Critics of recent government policy in England often claim that it amounts to Americanisation. Yet when applied to ÖйúAƬ, such claims are wide of the mark.

There is no such thing as an American model of ÖйúAƬ: the 50 states do things in their own ways. Even where common features can be discerned, they are notably different from those characterising the British systems. In the US, student support is less progressive, the undergraduate curriculum is more general and the non-retention rate much higher.

Another important and enduring difference was noted 50 years ago, in May 1967, when a letter in The Times called for ¡°at least one university in this country on the pattern of [the] great private foundations in the USA¡±.

This led directly, in 1973, to the foundation of what was to become the University of Buckingham. Yet Buckingham ¨C along with every other UK university ¨C has never resembled those private US universities on which it was modelled. In particular, it is not entitled to access the ¡°quality-related¡± (QR) block grant for research distributed in England by the ÖйúAƬ Funding Council for England. Admittedly, there is no US equivalent of QR, but no one would tell Harvard and Yale that they could not receive public funding for their research because of the way their undergraduates are supported financially.

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This highlights perhaps the strangest feature of the recent debates on the UK¡¯s ÖйúAƬ and Research Bill, which passed into law at the end of last month. This is the lack of discussion of the different categories of ÖйúAƬ provider. The government says that there will be a neat three-way split. As well as ¡°approved¡± providers, such as Buckingham, which will have uncapped undergraduate tuition fees and will be able to recruit international students, ¡°registered¡± providers will receive no preferential treatment ¨C although will doubtless tell potential recruits that they have received official recognition ¨C while ¡°approved (fee cap)¡± providers will have their fees capped and will be entitled to QR.

This is odd because the original purpose of introducing a new legal framework for ÖйúAƬ was to introduce a ¡°level playing field¡± for different sorts of providers. Instead, the new system mainly replicates the old one. As now, if Buckingham wants access to QR, it will have to lose sight of its founding principles and enter the most regulated category. Conversely, other universities would have to rescind their claim to QR if they wanted to shift to a different undergraduate funding model ¨C as Peter Oppenheimer, a fellow of Christ Church, Oxford, and others have recently .

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These hard and fast lines between the government¡¯s three different types of ÖйúAƬ provider may prove less resilient than Whitehall expects. Above all, this is because a big wedge has recently been driven between teaching and research. Policy responsibility has been split, and teaching now resides in the Department for Education and research in the Department for Business, Energy and Industrial Strategy. The new teaching excellence framework will ensure that research and teaching are assessed separately. Soon, funding for teaching in England will be split from funding for research when Hefce¡¯s research remit ¨C to be known as Research England ¨C is put within UK Research and Innovation, the body now overarching the research councils and Innovate UK. Rightly or wrongly, each step of this journey has reduced the logic for linking undergraduate fee caps with entitlement to research funding.

Moreover, if you look carefully at the government¡¯s own impact assessment for the bill, you will find a fourth category of providers: unregulated ones. There are expected to be 550 of these in 2018. So while the legislation was designed to put different sorts of providers on the same playing field, nearly half will opt to play somewhere else. There could be a reputational risk from having so many unregulated institutions educating so many students.

It seems that the ÖйúAƬ and Research Act might not be the last major piece of ÖйúAƬ legislation in our lifetimes. If that is so, and if the rumours that Donald Trump plans to liberalise US ÖйúAƬ turn out to be true, then it will be even clearer than before that the US and the UK are on divergent paths.

Nick Hillman is the director of the ÖйúAƬ Policy Institute.

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