The Office for Students is exercising power but not rigour

England’s Office for Students promises to regulate higher education providers to ensure that students achieve “successful outcomes”. It will be “supporting” the “improving of outcomes” with funding, and providers that do not deliver those “successful outcomes” will be punished.

Yet, at the same time, the nascent regulator is also threatening to punish providers for “grade inflation”. “Universities and other higher education providers hold the key to solving this problem. If they do not take action, we will use our powers to drive change,” OfS chief executive Nicola Dandridge wrote in December. So providers that took the “successful outcomes” funding and pursued the obvious remedy of awarding more top marks could well find themselves using that money to pay a fine.

Such institutions could also find themselves marked down in the teaching excellence framework, which the OfS “manages”; former universities minister Sam Gyimah had already warned in October that “grade inflation will be an important feature of the criteria considered” in future iterations.

The OfS is clearly in a hurry to make a reputation, and its website features a comprehensive list of media coverage of its announcements. But it seems a strange folly for it to be exposing such headline-grabbing policy contradictions.

Here is another example of its undue haste. Regarding fair access, its business plan for 2018-19 includes a list of “strategic outputs”, one of which is to develop “a new, outcomes-focused approach to access and participation”. New “guidance” is promised by February, while a “target for this measure” will be published at some unspecified point this year. “Further analysis” is mentioned. Yet, ahead of that analysis, the OfS has already pledged to close “the gaps between white and black students and disabled and non-disabled students in achieving top degree marks”.

The quango appears to be in a rush to fulfil the policy desires of a succession of ministers before doing its homework. That is true even when those desires have little to do with the education on offer. Take the OfS Strategy for 2018-21. Required features of the student “experience”, it says, include “outcomes” with which the student will be “highly satisfied”. But these “outcomes” are further detailed in what are chiefly policy rather than educational terms. Students will be “able to progress into employment, further study, and fulfilling lives, and their qualifications [will] hold their value over time”. They will “leave with the knowledge and skills that will contribute to their national and local economies and communities, and drive productivity”.

In its business plan, the OfS pledges to measure its own “success” in achieving “outcomes” against key performance measures. These rely partly on existing national surveys. For instance, data from the Higher Education Statistics Agency Graduate Outcomes Survey will be used “to show the percentage of graduates in highly skilled or professional roles”. But the OfS will simply “assume” that graduates in such roles “are using the knowledge and skills they acquired in higher education”.

“Graduate well-being”, by which the OfS means “the extent to which higher education enriches students’ lives after they’ve left”, will be assessed via the Office for National Statistics’ Annual Population Survey. But the business plan states that this will “allow us to compare the well-being of graduates with the rest of the population, and so see if there is a link between higher education and well-being” (my italics). In other words, the case for “graduate well-being” to be a key performance measure for the OfS has not yet been made.

For other “outcomes”, there is no ready-made measure. One example is improving “information, advice and guidance” for would-be students. There is merely the hypothesis that if this is “effective” it “underpins informed choice, good experiences and successful outcomes”.

Those working in universities look in vain for signs that the regulator does its research before publishing its conclusions, uses language with exactitude and avoids contradicting itself. Using its considerable powers to discipline providers when it is displaying a lack of the intellectual rigour that it ought to expect from them poses a growing danger to higher education, knowledge creation, learning and the self-reliance and resilience of students.

Gill R. Evans is emeritus professor of medieval theology and intellectual history at the University of Cambridge.