Access and participation plans

FAQs

Process

How do I access my targets and investment plan and fee information document?

Providers can download their targets and investment plan from the OfS portal. The fee information document will be available in mid-March. Login instructions have been sent to each provider’s accountable officer.

If you are having difficulties accessing the portal, please contact [email protected]

What should my access and participation plan look like?

OfS has provided a template to help providers structure their access and participation plan. Providers are expected to use the titles and subtitles in the template. If they don’t use the template it may take longer to receive an approval.

The plan should be a single Microsoft Word document that should not normally exceed 20 pages of A4. There is no minimum length requirement, and we expect that the length of the plan will vary depending on factors, such as the size of the provider, the scale and ambition of what is being proposed, and the level of inequality across the student lifecycle at the provider.

Providers will also need to submit the targets and investment plan and fee information document (Microsoft Excel templates) alongside the access and participation plan.

Are we able to submit additional documents alongside our access and participation plans?

The plan should include the necessary information to show that it follows our guidance.

If there is extra information you would like us to consider that could not be included in your access and participation plan, you may submit an additional document alongside your plan. This might, for example, cover information that you are not able to publish.

This should be clearly marked as separate from your access and participation plan.

In particular, we encourage student unions and student representatives to comment on how their provider has consulted and involved them in the provider’s access and participation work.

Providers may choose to include this information in the access and participation plan or, student unions and representatives may submit this as a separate submission.

The guidance says that providers will have two re-submissions. How does this work?

We encourage providers to make sure that their first submission contains all the information we require to assess the plan and ensure it is ambitious and credible.

We will contact providers if the plan does not contain enough content for us to make an assessment. After two re-submissions the Director for Fair Access and Participation will normally reject a plan if it doesn’t contain enough content.

If we feel we can approve a plan, we will then consider risk of breach of condition A1 in the regulatory framework. Where a provider has a plan which is less ambitious and/or credible, we may consider it more at risk of breach of condition A1.

We will not always contact providers about their ambition and credibility. So it is important that providers make sure their first submission is as ambitious and credible as possible.

For more about the assessment process, see paragraphs 19-37 of Regulatory Notice 1: access and participation plan guidance.

What has changed from previous access and participation plans?

In 2018, we assessed our approach to access and participation, including access and participation plans, and considered further reforms for 2020-21 plans onwards.

These reforms include:

access and participation plans which are more strategically focused and in force for up to five years
encouraging providers to set targets which align with OfS access and participation key performance measures where appropriate
the introduction of an access and participation dataset to help providers with their assessment of performance
no longer requiring providers to spend a minimum amount on access and participation. Though we will still look at how much they spend when we judge the credibility of their plan.
a greater focus on evaluation, including providing an evaluation self-assessment tool to help providers identify areas for improvement.

How should we consider sub-contractual arrangements in our access and participation plan?

Providers require an access and participation plan if they:

offer higher education courses directly to students (i.e. if it registers its own students and receives payment directly from students or directly from the student support system on behalf of its students)
are registered in the approved (fee cap) category of the register
charge above the basic fee level.

This is regardless of whether the provider’s courses are validated by another provider or awarding body.

Where all of a provider’s higher education courses are being delivered on behalf of another provider (the lead provider) under a sub-contractual arrangement, the provider delivering the courses (the delivery provider) will not normally be required to register, and therefore will not need an access and participation plan.

In a sub-contractual arrangement, the students studying with a delivery provider are students of the lead provider. The lead provider has responsibility for the higher education provision, including its quality and costs.

More information can be found in paragraphs 61 to 66 of the OfS regulatory framework.

Dataset

How do I use the dataset?

Providers should use the dataset to assess their performance. This should inform their aims, ambitions and targets.

We have produced a user guide on how to use the dataset. We also ran workshops and webinars in spring 2019 to help providers understand the data.

How should we use statistical significance in the dataset?

