation to condition B2 as it appears this provider did not take all the steps it could and should have taken after a pattern of low attendance emerged, to ensure students received sufficient resources and support as relevant to their academic needs which would ensure their success in and beyond higher education.

This theme links to the aspect of condition B1 that relates to whether each higher education course is ‘effectively delivered’. It also links to the aspect of condition B2 that relates to whether each cohort of students receives sufficient support.

The panel identified situations where the volume of recorded lectures and other digital learning resources students were receiving was too high for them to engage effectively. This was exacerbated where the overall plan for learning and teaching was not joined up across modules. Where this is the case, it suggests that there is an inappropriate balance on a course between delivery methods or directed and independent study, and therefore that the course may not be effectively delivered. We would be likely to have compliance concerns in relation to condition B1 if a large volume of learning content negatively affects students’ ability to participate fully in their course.

Students reported that they struggled to manage their timetables, often not knowing how long to spend on tasks or how to prioritise work. Students often missed course content as a result. Although students need to manage their timetable on any higher education course, doing this on blended learning courses can be more challenging because of the range of delivery approaches and the need to balance on-campus and independent work. Providers should be able to remedy these issues by offering students appropriate support to help them manage their workload more effectively. We would be likely to have compliance concerns in relation to condition B2 if a provider did not take steps to support students with timetable management challenges.

As discussed in the case study example in the 'The blend approach: strategic, departmental, local?' section above, students at one provider reported that the volume of pre-recorded online lectures assigned to them each week made it challenging to complete all their assigned work. As a result, students frequently did not watch online lectures or watched them at increased speed. This example suggests an ineffective balance of independent and directed study, meaning the course may not be effectively delivered, and this may mean we are likely to have compliance concerns in relation to condition B1.

At one provider, for each module there was a dedicated space on the virtual learning environment (VLE) which provided a breakdown of each week’s content, the online resources available to students, and the delivery approach for different elements of learning and teaching. Students reported that the information shared on the VLE made it easier for them to plan and manage their own timetables. Increasing communication on course structure, as in this example, is one of a number of steps that providers may take to support students. In this instance we would be likely to have compliance concerns in relation to condition B2 if a provider is not taking steps to meet students’ academic needs and providing support in this way.

This theme is linked to the aspect of condition B2 that relates to whether each cohort of students receives sufficient support.

Where students lack appropriate digital skills, they may not be able to access or participate effectively in elements of their course. Digital skills gaps can be general, with students lacking proficiency in standard digital tools, or course specific, with students lacking proficiency in specialist digital tools that are necessary for their course content or the blended learning approaches being taken on their course. Providers should be aware of the digital skills gaps in each cohort of students. They should consider what support may be appropriate to facilitate effective student participation in digital learning and teaching. We would be unlikely to have compliance concerns in relation to this aspect of condition B2 if a provider took steps to offer appropriate support to ensure students have the digital skills relevant to their course, and this support was effective in practice.

The panel described a variety of approaches taken by providers to offer effective support to students, facilitating the development of digital skills. These are examples of the type of support providers may consider which would help ensure students have appropriate digital skills to participate effectively in digital learning:

1. Employing and training students to offer digital teaching and learning support to students and staff.
2. Offering step-by-step written guides on how to use online resources and ensuring access to learning technologists where individual support is required.
3. Making strategic choices about the online platforms used. A course at one provider did not use the provider’s institution-wide VLE. Instead, it used alternative online platforms which were more appropriate to that course and its students.

We would be unlikely to have compliance concerns in relation to condition B2 if providers, as in these examples, were considering students’ digital skills needs and offering appropriate support to develop their students’ digital skills that was effective in practice.

This theme links to the aspect of condition B1 that relates to whether each higher education course is effectively delivered.

