Happy academics are all alike; every unhappy academic is unhappy in his own way - Leo Tolstoy might have said this, had he compared university life on both sides of the pond. In the US, as in the UK, education systems with poor immunity have been succumbing to potentially terminal cases of commercialisation. But the specifically British symptoms include the recent and revealing changes in status undergone by the previously uncontroversial term "university". Formerly sandwiched by reassuringly utilitarian values in the middle of the Department for Innovation, Universities and Skills, the term is omitted in the latest, and even more commercially resonant, Department for Business, Innovation and Skills.

Unhappy at this Gradgrinding down of scholarly values, and with a significant amount of professional and personal experience of life stateside, I've long looked at the American sector like Homer Simpson contemplating a doughnut. In the US, the professor (a title used for all lecturers) is the sole arbiter of his or her module content, mode of assessment and mark schemes. This is a degree of professional autonomy that Brits can only dream about. We bear more prosaic titles such as "module manager" to convey our hod-carrying status at the chalk-face of the new learning and teaching ziggurats. As we chat over excessively cold beers, my American colleagues assume the appearance of cartoon characters as, eyes bulging and jaws hitting tables at speed, they listen aghast to tales of the bureaucratic banality that has colonised and blighted UK academic life to such an extent that Japanese knotweed would need to take Viagra to compete.

An annual look at world university rankings makes chastening reading, whatever qualms a British readership may have about the precision of any league table. The standard response to US table-hogging fixates on the financial advantages its institutions enjoy, but while it is valid in part, this argument fails to engage with myriad other factors. The more uncomfortable truth is that, unlike the actual world-class achievements of US universities, Britain's claims to world-class fame - with occasional honourable exceptions - are limited to the global lead we have assumed for the number of times the terms "world class" and "excellence" are used in our aspirational prospectuses.

True, the UK sector is not blessed with the high levels of alumni giving and general philanthropy that exist in the US. However, when ?888 million was made nationally available in the heraldically misnamed Rewarding and Developing Staff fund, it was invested with Royal Bank of Scotland levels of circumspection - impressively world class only in its ability to make academics wonder what purpose it serves. Meanwhile, the futility of seeking world-class status by extracting ever more surplus value from academics, who still contribute most to the bottom line of the "business" by way of research and teaching income, continues. This foolish cross-subsidisation includes the expanding and self-justifying armies of training providers and "quality-control" overseers, whose main contribution to university life is the conflation of the otherwise profound distinction that needs to be made between training and education. The political theorist Hannah Arendt praised the ideals of "training the imagination to go visiting" and "thinking without a banister" and "enlarged thought", yet UK universities currently promote training for training's sake, thinking with a Stannah stairlift and etiolated thought. Ubiquitous and pathologically generic, "centres of excellence" act as Trojan mice for further future corporate encroachments on academic autonomy.

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The most striking difference in attitudes when speaking to US colleagues is the extent to which, no matter how competitive and cut-throat their tenure track system is (or maybe precisely because of its Uber-Darwinian nature), those academics who survive retain a strong sense of scholarly self-worth that is largely extinct in the UK. Apparently either too insecure or complicit in our own managerial oppression, self-hating academics in the UK have failed to oppose the plague of managerial "cliche-agglutinations" (a phrase coined by Duke Maskell and Ian Robinson in The New Idea of a University (2001)) with their own, rather more hard-earned, intellectual standards. This is how such metastatic terms as "excellence" become honoured more in their rhetorical repetition than their observance. The more assessment-insulated US professors are saved from the need to participate in research assessment exercise/research excellence framework regimes - the pre-ordained outcomes of which make the Eurovision Song Contest seem a model of voting probity.

A strange mode of cognitive dissonance exists among UK academics that is not as evident in the US. You are encouraged to strive to be an internationally recognised scholar, but your day-to-day working life is dominated by bureaucratic procedures designed by people who sometimes fail to be recognised on their own corridor. You are encouraged to deliver cutting-edge, research-informed teaching, but since it can take 18 months to get a new module past various Masonic administrative cabals, in bad faith we learn to pretend that the dulled cutting edge is sharper than it really is. The student learning experience is claimed to be at the heart of the university mission, but part of the unwritten rules for obtaining senior academic status in the UK seems to be the ability to prove that one can consistently find ways to avoid teaching. In stark contrast, well-established career-advancement procedures exist in the US so that professors who are enthusiastic lecturers are recognised by students and rewarded by their managers.

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In the UK, infestations of consultants and commercially orientated, self-appointed experts - not only unopposed but actively encouraged - now dominate ÖйúAƬ discourse as the sector's raison d'etre evolves from an explicitly public service to an implicitly commercial activity with a scholarly facade. Exemplifying proverbially "interesting times", the interregnum we inhabit is one in which previous intellectual standards slide into flux. Counter-intuitively, in the even more commercially driven US society, the boundaries and limitations for scholarship are more clearly defined and longer established. This has allowed a more forthright assertion of academic autonomy. The American traditions of philanthropy and tenure act as powerful checks to counter corporate depredations upon independent thought.

