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The following is the University's response to the QAA's consultation document which was approved by the General Board after consulting Faculties and Departments.
The proposals in the consultation paper rest on a number of assumptions which need to be challenged.
The document takes as its starting point the Dearing and Garrick Reports, which it rightly says outlined a model for assuring quality and standards in UK higher education and suggested that the QAA should manage its development and implementation; what Dearing surely did not have in mind was the creation of an immense bureaucratic super-structure as is now suggested.
Regrettably, the consultation document is selective in its references to Dearing. Where, for example, is there recognition of the following statements in paragraphs 1.6 and 10.6 of the Dearing Report?
| 1.6 | Institutions of higher education do not and will not fit into simple categories: they do and will emphasize different elements in their chosen purposes and activities: they are and will be diverse. Those which already have an established world reputation should be able to retain their distinctive characters: there should be no pressure on them to change their character. Their aim should be to sustain their outstanding achievements in research, scholarship and teaching. |
| 10.6 | Institutions of higher education and their staff have demonstrated great commitment to ensuring the quality of provision over the last decade, at a time of an expansion of student numbers unmatched by increases in funding. Indeed, the systems in the United Kingdom for assuring the quality of higher education provision are among the most rigorous in the world. |
The whole tenor of the consultation paper runs entirely counter to Dearing paragraph 1.6 and pays scant attention to, and shows little understanding of, the circumstances of institutions such as Cambridge, whose structure and systems may be unusual but which by all the measures applied have repeatedly demonstrated the richness of their teaching provision, the intellectually challenging nature of their courses, the depth and breadth of their curricula, and the high standards maintained. The proposals of the QAA are alien to the character of the University and carry pressures which could seriously damage the flexibility and diversity which is a particular strength of Cambridge; they would certainly be unprofitable for a University such as this.
The thrust of the QAA paper is that present quality assurance arrangements in institutions generally are flawed and that a single system with standardized procedures is therefore necessary. The Dearing Report clearly did not believe that this was the case, and, while it did state that the expansion of student numbers had put the system under strain, it went on to say: 'In some areas professional bodies are expressing concern about present arrangements. There have been a few highly publicized cases where concerns exist about the adequacy of arrangements to ensure that quality and standards are safeguarded where an institution franchizes programmes to another, whether in this country or overseas'. The key words here are 'In some areas' and 'a few highly publicized cases'. Dearing recognized the fact that throughout the sector there are universities, such as Cambridge, which, long before the QAA was a gleam in the eyes of the Joint Planning Group chaired by Sir William Fraser, have been and still are fully committed to maintaining and developing arrangements to ensure that education of the highest quality is provided at both undergraduate and postgraduate level. This is a far cry from what is now proposed. Instead of seeking to develop arrangements which would be applied selectively as required, the QAA is proposing a single bureaucratic system which treats all institutions as if they were the same. Paragraphs 16 and 31 of Part I of the consultation paper refer to the possibility of differentiation of approach to reflect the relative strengths and weaknesses of institutions, but this is a very limited concession since it assumes that all the apparatus of qualifications frameworks, templates for programme specifications, subject benchmarks, and codes of practice will operate for the system as a whole. As a means of fulfilling the purposes of external quality assurance, a single system for a diverse sector is a contradiction in terms and is not feasible; indeed the continuing drive towards uniformity which characterizes the consultation document is totally inimical to the diverse nature of higher education, notwithstanding the statements in the paper about the importance of maintaining diversity. Paragraph 10.8 of the Dearing Report referred to the 'need to develop quality assurance practices which allow for diversity throughout the system, yet ensure that diversity is not an excuse for low standards or unacceptable quality'. In seeking to construct a single system, applied to all institutions alike, the QAA has lost sight of this injunction in Dearing concerning practices, and apparently refuses to acknowledge that there are institutions whose systems are robust and whose excellence in teaching is widely recognized within the United Kingdom and internationally.
Nor can a single system as envisaged in the consultation document be cost-effective. Basically, the QAA should not be spending public money in imposing time-consuming and costly bureaucratic processes on institutions where all the evidence is that provision is known to be strong. This must be especially true at a time when resources are scarce.
