The OfS compiled a provisional report which was shared with the QAA in April 2022. The QAA provided representations in response to the provisional report which were carefully considered before a final report was submitted to the Secretary of State for Education in November 2022. While the report was being finalised, the QAA announced in July 2022 that it had asked the Secretary of State to remove its designation from 31 March 2023.
In the report, the OfS set out its view that the designation of the QAA is no longer appropriate for securing the effective assessment of quality and standards. The OfS supports the QAA’s request to have its designation removed. Had the QAA not made that request, the OfS would have recommended that the QAA should no longer be designated on grounds relating to its ability to perform the assessment functions in an effective manner.
The report identifies four issues with the QAA’s performance. These were:
- Quality of assessment reports: Reports provided by the QAA following assessment of quality and/or standards for individual providers are not fit for purpose because they do not meet the OfS’s requirements for use in regulatory decisions.
- Methods for assessing quality and standards: The QAA was asked to make proposals for how it would assess quality and standards in relation to the OfS’s new conditions of registration. Despite detailed feedback, and three successive submissions, the OfS’s judgement was that the QAA’s proposals would not enable the OfS to make effective regulatory judgements.
- Conflict of interests: The QAA operates as both the DQB and as a paid-for membership organisation to which the majority of providers the OfS regulates choose to subscribe. Its membership scheme for providers in England began in August 2019 and has since significantly expanded. The OfS’s view is that this gives rise to a conflict. The QAA has made changes to its management and governance arrangements, but these fail to resolve the issue.
- Value for money: The charging structure used by the QAA to calculate the fees it charges to providers for its work as the DQB is consistent with the requirements in section 28 of the Higher Education and Research Act 2017 (HERA). However, given the substantial concerns the OfS has identified about the QAA’s capability to perform the assessment functions effectively, the OfS does not consider that the current fee levels represent value for money for individual higher education providers, the sector more broadly, or for students whose fees are likely to be contributing to these costs.
The OfS has provided significant feedback to the QAA over the past four years on these issues, and the OfS’s Quality Assessment Committee has informed the QAA that it has significant concerns about its performance as the DQB. While there has been improvement in some areas, this has not been sufficient or sustained and, in the view of the OfS, has not resulted in satisfactory performance.
