HEA response
Further and Higher Education (Wales) Bill
Question 1: What other changes could be implemented to increase colleges’ autonomy?
Question 2: What do you consider to be the advantages of the proposedchanges to the Further and Higher Education Act (FHEA)?
Given the nature of the FE proposals, there is little for the HEA to comment on directly. Here, the HEA is concerned with how the proposals may affect learning and teaching, the student experience and pedagogy at Welsh FE colleges. From the information available, it seems students and employees at Welsh FE colleges will see no difference at the FE colleges in any way.
There is a key role for the HEA to play, either in collaboration with Colegau Cymru or in parallel with Colegau Cymru, in developing a code of practice for HE in FE in Wales. This would draw from the work being undertaken by the HEA around this agenda, including for example, scholarly activity in HE in FE[1].
The paper refers to an “intent of the Welsh Government to develop a capital investment plan for the FE sector”. This is to be applauded as a key investment in the skills agenda.
Question 3: What do you consider to be the disadvantages of the proposed changes to the FHEA?
The HEA is keen that the ‘rationalisation’ of Welsh FE colleges is completed without jeopardising the quality of learning and teaching, and with the interests of students central to the work.
Question 4: Are there any unforeseen consequences?
Question 5: Do you agree that provision should continue to be made forthe Welsh Government to provide support to students who seek toaccess designated HE courses delivered by private providers?
The HEA strongly agrees with “The Welsh Government considers that all HE institutions and other HE providers offering courses which are designated for the purpose of statutory student support in the form of Government-backed grants and loans for students should be required to comply with the same regulatory controls in order to protect the interests of students, taxpayers and Welsh society”. The HEA supports the notion that all institutions that are funded by public money to deliver HE should fall under the same controls and audit requirements.
Question 6: What are the advantages and disadvantages of maintainingsuch support?
Question 7: Do you agree that all providers of HE in Wales which offercourses which are designated for the purposes of student supportshould be required to comply with arrangements:
• on an institution-wide basis (concerning financial and qualityassurance and dispute resolution via the OIA); and
• arrangements in respect of individual courses (fair accessarrangements, fee regulation, information provision and studentnumber controls)?
The HEA is supportive of these arrangements as they ensure that a consistent approach is taken across the sector. The HEA believes that this is in the best interests of both students and institutions.
Question 8: Do stakeholders agree that a provision for Welsh Ministersto directly fund HE in strategically appropriate circumstances would bebeneficial for partnership and collaborative activities?
The paper states the Welsh Government will “seek a provision in the Bill to enable HE provision to be directly funded by Welsh Ministers in instances where it is strategically appropriate to do so. By way of example, such a power could be used by the Welsh Government to tackle any significant failures to meet identified employer needs and learner demand in identified priorities. This provision will enable the Welsh Government to fully fund partnerships including schools, FE and work-based learning, through to HE and career and professional development provision from a single funding source of Welsh Government funding. The consortium or partnership itself could be funded as opposed to individual providers. A learner could be able to identify provision and appropriate progression opportunities from school through to the workplace within the same collaborative partnership. This should enhance partnership working by enabling better joint planning and delivery of provision, through having a shared mission and reducing competitive behaviour and duplication of provision”. The HEA is concerned that, whilst the aims of encouraging and developing partnership working and more seamless progression through education are laudable, direct funding may lead to an erosion of independent HE governance. The HEA believes that other options, such as exploring how existing agencies can collaborate on such strategic issues in the learning sector, should be considered prior to introducing the provision for Welsh Ministers to directly fund higher education.
Question 9: A number of advantages have been identified in Section 4.2.Would there be any disadvantages arising from Welsh Ministers fundingHE provision directly in strategically appropriate circumstances?
See above.
Question 10: Do you agree that the proposed statutory duty to securethat provision is made for quality assessment and enhancement shouldextend to the following:
• all HE institutions,
• providers with degree awarding powers and
• any other providers who offer courses which are designatedfor the purposes of student support operating in Wales (but which are not HE institutions or do not have degree awarding powers)?
The HEA believes that there are significant benefits to a common approach and frameworks for all HE providers across the Welsh sector. The HEA is supportive of a simplification of quality assurance processes, levelling the playing field, and providing confidence for the sector in quality assurance processes and frameworks.
The HEA’s work in Wales to date, through the Future Directions for Higher Education in Wales quality enhancement programme, the Welsh Institutional Group (WIG), the Education for Sustainable Development and Global Citizenship (ESDGC) and other activities, has demonstrated the positive impact collaborative working can have. Institutions, sector agencies and students focusing on one theme (currently Graduates For Our Future) provides a strong focus for the sector, and has provided a wide range of opportunities for innovation, sharing and enhancing the student learning experience.