We would urge the QAA to rethink its strategy in the light of the points set out above. It would be nothing short of disastrous if the system proposed, which seems essentially concerned with lowest common denominators, 'with protecting the public at home and abroad from shoddy goods' (Times Higher Education Supplement, 17 April 1998), were to have the effect of crippling those institutions whose expectation is excellence and whose performance is outstanding. There is a serious risk that the present proposals would do just this.
Individually, the proposals for qualifications frameworks, templates for programme specifications, subject benchmarks, and codes of practice may conceivably have some merit for some institutions, but taken together they undoubtedly lead firmly in the direction of a national curriculum for higher education. It would be only a short step to central dictation of the structure and content of teaching programmes, courses, and assessment methods. Anyone who has a genuine interest in the future of UK higher education would surely agree that it is vital that any movement in this direction must be arrested before it gains the slightest momentum. As has been said so often, diversity is a great strength of the British system and we are not at all reassured by statements in the consultation document that diversity and innovation will be accommodated. On the contrary, the proposals have the appearance of being excessively prescriptive in terms of rigid specification of the scope and content of courses. In addition, the underlying implication of the document is that standards should be the same at all HEIs across the country. This clearly is not, and should not be, the case. If they were the same, either the best students would not be stretched intellectually or others would be deterred from entering higher education.
The final report of the Joint Planning Group stated that the national quality assurance process for which the Agency would be responsible should operate as cost-effectively as possible. Paragraph 15 of the present consultation paper mentions a concern to reduce costs and indicates that this, together with the general purposes of quality assurance and a reduction in the burden of external scrutiny of institutions, is a factor against which the model should be judged. Sadly, we have yet to see a serious attempt to address the issue of costs and, particularly when higher education is expected to produce more with fewer resources, the time is now long overdue for this matter to be examined in detail. Apart from the direct and continuing costs associated with the Agency itself, the procedures, the documentation, the visitations, etc., there are the immense costs for institutions, both financial and educational. For example, the consultation paper discusses the role and duties of members of subject benchmarking groups and registered external examiners (REEs); some quantification is attempted of the demands upon their time, but uncertainty is admitted even in this limited context. However, the fact is that the hidden cost to UK scholarship and research is impossible to quantify, and this appears to have been ignored entirely. Paragraph 8 of Part VI of the document states that the Agency intends to resolve a conundrum relating to the validity of the Codes of Practice. A more important task for the Agency would be to face up to one of the dilemmas epitomized in the consultation document, namely that the exponential increase in the work involved in the processes of accountability further reduces the amount of time available to academic staff to deliver effectively the product for which they are supposed to be accountable. We believe that the latest proposals raise the spectre of the accountability process submerging the delivery of effective teaching. This would be to the detriment of the student learning experience.
For a national consultation concerned with quality and standards in higher education there are two glaring omissions:
| (i) | Notable for its absence from the document is any academic content. Particularly unfortunate is the fact that there is no mention of research and no apparent understanding of the importance of active research in university teaching. This ignores the fact that there are universities, such as Cambridge, where teaching and research are bound together inextricably and where the student learning experience is informed and greatly enriched by staff research interests, many of which are at the frontiers of knowledge. |
| (ii) | The QAA document betrays little sign that the issues considered have been thought through in an international context. What other assessment models might be taken into account? If there are to be benchmarks should they not have an international dimension? Questions such as these appear in themselves to be grounds for not rushing into an as yet ill-considered scheme whose imperfections are already evident. |
As has been the case in previous documents issued by the HEFCE and the HEQC in recent years, the consultation paper pins considerable hopes on the prospects for reducing duplication of effort by better co-ordination of the review activities of the Agency and of professional and statutory bodies. On the face of it this has much to commend it, but on closer examination of the different purposes of these exercises there is considerable scepticism that this can do much to reduce the load on institutions, and in some subjects at least the kind of collaboration referred to in paragraph 16 of the document is not feasible in practice. If there is to be a serious effort to reduce the burden of external scrutiny and to adopt a differentiation of approach to reflect the relative strengths and weaknesses of institutions, the Agency must explore alternative approaches to make the best use of the internal quality assurance arrangements of universities. Most if not all institutions have internal review procedures, and the way forward may reside in seeking to employ these by adding an appropriate level of externality (see our comments on Part VII below).
