BIS Green Paper consultation response

The Department of Business, Innovation and Skills is currently undertaking a consultation on proposals for higher education reform in the UK, as outlined in November’s Green Paper: Fulfilling our Potential: Teaching Excellence, Social Mobility and Student Choice.

I’ve not been able to answer all 28 (!) questions  – see Martin Eve’s very thorough response for a more in-depth analysis – but here are the answers to six questions which I will be submitting.


1a. What are your views on the potential equality impacts of the proposals, and other plans, that are set out in this consultation?

It seems to me that the TEF as proposed will increase inequality and social mobility – if high-performing institutions have higher fees, and maintenance grants have been scrapped, then surely those students who are economically disadvantaged and need to minimise their expenditure will see higher fees as a disincentive to apply to those institutions.


2. How can information from the TEF be used to better inform student and employer decision making? Please quantify these benefits as far as you can.

Since the Green Paper does not actually say what the TEF will measure and what metrics will be used, it is impossible to give a full answer to this question and certainly not possible to quantify the benefits. Presuming that ‘student decision making’ means the choice of which university to attend, then I would have to say the TEF will provide no useful information. Speaking as a postgraduate student, the choice of course is far more important to me than choice of institution; if the TEF produces a single score for an institution that will have zero relevance to my decision about a particular course at that institution. I don’t believe that it is correct to be confident that ‘those providers that do well within the TEF will attract more student applications’ (p.19) – universities’ reputations have been achieved over a long period of time, are based on far more complex things than ‘value for money’, and will not quickly shift.


11. Do you agree with the proposed approach to the evidence used to make TEF assessments – common metrics derived from the national databases supported by evidence from the provider? Please give reasons for your answer.


Any assessment based solely on metrics will fail to capture the most important aspects of teaching, so it is admirable that the proposed approach goes beyond this to allow further evidence. However, this highlights one of the main failings of the TEF, which is that a single number (or small set of numbers, since we don’t know yet what the results would look like) can never adequately convey information about teaching quality across an institution that is relevant to a student deciding which institution to attend. This is particularly true of postgraduate students, who have already made the choice to undertake further study in a particular area – often an area in which they wish to advance their career. Since an institution-wide TEF score will average out across better- and worse-performing subject areas, then it will say nothing about the particular area that a student will spend their entire time at university in. If the purpose of the proposed TEF is really to assist with student choice then a much clearer case needs to be made of how this is so.

One of the proposed metrics, ‘Employment/destination’, is particularly concerning because employment outcomes have nothing to do with teaching quality (especially at course level). Also, this metric could not be applied consistently across undergraduate, postgraduate, full-time, and part-time students, given the differing employment statuses of students at different stages of study. It must be remembered that not all higher education students are 18-year-olds fresh out of school.


20. What steps could be taken to increase the transparency of student unions and strengthen unions’ accountability to their student members?

None. I reject the premise of this question. Unless compelling evidence is provided that students themselves are demanding more transparency and accountability from their unions, then no changes are necessary, and even if changes were warranted then as far as possible it would be best left to students to retain autonomy and manage themselves – the government should not intervene.


23. Do you agree with the proposed deregulatory measures? Please give reasons for your answer, including how the proposals would change the burden on providers. Please quantify the benefits and/or costs where possible.

The proposed deregulatory measures would harm democratic accountability and are probably unworkable. Ensuring that higher education providers are subject to the Freedom of Information Act is certainly ‘in the interest of students and the wider public’. The costs incurred by institutions of complying with the Act are a small price to pay for the level of democratic accountability that is gained. As I have argued elsewhere (Lawson, Stuart, Jonathan Gray and Michele Mauri, Opening the Black Box of Scholarly Communication Funding: A Public Data Infrastructure for Financial Flows in Academic Publishing (November 13, 2015). Available at SSRN:, classing higher education institutions’ income as ‘public’ or ‘private’ is actually fairly complex because they derive a lot of money from both sources – and even ‘private’ tuition fees are to a large extent backed by the public purse, in amounts which dwarf the income of any single institution. So to say that ‘the income of nearly all of these providers is no longer principally from direct grant and tuition fee income is not treated as public funding’ is to gloss over the complexities of the current funding environment and certainly no justification for removing the need for universities to comply with the FOIA. If the government genuinely wishes to encourage transparency and accountability I see no alternative but to increase to reach of the FOIA to also apply to private providers.

For details of why the proposed measures are unworkable I refer to Andrew Gray’s response (


24. In light of the proposed changes to the institutional framework for higher education, and the forthcoming Nurse Review, what are your views on the future design of the institutional research landscape?

The proposed changes do not appear to do anything to strengthen the links between teaching and research – if anything, splitting HEFCE’s functions up so that research becomes focused in a single organisation while a separate Office for Students handles the TEF would have the opposite effect.

It may appear conceptually more straightforward to have both QR research funding and the Research Councils in the same organisation, but the complexities of ensuring functional (and political) separation between the two may prove to be no more efficient than the current system and thus produce no administrative savings.