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Department of Business, Innovation and Skills Green Paper - Higher education: teaching excellence, social mobility and student choice

The Department of Business, Innovation and Skills has published a green paper and consultation on its proposals for Higher education: teaching excellence, social mobility and student choice. Details of the consultation can be found on the Government website. The submission was in the form of an online form where not all questions were answered. The submission produced jointly by the Geological Society and University Geoscience UK can be found below:

Submitted 12 January 2016

Public sector equality duty

Question 1:

a) What are your views on the potential equality impacts of the proposals and other plans in this consultation?

This submission has been produced jointly by the Geological Society of London and University Geoscience UK.

Diversity, inclusion and equality are important components of the work and future strategy of the Geological Society and of University Geoscience UK. Improving diversity and inclusivity in geoscience education is vital to the strength and diversity of the future geoscience workforce, to the benefit of the UK’s future prosperity and wellbeing. The terms diversity, equality and inclusion are not interchangeable and have different meanings in different contexts. The content of the paper implies that diversity in what is offered by the higher education sector will necessarily lead to improved access and equality of opportunity. While increasing the diversity of market offerings might lead to a more effective or efficient market, this does not necessarily translate to an improvement in real access, diversity of the student body or student inclusivity - though we note that the stated aim of the paper is wider participation in higher education to drive social mobility.

b) Are there any equality impacts that we have not considered?
☐ Yes ☐ No ☐ Not sure
Please provide any further relevant evidence.

The exact equality impacts of the outlined proposals are impossible to know in advance of implementation as is the case with many new policy proposals. Meaningful understanding of the impacts requires building monitoring mechanisms into the policy proposals to measure the impact of the proposed metrics for potential biases as they are applied. One particular area where our respondents raised concern over impact was on the implementation of the Grade Point Average as a description of students’ performance. The detail on this in the document is not clear. If the intention is to place equal weighting on all modules and each stage of the degree then this could disadvantage students from backgrounds where going to university is not the norm. These students may struggle more in the first year in comparison to later years and with equal weighting there would be no way to make up for any early teething problems.

Teaching Excellence Framework (TEF) (Part A: Chapters 1-3)

Question 3:

Do you agree that the ambition for TEF should be that it is open to all HE providers, all disciplines, all modes of delivery and all levels?
☐ Yes ☐ No ☐ Not sure
Please give reasons for your answers.

We agree in principle that if implemented, TEF should be open to all disciplines at all levels.

If it is to be successful, as proposed, it is important that this quality assurance work is done primarily at subject level. Different disciplines have different epistemologies, which require different pedagogies and have different learning outcomes which in turn require different assessment methods. Effective assessment of teaching excellence, if these variables are to be recognised, needs to be extended to individual disciplines.

If teaching excellence is also to be assessed at an institutional level, it makes sense to aggregate up from the subject level. However there are some pitfalls to this approach. Some quality-related aspects of higher education provision are controlled institutionally (such as learning facilities) and others are entirely discipline related. In order to reflect this dichotomy, the TEF should incorporate institutional level factors as well as separate discipline level assessments. Assessment of TEF at institutional level should also make publicly available metric data ascribed to individual departments and subject assessments. This would ensure that data on excellence in a given subject is not hidden by the overall level of institutional award.

We are concerned that the quality of data currently available for individual subjects may be insufficient to prepare discipline level assessment. Currently, for instance, data compiled by the Higher Education Statistics Agency (HESA) groups geoscience with oceanography and environmental science. These subjects vary from geoscience in terms of content, application and graduate outcomes, and grouping them together for reporting purposes masks significant differences between disciplines. Granularity of data provision at programme level will be needed to ensure that genuine areas of teaching excellence might be distinguished from lower quality programmes, and that metrics are not inappropriately applied.

Question 6:

Do you agree with the proposed approach to TEF assessments on
☐ Yes ☐ No ☐ Not sure
Assessment panels?
☐ Yes ☐ No ☐ Not sure
and process?
☐ Yes ☐ No ☐ Not sure
Please give reasons for your answer.

The paper is silent about the role of external examiners in the proposed framework. We assume that they will continue to have an important role, and would support this, but given the focus on external examiners in previous consultations on this topic, we are surprised not to see them mentioned here. It is important that the relationship between quality assessment and the external examination system is clarified.

The paper notes that implementing an appeals process is still under consideration. In our view, there will need to be robust mechanisms by which, on the one hand, assessment panels can raise concerns when a particular deficit is repeatedly not addressed; and, on the other hand, a clear appeals process by which a department may wish to dispute the opinion of an assessment panel. If, after such a process, an issue had not been addressed appropriately then a flag might be triggered, requiring an escalation in the evaluation of academic standards or student experience for the programme concerned. Similar appeals and escalation mechanisms should be implemented for external examiners in respect of any future role they play in quality assessment.

Question 7:

How can we minimise any administrative burdens on Institutions? Please provide any evidence relating to the potential administrative costs and benefits to institutions of the proposals set out in this document.

