This is a transcript of a speech given on 27 September 2022 by John Blake, Director for Fair Access and Participation, at an event organised by the Social Mobility Foundation.
I would like today to talk about the direction of travel for the Office for Student’s work on equality of opportunity in higher education (HE), particularly our approach to access and participation plans, ahead of the opening of our consultation on new regulatory expectations next week.
Because a substantial portion of our new expectations rests on collaboration and partnership between higher education institutions and others, including employers and the third sector, I’m delighted to have the chance to speak here at Browne Jacobson, whose work on social mobility is exemplary and includes their ground-breaking Fairer Access into Real Experience initiative, which rightly identifies a lack of experiences of meaningful engagement with professions and careers as much if not more so a barrier to the success of those from lower socio-economic backgrounds as a lack of aspiration.
Browne Jacobson was recognised as the UK’s leading employer in the Social Mobility Employer Index 2021 by our other kind hosts, the Social Mobility Foundation, who through their own programmes, policy work and advocacy have done so much to keep the spotlight on social mobility, and the partnerships between education, employers and charities which is so central to tackling the barriers to social mobility.
Higher education central to social mobility
That higher education is good for social mobility has been axiomatic in our policy and political discourse for decades. Early 21st century, the financial underpinning of higher education (HE) was reshaped to match the conviction of a mutually beneficial outcome from higher education for both the individual and society – students would pay a greater percentage of the costs of their courses in expectation of excellent career prospects, but in a manner underwritten by government funding in such a way that if the economic return did not appear, government would bear that cost, not the individual.
Even those who disagreed with the terms of that bargain did not doubt that higher education was central to social mobility; indeed, much of the opposition was driven precisely by that concern – protests were mounted across the country by students at each point that fees were raised, fearing that charging more cash would see fewer students from disadvantaged backgrounds attend universities and colleges.
Those who feared that fees would halt access to higher education from disadvantaged groups were wrong, the percentage of such students in HE has continually increased from 2004. It remains strong today – this summer, more students from disadvantaged backgrounds sought and achieved places in higher education than ever before. The demand for higher education, from all sections of society, remains strong.
I appreciate that overview is brief and therefore necessarily crude, but as the OfS comes to review our work in this area, it seems appropriate to ask if higher education has delivered on that promise of social mobility, and if not, what regulation might be able to do about it.
The OfS is reviewing its approach to regulating equality of opportunity
On the one hand, the intertwining of university attendance with social mobility has bred its own challenges: the new chair of the Social Mobility Commission has stressed strongly that society needs to take a much greater interest in “those young people and adults who have not followed the higher education pathway”, that we cannot be indifferent to social mobility for those who do not wish to attend higher education.
On the other hand, questions have been asked about how effectively higher education is facilitating social mobility even for those who go: last year, the Institute for Fiscal Studies reported that whilst the average undergraduate saw a positive financial return from attending higher education, there was substantial variation – sadly, there are students in higher education now who would have been better off if they had not gone.
And others have questioned whether the price for social mobility for graduates is actually geographic mobility, from villages and small towns to the cities and, ultimately, to London, cut away from families and communities in order to reap the rewards of higher education.
It is in this context of both incredible success of the expansion of higher education over the past decades, but also growing and genuine concerns about the impact of that success on those who do not go into HE, and even on those who do, that the Office for Students is reviewing our work on access and participation, and equality of opportunity more widely.
It is also in a wider context of a nation recovering from the coronavirus pandemic, the greatest disruption of our society since the Second World War, and now also dealing with the impacts of global crises on inflation and the cost of living, and the very real risk that the cumulative effect of all those impacts may cost us, as a society, decades of progress on social mobility.
As the regulator for higher education, of course the OfS believes that universities and colleges can and should make a huge different to the life chances of those they educate. And we also contend there is a wider mission for higher education – a civic and moral duty to always seek out new ways to serve our society, better ways to ensure that those historically excluded from HE can benefit from it.
But of course we also accept that there are limits to how much universities and colleges alone can challenge global, national and systemic barriers to equality. The economic, cultural and intellectual power of English higher education must be fused with the dynamism, ingenuity and experiences of employers, schools, charities, local and regional government to meaningfully tackle these challenges.
