Noting that the HE press has already commented that the new strategy is as much about ‘how’ the OfS regulates as ‘what’ it regulates, we offer some initial thoughts on what this could mean for our member institutions – and where the real opportunities lie.
Quality
What’s encouraging about the quality section is that it’s grounded in student consultation and aims to build on ideas and initiatives which should have worked before – but this time with teeth. While some of the proposed actions are aspirational, the roadmap points toward defining what good actually means in practice and responding to what students are telling us, working in alignment with the headlines from the recent White Paper. From our work with institutions, we see a renewed focus on quality questions – particularly around understanding the factors which influence student decision making.
Student experience and support
Again, the roadmap and actions offer clarity and focus on a smaller number of priorities with an indication of more collaborative relationship building from the OfS. Much here positions the OfS as a broker, co-ordinating between students and institutions, but the kicker comes with the promise of strengthened regulation and expanded powers for the OfS. However, there is a helpful combination of continuation and regulation, as the OfS uses data to both empower and protect students while supporting institutions to address areas of concern.
Sector resilience
Of the three themes, this signals the most significant potential change. While the opening text may underestimate the work the sector has already done to address their financial challenges and transform operations to prevent financial risks from crystalising, the actions aim to balance planning for the worst while hoping for the best. The focus on governance clearly responds to the Gillies Report and recent concerns around partnerships so again, there is focus but not clarity – though the devil will be in the detail. The OfS has long grappled with how to tread the fine line between regulator and broker. As regulator, this section prepares for the symptoms of a sector lacking financial resilience rather than the causes, but that does mean clear alignment with the OfS remit to mitigate risk and protect public finances. As our recent work with the Office of the Independent Adjudicator (OIA) has highlighted, good governance and preparedness for financial change – especially considering the likelihood and impact of potential market exit – must be high on every institutional agenda.
The bottom line
There’s a lot here that institutions are already working on, and a welcome evolution of regulatory thinking. Academic quality and financial resilience are core areas of regulatory oversight and the ‘plan for the worst’ mindset is essential for the OfS given the heightened risk of unexpected provider exit from the market. The strategy signposts this shift, but the most interesting point is the change of tone – the strategy successfully combines insight, clarity and focus and may well mark the start of a more collaborative regulatory style – and that could be exactly what we need in the next few years.