The lack of detail on what metrics will be used in the TEF makes providing evidence on the potential administrative costs and benefits to institutions very difficult. Any additional burden will depend on the metrics required and the method of submission, neither of which have yet been specified. It seems inevitable that there will be additional costs associated with the administration of a TEF system, over and above that required for the current QA (which is largely based on existing documentation). There is a significant risk that the administration of TEF will become an additional burden to academic members of staff, further distracting them from the core business of teaching and research.

Requiring institutions to pick up the significant cost of TEF assessment will divert already stretched funds from delivery of primary academic objectives, and adversely affect the resources available to departments.

Question 9:

Do you agree with the proposed approach to incentives for the different types of provider?
☐ Yes ☐ No ☐ Not sure
Please give reasons for your answer.

The proposals set out on financial incentives for institutions are confusing and unclear. If the paper is intended to be a policy document to open up discussion on increasing university fees then in its current form this document is unhelpful. Discussions on levels of fees and how they might vary across institutions and disciplines are of wide interest to academics and others. Several of our respondents have raised issues on this matter in their communications with us, including some who would like to see the cap significantly lifted. Possible changes to the policy on tuition fees requires a detailed and broad-ranging public consultation to consider all impacts of a change in policy and all the dimensions across which fees might be differentiated (e.g. type of institution, discipline, various performance measures and proxies). This will not be achieved through presenting changes as an afterthought to a consultation on teaching excellence.

Some of our colleagues believe that it would be better to focus on reputational incentives rather than financial. Elite institutions are not likely to become strongly engaged through the financial incentives proposed here as the available increases will be fairly insignificant compared to the other resources available to them. In contrast all institutions care about their reputation. Additionally, the application of financial penalties in the case of a programme or institution failing to maintain appropriate academic standards would potentially make it more difficult to re-establish the teaching quality that is aspired to. If a department or institution, through a risk-based QA process, were found to be wanting over a period of time and despite having been given the opportunity to respond to identified shortcomings, then a more robust approach would simply be for degree-awarding status in the particularly subject area(s) to be suspended until it were established that a teaching team were in place that could reasonably be expected to achieve and maintain the requisite curriculum and student experience.

Question 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?
☐ Yes ☐ No ☐ Not sure
Please give reasons for your answer.

In our view, it would be essential to allow institutions to submit supplementary evidence. In the current system, there are many examples of good practice being conducted in the reviewing of course structure and content. External consultations, including with employers, are routinely carried out to aid in the course and curriculum design and implementation process and these could be formalised within the TEF system.

We welcome the recognition of the important role that Learned Societies, PSRBs and employers can play in course design, delivery and accreditation. The Geological Society has a well established scheme to accredit undergraduate and postgraduate geoscience degrees. Our accreditation scheme, in itself, draws on both metrics and qualitative information. The range of evidence used includes QA reports, career progress data, institutional facilities, programme specifications and programme assessment methods, quantity and quality of field work and external examiners’ reports. In subjects where there are already existing, robust accreditation schemes they could be a useful and important part of the basis for the proposed quality assessment at the subject level. The Society scheme is a well developed, fit-for-purpose scheme which is built on our expertise in geoscience education and the needs of employers in our sector. Incorporation of the work of accrediting bodies could be a useful addition to the QA framework, providing that the burden of administering accreditation does not increase significantly. Change which increased this burden would result in increased administration costs, which accrediting bodies would in turn have to pass on to universities seeking accreditation. We would be pleased to provide further details of our accreditation scheme or to discuss in greater detail how this and similar schemes might support a future teaching QA framework.

The current proposals relate to degree providers in England only whereas most organisations administering accreditation do so for England and the devolved nations of Wales, Scotland and Northern Ireland, as well as overseas. Accreditation schemes will need to continue to be sufficiently flexible to accommodate departments outside England.

Regarding the proposal to use employment and destination metrics; we are concerned that metrics based on employment rates or salary are broadly ineffective because of the vast variation in destination choices. These problems are exacerbated by HESA grouping geoscience with other subjects as noted above, reducing the granularity of the data. There is also variation in industry and in the skills market over time and from place to place. In addition to this, even within subjects such as geoscience there are huge disparities in skills needs and variabilities in the employment market. For example, the oil, gas and minerals industries are significant employers of geoscience graduates. These industries are currently experiencing a major downturn in production and this is having a negative effect on graduate employment. At other times, this is also the case with other industries such as construction. These periodic cycles in industries, which are often out of step with one another and with the economy as a whole, may distort the data captured by employment and destination metrics.

One of the metrics discussed in the paper is that of ‘teaching intensity’. The description is not sufficiently detailed to be able to comment in detail on its impact, but if such a metric is not carefully designed there is a risk that it may discriminate again teaching staff in certain subjects. Teaching and research excellence is achieved in different ways across disciplines due to inherent subject differences. Implementation of TEF needs to include measures that are alert to these differences.

In the case of geoscience, any metric-based approach to teaching intensity will need to take account of the fundamental importance of fieldwork in teaching and research. Excellent researchers at all levels need to undertake fieldwork, often for extended periods particularly if they are working in remote locations. This aspect of their work greatly strengthens the learning experience of their students, as well as their own research. It is not always possible for staff members to restrict their fieldwork seasons to university holidays. Good departments take account of this and it is planned in to the teaching programme. Nevertheless, any metric of teaching intensity that did not take such factors into consideration (for example, a simple measure of teaching sessions ‘missed’ by course leaders) could be highly misleading.