We support the proposition that there should be a more differentiated approach in external scrutiny, but we believe that this should go further than variations in the frequency or intensity of scrutiny. Such an approach should allow for flexibility with regard to all aspects of the model for quality assurance. In the words of paragraph 17 of the QAA's own response to the Dearing Report, the process should be 'tailored to the needs of the individual institutions'. If this were to be at the heart of the new system it would be possible for the Agency to discuss with universities on an individual basis the most satisfactory means of working with the internal processes of institutions within a very broad framework.
Paragraph 11 of Part I of the consultation paper states that the Agency will wish to consider ways to take account of student and employer views in its assurance process, which could include use of statistical data such as the first destination of graduates. In our experience, this has always been well covered by the TQA exercise. Each team which has visited this University has been provided with comprehensive statistical data and other material produced by our Careers Service, has met a member of that Service, has met groups of students, has received completed student questionnaires and analyses of them, has received employer comments, and in some cases has met representatives of major employers. If the Agency were to operate on the basis of the suggestions made above about the internal processes of institutions we have no doubt that there would be ample opportunity for the views of students and employers to be taken into account.
Part I of the consultation document concludes with an outline timetable. We regret that development work in some areas had already been initiated before the consultation paper was issued, and we are particularly dismayed that trialling of the ill-advised scheme for registered external examiners has already been set in motion. While we acknowledge that the Agency may be under pressure from government to demonstrate that it is making progress, the proposed timetable gives the strong impression of rushing headlong into radical change for the sake of it. On matters which are fundamental to the future of UK higher education, the over-riding consideration should be that a new national system of quality assurance must be evolved carefully through extensive consultation and debate with all interested parties; if the Agency gets it wrong, the consequences could cause serious damage to systems which, as the Dearing Report said, 'are among the most rigorous in the world'. We would therefore urge the Agency to take more time to consider, in consultation with the sector at all stages, the implications of its proposals. If this means that it takes a year or two longer to introduce new arrangements, then so be it. What is this in the historical time-span of UK higher education?
The section of the consultation paper concerned with the qualifications framework seems to us to be a particularly obscure area. On the one hand, the entire framework is based on modularization and credit accumulation. On the other, the specimen programme specification template appears to imply that institutions might or might not operate such a scheme. Different universities have responded to modularization and the accumulation of credits in very different ways; it is difficult to see how a national credit accumulation scheme would be readily compatible with the Cambridge concept of accumulation of Honours in a sequence of Tripos examinations. Much would depend on the 'grain' of the components of a framework. If very fine-grain, it could destroy the capacity of institutions to self-regulate. If coarse-grain (but still providing a sufficient basis for some credit transfer), it might carry advantages. Clearly, it is of great importance to us that Cambridge students should be able to benefit from the opportunities offered by periods of study in centres of excellence elsewhere (including overseas) if we are satisfied that suitable arrangements can be made, and vice versa for the students of such institutions.
Although the document refers to flexibility and diversity in the frameworks, we are greatly concerned that the language primarily has regard to skills training rather than to education in its wider sense. The diversity to which reference is made seems to be on a horizontal level only, being concerned solely with variety of subject content and not with intellectual depth.
The issues raised in paragraph 19 simply highlight the extreme difficulty of developing frameworks which can successfully deal with the entire higher education sector, and we are not at all convinced that it will be fruitful to spend further time, money, and effort in attempting to do so. For our part, we would not accept that there is confusion among stakeholders (students, employers, etc.) about the nature and level of Cambridge qualifications. The evidence is that they are well understood.
It is, of course, absolutely basic in any well-run university that students and other stakeholders are provided with comprehensive and accurate information in prospectuses, guides, and other documentation about the purposes and objectives of programmes and qualifications and about courses, subjects, assessment methods, and so on. Not to provide such information is unthinkable and we believe that, in addition to our general University literature, our Faculties and Departments do this successfully, a view which has been shared by successive teams of quality assessors. In our judgement the arrangements for providing full and up-to-date information of this kind are not improved or assisted by the production of a programme specification template. On the contrary, such templates serve only to impose artificial constraints on the description of courses and as such are not specially helpful to students. A skeleton list of headings might possibly serve some purpose, but the headings and format must not be prescriptive, and each course description must refer to a source where a more detailed and useful description can be found.