On the upside, there are still aspects of the British system that compare favourably with the US and, like good conversation in the age of Twitter, are just about managing to survive. Thankfully, UK students remain immune to the boorish conformity of the frat-house mentality that seems to exist only to prove Boris Pasternak's observation that "gregariousness is the refuge of mediocrities". Also, unlike their US counterparts, UK university bookshops are not (quite) yet at risk of being sued under the Trade Descriptions Act for their lack of actual reading material, overtaken as they are by cuddly toys and leisure wear. Similarly, British campuses have not yet (fully) reached the neo-Orwellian state of US sites, where the herds of students, uniformly swathed in university-logoised sweats, bovinely browse in heavily franchised educational paddocks.

"Academic enterprise" and "knowledge transfer" - the sort of phrases George Steiner had in mind when he referred to "the greasy idiom of the profiteers" - have become the buzzwords du jour instead of being recognised as ideologically riddled oxymorons. As the UK and US are military allies in Afghanistan, perhaps academics on both sides of the pond can join forces to defeat the Taliban-with-spreadsheets squatting in our ivory towers. The British would do well to heed C. Wright Mills, the American sociologist, who warned against "the curious passion for the mannerism of the non-committed" that the sterilisation of the academic imagination creates. He made this apposite plea: "Above all, do not give up your moral and political autonomy by accepting in somebody else's terms the illiberal practicality of the bureaucratic ethos." While the US system offers at least some safeguards for scholarly autonomy, it remains to be seen how denizens of the British system will fare, but the auguries are not good.

In Waiting for the Barbarians, Lewis H. Lapham notes that when Alaric's Visigoths breached the walls of Rome in 410AD, the Emperor Honorius was in his palace on the Adriatic coast, fussing over his collection of prize poultry. When informed by an attendant that Rome had perished, he was initially shaken with disbelief and anguish, only to regain his composure when the confusion was cleared up. Much to his relief, it turned out that it was Rome the city that had fallen and not his favourite chicken, as he first feared. Today, on this side of the pond, corporate attitudes to the ivory tower and the latest prized chicken-brained "initiatives" have more than a passing resemblance to the inversely misplaced affections Honorius held for his capital city and eponymous bird. Here, chickens are not so much coming home to roost as cluckily preparing training courses for the inevitable advent of the University of KFC.

SOMETIMES, THE TRUTH IS ALMOST THE SAME AS FICTION

"For anyone thinking about a job swap in the US or UK," says an American academic, "I can recommend nothing better than David Lodge's Changing Places."

The British scholar who recently traded places with him concurs. "It really does highlight the culture differences between the two systems."

The two are in agreement that Lodge's 1975 satirical novel accurately represents the way academics are treated by their own departments.

"I went to America ready," says the UK academic. "I was prepared to defend my course choices, submit my course materials and exam papers and organise my timetable ... and then I didn't have to do any of it."

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The US academic says the independence enjoyed by scholars in American ÖйúAƬ is something British universities should emulate. "If I want to spend time researching a book, I can do so, and I don't have to justify it to anybody. It's very liberating."

But present-day reality differs from Lodge's fictional academy in the matter of tenure. Recent years have seen the erosion of its long-standing prevalence - much envied by British scholars - in US ÖйúAƬ. "We have tenure peer reviews every seven years now," says the American academic. "It's supposed to make sure that we're still doing the job we're appointed to do."

Nevertheless, he says, it is still difficult to have tenure removed once it has been achieved.

"I was reading student feedback forms for a colleague in my faculty and kept coming across complaints that she had exposed herself. By the time I got to a complaint saying that she had bared her chest, I had a pretty good idea that this wasn't a metaphor."

He goes on to detail the repercussions. "We held a tenure meeting and decided as a group that due to her emotional issues, it would be best to remove tenure.

"We found out a week or so later that the head of department had reversed our decision, which they are fully entitled to do under the system."

The UK academic cites student feedback as another major difference between the two systems. While he was teaching in the US, he recalls, he was not allowed in the same room as the completed feedback forms until he had finished his marking, as the department "wanted to avoid any accusations of favouritism".

But some British departments, he adds, have no such scruples. "I know an academic who is an amateur graphologist. His department gets student feedback long before the exams, and he makes a point of going back to his room and deciphering who has said what about him. Apparently he has halved marks in revenge."

Unlike the protagonists in Lodge's novel, however, neither academic has ever seriously considered making his move across the pond permanent.

"I couldn't give up the control," the US academic says. "I prefer having that autonomy over my work."

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The UK academic's reason is slightly less work-focused, but no less important to him: "I'm simply too pale for life in the US."

- Sarah Cunnane