Statistical significance is used as an indication of the strength of the evidence in the data but it will not tell you the ‘importance’ or not, of the gap.

Providers should first look at the areas where there are the largest absolute gaps. If this gap is statistically significant providers can conclude that this is an area they may need to focus on in their access and participation plan.

Where a gap is large but not statistically significant, providers will need to use additional evidence to understand whether the gap is, or is not, an issue for their organisation which they will need to address in the plan.

How should providers consider the use of POLAR in their access and participation plan?

The OfS strongly encourages providers to use POLAR4 when setting targets as it is a robust and widely used measure of underrepresentation in higher education.

Where providers have clear evidence that POLAR4 does not reliably reflect disadvantage in their specific location or context, they may choose to use an additional measure of disadvantage identified in the access and participation dataset, such as the English Index of Multiple Deprivation (IMD).

Providers can also suggest an alternative measure, though the acceptance of this will be subject to negotiation with the Director for Fair Access and Participation.

More information about appropriate use of POLAR data can be found in our POLAR FAQs or our access and participation plan guidance (regulatory notice 1).

Assessment of performance

How should we approach assessment of performance?

Providers should use the following sources for their analysis in the assessment of performance section of the plan:

the OfS access and participation dataset
nationally available data and their own data and research (both qualitative and quantitative).

Providers should use this data to understand the inequalities in access, success and progression at their organisation and for the priority areas the OfS has identified.

Providers should show that they understand their own performance, and that this underpins their targets and strategy. The assessment should inform which underrepresented groups they need to target, areas of success to build on, and where they can improve.

We expect providers to examine the intersections of characteristics so they can accurately identify gaps for particular groups of students. This might reveal, for example, where examination by a single characteristic may mask or underestimate the extent of a gap that needs addressing for a particular group.

For more information about the requirements for the assessment of performance part of the plan see page 19 of Regulatory Notice 1: access and participation plan guidance.

For advice on how to assess performance see paragraphs 13-39 of the Regulatory Advice 6: Effective practice advice

What should we do if we don’t have access to certain types of data (for example on certain target groups)?

We expect providers to base their assessment on the best data available to them and describe how they intend to develop their use of data in future.

They can use the OfS dataset, their own student data and research as well as nationally available data and academic research. We will not approve their plan if we think their assessment of their performance is not credible.

Providers may not have any data for groups or a stage of the student lifecycle for which we require an assessment of performance. If so, they should state this in their plan and use alternative quantitative and qualitative evidence to understand whether this is an issue they need to address. They should also note how they plan to develop their data capabilities in the future.

Regulatory Advice 6: Effective practice advice includes links to further sources of support for providers as well as links to sector-wide data and reports.

What should we do when reporting on small numbers and ensuring information submitted as part of the plan complies with the General Data Protection Regulation (GDPR) 2018?

Providers must ensure that personal data is processed in accordance with the General Data Protection Regulation (GDPR) 2018 and the Data Protection Act (DPA) 2018. This includes ensuring that no personal information is submitted and no students can be identifiable from the data reported.

Some providers, due to small numbers, cannot conduct a quantitative assessment of performance for an underrepresented group.

As a general rule, if numbers are below five there is a significant likelihood of individuals being identified and as such this information should not be submitted as part of the plan. Instead they should state this in their plan and use additional or alternative quantitative or qualitative evidence to assess whether this is an issue they need to address.

Providers may also wish to refer to HESA’s guidance on anonymising statistical data.

Small numbers through disaggregation related to statistical significance

Some providers, due to small numbers caused by disaggregation of underrepresented groups, cannot conduct a meaningful quantitative assessment of performance for an underrepresented group. If so, they should state this in their plan and use additional quantitative or qualitative evidence to assess whether, in an honest appraisal, this is an issue they need to address. Such evidence may include, for example, national level data and/or academic evidence.