The draft template in Annex A of the consultation paper reinforces the view that much of the quality assurance model proposed is an exercise in pure rather than applied bureaucracy. The kind of cognitive skills referred to in section 6 of the template, for example, could be said to result from any learning process from nursery education upwards. The same is true of section 7. In practical terms, the kind of paper-specific information on criteria used for marking and assessing aspects of the University's courses is infinitely more helpful that the kind of template suggested. The unsuitability of the scheme for a system such as the Cambridge Tripos system is hinted at in paragraph 10 of Part III: 'The ability of a specification to represent an individual learner's programme diminishes as the amount of student choice increases'. It is also surely the case that a template which did not stifle innovation and change would inevitably (and particularly in a two-page A4 format) be so generalized and bland as to be unlikely to fulfil even the minimal objective of providing useful information for potential applicants.
We therefore feel strongly that it would be a retrograde step to require universities to provide information in the form suggested in Annex A, and there should be no expectation by the Agency that a template of this sort will be used. If some institutions believe that the template improves their arrangements they should be free to use it.
Apart from these observations, we feel that since subject benchmarking groups have already been set up in Chemistry, History, and Law it would be inappropriate to comment further until these groups have brought forward proposals. We trust that their findings will be distributed as soon as they are available and that there will be a reasonable consultation period in which institutions will be given sufficient time to consult internally and to submit detailed comments which can make a real impact on the outcome.
Paragraph 21 suggests that it may be possible for institutions to develop their own codes independently of the Agency. On the assumption that for the institution concerned such an arrangement would be in place of a generally applicable national code, this is an option which we would wish to discuss further, and with that in mind it does not seem relevant at this stage to comment on the proposed form of a code and whether it is a single document with sections rather than a series of codes.
With regard to the proposed form of consultation for a code, detailed discussion of draft texts with active practitioners drawn from the sector and with relevant expertise will certainly be needed, but this should not take the place of extensive consultation with universities directly, not just at the end of the process but during it.
Paragraph 20 of Part VI refers to the fact that Dearing envisaged that institutions should be required to 'adopt' the codes of practice and that compliance with them should be verified through the institutional review procedure. It is not at all clear what sanctions would be applied for non-compliance and this perhaps explains the opening words of the next sentence in paragraph 20: 'If this process is to be followed ....'. Clearly, it would be essential for there to be a period of grace from promulgation to adoption. In the absence of more detailed information about the form of the sections of a code, it is difficult to say what period of time would be required, but the list of sections identified in paragraph 14 suggests that eighteen months might be more appropriate than one year. This period of grace in itself is an example of how the diversity of the sector must be respected to take account of differences in structure and organization.
Our first comment in relation to this part of the QAA document is that the use of the word 'strengthening' in the title is wholly inappropriate; we cannot accept the first sentence of paragraph 9, which suggests that the 'system worked reasonably well ... when the sector was relatively small and relatively homogenous'. It may be the case that for some institutions the external examiner system is in difficulty but for Cambridge, and we believe a substantial number of other universities, the current arrangements for external examiners continue, as they have in the past, to work extremely well.
The intentions of the QAA in relation to its proposals for the future of external examining are stated in paragraph 11 of this section, which refers to moving the higher education sector from a position in which academic standards are determined by institutions to a system in which there is collectivity in the setting of standards, to be vetted and calibrated by registered external examiners (REEs). If common standards are the goal, it is extremely difficult to see how this could be achieved through a system of REEs who, we believe, would be in no position to make consistent judgements and meaningful comparisons across the sector. Furthermore, as we have already indicated (see paragraph 2 above) we do not accept that standards should or can be the same. Certainly, there are some standards that it is reasonable to expect should be uniformly high in all institutions (such as those applying to student support and guidance) but there are also standards (such as the academic attainment levels expected) that cannot be common in a diverse sector. As Professor Lewis Elton said, in a recent article in Studies in Higher Education, degree programmes have diversified to a great extent in recent years, with the consequence that the concept of a common standard is becoming increasingly problematic. We would go further and say that it is unattainable, and is in fact contrary to the aims of a sector catering for the diverse needs of students.
