Not another County name for a university

Now we have seen the consultation on the proposed name change of the University of Bolton to the University of Greater Manchester, which has caused some comment.  Here’s a version of my response to the OfS consultation. It is very similar to my response to the consultation on UCLAN’s proposed new name, as the main point applies. It doesn’t say you can’t self-plagiarise these things.

Precedent

The emergence of English universities in towns where they were based, cemented the form ‘The University of X’.  The dominance of two universities in England reinforced this and the universities in Scotland also adopted this form.  

From the middle of the 19th century regulatory preference was for federal examining universities which took a neutral name, not based on a town or city that might be seen to have precedence.  When Owens College sought university title, there were objections both to a university just named after Manchester and a university united with a teaching college. The result was that the Victoria University followed in the pattern of the University of London and the Queens University (later the Royal University in Ireland) in being a federal examining university. Wales followed and there were plans for both Midlands and West of England universities. Joseph Chamberlain broke this model, insisting that Mason College should neither be a federal university not named after a region.  The granting of a charter to the University of Birmingham created a crisis that destabilised the Victoria University and led to consideration by the Privy Council which created the naming precedent that holds today and which should be honoured today.

In 1902 it was agreed that the petitions of University College Liverpool and Owens College, Manchester, together with the counter-petitions of the Victoria University and the Yorkshire College among many other interested parties should be considered by a committee of the Privy Council.  The committee was comprised of senior members of the Privy Council, including a previous prime minister Lord Roseberry.  As well as the evidence submitted to it, there were hearings where witnesses were examined by the two ‘sides’ in the case of whether the federal examining university should continue or whether new, civic teaching universities should be allowed.  R B Haldane was a keen supporter and would have presented the case for the civics if he hadn’t been promoted to the Privy Council himself.  Haldane subsequently viewed the work of the committee as of the ‘first importance in the history of higher education’ (1929, p146).

The committee agreed to to the civic teaching university and the university of Liverpool and Manchester – Haldane noting ‘I had convinced myself that a Civic University was a possible institution, and that if called into being it would have a great molding influence and a high standard under the impulse of the local patriotism of the great cities where it was to be established’ (1929, p140).  However, the issue of what would happen to the Yorkshire College was left to further discussions.    

The Yorkshire College was based in Leeds and was the smallest and youngest of the members of the Victoria University. It argued for the continuation of a federal university, perhaps because it thought it might not get its own university title.  However, there was another university college in Yorkshire, Firth in Sheffield, and the argument was that if it was to be a university for Yorkshire, then it couldn’t exclude Firth (or make it a junior partner).  The argument went on, in not particularly good faith, for many months.  The Privy Council archive has the files: we can see the frustration of the clerk and in the end Yorkshire College gets a firm note back:

I am directed to say further that Their Lordships do not, as at present informed, see their way to advise the grant of a Charter under the title of “the Victoria University of Yorkshire” 

A FITZROY TO MESSRS GEDDEN, SON & HOLME 18 NOVEMBER 1903

The charter that they’d prepared was returned showing the Privy Council’s amendments – ‘Victoria’ and ‘Yorkshire’ are crossed out and ‘Leeds’ is written in.  They  established a principle: you can’t claim to be the university of a county, if that has other universities in it.

New Universities

This pattern is established.  When Haldane opened the new buildings for University College Nottingham, there’s still a sense it might be the base of an East Midlands University and in Southampton the name of Wessex is mooted, when charters come they are for civic city names.  The test comes with the completely new universities which are planted in greenfield sites as a result of active planning.  Here the UGC accepts the arguments (and there was a lot of arguing at local level) for the universities of Sussex, Kent and Essex.  The local level is important; often it’s the county council that is the driving force, so the town chosen is secondary.  For example, Essex could have been at Chelmsford, but ends up near Colchester.  There was no attempt to create a University of Lancashire; after discounting Blackpool as a possible site, one near Lancaster was available. We do have complications over counties: when the Lancaster name was chosen, Manchester and Liverpool were still in the county. 

Newer Universities

The pattern was confirmed in 1992.  When the Privy Council had to adjudicate on whether new names were confusing, there was a sense of which differentiator was acceptable – at that point the words ‘new’ or ‘city’ were not thought to be sufficient.  This briefing note to John Major makes that clear.

We have seen acceptance of those words since then, particularly with Buckinghamshire New University being seen to be sufficiently different to the University of Buckingham.  

County  

The only example I can find is the short-lived University of Humberside in a current county with an existing university.  In this case, the Hull College of HE successively became Humberside College of HE (1983), Humberside Polytechnic (1991) before taking the county name in 1992.  Neither the county or the university have that name anymore, I imagine Hull did not protest when it took it on. Middlesex became a university twenty seven years after the county ceased to exist. Similarly, Bristol hadn’t been a part of Gloucestershire for twenty seven years when the university took the county’s name. Greater Manchester remains the ceremonial county and has been the combined authority since 2011.

