Proposals for a revised approach to assessing and rating quality

Key points of this proposal

• We would only require student submissions for TEF student experience assessments.
• We would expect student submissions to address all the student experience criteria, with a particular focus on the issues that matter most to students and where they have the strongest evidence.
• Student submissions would draw on a wide range of student views, with transparency about the views represented and any limitations.
• Student submissions would normally be submitted in writing, with a maximum length of ten pages, with the option of submitting an audio recording accompanied by a transcript.
• Student submissions would be coordinated and submitted by a suitable student representative nominated by the provider and acting on behalf of the wider student body.
• Providers would be required to offer all reasonable support to enable students to prepare an independent submission while not influencing its content.
• Where a provider does not sufficiently support an independent submission, this would be a breach of revised condition B6 and would inform assessment of the student engagement criterion.

Explanation

236. Following stage one, we decided that students should be encouraged and enabled to provide a direct and independent perspective on their academic experience through a TEF student submission. We decided the submission should focus on the student experience aspect rather than student outcomes.
237. We recognise the value of hearing directly from students when assessing the quality of a provider’s educational experience. We have therefore considered whether a student submission should form part of assessments against only minimum requirements. However, we consider that it may be disproportionate to require a separate student submission in all cases. Instead, we propose that providers should confirm that they have shared their submission with relevant student representatives and have provided an opportunity for those representatives to comment on its content. Where we identify risks requiring an enhanced assessment, as set out in Proposal 11, the assessment would include direct engagement with students during the site visit.

Scope, content and format of student submissions

238. We propose that TEF student submissions would normally be expected to address all of the student experience criteria. However, students would not be expected to cover each criterion in the same level of detail and could focus on the issues that matter most to their student body and where they have the strongest evidence.
239. To support students in preparing submissions, we propose a more structured approach than in the previous TEF, based around a common set of questions linked to each of the student experience criteria. Students would normally be expected to respond to a broad question about each criterion, while retaining flexibility to determine the level of detail provided for each area. Optional prompts would also be provided to help students identify relevant issues and evidence, but students would not be expected to respond to every prompt. Our draft guidance for students includes a draft template setting out the proposed questions and prompts.
240. We consider that this approach would provide greater clarity about the areas on which we are seeking student views, support students in gathering evidence and preparing submissions, and help to ensure assessors receive information in a more consistent format. The proposed questions and prompts are intended to focus student submissions on areas where students can provide the greatest additional value to the assessment, including aspects of the criteria that may be less well covered by the NSS.
241. We recognise that this approach is less flexible than asking students to determine entirely for themselves which areas to cover and how to organise their submissions. We welcome views on whether asking students to address a common set of questions, while retaining flexibility over the level of detail provided, strikes an appropriate balance between structure and flexibility.
242. We propose the submission should reflect the views of the wider student body taught by the provider, as far as reasonably possible. This is so the submission could meaningfully inform the assessment. However, we recognise there would often be practical limitations and we propose the submission should be clear about which students’ views are represented and any limitations in representation. This would help enable the assessors to gauge how much weight to place on the submission alongside the other evidence.
243. We propose the submission should aim to include apprenticeship students taught by the provider. It should not include any students taught by other providers through partnership arrangements, as those students’ views would be captured through the relevant partner provider’s student submission.
244. We consider the submission should focus primarily on the views of current students, although views from previous cohorts may also be included where available. This could be up to four years previously, to align with the timeframe for the provider submission.
245. Students would be encouraged to draw on evidence of student views that already exist through student representation processes, such as surveys, course representatives, committee discussions, student-led research, campaigns and other representation activity. Additional evidence-gathering activity could be undertaken where needed.
246. We propose that submissions should explain how evidence has been collected and how it supports the views presented. We would provide guidance to help students gather and present evidence effectively and efficiently.
247. We propose that student submissions should normally submitted in writing, with a maximum length of ten pages. This limit is the same as in the previous TEF, and we received feedback that this limit was appropriate. We also propose that students should have the option of submitting an audio recording accompanied by a transcript, instead of a written submission. This is to enable more students to participate and make submissions. However, we do not propose allowing a video format (as permitted in the last TEF), as we consider that this would be less comparable to a written submission than an audio recording with a transcript. To further support comparability across submissions, the same page limits would apply to written submissions and transcripts.