It is important that providers are disaggregating their data by different ethnic groups and disability types, as each group may experience different barriers which can be hidden if these students are only considered as a whole. Therefore we are again encouraging providers to look at sub-groups with regards to ethnicity, and at different stages of the student lifecycle.

Can we consider gender as an underrepresented group?

Gender can only be included as an underrepresented group in an access and participation plan where:

it is considered with another characteristic as an intersection, for example in the case of white men or women from low participation neighborhoods (white working class men and women).
there is additional qualitative evidence to show that the group do not experience equality of opportunity in the provider’s context and this has been considered in the national context. In other words being sure that the group are underrepresented at the university or college, or at a subject level because of barriers to education, rather than having made a choice to study or work elsewhere.

The Director for Fair Access and Participation is unlikely to approve a plan which targets access and participation activity at men or women as a whole group, because this may include men and women not otherwise considered as underrepresented.

How should we consider higher level and degree apprenticeships in our access and participation plan?

Providers may (or may not) include higher level and degree apprenticeships in their plan. This is in recognition that students studying degree apprenticeships are higher education students and therefore should experience equality of opportunity.

Apprenticeships can also provide alternative routes into and through higher education and so support providers’ access and participation strategies. Therefore, although apprenticeships are not regulated through the access and participation plan, providers may, where relevant, present them as part of their broader strategy to support access and participation.

If higher level and degree apprenticeships are included in a provider’s plan as a strategic measure, the provider should clearly set out how it promotes equality of opportunity. It should also have a clear outcome related to a provider’s aims and objectives.

How do higher level and degree apprenticeships affect our assessment of performance?

The OfS access and participation data dashboard includes degree apprenticeships data and higher level apprenticeships data where they have components of study at level 4 or above.

For the majority of providers this represents a very small proportion of the student population and therefore will not impact on their assessment of performance.

Providers who have a large proportion of apprenticeship students will need to look at additional data, for example their own provider data, to best understand the issues related to each student group. For example, a provider may need to take a different strategic approach for students they directly recruit as opposed to degree apprenticeships where the employer recruits the students.

Do higher level and degree apprenticeships need to be counted in the student numbers section of the fee document?

Higher level and degree apprenticeships students are not counted in the student numbers section of the fee information document because the provider does not receive any higher fee income from these students.

Which students should be covered in plans and what is the definition of UK domicile as used in the access and participation dataset?

A provider needs an access and participation plan if it has ‘qualifying students’ on ‘qualifying courses’ (see paragraph 8 of Regulatory Notice 1). ‘Qualifying students’ include most home and EU students.

The content of a plan should focus on equality of opportunity for UK-domicile students.

The access and participation dataset uses a student's recorded postcode and domicile prior to entry to determine whether they are UK domiciled. Full details on the specific algorithm used can be found in the OfS Core Algorithms document.

Targets

How many targets should providers set?

Providers should have a set of outcomes-focused targets, which directly reflect the aims and objectives laid out in the plan. These should directly reflect the areas identified for improvement in the assessment of performance. So the number of targets required will vary depending on the university or college’s context.

We expect that providers will, for the most part, have fewer targets than in previous access agreements and that there will be very few, if any, activity-level targets. There should be no input or output-based targets.

See paragraphs 93-106 Regulatory Notice 1: access and participation plan guidance for further information the OfS’ expectations of targets.

You can also find advice on how to link your aims, objectives and targets in Section B of Regulatory Advice 6: Effective practice advice.

Are providers required to use the OfS example targets in the targets and investment plan?

The example targets in the targets and investment plan are related to the OfS KPMs. So if a provider is setting a target related to one of the KPMs because they have identified similar gaps in their assessment of performance, we expect they use the relevant example target.

This may be in addition to other similar targets. For example, a provider may have a target related to the ratio of POLAR4 quintile 1:quintile 5 students (the OfS KPM) in addition to a target related to quintile 1 and 2 combined or another measure of deprivation such as household income.

