England¡¯s sector regulator plans to require that 60 per cent of full-time first degree students at every university should go into ¡°managerial or professional employment¡± or further study, part of the latest stage of controversial proposals to regulate institutions using absolute numerical baselines on student outcomes.

If higher education institutions fail to meet the baselines ¨C not benchmarked to take account of variations in students¡¯ social backgrounds or in regional labour markets ¨C they face the ultimate risks of potentially being stripped of access to student loan funding or university title by the Office for Students, which unveiled the next stage of its consultation on the plans on 20 January.

Every subject group at every institution will be expected to meet the baselines. However, not every institution falling below baselines will be assessed by the OfS for ¡°non-compliance¡±: the regulator will?choose a ¡°limited number¡± of institutions each year through a ¡°prioritisation¡± process.

Highlighting the potential complexity of the new system, the three separate consultations published by the OfS ¨C on the new student outcomes approach, on constructing the indicators and on connected changes to the teaching excellence framework ¨C run to a combined 426 pages, with a document on calculating numerical baselines adding another 214 pages.

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The OfS is proposing changes to its conditions on quality and standards, which would require institutions to deliver ¡°positive outcomes¡± for students ¨C a move that comes in the wake of concerns in the Conservative government about ¡°low-value¡± courses.

The OfS plans to use three measures of student outcomes: on continuation, completion, and the proportion of students progressing to managerial or professional employment or further study.

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Using these measures, it will build indicators for full-time, part-time and apprenticeship students, across different levels of study (for example first degree, or postgraduate research).

The OfS also proposes to create ¡°split indicators¡±, showing performance across categories including?particular student social groups, such as those eligible for free school meals, and across categories including subject groups at an institution, ¡°for example business and management, computing, engineering, or health and social care¡± ¨C to address ¡°pockets of poor performance hidden within acceptable aggregate performance¡±.

In the OfS¡¯ proposals, for full-time students studying a first degree, the numerical baselines would be: 80 per cent of students to continue into a second year of study, 75 per cent to complete their qualification, and 60 per cent of students to go into managerial or professional employment, or further study.??

On the employment measure, the OfS says ¡°around 3,000 students each year (approximately 2 per cent) have gained qualifications from providers that had progression outcomes calculated as falling below the progression threshold we are proposing¡±, while 55 institutions ¡°had outcomes calculated as below the proposed threshold¡±.

Institutions will meet the quality and standards condition if ¡°in the OfS¡¯ judgement, the outcome data for each of the indicators and split indicators are at or above the relevant numerical thresholds¡±.

But the OfS proposes that it could allow institutions to meet the condition, even if below a baseline, where ¡°the provider¡¯s context justifies the outcome data¡±, taking account of factors such as variation in outcomes ¡°for different types of students and courses¡± ¨C a significant change from the regulator¡¯s initial proposals.

The OfS would publish all universities¡¯ outcomes data. But rather than assessing all institutions falling below baseline for ¡°non-compliance¡±, the OfS?would decide on a prioritisation process each year: which could involve focusing on providers with large numbers of students below baselines, providers significantly below baselines, randomly selecting providers below baselines, or it could be ¡°thematic¡±, focusing for example on ¡°part-time students on other undergraduate courses, or courses of all types in a particular subject, or outcomes for disabled students¡±.

The possibility of particular subject groups being targeted by the OfS is likely to generate concern in universities.

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The OfS also concedes there is ¡°a possibility of and scope for statistical uncertainty, and we would take account of this in our decision making¡± ¨C setting out in the consultation proposals to address this.

On potential sanctions for institutions, the OfS says it expects that, ¡°where we consider it necessary, we may take action that leads to a provider suffering loss of current or future income or damage to its reputation¡±.

But, it adds, ¡°We also intend, where we consider it appropriate, to provide the opportunity through an improvement notice for a provider to improve without suffering the loss to current or future income that would be caused by the use of our suspension or deregistration powers.¡±

The OfS proposes to develop the progression to professional employment or further study?measure using the Graduate Outcomes survey, taken by graduates 15 months after completing courses, and the Office for National Statistics¡¯ ¡°Standard Occupational Classification 2020 (SOC) major groupings, using groups 1 to 3¡± to define managerial and professional employment.

Nicola Dandridge, the OfS chief executive, said the proposals ¡°mark a landmark moment in our work to tackle poor quality provision in English higher education¡±.

¡°Students from all backgrounds deserve to be on good courses leading to qualifications which stand the test of time and prepare them well for life after graduation,¡± she said.

But Diana Beech, chief executive of London Higher and a former policy adviser to Conservative universities ministers, said the OfS¡¯ announcement ¡°strikes an unnecessarily aggressive tone¡± as universities and colleges are ¡°stretched¡± trying to deliver for students in the pandemic.

She added that it was ¡°concerning that the OfS should seek to impose thresholds for quality while Covid continues to negatively impact students¡¯ circumstances and employment prospects¡±, and that the proposals would mean ¡°punishing institutions serving large communities of underrepresented students¡±.

Alistair Jarvis, chief executive of Universities UK, which fiercely opposed the absolute baselines plan previously, said UUK recently published a framework on value?that ¡°highlights that student outcomes are not the only markers of quality and value. Universities should also consider how courses contribute to public services such as the NHS, to business creation and skills needs in local areas, and their contribution to cultural activity and the environment.

¡°We look forward to continuing to work closely with the OfS as we consider this consultation and the proposals.¡±

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Gordon McKenzie, chief executive of GuildHE, said the organisation welcomed the OfS¡¯ proposals, including its ¡°recognition of the need for contextual factors to be considered alongside the numerical baselines, particularly when it comes to student outcomes and the very real differences in labour market opportunities in different parts of the country. How these judgements are made in practice will be critical and we look forward to seeing more detail from the OfS.¡±

john.morgan@timeshighereducation.com