Friday 26-01-2018 - 11:51

Last month, we submitted our response to the Government’s consultation on the role of the proposed ‘Office for Students’ (OfS) in its Higher Education reforms.

What is the Office for Students? The Office for Students will be the government-approved regulatory and competition authority for the HE sector in England. HEFCE and the Office for Fair Access will be merged to create the OfS.

Before we submitted our response to the consultation, I met with Nicola Dandridge, the Chief Executive of the OfS. Among other things, we discussed the role of student unions, attainment gaps and the importance of seeing students as co-producers of their educational experience.

Here is a preview of our response to the consultation:

Given all the levers at its disposal, including but not limited to Access and Participation Plans, what else could the OfS be doing to improve access and participation and where might it be appropriate to take a more risk-based approach?

The regulatory framework states that the OfS will not impose widening participation targets on institutions. While we recognise the importance of academic freedom and institutional autonomy, we believe the OfS should have a bigger role in ensuring universities widen access and support students from WP backgrounds once they are at University. While access and participation plans are important, they do not always lead to meaningful change. We believe the OfS should draw on the expertise of Students’ Unions in this area. Of particular importance is prioritising work around differential attainment gaps, particularly for BME students. Students’ Unions across the country have done valuable research and work in this area. In the 2016/17 academic year we ran a research project on the BME attainment gap. It found that BME students often felt isolated, experienced mental health difficulties related to their ethnicity, and felt that the curriculum and staff body were not representative of them. This kind of research builds expertise within Students’ Unions, and as such it is important that a partnership approach is adopted by universities on the area of access and participation. Finally, we would like to highlight that there is little evidence that the sponsoring of schools by universities is an effective widening access measure. Indeed, the school sponsored by Bristol University, Merchants Academy, has recently gone into special measures.

Do you agree or disagree that a student contracts condition should apply to providers in the Approved categories, to address the lack of consistency in providers’ adherence to consumer protection law?


We are concerned about a shift away from collective rights of students towards the individual rights of students. We are unsure how or if students would come forward in an individual rights system, and believe it is likely that only the most privileged students would be able to do so.

Students’ Unions have long held an advocacy role for students, particularly through independent impartial advice centres such as our own, Just Ask. We believe that the OfS should make it a condition for registered providers to fund independent advocacy and advice centres.

What more could the OfS do to ensure students receive value for money?

We do not agree with the considerable focus on value for money in the regulatory framework. We believe this takes away from the value that education has for society, not just the individual student. We also believe that students should receive a high-quality education irrespective of whether they are paying for it. We are also keen to stress that the value of a University education goes much wider than a high quality educational experience. A University education gives one the chance to broaden one’s horizons and develop social capital, a non-monetary good. Value for money cannot purely be conceived as relating to salary or employment after graduation. We do believe however that in the context of ‘value for money’ it is important that students play an active role in the remuneration decisions of senior management at the University. 

Do you agree or disagree that a registration condition on senior staff remuneration should apply to providers in the Approved categories?


We welcome the suggestion that pay above £100,000 for senior staff should be published and justified to OfS. We would ask why this does not apply to all registered providers, rather than just approved providers. We would advocate that institutions follow a 1:5 pay ratio as a guide. However, we also believe that this point needs to go further than senior staff remuneration. Gender and ethnicity pay gaps should also be published, along with gender ratios of Professorial staff. It is important that the staff body looks and feels representative of the student body, to ensure all students feel welcome and able to succeed.

What are your views on the potential equality impacts of the proposals that are set out in this consultation? Please provide any relevant evidence if you can as this will support policy development going forward.

We agree with NUS that the move away from market forces to drive widening participation is a good step, particularly with regards to race. Like NUS however we are concerned that the equality analysis highlights that mature and BME students are more at risk of having their provider exit the market. This combined with the lack of a mandatory student protection plan for registered basic providers means these students are particularly at risk. We would also raise that we believe the changes in the framework around freedom of speech, which will impact Students’ Unions autonomy to choose who speaks on their premises, is likely to impact groups with protected characteristics the most. Whilst these students are protected from extremism by the framework, speech which is not considered extreme but is likely to be profoundly upsetting to students will be required to take place on Students’ Union premises.

You can read our full response to the OfS consultation here.

We also responded to the Consultation on the redevelopment of the UK Quality Code for Higher Education. You can check out our response here.

Mason Ammar, Undergraduate Education Officer

Note: A huge thank you to Alice Phillips, our Representation & Policy Coordinator.