Submission process and timing

248. We propose broadly the same approach as in the previous TEF in terms of who would make the submission on behalf of students. The submission would be coordinated by a nominated student representative acting as the TEF student contact. We would normally expect this to be a student who has been elected to represent students on educational matters, such as a students’ union officer. Where this is not possible, providers should identify another suitable student representative or use a student-led nomination or election process.
249. The student contact would be responsible for submitting the submission on behalf of the student body or, where students decide not to participate, an opt-out statement.
250. Each year, the providers selected for assessment would typically be informed of this in July, including whether they can apply for a TEF student experience rating. If they choose to apply for a TEF rating, they would be asked to nominate a TEF student contact by the end of August. We propose that student contacts would then be given until the end of January of the following year to make their submission. This would allow approximately five months between nomination and submission.
251. Previous feedback from TEF student contacts suggested that the timing of the TEF 2023 student submission (October to January) was challenging. We therefore propose to extend this window as far as possible, without unduly affecting the assessment process. A deadline later than January would mean the assessors would conduct a significant amount of assessment work prior to receiving student submissions which would risk reducing their impact.
252. This timeline would also mean that both the provider and the TEF student contacts would have around five months’ notice before their submission deadline, with the timeline for student contacts running later.
253. We propose that providers should be required to share their final submission with student contacts, allowing them the opportunity to comment on it in the student submission.

Provider support for student submissions

254. Following stage one, we decided that providers will be expected to facilitate an independent student submission. We also said that in stage two we would consult on the expectations on providers and the implications where students do not make a submission.
255. We propose that providers would be required to offer all reasonable support to enable their students to make a submission, and this would be a requirement under condition B6. The proposed condition B6 is published alongside the draft guidance. Support could include, for example:
• ensuring students are aware of the opportunity to make a submission and understand the purpose of the process
• providing access to relevant information and data
• helping to arrange evidence-gathering activities
• providing practical, administrative or accessibility support
• providing financial support to cover costs directly related to preparing the submission
• giving frequent opportunities for students to engage with relevant staff.
256. Providers would be expected to ensure that communications about the submission are neutral and make clear that positive, negative and mixed experience are all equally valuable.
257. Responsibility for the content of the submission would remain with students. Providers would support students to understand the process for making a submission and to overcome any practical or accessibility barriers to participation. However, providers must not influence, direct, review, edit, approve or incentivise the substance of any submission.
258. In particular, providers would not be allowed to draft submissions on behalf of students, suggest particular themes, viewpoints or wording for inclusion, encourage positive feedback or discourage criticism. Providers could offer financial support to cover costs of specific activities involved in preparing the submission, but not offer financial or other incentives linked to participation or the content of submissions.
259. To help student contacts with potential time pressures, we would expect providers to have early discussions with them about what support they would need and to put that support in place in a timely way.
260. Where students decide not to submit, they would be asked to provide an opt-out statement explaining the reasons for that decision. Depending on the reasons given, the decision not to participate may be treated neutrally, or may inform the assessment of the student engagement criterion.
261. Providers would be expected to support students to participate effectively in the process. We would therefore consider any evidence that students were unable to participate effectively because the provider had not provided adequate support, access to information, staff capacity, or other assistance that could reasonably have been expected. This may include situations where the provider does not identify a suitable TEF student contact, students do not submit but also do not opt out, or where the submission or opt-out statement indicates that support was inadequate or that the provider sought to influence the content of the submission.
262. Evidence that students were not adequately supported, or that the independence of the submission was not maintained may indicate weaknesses in the provider’s arrangements for student engagement. Such evidence would be considered alongside other evidence, when assessing the student engagement criterion and may also be considered in any compliance judgement with the proposed revised condition B6.
263. The rationale for this approach is that the purpose of the student submission is to provide an independent student perspective on the quality of the student experience. While students should be free to decide whether to participate, providers should have effective arrangements in place that enable and encourage meaningful student representation and engagement. The student submission process provides an opportunity to demonstrate the effectiveness of those arrangements. Where students are unable to participate effectively because student engagement capacity or mechanisms are limited, support is inadequate or independence is not maintained, this may indicate weaknesses in the provider’s wider approach to student engagement.