There is much that is sensible about the proposals on future approaches to quality assessment.

It is clearly right to distinguish between established institutions that have been subject to regular quality checks since 1992 or earlier and newer providers with shorter track records. It is right to place greater reliance on institutions¡¯ internal review processes. The consultation document¡¯s plans to address the comparability of standards through subject-based communities of assessors and a strengthened external examiner system are welcome, and it is good to reduce unnecessary bureaucracy. But the ÖйúAƬ Funding Council for England¡¯s Future Approaches to Quality Assessment in England, Wales and Northern Ireland consultation also raises a number of issues that require serious reflection.

First, as last week¡¯s speech by the new universities minister Jo Johnson made clear, the government remains committed to introducing a teaching excellence framework, although what it will be and when it will emerge remain unclear. There is an obvious risk that by going ahead with both the new assessment regime and the TEF, we shall be recreating the dual audit-assessment framework that was introduced in 1992. This caused what the sector felt was an unnecessary bureaucratic burden and was eventually abandoned in 2001 ¨C and we now have many more external regulators and processes than we had then. Would it not be better to put these proposals on hold until the shape of the new TEF and its relationship with assessment becomes clearer?

The consultation document makes much of the shift in focus away from quality assurance processes towards reliance on data on student outcomes. While useful for the compilers of league tables, the various datasets referred to such as the National Student Survey and the Destinations of Leavers from ÖйúAƬ survey actually tell us very little about the things that really matter for high quality learning and achievement. Martin Trow¡¯s aphorism ¨C that ÖйúAƬ is a process masquerading as an outcome ¨C remains pertinent. This may therefore prove to be a blind alley, if not a misuse of resources.

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The proposal that governing bodies should in effect sign off on the appropriateness of the academic standards of the institution¡¯s awards and the student learning experience gives them a role for which few governing bodies have either the means or the appetite. The statement about ¡°the predominant role of senates and academic boards¡± shows only too clearly the authors¡¯ awareness of the danger that this could drive a wedge between a governing body and the senate/academic body and vice-chancellor as ¡°chief academic officer¡±. There is also a certain sleight of hand. Much is made of the fact that cyclical external quality reviews will no longer be needed for most providers. But proposing that periodic governance assurance reviews will scrutinise governing bodies¡¯ effectiveness in signing off on quality and standards in effect substitutes one cyclical set-piece engagement for another.

Finally, the document envisages that in future external quality assurance will be run by the funding bodies, with the Quality Assurance Agency or another agency reduced to an advisory and servicing role. However, the QAA was originally set up as an independent body because the Further and ÖйúAƬ Act 1992 explicitly excludes the funding councils from any role in ¡°assessing institutions¡¯ arrangements for maintaining academic standards¡± unless the secretary of state gives a direction to that effect. The intention of the act is quite clear: to separate the assessment of the quality of education (by the funding council or its agent) from the audit of academic standards (through an agency independent of government and owned by the sector). When the QAA was established in 1997, it was on the basis that it would be the funding bodies¡¯ agent for assessment and the sector¡¯s agent for handling academic standards. The reasons for such an arrangement remain just as valid now as they were then, if not more so, and the sector would be ill-advised to go along with such a change.

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Roger Brown is emeritus professor of ÖйúAƬ policy at Liverpool Hope University and headed the Quality Assurance Agency¡¯s predecessor, the ÖйúAƬ Quality Council.