As such, the HEA believes that expert bodies, such as the HEA, should have a leading role in developing and delivering details of any quality enhancement processes. Quality enhancement and quality assurance are two distinct features of higher education, and the HEA believes that there are significant benefits to higher education providers, students and the sector in treating them as such. The HEA is the voice for learning and teaching in higher education in the UK, and the HEA’s mission is to support the higher education community to enhance the quality and impact of learning and teaching.
The HEA agrees the proposed statutory duty to secure that provision is made for quality assessment and enhancement should extend to the bodies listed.
Question 11: In relation to HEFCW having due regard to quality assurance and enhancement guidance provided by the Welsh Government, what guidance would be considered beneficial to qualityassurance and enhancement?
The HEA supports the Welsh Government’s stance on focusing on improvement and not depending on market forces but seeking “alternative means” to drive up quality. An alternative approach is welcomed, as is the explicit statement on the greater involvement of learners in quality processes.
Since 2009, the HEA has led the quality enhancement work in the HE sector in Wales through the Future Directions for Higher Education in Wales[2] programme. Working closely with HEIs, students and sector agencies, the enhancement theme Graduates For Our Future was identified for the sector to focus on. The theme was developed to support the sector in addressing the twin priorities outlined in For Our Future[3] - delivering social justice and supporting a buoyant economy. The theme has three strands: Students as Partners; Learning in Employment; and Learning for Employment. The theme and related strands were celebrated and showcased at the Inaugural Future Directions conference – Graduates For Our Future[4] in Spring 2012. The Future Directions programme has also been delivered through a range of sector events, for example, Future Directions: Feeding Forward, Enhancing Learning and Teaching through Technology[5] in April 2011, and Future Directions: Foundation Degrees – where policy meets practice[6] in February 2012. All Welsh HEIs, students’ unions and key sector agencies are involved in the work, in a variety of ways, for example, through membership of the Future Directions Steering Group, membership of the three work strand groups, submitting case studies, disseminating the work through networks, and participating in the Future Directions events.
The HEA would welcome support from the Welsh Government for the continuation of the sector-wide approach to enhancement already started with the Future Directions programme. Just as important is the need for HEFCW to continue working with the sector and appropriate stakeholders to develop and deliver quality assurance and enhancement. Two examples of this joined up approach include the Wales Initiative for Student Engagement (WISE) and the Skills and Employability Framework.
Proposals for a new function for HEFCW, namely to assess the quality of HE provision in Wales will need to take account of the role of the Quality Assurance Agency (QAA) who currently have responsibility for reviewing institutional academic quality and standards. If HEFCW do not continue to discharge its quality assurance responsibilities through a service level agreement with the QAA, how will HEFCW approach the assessment of the quality of HE provision? Before commenting on the robustness of quality assurance processes, further clarity must be provided.
The HEA is keen to highlight the difference between an enhancement-led approach, for example, in the Scottish HE sector, and embedding a stronger enhancement element into existing structures and processes.
Question 12: What other changes could be implemented to make thequality assurance system in Wales more robust?
From September 2012, the QAA will begin its new Institutional Review process[7] for the institutional management of academic quality and standards. Four judgements will be made on: the threshold standards of awards; the quality of students’ learning opportunities; the enhancement of students’ learning opportunities; and the quality of public information. Student Charters will also be included in the documentation.
To reinforce a sector-wide approach to quality enhancement activities, the HEA believes there is scope for aligning quality enhancement to quality assurance. For instance, institutions could be asked to demonstrate how they have engaged with the current enhancement theme and work strands during institutional review.
Similarly, the HEA believes that there would be benefits to aligning strategy development cycles to enhancement theme cycles (for example, learning and teaching strategies, enhancing learning and teaching through technology strategies).
To ensure greater student involvement in quality, the HEA believes it would be useful to see opportunities for broader student engagement in quality assurance processes, i.e. not only improving opportunities for student representatives, especially in relation to quality enhancement. This is particularly important at institutional, faculty and departmental levels, where issues that arise beyond the course representative role. The HEA notes the significant impact of the internationally recognised Student participation in quality Scotland (sparqs) has had on quality assurance and quality enhancement in the Scottish sector. Sparqs is an independent, non-political and centrally funded organisation, providing training, consultancy on representation models, and research into student engagement.