This is work the higher education sector already recognises it can and should do: I would like to thank all those institutions holding access and participation plans for their response to the recent ‘mass variations’ exercise undertaken in response to challenges I made not long after taking up this job. The scale, quality, and inventiveness of the work universities and colleges have committed to and, in many cases, are already doing has been a huge influence on the development of this new approach, demonstrating as it does that the higher education sector really does understand its responsibilities to future students as well as those already attending, and really does want to build strategic, enduring and mutually-beneficial partnerships with schools, colleges and third sector organisations, such as our hosts today, the Social Mobility Foundation.
Those responses have been a crucial influence on our thinking of the role the OfS as a regulator can play in scoping, facilitating, and accounting for this work. I see our job as building a framework that captures the scale of the sector’s work on equality, and channels it into a coherent, co-ordinated and compelling alignment that uses the sector’s limited resources and capacity to greatest effect.
To do this, we propose that our work in this area becomes the focus for a sector-wide discussion of the risks to equality of opportunity for prospective, current and past students of higher education, and that the access and participation plans in particular become a public collective record of the gravest challenges individual providers are taking on, the interventions they propose to use to tackle them, and the methods they will utilise to understand if they have succeeded and how and why that outcome has occurred.
We intend to move away from a model in which the OfS cascades through the higher education system a set of national targets on equality, pressing providers to adopt their own targets in imitation of our own, to one in which providers themselves will undertake serious and sustained analysis of their own context and mission, and identify the most serious risks to equality of opportunity they face, and outline measures to mitigate these.
Introducing an equality of opportunity risk register
To support this, the Office for Students plans to create an ‘equality of opportunity risk register’, which we will expect universities and colleges to have regard to in creating their plans. This will help ensure that sector-wide risks shared by all those in higher education are properly addressed by providers, whilst also respecting the autonomy and pluralism of the higher education sector.
We propose to define risks to equality of opportunity as occurring when an individual, because of circumstances that the individual did not choose, may have their choices about the nature and direction of their life reduced by the actions or inactions of another individual, organisation or system.
Tackling these risks is therefore not about ensuring equal outcomes for all but ensuring that differential outcomes are not the result of circumstances individuals cannot fairly influence.
Discrimination, both direct and indirect, is a clear example of a risk to equality of opportunity. But risks can also occur even where there is no malign intent – where the longer-term consequences of actions or inactions are only later discovered to have resulted in a narrowing of choices for individuals that was not initially obvious.
I have spoken before about my belief that higher education institutions have a strong civic and moral duty to work with other phases of education, and where appropriate with the third sector and employers, to improve the knowledge and skills of children, especially from the most disadvantaged backgrounds. This framework further captures the nature of that challenge: equality of opportunity in higher education is harmed when socioeconomic background is so strong a predictor of the GCSE and A-level outcomes that guide who gets in and where they go.
Deepening the knowledge and understanding of all possible prospective students is good for individuals, good for society, good for employers and good for higher education. Uni Connect, the network of partnerships funded by the OfS to support universities’ work with younger students, has already reached one million participants to assist in this work, and our new framework will make it easier for those in the higher education sector as well as partners outside it to understand the nature and scale of universities’ and colleges’ work with other phases of education, and allow us all to fully understand its impact, and drive forward improvements.
Positive, practical conversations I have had with senior leaders and access professionals across the sector also gives me the confidence to move forward with a system of regulation that asks universities and colleges to take a more proactive role in identifying both the risks to equality of opportunity they need to tackle, and what appropriate mitigations they will use.
We recognise that the task we are setting out is complex. Risks to equality of opportunity are complex and multi-faceted – the likelihood of risks impacting on any given individual’s choices, the severity of that impact, and number of individuals so impacted, requires sophisticated analysis. We know that some groups who face substantial barriers, such as care-experienced students or those from Gypsy, Roma and Traveller backgrounds are smaller in number than others, such as boys from working class communities, which is why I must be clear that determining which are the greatest risks is not a matter of quantity of those affected, but also the impact of the quality of life of individuals of a risk manifesting, and the likelihood it might occur. In some areas, there is still much more work to do to even understand the nature of the problems we face.