Greater

We have an established precedent about using a city name with a differentiator, but clearly here we have a different proposition. The old metropolitan county, now the combined authority, has drawn on the English use of ‘greater’ to mean wider. But obviously greater also means better. We understand the context that the Greater Manchester Combined Authority doesn’t sound better than the Manchester City Council. But we know the confusion is immediate in thinking the Greater Manchester University is better than Manchester University. People outside the UK will be far less familiar with the use of ‘greater’ in geographical terms. I want to argue that we stay with the precedent of 1903.  Where there are universities existing in a county, a new name should not be approved which is the county name, especially when that implies preeminence.

Finding more HE provision in Oxford

How do we understand the geography of higher education provision? I’d been helping (carrying bags) with a land use study in Oxford which took us to an industrial estate where a set of serviced offices house Oxford Graduate College Ltd. Another trip to a back street off the Cowley Road found City College Oxford, which advertises undergraduate and postgraduate courses.

I had a go at trying to capture all the provision that exists, or purports to exist, in Oxford before – this is another attempt. These are non hierarchical categories. I am, however, making a subjective judgement as to what being in Oxford means. The City’s boundaries are drawn quite tightly, I am allowing an amount of leeway, but this doesn’t to stretch to different towns. McTimoney College says that it’s ‘on Oxford’s doorstep’, but it’s in Abingdon. The same goes for places in other counties – there’s a provider called the ‘Oxford College of Education’ which is in High Wycombe.

Providers on the OfS Register
Activate Learning is a group of colleges and it trades as the City of Oxford College (although that trading name is not on the OfS register). It has a sub-brand Rycotewood which used to be in Thame and is famous for a court case on student rights.
The Chancellor, Masters and Scholars of the University of Oxford is a registered provider.
Oxford Brookes University is registered. It currently has two campuses which are former teacher training colleges outside the city boundary, but it is intending to leave both of them and just be based in Headington.
PHBS-UK – the Business School of Peking University is based in the former OU regional centre at Boars Hill, overlooking Oxford.
University of West London merged with Ruskin College which is now just basedin Headington.

Providers not in the OfS register but which offer courses of providers on the register
Oxford Business College has a number of sites in the city as well as branches elsewhere. It has used campuses of other providers. It offers business management degrees from Ravensbourne and Buckinghamshire New University.

Magna Carta College is based at Oxford Business Park. It has offered online education with Buckinghamshire New University, but is now starting a course with weekend tuition at BNU’s campuses in High Wycombe and Uxbridge.

Overseas providers on the student sponsor register
The Washington International Study Council has undertaken educational oversight monitoring with the QAA, most recently in February 2023. The students are taught at four Oxford Colleges where they earn credit to take back to their home universities. The administration for this is from George Street in Oxford.
Centre for Medieval & Renaissance Studies is a long standing provider of opportunities for study abroad in Oxford Colleges, it now has a link with Middlebury College. Its administration is in Shoe Street, students are associate members of Keble College.

Other providers
Azad University (IR) in Oxford. In Farmoor, just outside Oxford, is a branch of an Iranian university. It is exempt from student sponsor registration as students are registered at the Tehran university first.
EM Normandie offers bachelors and masters degrees which can involve some time on their ‘campus’ in Oxford – which is based on the City of Oxford College site.
Stanford University has a base on the High Street (previously it was based in grand country houses, Harlaxdon and Cliveden) where students visiting can live.
University of Georgia has a large house on the Banbury Road where students are taught UGA courses by Oxford faculty.
Oxford College of Marketing offers a range of CIM courses an a ‘Mini-MBA’ but their courses are not linked to HE qualifications.
CAE Oxford Aviation Academy is on the UKVI student sponsor register but their courses are not linked to HE qualifications.
Oxford School of Drama describes itself as a world leading conservatoire – it runs a three year course but has not linked this to a HE qualification.
Oxford Media & Business School offers a ‘professional business diploma’ – as an alternative to university. This is not linked to a HE qualification.
City College Oxford is in Hurst Street (pictures below). On the entranceway it advertises undergraduate and postgraduate courses, including MBA. The website lists of number of universities that award and deliver these courses, but that is not obviously reciprocated on the universities’ websites. The courses are online, which is handy as it’s not a very big building. ‘College’ isn’t a protected word in the names of companies (neither is ‘collage’ which it was briefly known as).