Fieldwork also constitutes a vital part of geoscience students’ learning experience, and is a setting in which the level of ‘teaching intensity’ in its true sense is very high. An effective metric of teaching intensity for geoscience would therefore need to take into account the pattern and mode of teaching delivered in the field – factors which do not apply in most other disciplines.

Reducing complexity and bureaucracy in research funding (Part D)

Question 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 signalled change to the research funding system is a major issue in its own right: including it as an afterthought in a paper on the Teaching Excellence Framework does not allow for the broad ranging discussion required on this issue. In addition, the Nurse Review reported shortly after this paper was issued and thus the level of detail available has now significantly increased. We assume there will be substantive consultation on the proposed changes. The findings of the Nurse report and in particular how it relates to the future of the research councils and the maintenance of the dual support system will be of significant importance and interest to the geoscience community. These policy proposals require a separate and detailed consultation and thus we will refrain from responding here and wait for the forthcoming consultation on the REF.

Question 25:

a) What safeguards would you want to see in place in the event that dual funding was operated within a single organisation?

b) Would you favour a degree of hypothecation to ensure that dual funding streams, along with their distinctive characteristics, could not be changed by that organisation?
☐ Yes ☐ No ☐ Not sure
Please give reasons for your answer

In light of the findings of the Nurse Review which were published subsequent to this green paper we expect there to be a consultation on the implications of the Nurse Review and the future of the REF. We will respond to the details of the proposed changes to the research infrastructure there.

Do you have any other comments that might aid the consultation process as a whole?


Fieldwork, not mentioned in the green paper, makes up a significant part of the content of geoscience degrees and a minimum mandatory level of fieldwork is required for accreditation. It requires dedicated teaching expertise and time in the teaching schedule, and imparts skills essential to the geoscience workforce. In many respects, the field functions as the geologists’ laboratory and field courses are an essential part of teaching and learning. Fieldwork and other variables in teaching from subject to subject need to be accounted for in the TEF proposal so that the metric data is not distorted as a result. We would be pleased to discuss further the implications of fieldwork for the TEF.

Implementation of the Grade Point Average System

The introduction of a ‘Grade Point Average’ (GPA) system has significant implications for institutions, degree courses, academics and students. We were surprised and concerned to see that the green paper includes significant proposals in this area, but that these are not reflected in the consultation questions.

There is a lack of detail on the GPA and how it will be implemented but if it is applied simply and as it appears in the paper then it looks as if the plan is to treat every module at every stage in the degree with equal weight, meaning that the first year of a degree will be equal to the final year of a course. Many respondents to our call for feedback have noted that geoscience is regarded as a strongly ‘progressive’ subject where learning builds on the content of preceding years. For this reason, results tend to be biased to the final year as being the most representative of the student’s ability at graduation. At present, examiners try to take into account “exit velocity” (as described in the Higher Education Academy (HEA) pilot study). This is perhaps more relevant to geoscience than some other disciplines because many geoscience students have not come into contact with the subject prior to university. Most geoscience departments recruit students both with and without geology at A-level or GCSE; an important priority in the first year is to bring both streams of students to a common level.

There are arguments that suggest the GPA could encourage students to engage more fully sooner in their degree, but there are also counter arguments. Some respondents suggested that the GPA could dissuade students from experimenting with novel and potentially difficult topics in their first year. It may also encourage students to game the system by selecting easier modules. The Higher Education Academy did not reach a conclusion on whether using weighting was a good idea and indeed recommends further consultation on this topic. The green paper does not address exactly what is meant by the GPA or how it is computed. There are questions as to what happens to students who are on the boundary of a grade. Currently when there are (arguably inevitable) uncertainties in marking of +/- 1-2%, examiners meet to consider the students on the boundaries. How would this be addressed in the GPA system?

Some respondents commented that the GPA scheme offers little additional benefit over the existing classification scheme, and arguably none that justify the massive upheaval that its implementation will entail. In the current system, employers can request a full transcript of grades which assist them in understanding the specific strengths of the candidate as they relate to the job description. A GPA system that does not include this type of supplementary information will not be useful to employers. Applying equal weighting across degree courses will only further mask the detail required by employers.

The paper states that GPA uptake will not be mandatory. If GPA is adopted on an ad-hoc basis it will result in significant variability across the sector. This will make comparison between university results hard for all concerned, including accrediting bodies such as the Geological Society.

The Geological Society (GSL) is the UK’s learned and professional body for geoscience, with about 12,000 Fellows (members) worldwide. The Fellowship encompasses those working in industry, academia and government with a broad range of perspectives on policy-relevant science, and the Society is a leading communicator of this science to government bodies, those in education, and other non-technical audiences.

University Geoscience UK is the subject association of Geoscience (geology, applied geology, Earth science, geophysics, geochemistry and some environmental science) departments/schools based within universities in the British Isles. It promotes discussion and exchange of information between departments and provides a point of contact between these and professional, government and quality control agencies.