We greatly value the external examiner system and believe that it is vital to have the independent view which external examiners bring to the University's examination process and to our quality control arrangements. Our view is that the main role of external examiners is to ensure that examination and assessment procedures are equitable and are fairly operated in the classification of students, and that the standards of our degrees and other awards are comparable with those of institutions of a similar academic level. For this purpose, we expect our external examiners to participate fully, with the internal examiners in each subject, in the approval of question papers, the definition of appropriate class boundaries, the assessment of results, and the adjudication of difficult and borderline cases. In addition, the University's letter of appointment to external examiners invites them to comment on a wide range of questions connected with their functions, such as the balance, content, and structure of courses, teaching quality and methods, the nature of the assessment procedures, marking standards, the quality of students' work and the degree classes awarded, and the general conduct of the examinations. To enable external examiners to fulfil their role, detailed information about the relevant courses, examinations, marking schemes, and classing conventions is made available to them. The reports which are sent to the Vice-Chancellor by external examiners each year demonstrate the importance of their contribution in Cambridge and this fact, together with the scrupulous manner in which the reports are considered and acted upon, both centrally and in Faculties and Departments, is frequently commented upon by the quality assessors.
Although the proposal now made in Part VII shows considerable modification compared with an earlier idea for a national register of external examiners, we remain totally opposed to any scheme which would involve even some external examiners in the policing role of being accountable directly to the QAA. If pursued, this proposal would seriously undermine the external examiner system. The large number of external examiners whom we engage each year draws on very senior and experienced academics, who are eminent in their fields and command respect in their disciplines. In our view it is virtually inconceivable that any significant number of academics 'who can command the respect of their peers' (paragraph 16) would wish to take on the functions prescribed for the REEs, particularly given that the commitment would no doubt be at some point between the 10-15 days which the QAA has suggested, but which seems quite unrealistic, and the 60 days proposed by Dearing, which for other reasons was even more unrealistic. Thus, we believe there would be a serious recruitment problem in obtaining the right kind of people to become REEs. This could well have 'knock-on' effects for external examining generally, in reducing the number of staff of high calibre, active in their field, who would be able and willing to give their time; this seems a particular danger in the light of the phrase at the end of paragraph 16: 'the Agency hopes that institutions would increasingly require membership of the register for all external examiners', which, notwithstanding the more limited application of REEs in the short term, appears to be a statement of intent for the future.
One of the most important reasons for the fact that external examining works well and is a rigorous process in Cambridge, and in other universities, is that it is based on goodwill, mutual trust, and shared responsibility. This relationship would be subverted by the policing role associated with the proposed REEs. It would almost certainly lead to much more bland reporting by external examiners as a result of their apparent dual function, and this would have most unfortunate consequences for a central aspect of the internal quality control processes of institutions which at present is highly valued. A system of REEs would also create a barrier of suspicion and mistrust, and this would apply not only in the years of the cycle when the QAA would expect REEs to report officially to them. It seems clear from paragraph 22 that REEs will have a role in intervening years and will have an obligation to report misgivings about quality or standards directly to the QAA. REEs will therefore always be perceived as potential policemen. For these reasons we feel strongly that the QAA's proposals would be entirely counter-productive in relation to the internal quality assurance arrangements of institutions, which were aided in their development by the helpful guidelines on external examining issued by the CVCP in 1989.
Paragraph 27(iii) admits that 'there are many unresolved practical and logistical issues to do with the recruitment, training, and development of the REEs'. There are indeed many such issues and we would suggest that the QAA should abandon this idea and turn its thoughts to other ways of working with the existing processes of institutions. In fact, paragraph 27(iv) suggests that it may be more appropriate to retain the existing relationship between institutions and external examiners, with some strengthening of the system. It appears to us that this line of thinking is more likely to lead to a productive outcome, and we would suggest that the Agency should examine this further in consultation with institutions.
Another idea which may be worth exploring is that described in outline in paragraph 20(ii), but only provided that the reference to REEs is removed. Virtually all institutions have their own internal review procedures, although no doubt there are many variations in the precise form of these. A national list of academic reviewers on whom institutions could draw might not only serve a QAA purpose but might also be of assistance to universities. The idea in its present state is embryonic and would require detailed consideration but, if the Agency does wish to reduce the burden of scrutiny on institutions and at the same time to meet the range of quality assurance purposes and stakeholders' requirements, and to provide public information about students' learning experiences at subject level, it is one that should be examined carefully.
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