In Wales, the HEA urges any changes in student representatives’ roles to be developed in partnership with NUS Wales. The HEA would be cautious of increasing demands on student representatives’ time through additional responsibilities. Some institutions are already addressing this in a variety of ways (often making involvement in institutional enhancement distinct from the role of representatives in advocating on behalf of their peers) and incentivising student involvement in different ways to recognise students’ contributions.
With regards to “delivery of specific projects to develop and share good practice and collectively generate ideas and innovative models for encouraging academic staff, support staff and students to share current learning and teaching experiences”, the HEA welcomes additional targeted investment in learning and teaching. This presents a great opportunity for the HEA and HEFCW to work in partnership in coordinating and delivering these projects – drawing on the HEA’s expertise and sector reputation in this area, for example, through the Future Directions programme of quality enhancement work. This would enhance the success and impact of these projects, and their integration with other quality enhancement work across the UK.
Question 13: What impact has the HEFCW guidance had so far onensuring that student unions are provided with sufficient funding todeliver a common set of functions? What else should be done tosatisfactorily achieve this aim?
There are multiple mechanisms to enable the learner voice to inform quality enhancement, at the local, faculty or school, and institutional level. The HEA believes that focusing solely on the role of students’ unions and student representatives creates a sense that these are the only voices that count. Learner voice and working in partnership with students should be at the heart of quality processes, providing all students with a range of opportunities to engage, rather than residing solely in the relationship an institution has with its students’ union. This is implicit in the notion that students are “active participants in shaping their own learning” (and other aspects of their HE experience) – but the HEA believes that it would be useful if this was better drawn out in the paper, to reflect a more inclusive approach to the learner voice. Similarly, indicating that learner voices should be “listened to and acted on” indicates a transactional relationship between students and their institution – this is also a danger in the language used in Student Charters. If students are truly partners in their learning, the HEA believes that this needs to be reflected in the way learner voice and Student Charters are framed – as authentic, inclusive and paying attention to the different roles within the partnership.
The Wales Initiative for Student Engagement (WISE) was launched in 2009[8] with the aim of helping students and students’ unions get involved with shaping the learning at their own university. The HEA has participated in WISE since its inception, working with the National Union of Students in Wales (NUSW), Higher Education Wales (HEW), the Higher Education Funding Council for Wales (HEFCW), the Quality Assurance Agency (QAA), and since 2012, Colleges Wales. WISE has delivered a range of benefits to both students and institutions, ensuring the student voice is being heard at all levels. The WISE action plan has delivered a range of activities to support the WISE statement[9], including HEA supporting the development of Student Charters, and a range of Students as Partners activities, delivered through the Future Directions for Higher Education in Wales quality enhancement programme.
In 2011-12, the HEA and the NUS ran a project which supported 21 students’ unions, including four in Wales, to develop and run their own Student Led Teaching Awards[10] (SLTAs). The project was inspired by three key issues: seeking innovative ways for students’ unions to address low National Student Survey (NSS) scores for academic feedback and assessment, and low satisfaction; to raise the profile and prestige of learning and teaching at all institution types in a positive way, rewarding best practice; and the positive impacts of awards schemes already running in some institutions. The HEA considers that SLTAs are a positive way to build good relationships between the student body and their institution, to find out more about students’ conceptions of excellence in teaching, and to bring together staff and students to celebrate success. SLTAs also provide an excellent opportunity to gather data on what students see as good learning and teaching practice. The data can be used to disseminate good practice at an institutional level and across the sector, and to raise the profile of teaching. In 2012-13 the HEA and NUS will be considering the SLTA data collected from across the UK, and will create a report highlighting students’ perceptions of learning and themes emerging from the project.
It is essential for students’ unions to receive sufficient funding, to enable effective participation in sector activities.
Question 14: Are the common set of functions for student unionsincluded in the HEFCW guidance appropriate?
HEFCW’s guidance on good practice in funding of effective, democratic student unions, and student representation[11] is useful. The HEA welcomes, in particular, section 18.9 which states “Student Voice: The partners will work collaboratively through a range of methods, to ensure that students are partners at every level of the institution”. Through the HEA led Future Directions for Higher Education in Wales quality enhancement programme of work[12], one strand of work is focused entirely on Students as Partners. As argued by Dr Nick Potter (Swansea Metropolitan University and leader of the Students as Partners work strand) in the Future Directions Students as Partners publication[13], “HE is rapidly altering its view of the role of the student in sharping the learning process and the student experience as a whole. A rich narrative is unfolding as the higher education landscape changes – one that increasingly highlights the importance of the student voice being heard – in everything from shaping curriculum or deciding how money for learning and teaching resources is spent, to designing institutional systems for quality assurance”.