QAA opened a consultation in April 2024 proposing a revised model for the UK Quality Code for Higher Education.
The revised model represents a significant change to the 2018 version of the Quality Code, offering providers more information when considering their approach to quality and standards. The proposal includes a new structural model and a revised approach to the Sector-Agreed Principles and Key Practices.
The consultation ran from 8 April 2024 to 17 May 2024.
Our response
In our response, we recognise the need for unification in the higher education quality landscape across the UK nations, as well as futureproofing to ensure that the Code remains fit for purpose for the maximum period before requiring further large-scale review.
IHE members have not indicated any concern with the overarching Principles in relation to provision on the FHEQ. Members are very welcoming of the new Code in their work with qualifications on the FHEQ, viewing it as another helpful mechanism for checking their approaches in key areas, to be deployed in the ways they see most useful for enhancement.
However, we noted a general lack of perceived applicability of the Code from members who offer programmes on the RQF. As such, we are hesitant in supporting a framing of the Code as applicable across tertiary education. As it cannot be used equally in all tertiary settings, it does not seem appropriate to rename the Code as proposed.
Some members in England raised concerns over potential tensions between expectations in the Key Practices, and other external expectations, namely the Office for Students (OfS) conditions of registration. IHE members are predominantly SMEs and it is likely that these small teams do not have the staff resources to dedicate to meeting both external requirements, such as those for OfS registration (key to meeting internal targets), as well as electing to map their practices against the Code (seen as elective by IHE members in England who are focused on meeting Designated Quality Body needs).
The duality is further complicated by the lack of common terminology between the English regulator and the QAA. IHE understands that QAA has chosen to align terminology with European Standards and Guidelines, and plans to undertake mapping between the Code and the OfS regulations to help with this divergence in terminology. Providing mapping of this nature will be incredibly helpful for maintaining engagement with the Code.
We also raised the following points on behalf of members:
- While the Principles and Key Practices provide a framework and supporting structure, it will not be enough without accompanying advice and guidance, which is still due for creation.
- Advice and guidance should be carefully worded to ensure that a range of approaches is established as acceptable for meeting sector alignment to the Principles, which takes into account those in partnership arrangements or with nuances of provider type.
- QAA membership should not pose a barrier to gaining access to the full advice and guidance on the Code. Such guidance will be particularly useful for those taking their first steps in the higher education regulatory system (not yet ready to embark on QAA membership).
- IHE members continue to hope for a return of the QAA to the role of DQB in the future, should this become feasible.
Read our full response using the download link below.