We have set out in the guidance underpinning condition B1 that a course that is predominantly taught through large-scale lectures without providing opportunities for small group teaching would be likely to raise compliance concerns.⁷ In relation to postgraduate research students, our view is that failing to provide opportunities for structured engagement with other researchers would also be likely to cause compliance concerns.

We would also take the view that a course delivered using blended approaches that does not foster collaborative learning among students would be likely to raise compliance concerns in relation to whether it is effectively delivered.

At one provider, the review panel identified a lack of alignment between students’ and the provider’s view of the sense of academic community experienced by students. While course leads emphasised how the use of online communication software such as Microsoft Teams encouraged students and staff to interact in new ways, students reported feeling that they were not engaged with courses or each other, with multiple reports of peers having left their course. One student at this provider remarked:

‘There's no way to build connections within your own school year or within your own group. That's one of the biggest issues we had with [online learning].’

The approach set out in the case study above would be likely to raise compliance concerns in relation to condition B1 as the lack of engagement between students on a course and the link to non-continuation suggests that the course may not be ‘effectively delivered’.

This theme links to the aspect of condition B1 that relates to whether a higher education course is ‘up-to-date’ and requires students to develop ‘relevant skills’.

Blended learning approaches can create new opportunities to develop students’ skills and knowledge. These skills may reflect developments in professional competences and skills requirements in relevant industries, such as new digital skills. We would be likely to have compliance concerns if a course does not appropriately reflect changing expectations of digital skills in relevant disciplines or industries such that a course was no longer up-to-date. This could also mean that the course did not require students to develop relevant skills, in a manner appropriate to the subject matter and level of the course.

Similarly, we would expect that a course that moves from a fully face-to-face to a blended approach, would be likely to raise a compliance concerns if it did not require students to develop practical skills in a manner appropriate to the subject matter and level of the course.

The review panel reported an example of a course which had rapidly integrated various forms of digital performance into its blended curriculum in response to changes in the performing arts industry, such as ‘headphone-’ or ‘Zoom-theatre’. The course content clearly included practical skills and professional competences that reflected recent developments in how industry professionals collaborated remotely. This approach, in the absence of other concerns, would be unlikely to raise compliance concerns about whether the course was up-to-date or delivering these skills.

The panel identified a cohort of students who were concerned that they had not experienced sufficient practical teaching as part of a blended learning approach. They considered this had put them at a disadvantage in terms of practical skills required for future employment. In addition, another graduate said that this blended course had not provided them with specific digital skills that roles in a related industry required. The situation these students described to the panel would be likely to cause compliance concerns in relation to condition B1 as it may indicate that this course does not reflect up-to-date industrial and professional developments.

1. The use of the term ‘coherent’ here by the review panel should not be assumed to have the same meaning as the defined term ‘coherent’ in condition B1.
2. Competition and Markets Authority, ‘Higher education: consumer law advice for providers’ (2015). Available at: www.gov.uk/government/publications/higher-education-consumer-law-advice-for-providers.
3. Office for Students, ‘Quality and standards conditions’ (2022). Available at: www.officeforstudents.org.uk/publications/securing-student-success-regulatory-framework-for-higher-education-in-england/.
4. Office for Students, ‘Quality and standards conditions’ (2022). Available at: www.officeforstudents.org.uk/publications/securing-student-success-regulatory-framework-for-higher-education-in-england/.
5. Please note that the review panel use the term ‘engagement’ to discuss the manner and extent to which students take part actively in their courses. This is different to the OfS’s definition of ‘engagement’ for the purposes of condition B2, which relate to the provision of opportunities for students to contribute to the development of their academic experience and course. In discussion of this theme, ‘engagement’ refers to the panel’s use of the term.
6. We have removed the number from quotation to protect the anonymity of the student.
7. Jisc, ‘Student digital insights survey 2021/22: UK higher education (HE) survey findings’ (2022), pg. 16. Available at: www.jisc.ac.uk/reports/student-digital-experience-insights-survey-2020-21-uk-higher-education-findings.