The most important thing is that providers have meaningful targets related to the key areas they need to address as identified by their assessment of performance, and that outcomes are improved overall for all underrepresented students.

How will the OfS assess the ambition of targets?

We will assess ambition related to a provider’s own context and will consider each individual target in the context of all other targets and the content of the plan.

We will use the sector key performance measures (KPMs) to understand progress where relevant. So providers should refer to the KPMs to understand our expectations related to ambition.

What are the expectations related to targets for small and specialist providers?

The OfS has high expectations relating to improving outcomes for underrepresented students and expects all providers to address the issues identified in their assessment of performance.

We appreciate that small and specialist providers may need to work together, or with other organisations, to address grass root issues, where providers are targeting outreach work nationally or where there is limited resource available at one provider. So collaborative targets may be appropriate in this instance.

Can providers submit targets for approval in advance of the access and participation plan submission?

The OfS is putting on events across March, April and May 2019 to help providers make their first submissions ambitious and credible enough. We will also run one-to-one telephone surgeries, which providers can book around May 2019.

The OfS may be able to look at some targets before plans are submitted. But we will not be able to say whether they are approvable or not because this can only be decided by the Director for Fair Access and Participation in the context of the rest of the plan.

What if setting a target related to the OfS KPMs results in a reduction for another group?

The national KPMs are not intended to be prescribed targets but rather a guide to suggested measures and the level of ambition we expect. We expect providers to use their assessment of performance to identify their own priority groups and set targets accordingly. The targets should reflect the OfS KPMs where appropriate. So targets should be institution-specific and based on the assessment of performance, which considers provider and national data.

The OfS is interested in targets which make a meaningful difference to equality of opportunity and have high expectations of providers – especially where there are the largest gaps.

So, if for example, a provider’s assessment of performance identifies a large gap in the proportion (measured by % or ratio) of low-participation students vs higher-participation students, we expect them to address this issue and be ambitious in their targets.

It is up to the provider to establish how they should achieve equality of opportunity. In addition, we would not accept, for example, a target related to POLAR Q1 which is at the expense of other underrepresented students such as POLAR Q2 students.

What is meant by aims, objectives and targets in an access and participation plan?

Strategic aims are high level aspirations. These may be general or may incorporate aims specific to your provider, for example where you have a particular remit for an underrepresented group such as mature students or children from military families.

An example of a strategic aim could be: ‘we aim to create an inclusive learning and teaching environment in which all students, whatever their background, are able to achieve their full potential.’

Objectives are how these aims will be achieved and these should be time bound. There may be a number of objectives which are related to meeting one strategic aim.

To create a measurable objective, providers should first identify which groups they are going to target and at which stage of the student lifecycle (access, student success, progression). This should be informed by their assessment of performance.

Objectives may be over a longer time period than the duration of the five year plan, for example ‘we will eliminate the attainment gap between black and white students by XX. We will eliminate the non-continuation gap between POLAR4 Q1 and Q5 by XX.’

Targets show what progress the provider expects to make towards meeting their objectives over the five year duration of the plan. Targets should be included in the targets and investment plan excel document.

What do we do about targets from existing access agreements and our 2019-20 access and participation plans if we want to change our strategic direction following a new assessment of performance?

Should a provider’s assessment of performance result in revised aims and objectives and a new strategic approach, it may be the case that targets in existing access agreements and the 2019-20 access and participation plan are no longer relevant.

If certain targets will no longer be delivered against, providers should provide a clear rationale for this in their 2020-21 access and participation plan. Similarly, they should re-state this rationale when completing their monitoring returns for the relevant access agreement or access and participation plan.

Providers may wish to include a paragraph in the aims and objectives section of the plan to state what changes they are making and why. It is important to note that a change of strategy is unlikely to be accepted if it represents a reduction in ambition in terms of outcomes for underrepresented students.

Which student outcomes should targets set in 2020-21 to 2024-25 plans relate to?

