This post is part of an ongoing series where I intend to develop my full personal (not institutional) response to the HE Green Paper. Comments are welcome to refine this.
The Green Paper asks in Question 17:
Do you agree with the proposal to introduce a requirement for all providers to have contingency arrangements to support students in the event that their course cannot be completed?
I agree in part with the proposal to introduce a requirement for all providers to have contingency arrangements to support students in the event that their course cannot be completed. However, I have a number of important points to raise here that should be considered.
Paragraph 4 on page 54 notes that “Difficulty attracting students or poor quality provision would not be in the long term interest of students, and could damage the reputation of the sector”. Yet this is precisely the set of circumstances that the removal of regulation of alternative providers proposed elsewhere in the Paper is likely to facilitate. By lowering barriers to entry, it is more likely that poor-quality provision will creep in.
A student protection requirement is a good idea, but it misses a crucial point. Namely, that the biggest damage to students will come, in such circumstances, from having a qualification from an institution that nobody recognises, because it has undergone “market exit”. A better idea would be that institutions agree with one another to take on a cohort of students in the event of provider exit, thus ensuring that students have qualifications from recognisable venues. This could also strengthen the incentives for rigorous comparable validation between institutions, since the backup provider would have a direct potential stake in ensuring students were taught well at other institutions.
The focus on “subjects of national importance, such as STEM” as areas meriting special protection is somewhat short sighted. While few would disagree that it is important that we have a focus on high-quality STEM provision, it is also important that we have experts on niche areas of, say, cultural history and languages. The focus here on pure market return risks us losing expertise in areas of great national, cultural and historical significance, but that we do not wish to provide at the same scale as STEM. Revisions to the policy should also consider the importance of preserving niche disciplines outside of STEM where such expertise will be lost should a subject-area or institution close.
As a final note, there is some extremely contradictory rhetoric here. At once, the Paper acknowledges that “Prior to 2010, fluctuation in the [HE] sector was limited, the sector was very stable”. This stability is viewed, by the Paper, as a problem. On the other hand, when it comes to students, stability is desired: it is claimed that “protecting the interests of the student, and minimising disruption to their studies” is the government’s goals. So, on the one hand, stability of providers is an evil while on the other it is a virtue. I would argue that stability of providers is good for students since they want qualifications from recognisable institutions. Productively working to improve provision across a range of providers, rather than engineering systemic instability and uncertainty (which limits employer and student confidence in HE), would be a better route. It is also not the case that the sector was static even before 2010. The most obvious point is the mass expansion of post-92 institutions. Another, in the opposite direction (and in terms that were detrimental to both universities and UK industry/the economy), the closure of many modern language departments.