Evaluation and collaboration are key to success
We are putting the task of building individual agency at the heart of our work, and that means we must accept that interventions may have unintended consequences on those who they are designed to support, and on others not subject to the intervention. A given institution may not possess adequate resources, capacity, or authority to tackle a given risk, or may only be able to address an aspect of the risk rather than the whole.
For these reasons, evaluation and ongoing learning about efficacy and efficiency is essential to understanding whether risks to equality of opportunity have been reduced; if so, how that reduction has occurred; and, if not, what other intervention may work better.
Again, the mass variation process and the quality of discussions amongst evaluation leaders across the sector gives me confidence that our objective of more and better evaluation of access and participation initiatives is both necessary and realistic. In consulting on our new regulations, we will seek views on our expectations that universities and colleges include in their access and participation plans details of the risks to equality of opportunity they are seeking to mitigate, the interventions they will undertake to do so, and a clear evaluation plan, including the methodologies they will use and when they intend to publish outcomes.
We plan to hold providers to account for this, but because the access and participation plans (APPs) are public documents, so too can and should others in the sector and outside of it. We are keen to see a thriving discussion of all aspects of the plans, and we will continue to fund TASO, the 'what works' centre for higher education equality activity, to ensure there is a forum for that debate and an institution to capture and reflect on the outputs from these evaluations.
I am also very conscious of the need to ensure that our regulation does not overburden providers and so become a barrier in and of itself to them contributing to this vital work. In particular, I know that smaller providers have found the access and participation plan process onerous and often feel they have agreed to targets they are not comfortable with simply to make the whole thing go away, at least for a little while. It cannot be right to run a system where we are deliberately deceiving ourselves.
For that reason, we will be explicit in our regulatory approach that, whilst we expect the same standard of intervention and evaluation from smaller providers, the volume and range of activity an institution is expected to commit to in its APP will be less for those with less capacity and resource. These institutions still have a vital role, but to be meaningful, it must also be realistic, and that requires a new approach from us as a regulator, as well as from those regulated.
There is more to say on the specifics of these proposals, and a draft of the new regulatory notice, indicative content for the equality of opportunity risk register, and a full consultation document will be released shortly, and I am happy to answer a few questions today.
But for now, I would reiterate the core of these changes is building a framework that allows us, as the regulator of higher education, to discuss and agree with those we regulate the problems we will collectively tackle on equality, how we will do it, learn more about what works and what does not, and commit to expanding that knowledge base into the future.
Collaboration is crucial – between students and university and college staff, between higher education providers, and especially across different phases of education, and with charities and employers, who I know are keen to be part of this work.
Openness and transparency between all those partners will be underpinned by the OfS’s regulatory expectations and the support we provide to TASO, Uni Connect and other projects.
We do not expect every intervention to succeed – there are no ‘silver bullets’ in this work, nothing that works everywhere all the time, but we will hold universities and colleges accountable for undertaking and evaluating the interventions they have committed to, ensuring that they are taking action to tackle risks to equality of opportunity, and helping build our knowledge of what works, and what does not, in a coherent manner.
And we hope and intend that by publishing universities’ and colleges’ commitments in public, easily accessible APP documents, that other stakeholders, especially the communities higher education serves, can hold them accountable too.
In life, none of us can simply choose to be and do anything without reference to our circumstances – our own interests and efforts impact on our aspirations, and it is right that hard work should be rewarded.
But some amongst us have a far greater capacity to exercise choice about their lives than others: not just because they may have greater resources, financial and otherwise, to draw on in creating chances to live and work in different ways, but also because their circumstances and the experiences they derive from them, change what they believe it is possible for them to do and be.
The reforms we are proposing do not suggest the higher education sector alone can erase all barriers to equality of opportunity – but we believe that our regulation can and will establish greater clarity and co-ordination of the sector’s work in this area, expanding impact and making possible more and better activity in partnership with employers, schools and charities, to ensure that choice, and not chance, determines who accesses and succeeds in English higher education.
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