Alex Proudfoot, Chief Executive of Independent Higher Education (IHE), said:
"For policy more than a year in the making, this is a deeply disappointing announcement which leaves critical questions from our members unanswered, while the compliance clock ticks ever closer to midnight. The ‘new’ approach to regulating quality confirmed by OfS fails to understand the generational challenge facing higher education and shows no sign of rising to the moment to support the transformation, innovation and experimentation the sector urgently requires.
"Cookie-cutter processes and metrics built for large universities do a disservice to the diversity and dynamism of the English higher education sector. TEF has never worked for small providers, but the answer to limited datasets cannot be to just not award a rating at all. This will put specialist providers and those in an early stage of development in the same position as large, established institutions who have failed to make the grade. It will also silence the student voice in a significant number of cases. Neither outcome should be acceptable.
"The Government has clearly signalled that it wants more specialisation and collaboration from higher education providers, but this 'integrated' quality system will have the opposite effect. We have repeatedly offered alternative models to better achieve these aims, but OfS has taken a year to dismiss them out of hand. This is not the way to drag an underperforming regulatory system up to the standard of efficiency, proportionality and collaboration that the sector requires.
"The truth is that small and specialist providers comprise more than half of the OfS register today, no matter how inconvenient this might be for the regulator. Growing numbers also specialise in work-based learning, yet they will have to wait for any hint of detail on how apprenticeships might be assessed. These often industry-leading and innovative institutions cannot simply be an afterthought.
"Fundamentally, we are concerned that OfS is chasing a simple solution to a challenge in which complexity is unavoidable and sophisticated regulation is what is required. Providers and students alike deserve an assessment framework which is both proportionate in its approach and generates real insights into the quality of provision on offer at all providers.
"Plans to make TEF the gateway for other benefits such as Degree Awarding Powers (DAPs) and the Strategic Priorities Grant underline the importance of getting this right. The very providers who will use DAPs to innovate and respond to fast‑changing economic needs are those most at risk if the system fails to contextualise where data is unavailable. Perhaps the technical consultation can clarify how this new approach will not discriminate against and stifle innovation, but the signs today are far from encouraging."