Where providers set targets, they should define the timescales over which they expect to meet them. The earliest you could expect to see progress towards meeting these targets is from the next available year of data once their plan comes into effect.

Where providers implement measures to contribute towards achieving a target, the timescales over which it can have full effect will be dependent on the measure, and which stage of the student lifecycle the target relates to.

The earliest that effects can be seen in the data for each lifecycle stage is described below:

Access – entrants in 2020-21 available in the 2020-21 data
Continuation – outcomes for entrants in 2020-21 which will first be available in 2021-22 data for full-time students or 2022-23 data for part-time students
Attainment – outcomes for qualifiers in 2020-21 available in the 2020-21 data
Progression – outcomes for qualifiers in 2020-21 available from the Graduate Outcomes survey 15 months after graduation

As an example, a provider may set a target to eliminate their attainment gap between white and black full-time, first degree students by 2024-25. The provider may implement a number of measures to achieve this target.

The provider may first see the effect of short-term measures in the data in 2020-21. The effect of longer-term measures may not be seen fully in the data until 2022-23 for 3 year programmes. This is when entrants in 2020-21 on a 3 year programme would be expected to qualify.

How should we balance our own targets against collaborative and national targets?

Providers must include targets related to the material gaps in their own organisation as identified in their assessment of performance.

In addition, providers may include collaborative targets or targets related to access to higher education nationally.

The OfS will look favourably on providers who are collaborating and working towards the national good in addition to addressing equality of opportunity gaps in their own organisation.

What is an acceptable raising attainment target and how do we create one?

Targets related to raising attainment may look different dependent on a provider’s context and what they are trying to achieve with their activity.

These targets are particularly relevant for providers who need to work with schools and communities on a longer term basis to generate more applicants who are eligible and ready for higher education level study.

Providers may wish to create an evidence-based logic chain or theory of change related to their activity. This should also inform the programme design.

Most raising attainment targets would be related to the longer term outcomes of increased attainment at levels 2 and 3, or increased access to higher education. However, a longer programme of work, for example with primary school children, may need to use an intermediate outcome from their logic chain as their target because the longer term outcomes will not be realised in the five year duration of the plan.

How do we define continuous improvement in targets?

The following types of targets are considered as demonstrating continuous improvement:

A linear year on year improvement in performance.
An upwards curve, where progress increases more in the later years of the plan. There is a high level ambition over the five year duration of the plan.
A target with initial improved performance followed by maintained performance only where equality of opportunity is reached.

Providers should not include targets which maintain performance where a provider is already doing well.

In rare circumstances, where there is a totally new programme of work related to collaboration or raising attainment, a target with no milestones for the first years of the plan may be acceptable. In this instance it is advisable to contact [email protected] to discuss.

How should we consider DLHE and graduate outcomes data when setting progression targets?

Providers should set targets for progression where the Destinations of Leavers from Higher Education (DLHE) data, used in the assessment of performance, indicates that there are gaps to be addressed, and they make sense in the provider’s context.

The Office for Students (OfS) expects providers to be drawing on DLHE data at present, transitioning to Graduate Outcomes data in the future.

The OfS recognises that there will be definitional changes that result from the transition to Graduate Outcomes, and that providers may need to revisit these targets (and adopt new baselines and milestones as appropriate) once the extent of differences from DLHE become clearer.

In the meantime, triangulation against other sources (longitudinal DLHE, Longitudinal Education Outcomes (LEO) data or other studies that consider differential outcomes experienced through graduates’ early careers) may help to verify whether the issues and gaps identified from DLHE data are those that persist through early careers and so seem likely to remain within the Graduate Outcomes findings.

How should we approach setting a collaborative target on our NCOP activity?

We are supportive of providers working in partnership with other providers to reflect their NCOP and other collaborative activity in their access and participation plans. Providers’ targets must be stretching, outcomes-based, and measurable on a consistent basis. If providers wish to collaboratively set a target on their NCOP activity, the target must meet these requirements.