RB (Royale Business) College has a ‘campus’ at the Oxford Business Park. It says you can do online degrees validated by Portsmouth or MBA/DBA ‘through London Graduate School which is validated and awarded by UK Universities’ (which may be Buckingham).
Oxford Graduate College is based on the Osney Mead industrial estate, although the address is a shared service office. It offers degrees in Chaplaincy, Pastoral Counselling & Psychology, and Comparative theology at bachelors, masters and doctorate level. These area awarded by ‘Alpha University’ which is probably the one based in Florida which benefits from the curious situation that Florida doesn’t require religious universities to be accredited (a situation exploited previously by ‘Oxford City University‘)

Preparatory providers
There’s a long tradition of provision preparing people for university-level study, sometimes these were known as ‘crammers’, and among the large number of independent providers are several that focus on pathways. These include Carfax, Cherwell, Greene’s Oxford Tutorial College, Oxford International School and Oxford International Study Centre. EF offers a six to nine month university foundation alongside a host of different English language courses. There was a report last year that Oxford University was taking action in the courts against Oxford Royale Academy and Oxford Programs running summer schools because of including ‘Oxford’ in their names. Kings, Oxford offers foundation programmes without sounding much like a college…

Other other providers
The Maison Française d’Oxford is associated with the university, designed to create links between it and French universities. Oxford Centre for Hebrew and Jewish Studies, Oxford Centre for Hindu Studies and Oxford Centre for Islamic Studies are independent institutions which have various links with the university. The first two centres look like departments but the Centre for Islamic Studies is vast and looks like a college.

Then there are 39 colleges and 4 private public halls whose foundation dates range from the 1280s to the 2020s. They are not registered with the OfS, but they do have UKPRNs and some parts of the HE regulatory infrastructure point at them. For example they are members of the OIA complaint scheme and as constituent colleges of the university they are subject to the HE (Freedom of Speech) Act (but not any students’ unions they themselves might have). Although most of their students are matriculated at the University, they often have visiting students (some via the overseas providers above) and some run their own summer programmes. There’s a list here.

County Names for Universities

The consultation on the proposed name change of the University of Central Lancashire, a university that has used its acronym UCLAN heavily, to the University of Lancashire has caused some comment.  Here’s my response to the OfS consultation.

Precedent

The emergence of English universities in towns where they were based, cemented the form ‘The University of X’.  The dominance of two universities in England reinforced this and the universities in Scotland also adopted this form.  

From the middle of the 19th century regulatory preference was for federal examining universities which took a neutral name, not based on a town or city that might be seen to have precedence.  Thus charters were granted to the Queen’s, later Royal, University in Ireland, Victoria University in the north of England and of course the University of Wales.   Joseph Chamberlain broke this model, insisting that Mason College should neither be a federal university not named after a region.  The granting of a charter to the University of Birmingham created a crisis that destabilised the Victoria University and led to consideration by the Privy Council which created the naming precedent that holds today and which should be honoured today.

In 1902 it was agreed that the petitions of University College Liverpool and Owens College, Manchester, together with the counter-petitions of the Victoria University and the Yorkshire College among many other interested parties should be considered by a committee of the Privy Council.  The committee was comprised of senior members of the Privy Council, including a previous prime minister Lord Roseberry.  As well as the evidence submitted to it, there were hearings where witnesses were examined by the two ‘sides’ in the case of whether the federal examining university should continue or whether new, civic teaching universities should be allowed.  R B Haldane was a keen supporter and would have presented the case for the civics if he hadn’t been promoted to the Privy Council himself.  Haldane subsequently viewed the work of the committee as of the ‘first importance in the history of higher education’ (1929, p146).

The committee agreed to to the civic teaching university and the university of Liverpool and Manchester – Haldane noting ‘I had convinced myself that a Civic University was a possible institution, and that if called into being it would have a great molding influence and a high standard under the impulse of the local patriotism of the great cities where it was to be established’ (1929, p140).  However, the issue of what would happen to the Yorkshire College was left to further discussions.    

The Yorkshire College was based in Leeds and was the smallest and youngest of the members of the Victoria University. It argued for the continuation of a federal university, perhaps because it thought it might not get its own university title.  However, there was another university college in Yorkshire, Firth in Sheffield, and the argument was that if it was to be a university for Yorkshire, then it couldn’t exclude Firth (or make it a junior partner).  The argument went on, in not particularly good faith, for many months.  The Privy Council archive has the files: we can see the frustration of the clerk and in the end Yorkshire College gets a firm note back:

I am directed to say further that Their Lordships do not, as at present informed, see their way to advise the grant of a Charter under the title of “the Victoria University of Yorkshire” 

A Fitzroy to Messrs Gedden, Son & Holme 18 November 1903

The charter that they’d prepared was returned showing the Privy Council’s amendments – ‘Victoria’ and ‘Yorkshire’ are crossed out and ‘Leeds’ is written in.  They  established a principle: you can’t claim to be the university of a county, if that has other universities in it.

