Green Paper response from The University of Nottingham


January 18th, 2016

A message from Dr Paul Greatrix, Registrar of The University of Nottingham

We have now submitted The University of Nottingham response to the Green Paper and the Nurse review. In our response we especially welcomed the Government’s explicit commitment to excellent research, the dual support system and the Haldane Principle.

The Green Paper’s ambition to put students at the heart of the system mirrors The University of Nottingham’s aims in this regard. We see excellent teaching both building on and being fundamentally linked to excellent research and this is why we value both so highly.

A few specific points from our response:

High Quality Teaching

The central point for us is that we and other research intensive universities already deliver high quality teaching which we can evidence. In the light of this, it is noticeable that the evidence cited in the Green Paper for there being a problem in regard to teaching quality is far from robust. We are now in a position where high quality teaching should be a given as being core to university operations. There is therefore no need for carrots or sticks, i.e. financial incentives, fee-setting entitlements or reputational risks, to incentivise our interest in teaching quality. Market forces operating by themselves will perform this function, particularly if the fee cap were to be removed without the need for the bureaucracy of the Teaching Excellence Framework (TEF) to be attached to that removal.

Teaching Excellence Framework

There are many unanswered questions about the TEF which cause us concern about how it will be implemented in practice, what it will actually achieve and what the outcomes will mean. A threshold judgement on the quality of an institution’s provision (as currently provided by QAA Higher Education Review) does have a clear safeguard function, but multiple tiers as suggested by the TEF is highly problematic – both in terms of what it achieves and the use to which it might be put. The unintended consequences of negative labelling are particularly worrying. What, for example, will be the impact on international recruitment to UK HE if only a fraction the country’s output in this sector is described as being ‘top tier’?

In advance of the technical consultation we would therefore wish to record some profound reservations about some of the possible metrics for the TEF, with the main concern being that they do not help indicate teaching quality.

Research

We would strongly reinforce the absolute importance of QR remaining a separate, distinct and protected funding stream so that dual support remains intact and is not eroded over time. In order to embed dual support fully in the new system we would advocate that the two funding streams are clearly established in legislation through an act of parliament.

In STEM subjects we support work to validate the use of metrics in the assessment of outputs. In other subject areas the use of metrics is a poor surrogate measure of quality and peer review remains essential. Because of this challenge it would be difficult to extend the use of metrics beyond that used in REF 2014 for the arts, humanities and social sciences and also in judging the quality of interdisciplinary research or in new fields of inquiry.

Maintaining the approach used in REF 2014 would help reduce the burden on institutions in preparing for REF particularly with regard to impact which as a new aspect for REF 2014 created a significant burden in preparing for a new aspect of assessment. Longer time intervals between assessments and delaying the next REF would also help to reduce burden and cost to institutions. A single environment submission per institution could also assist with reducing burden.

The Green Paper proposes to split responsibility for research funding (QR) and teaching funding, which both currently sit with HEFCE. It will be difficult for two bodies jointly to model the impact of changes in teaching and research funding at an individual university level. It also unhelpfully signals a separation between research and teaching, which should be linked closely.

Regulatory Framework

Although we have substantial reservations about aspects of the current Quality Assurance (QA) architecture, we believe the Quality Assurance Agency (QAA) serves a valuable purpose in terms of reassuring everyone in this country and overseas about the quality of UK HE. It is also important to separate the funding of HE from the assurance of quality and this would be achieved by maintaining the QAA as a separate body.

There is a distinct need to reduce the QA burden and the overall regulatory burden on universities. We are therefore gravely concerned that the TEF proposals would seem to go in the opposite direction, adding new layers of regulation on institutions while taking little away. The regulatory framework needs to be risk-based and proportionate. New entrants and high risk providers need much greater scrutiny than long-established and high quality providers.

These points and many more detailed comments are made in the submission which you can view and download here (PDF).

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