We understand there may be challenges to using NCOP as the basis for a collaborative target. The targeted NCOP programme is currently set to be funded by the OfS for a further two years from academic year 2019-20. This means it may only be in place for the first year of the 2020-21 access and participation plans.

Although we would welcome the work of the programme continuing beyond 2020-21 in some form, it may be difficult for providers involved in the targeted programme to agree collaborative targets for the purposes of their plans on the basis of their work in NCOP. The outreach hubs, which OfS hopes to be able to continue to support beyond 2020-21, will be broader in scope in respect of coverage and so may provide a firmer basis on which targets might be agreed, although we appreciate that the hubs are currently developmental.

If providers are not currently in a position to be able to set an outcomes-based, collaborative target, they may instead include firm commitments to collaborative working as part of their strategic measures set out in their access and participation plan. This should include:

a clear statement of how a provider will work with partners
a theory of change, including details of shorter, intermediate and longer term aims
details of the evidence base for the chosen approach
information on how providers will collectively understand the effectiveness of the approach and its impact on learner outcomes.

Strategic measures

Do you want to know about the activities we deliver/will deliver?

The purpose of this section of the plan is for a university or college to demonstrate that they have enough measures in place to achieve the aims, objectives and targets stated in the plan. In other words, that the provider has a credible strategy to achieve their ambitions.

Any strategic measures or activities included should state the intended outcome and how this relates to the provider’s aims and objectives.

Where we are moving to more strategic plans which run for up to five years, we expect the content of the plan to be at a more strategic level than previously included in some access and participation plans and access agreements. So, while we do expect the provider to include the strategic measures they are planning, we do not need a comprehensive list of all their access and participation activities, although they may include examples where relevant.

Investment

How much investment does the OfS consider acceptable for a plan to be credible?

The OfS does not have set expectations about the amount of investment providers should make through their access and participation plan. However, the amount invested should be sufficient to demonstrate a credible approach to achieving the provider’s ambitions. A plan with enough investment may not be approvable.

If the provider’s investment is very different from previous years, it is likely that we will ask them to make assurances about how they know they can deliver the provisions in the plan for the stated investment. This may affect our judgement of risk of breach of condition A1. If the provider intends to make significant changes to their investment, we recommend they contact the OfS to discuss this.

What investment can be counted in my access and participation plan?

The investment providers include should relate to delivering their access and participation aims and objectives as set out in the plan. So it should only be related to activity targeted at underrepresented groups.

They should not include the cost of business, as usual investment such as normal recruitment activity or infrastructure projects. Providers are already required under the Equalities Act 2010 to make reasonable adjustments for disabled students. This investment cannot be counted in their access and participation plan.

For more information on understanding what investment to include, see paragraphs 85-86 in Regulatory Advice 6: Effective practice advice.

Student engagement

Do you expect student engagement to be representative of underrepresented groups?

We expect that providers will involve students as active partners and cocreators in developing, implementing and evaluating their access, success and progression work. We would normally expect them to collaborate with their student union or student representatives.

As part of this, they should consider how students from a range of backgrounds will be included in their consultation on and delivery of their plan, particularly where they identify groups that may not be reached through their student union or student representatives.

For more information on student engagement see paragraphs 156- 167 in Regulatory advice 6: effective practice advice

Do students need to be consulted on the final access and participation plan?

Engagement with students about the access and participation plan should be meaningful rather than tokenistic.

We expect providers to provide students with the opportunity to express their views about the content of their plan before it is submitted for approval.

Students do not need to sign off the final access and participation plan, but providers must demonstrate how students were consulted on the plan, and steps that they took as a result of this consultation.

This should form part of the year-round engagement that providers have with their students on access and participation work.

We expect that providers with existing access agreements will build on existing student consultation and involvement.

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