Right Here; Right Now: Providing the Information your Students

Need and your Regulator Requires

Marieke Guy, Data Analyst

Institutional Web Management Workshop23rd June 2016

The Quality Assurance Agency for higher education (QAA)

Our mission is to safeguard standards and improve the quality of UK higher education wherever it is delivered around the world.

Our main work• Higher Education Review (HER) of HEIs, FECs and

Alternative Providers• Maintaining UK Quality Code for Higher Education • Investigating concerns about academic quality

and standards • Involving students in quality assurance work• Working internationally with other QA agencies• Supporting the assigning of degree awarding powers• Regulating the Access to Higher Education Diploma

Students as Consumers?

A changing HE landscape• Greater share of HE provider funding coming directly

from students• Students have clearer expectations regarding the

offering from their provider• Different providers have different offerings at different

costs – an increase in marketisation• The sector is expanding with more HE provision

available – FECs, alternative providers• Complaints by students are generally on the rise• However HE is not a conventional market…

“For most students, decisions on what and where to study will be a ‘one-off’ involving the investment of a significant amount of time and money. Therefore that decision needs to be properly informed and right for them.”

Gordon Ashworth, CMA

Regulation

Student protection

Students protected by:

Consumer Rights Act

2015

Consumer Protection from Unfair

Trading Regulations 2008 (CPRs)

Consumer Contracts

Regulations 2013 (CCRs)

Unfair Terms Regulations (UTCCRs)

Office for Independent Adjudicator

(OIA)

Competition and Markets

Authority (CMA)

Consumer Rights Act• Came into force in October 2015

– pulled together pieces of previous legislation• Protection covers pre-enrolment and

post-enrolment• Requirement to provide sufficient information

including: programme structure and content, contact time, accommodation options and breakdown of fees

• Information should be accurate, complete and clear and made available in a variety of ways

CMA guidance• March 2015 - Competition and Markets Authority

(CMA) publish advice to support the sector in complying with obligations under pending law

• Majority of students (75%) use the university website or prospectus to make their first and insurance choices (Which? 2015)

• http://bit.ly/HEadvice

CMA guidance covers:• Information provision – clear, timely, accurate and

comprehensive in advance of choices– Stage 1: Research and application stage– Stage 2: Offer stage– Stage 3: Acceptance stage– Stage 4: Enrolment stage

• Terms and conditions – covers all contracts, rules and regulations documents that students are bound by – should be easily located, in plain language

• Complaint handling processes and practices – should be easily located, fair and accessible

What information?• Entry requirements• Core modules• Contact hours• Expected workload• Teaching qualification

of staff• Assessment• Course award, location,

length, accreditation• Fees, extra costs

Course changes• An admission offer is an offer of a contract• University must obtain applicants agreement to

change anything stated at stage 1 – what does this mean in reality?

• Will result in longer planning schedules for curriculum design (up to 5 years for UG)

• Clearer deadlines for changes• Need for good internal and external communication• Decrease in dynamic, innovative courses?

“There is significant risk to organisations which are found to be non-compliant with consumerprotection law. These range from the relevant contracts being deemed to be unenforceable, through to fines and significant reputational damage.”

UEA CMA action plan

Do students get the information they need?

• Which? compared websites of 50 unis offering psychology courses

• 38 did not give all the details required under consumer law

2014

2015 Which? report found failings..• Looked at 12 areas including entry requirements,

contact hours, assessment, course award and location • Nearly two-thirds failed to provide updated information

about tuition fees on their website• Three providers failing to provide approximately 30%

of the material information required• Main issue areas:

– Missing information on course fees or extra costs– Lack of context for KIS widgets– Missing information on indicators of quality for course

e.g. contact hours

QAA review findings• Higher education Review 2014-15 – 100% HEIs

expectations were met with regard to information• However still significant number of recommendations e.g.

– adopt a coordinated approach to the provision of information on fees and additional course costs at programme level

– publish the current Admissions Policy on the website– make information regarding its collaborative partnerships publicly

available for potential students– ensure that all students have appropriate and timely access to

information on procedures for complaints and appeals

“Information, particularly on price and quality, is critical if the higher education market is to perform properly. Without it, providers cannot fully and accurately advertise their offerings, and students cannot make informed decisions.”

Success as a Knowledge Economy, BIS White paper May 2016

Challenges for the Web

Web governance• Corporate responsibility for what is said about a

university’s education offering• Central group need to insure information is accurate,

timely, clear, easily available etc.• Change needs to be managed – clear deadlines,

understanding of what is reasonable to change…• SLAs• Clarity around roles of different marketing channels

(prospectus, course database, web pages, social media) • Old information to be removed promptly

On the website…• Is all your information available? T&Cs, regulations,

disciplinary procedures, complaints etc.• Is all your information clear e.g. total cost of course

– does it include additional cost associated with a course?

• Are you informing students of changes to courses? Wider discussion around when this is necessary and curriculum development cycle

• What are you doing with your KIS widgets? Are they contextualised, are they at the top of the page? Is there a break in content before the widget?

How can QAA help?

UK Quality Code part CInformation about Higher Education Provision

• Chapter C requires that providers produce ‘appropriate information, focused on their intended audiences, about the higher education learning opportunities they offer’.

Quality Code principles #1• Principle 1: Information should be timely, current,

transparent, and focused on the needs of the intended audiences.

• Principle 2: Providers are responsible and accountable for the information they produce but have autonomy regarding the mechanisms and media they choose to communicate this information.

Quality Code principles #2• Principle 3: Information should be available and

retrievable where intended audiences and information users can reasonably expect to find it. The format and delivery of information should take account of the access requirements of a diverse audience.

• Principle 4: Information produced by higher education providers should offer fair and accurate reflection of the higher education learning opportunities they offer.

Guidance documentsOn explaining:• staff teaching qualifications• class size• Workload (covers academic support, approaches to

learning and teaching, assessment, contact time etc…)

• Responding to feedback from students

Universities are responsible for ensuring that they comply with consumer protection legislation.

Failure to comply could result in fines, complaints and loss of reputation.

Other resources

Other Resources• Higher Education Providers: Consumer Law

– 60 second summary (CMA)• Guidance work on explaining staff size, workload,

responding to feedback from students (QAA)• Impact Study of the Guidance Documents (QAA)• UK

Quality Code: Part C: Information about Higher Education Provision (QAA)

• Audit of providers’ website information provision (Which?)• Consumer Protection Law assessment

(Durham University) – works through scenarios used by David Palfreyman

qaa.ac.uk

enquiries@qaa.ac.uk

+44 (0) 1452 557000

© The Quality Assurance Agency for Higher Education 2015

Registered charity numbers 1062746 and SC037786

Images

• Images on slide 4 and 12 copyright QAA• Images on slide 14 copyright CMA – available via Flickr (

https://www.flickr.com/photos/cma-gov-uk/)• Other images CC0 from Pixabay (https://pixabay.com/)