Consultation on the future approach to quality regulation

Section 5: Implementation, ongoing development and evaluation

Proposal 15: Implementation timeline

We propose to consult further during 2026-27 and carry out the first cohort of future TEF assessments in 2027-28.

Timeline

228. Table 4 sets out an indicative timeline for carrying out further consultation and implementing the future system. We will be working to deliver the new system as quickly as possible, as we are conscious that current TEF awards were originally planned to be updated in 2027. Additionally in our sector engagement we have heard there is appetite for a cyclical and rolling system of quality assessment. The timeline below is therefore subject to change; we will seek to deliver to a quicker timeline where possible. We will publish more information on timelines in the next stage of consultation.

Table 4: Indicative timeline

229. We envisage that an annual cycle of selecting providers for assessment, submissions and assessments would take place on the same timeline as that set out for the first year (academic year 2027-28). While we would expect to have a single submission deadline in each year, we anticipate that outcomes would be published in batches rather than all at the same time, as some assessments are likely to take longer than others to complete.

Transition to the new scheme

230. We anticipate assessing the first cohort of providers under the modified TEF in academic year 2027-28, and we expect to be able to assess up to 150 providers in any single year, given the proposed changes in the assessment approach. There are currently 227 providers with 2023 TEF ratings, which they would retain until they are assessed under the new scheme.^[17] Table 2 sets out a proposed timeline for assessing providers for the first time under the new scheme. This would result in some providers with existing TEF ratings retaining them during a transitional period, while other providers have ratings under the new scheme.
231. We acknowledge that the ratings from the 2023 TEF and the future TEF scheme would be based on different criteria, and that existing 2023 TEF ratings will become increasingly out of date. In particular, the meaning of a Bronze rating would be different in the future approach. Our proposed timeline for assessing providers for the first time includes assessing all providers with a TEF 2023 Bronze rating in the first year of the cycle, and completing the first cycle as rapidly as would be practicable.
232. We are considering how best to communicate outcomes from both schemes during this transitional period and welcome views on two possible options, as well as suggestions of others:
     1. We could ‘archive’ the published TEF 2023 outcomes from autumn 2028 (once we publish the first set of outcomes under the new scheme) and require providers to stop publicising any TEF 2023 ratings. With this option, a provider’s TEF 2023 rating would remain valid until replaced by a new rating and would provide access to the fee uplift, but could be communicated as historical in terms of student information.
     2. We could publish TEF 2023 ratings that remain valid alongside ratings from the new scheme, with clear labelling and explanation of what the ratings mean from each scheme. Providers would be able to publicise TEF 2023 ratings if still valid.

Assessment costs

233. The costs to the OfS of delivering the TEF (including fees for panel members) were previously met directly by the DfE. We do not expect this to continue, so we would in future need to recover our costs from providers. We envisage that this would be through charging an assessment fee rather than an increase to OfS annual registration fees. We have been mindful of this in developing our proposals and therefore have sought to streamline our approach where possible, to limit the costs. We welcome further suggestions to streamline the approach.
234. If the TEF was developed and implemented along the lines proposed in this document, we initially estimate that the average cost of a provider’s assessment would be in the region of £25,000. This includes costs related to OfS staff time and external assessors. However, this estimate is based on a number of assumptions and could vary depending on the final shape and details of the scheme. We expect to provide a revised estimate when we consult further on the detailed methods and guidance.
235. Respondents to this consultation should bear in mind that suggestions that add complexity to the process or involve increasing the workload of OfS staff or TEF assessors would, if taken up, result in higher fees for providers. There could also be additional costs, and therefore higher fees for providers, involved in adhering with European standards and guidelines.

Ongoing development

236. As in the past, we will reflect on an ongoing basis on how well the quality system is working, both operationally and in terms of achieving its aims, and make improvements where we identify these and when we consider them to be deliverable.
237. There is scope for us to make operational changes between TEF assessment years without compromising the comparability of ratings. After the first year of operation we are likely to review and refine the operational procedures, but we would avoid making more fundamental changes, such as changes to scope or assessment criteria, at that point.
238. To test the robustness of the assessment outcomes and inform ongoing development of the approach, we also think it would be beneficial to carry out a small number of sample-based visits to providers. These visits would test how well the outcomes of the desk-based TEF assessments reflect students’ experiences on the ground.

Development for future cycles

239. As set out under Proposal 3: Provision in scope, we are proposing to expand the TEF to include taught postgraduate students from the second assessment cycle onwards. Our intention would then be to rate taught postgraduate provision separately to undergraduate provision. Expanding to include PGT provision from the second cycle gives us sufficient time to collect PGT student feedback data and develop the benchmarked data indicators that we will need to inform the assessments.
240. We plan to develop a national survey for PGT students as follows:
     1. During 2026 we would develop a questionnaire and carry out cognitive testing, drawing on previous pilot work, the current NSS questionnaire and the Postgraduate Taught Experience Survey.
     2. We would pilot the survey in 2027.
     3. It could be implemented in full from 2028. This would enable data to be gathered in advance of the second cycle of assessments.
241. Proposal 3 also sets out our intention to undertake preparatory work to allow us to include indicators relating to modular provision, from the second assessment cycle. As a minimum, we anticipate this will include developing a module completion measure, which we anticipate being available to use for regulatory purposes from 2030-31, and considering how transfers to and from modular study should be treated in existing measures. We anticipate we will also consider:
     • whether it would be appropriate to develop additional measures specifically for modular study
     • how to benchmark any measures related to modular provision
     • how we might best understand and assess the experience of students undertaking modular study
     • whether the assessment criteria should be adapted to accommodate modular provision.
242. In future cycles, it could be possible to extend assessments to consider additional areas of provision such as transnational education, or additional assessment themes, for example relating to wider student support and student wellbeing. We could also consider further integration of access and participation into the assessments. When considering extending assessments to other areas we would undertake scoping work to understand how they could be incorporated, their relative priority, and the extent of the development work needed to provide the TEF assessors with a sound evidential basis for their judgements before consulting with the sector on proposed additions.

Evaluation

243. We have carried out evaluations exploring different component parts of our current quality system, including the TEF and B3 assessments, and we are due to publish a further evaluation of our quality investigations in October.^[18] We recognise that looking at these components in isolation has the potential to miss how they work together to help us achieve our regulatory objectives. We are currently beginning a wider programme of evaluation, which will explore the extent to which our overall approach to regulating quality achieves its intended impacts. This programme will also look at how the impact changes as we revise our assessment approach and is expected to last from 2025 until as late as 2035. The two key questions for the evaluation are:
     1. Does the OfS’s overall approach to regulating quality result in improvements for students?
     2. How could the quality system be improved to have greater impact on:
        1. Providers at risk of being not compliant with the OfS’s minimum requirements?
        2. Continuous improvement for high quality providers?
244. The detailed evaluation questions that sit below these will be answered through a combination of methods, including quantitative and qualitative data collection from providers and students, analysis of existing secondary data such as NSS and student outcomes data, and repetition of methods to look at changes over time. We are in the process of contracting with independent evaluators, through an open procurement process, to collect and analyse data from providers and students.

Notes

[17] We state in paragraph 17 of the TEF 2023 guidance that ratings will last for four years, or until the subsequent exercise concludes, whichever is later.

[18] Available at OfS, Evaluating the TEF and Evaluating our approach.