Bridge Group response to the Office for Students’ consultation on access and participation

The Bridge Group is pleased to respond to the Office for Students’ consultation on access and participation because accurate data and sound planning are essential to progress on socio-economic diversity and equality.

The OfS’s proposals for the regulation of access and participation contain much that is sound in principle, but for which the implementation requires careful consideration. Here some details fall short. In particular, there are omissions and inconsistencies in relation to underrepresented groups, datasets and performance measures.

Key to effective scrutiny are accurate performance measures that allow in-year reporting. Using the intake of low-income students as a measure meets both requirements, but oddly isn’t included. Instead the OfS proposes a measure based on Free School Meals (FSM). There is strong evidence that FSM criteria reduce its accuracy as a proxy for economic disadvantage in schools, while barriers such as limited language and literacy, local culture and perceptions of social stigma  all affect uptake by those who are eligible. Furthermore, FSM is at least two years out of date when students enter higher education and it is unclear how accurate the tracking of FSM recipients into higher education is. Why use this old, inaccurate and incomplete measure when Student Finance England assesses household income at entry?

There are some unexpected omissions in relation to underrepresented groups and datasets. Men are included in neither, despite the growing gender gap. (Mark Corver reported recently that in 2018 the UK entry rate for 18-year-old men was more than ten percentage points below that of women: 27.8% compared to 38.1%.) While low-income students and care leavers are named as underrepresented groups, they are not included in the dataset. When low-income students collectively received £418m in university bursaries in 2016-17 and more in additional Government loans, is it not incumbent on the OfS to monitor them? There also seems to us to be a duty to include students on Access and vocational pathways, to enable OfS to track the impact of national policy shifts and qualification reforms affecting these students.

OfS should work closely with individual Higher Education  Institutions (HEIs), UCAS, and the Office for National Statistics to identify an appropriate measure on place to build understanding of the way it influences participation and success. With increasing numbers of students choosing to study close to home, alarm bells ring for those who live far from HEIs or have limited choice.

One surprising proposal is that annual action plans are not universally required. The emphasis instead is on annual impact reports, but few HEIs will volunteer to discuss in a public document what didn’t work. Linking action plans, past and present, to the impact report would help to address this: HEIs would report what impact key actions had had on the issues they were seeking to address, then confirm in the action plan for the next year whether it would continue or change current actions. (Often there won’t have been an impact, despite sensible actions, but that’s helpful for the sector and those regulating it to know. There are difficult issues for which there is no quick fix.)

There are positives, for example the proposal to disaggregate outreach spend by age group. This should help to focus attention on the need for more investment in work with younger and mature students. And it is right that OfS is still examining outreach spend: in this area, relying on meeting outcomes as an incentive is likely to result in a focus on easy wins and institutional recruitment. However, abandoning the requirement to report spend on student success and progression is also eminently sensible. The link between outcomes in success and progression and the Teaching and Excellence Framework provides an excellent incentive for HEIs to improve.