Proposals for a revised approach to assessing and rating quality

Key points of this proposal

• We would present student experience and student outcomes data separately for taught provision, subcontracted provision and validated-only provision.
• Students on subcontracted provision would contribute fully to a provider’s TEF ratings and minimum requirement assessment outcomes.
• We would consider differences in quality between taught and subcontracted provision in the same way as other variations within a provider’s provision.
• Validated-only provision would not contribute directly to a lead provider’s TEF rating. Assessors would make a separate judgement about whether validated-only provision is satisfactory or unsatisfactory.
• Where validated-only provision is unsatisfactory, we may consider restrictions on the provider’s DAPs.
• We would not assess modular provision distinctly in the first cycle of the TEF but we would still expect providers to secure positive outcomes for modular students and we would monitor risks associated with modular provision.
• We would introduce a modular completion measure in future that is likely to count the outcome of every module studied and may use different census dates from existing completion measures.
• We are considering introducing a new split indicator for fully flexible part-time study in the existing student experience and student outcomes measures.
• Future TEF cycles may report modular and flexible provision as a distinct mode of study, separate from full-time, part-time and apprenticeship provision.

Explanation

Provision in scope of quality assessments

149. Following stage one we decided that the first TEF assessment cycle will cover undergraduate provision, with taught postgraduate provision joining from the second cycle. This reflected limitations in the data currently available for taught postgraduate provision. We now propose that the provision in scope of an assessment against only the minimum requirements would be the same as for a TEF assessment. This would help make sure that we assess minimum quality requirements consistently across the whole system.
150. However, where we identify serious concerns about the quality of taught postgraduate provision during the first cycle, we may conduct a quality investigation.

Partnership provision

151. Following stage one, we decided TEF assessments would include provision delivered through partnership arrangements. We also said we would consult further on how we should reflect different types of partnership provision in assessment and ratings.
152. We now propose different approaches for subcontracted provision and validated-only provision.
153. Where a provider subcontracts the delivery of teaching, it recruits and registers the student and remains directly responsible for the quality of the student’s experience and outcomes. The teaching partner delivers provision on the provider’s behalf. We therefore consider it appropriate that students studying through subcontracted arrangements should carry the same weight in assessments as students taught directly by the provider.
154. Under this approach, student experience and student outcomes in subcontracted provision would contribute fully to TEF ratings and to minimum requirements outcomes for each aspect. We would consider any differences in quality between directly taught and subcontracted provision in the same way as differences between other parts of a provider’s provision, such as different subjects, modes of study or student groups. The effect on TEF ratings and minimum requirements outcomes would therefore be consistent with our broader approach to considering variation within provision (see Proposal 17).
155. We would base the indicators for assessment on data from students taught directly by a provider and students taught through subcontracted arrangements. Both groups would contribute equally to the provider’s assessment outcome. We would also present separate views for directly taught and subcontracted provision, so that assessors can identify and explore any material differences between them.
156. We propose a different approach for validated-only provision. Although a validating provider remains responsible for quality and standards, it does not directly teach students, register them, or hold a contractual relationship with them. We therefore do not consider it appropriate for the quality of validated-only provision to contribute directly to a provider’s TEF ratings.
157. At the same time, we consider it important that validated-only provision remains visible and subject to scrutiny. We therefore propose an approach that holds the validating provider to account for meeting the minimum requirements for quality and outcomes of provision that it validates, without directly affecting its TEF ratings.
158. We propose presenting data for validated-only provision separately from data for provision that providers teach directly or subcontract to others. Assessors would consider all the available student experience and student outcomes data for validated-only provision, together with any relevant contextual information the validating provider submits. Assessors would then judge whether the quality and outcomes of its validated-only provision is satisfactory or unsatisfactory. This judgement would be set out in the assessment report. It would not affect the provider’s student experience or student outcomes TEF ratings.
159. We would also take account of evidence from assessments of validated partners where available. For example, where one or more validated partners are assessed as Requires improvement or Unsatisfactory, we may consider that relevant to our judgement about the quality of the validating provider’s validated-only provision. This would help make sure that decisions about validated-only provision are based on students’ actual experience of quality, rather than only on information from the validating provider.
160. Where validated provision is Unsatisfactory, this would represent concerns about the quality or outcomes of provision validated by the provider. We would consider whether the judgement has implications for the provider’s ability to validate other provision, including whether it would be appropriate to restrict the provider’s power to award degrees. This might include varying the provider’s DAPs to restrict it from entering new validation arrangements.
161. We would expect the provider to address these concerns and demonstrate improvement through the next assessment cycle. If we judge a provider’s validated-only provision as Unsatisfactory again at its next assessment, we would normally remove its ability to validate provision delivered by other providers. Proposal 20 explains the possible consequences of an Unsatisfactory judgement, including restrictions on validation activity.
162. We consider this approach appropriately reflects the different relationships providers have with students studying through subcontracted and validated-only arrangements. It ensures that provision delivered on behalf of a provider contributes fully to its TEF ratings, while maintaining separate accountability for the quality and outcomes of validated-only provision. It also allows us to address concerns about validation activity through targeted regulatory action where appropriate.

Modular and flexible provision

163. In the context of the funding for modular pathways through the Lifelong Learning Entitlement (LLE), we decided following stage one to take a phased approach to assessing modular provision in the TEF. We are now consulting on the details of the approach, which would apply to the quality system as a whole.
164. For the first cycle, we decided TEF assessments will consider the quality of the courses within which funded modules sit. We will not require providers to address modular provision separately in submissions, though they may do so where relevant.
165. Student experience and student outcome indicators for modules will not be available to include in the first cycle of assessments. Nevertheless, we would still expect providers delivering modular provision to secure positive outcomes for modular students. Under Proposal 12 we propose to revise condition B3 to make this expectation explicit, but without introducing thresholds at this stage while measures are being developed.
166. During the first cycle, we will monitor risks linked to modular provision, including those funded through the LLE and those funded in other ways. Existing quality risk indicators are likely to apply to modules and modular pathways, including rapid changes in student numbers and exceptional staff-to-student ratios. We will also monitor emerging risks and engage with providers delivering modular provision to inform the development of any future modular-specific risk indicators.
167. As decided in the stage one consultation, we will develop student outcome indicators for modular study for use from the second assessment cycle onwards. We intend to develop a module completion indicator and associated B3 thresholds. We propose that the modular completion measure should align with the existing completion measure by counting students who have completed modules or are still studying them at the census date, as positive outcomes.
168. We are seeking early views on two proposed differences from the existing measure:
     1. Census date: Because modules are shorter than full courses, we will explore census dates that provide a more timely assessment of completion while allowing sufficient time for study to be completed. For example, we expect to consider options that would include measuring the proportion of students who complete or continue after three months or six months. We intend to observe data from early rounds of modular delivery to inform our decision on a census date, and welcome views on other options we should consider.
     2. Counting modules: We propose to count the outcome of every module studied because students may study more than one module within an academic year. This differs from the current completion measure, under which students studying multiple instances of higher education at the same provider and level are counted only once per reporting year.
169. We will begin collecting data for the modular completion measure from 2027-28. We expect to consult further on the modular completion measure and minimum thresholds before introducing them in 2028-29 or 2029-30, depending on data quality. Final definitions will also be informed by evidence on student behaviour following the launch of LLE-funded modules in January 2027.
170. As our understanding of modular study develops, we will consider whether additional measures of student outcomes or experience will be helpful and how best to obtain the relevant information. This work will draw on evidence gathered through our 2023 call for evidence and the 2025 summary of responses⁵ and we will continue to engage with the sector on additional measures. This may include a progression measure capturing post-study outcomes for modular learners. We would not expect any modular progression measure to be available until at least 2030-31.
171. We think it would be helpful in future to report modular study as a distinct mode of study, separately to full-time, part-time and apprenticeship provision. This would recognise the distinct nature of that provision, and the different measures we would be using.
172. We are interested in views about whether students on fully flexible courses should in future also be reported separately from full-time and part-time provision, in the same mode as modular students. This could recognise a more similar pattern of study for modular students and students who register for a full qualification on the basis that they can study at their own pace, pause and return to study in a flexible way.
173. We do not propose introducing a separate mode of study for modular or fully flexible learners at this stage, as we have not yet developed the relevant measures. However, it would be possible to introduce an additional split in the part-time indicators for students on ‘fully flexible’ courses. We are interested in views about whether this would be a useful way to take account of different study patterns.

Postgraduate taught provision

174. We decided following stage one that taught postgraduate provision will be included in the second TEF cycle. We received feedback about the issues we need to resolve before we can include taught postgraduate courses in TEF assessments in future. We are in the early stages of working with Advance HE on the development of a taught postgraduate student survey and will engage with the sector about this from autumn 2026. We will consult at a later stage on the taught postgraduate survey and other issues involved in assessing taught postgraduate provision from the second cycle, before the second cycle of assessments starts in 2030-31.

Notes

[5] See OfS, Positive outcomes for students studying on a modular basis and Positive outcomes for students studying on a modular basis: Summary of call for evidence.