New Universities

This pattern is established.  When Haldane opens the new buildings for University College Nottingham, there’s still a sense it might be the base of an East Midlands University and in Southampton the name of Wessex is mooted, when charters come they are for civic city names.  The test comes with the completely new universities which are planted in greenfield sites as a result of active planning.  Here the UGC accepts the arguments (and there was a lot of arguing at local level) for the universities of Sussex, Kent and Essex.  The local level is important; often it’s the county council that is the driving force, so the town chosen is secondary.  For example, Essex could have been at Chelmsford, but ends up near Colchester.  There was no attempt to create a University of Lancashire; after discounting Blackpool as a possible site, one near Lancaster was available. We do have complications over counties: when the Lancaster name was chosen, Manchester and Liverpool were still in the county. 

Newer Universities

The pattern was confirmed in 1992.  When the Privy Council had to adjudicate on whether new names were confusing, there was a sense of which differentiator was acceptable – at that point the words ‘new’ or ‘city’ were not thought to be sufficient.  This briefing note to John Major makes that clear.

We have seen acceptance of those words since then, particularly with Buckinghamshire New University being seen to be sufficiently different to the University of Buckingham.  

County  

The only example I can find is the short-lived University of Humberside in a county with an existing university.  In this case, the Hull College of HE successively became Humberside College of HE (1983), Humberside Polytechnic (1991) before taking the county name in 1992.  Neither the county or the university have that name anymore, I imagine Hull did not protest when it took it on.

I’m sure the OfS will have means to determine whether the word ‘Lancashire’ is sufficiently different to ‘Lancaster’ to avoid confusion, but I want to argue that we stay with the precedent of 1903.  Where there are universities existing in a county, a new name should not be approved which is the county name.  So, I don’t think the University of Lancashire is acceptable.  Sticking with the north-west, I also don’t think the ‘University of Greater Manchester’ should be allowed either.  

A Fully Functional Quality Assessment Committee

The OfS has been putting in place the arrangements for it to carry out the functions of the former Designated Quality Body (DQB). You will recall that the QAA gave notice in July 2022 that it didn’t want to continue and that took effect from April 2023. There’s been a range of adjustments made, mostly behind the scenes, but a further stage seems to have taken place in December 2023 with new appointments to the Quality Assessment Committee (QAC) at OfS.

Seasoned OfS watchers know that the regulator publishes information about its activities in different ways. Sometimes it has issued press releases with headline-grabbing features to accompany reports. Sometimes there are publications that just go up. Sometimes changes are just made to webpages – many of which get a mention in the very helpful weekly roundup email.

That the OfS is now able to discharge the functions of the DQB had been foreshadowed in the report of the QAC meeting on 12 June as received at the OfS board on 4 July (in the last set of papers we can see).

15. Members asked if the membership of the committee would need to be expanded to accommodate DAPs-related work. The secretary to the committee reported that a recruitment process would take place over the summer and that new committee members were expected to be appointed by the autumn. It was noted that any recruitment would need to ensure that the committee as a whole meets the requirements of section 46 of HERA in terms of the experience and background of members

The QAC is defined in the Higher Education Research Act (HERA) at s24, noting that it gives advice to the OfS and that a majority of its members must have experience of providing HE. The nature of the body that advises the OfS on the authorisation of degree awarding powers is set out at s46. As the QAC had noted, if it was to undertake the role of advising on DAPs, it had to have new members. In January 2024 the OfS added details of new members of the QAC who had been appointed with effect from 1 December 2023. Without going into detail, s46 requires a distribution such that someone on the committee must have experience of HE in a place that doesn’t have DAPs and HE in FE. OfS doesn’t confirm which of the members were appointed under which of these, but it’s evident that these criteria have been met by the new members.

The weekly round-up email said there was a change to the committee memberships page. There were new members for both the Risk Provider Committee (1 January 2024) and the QAC (1 December 2023). This means that, without much in the way of announcement, from December 2023 the OfS had a fully functional QAC and therefore is able to receive advice again on the authorisation of degree awarding powers. 

Registered Names

The name of your higher education provider matters. I’ve explored before how, in Britain, we have evolved a different tradition to naming universities than in other countries. Having been prompted to think about this again, I have widened this to look at all the OfS providers. There are 423 providers on the register, I think 39 of them are named after a person.

There’s an issue about the title of the provider. The OfS register lists some trading names, but not all. So, I have gone for the legal name. That means we get Andrew Bonar Law, whose name is on the memorial trust that Ashridge trades under. The first name on the list is John Ruskin; there are two providers who effectively trade under his name; but Ruskin College is now part of West London (and OfS does not list that as a trading name). 

The difference between the trading name and the legal name is a very old one. One fun question is, apart from Isaac Wolfson, how many people have a college at both Oxford and Cambridge named them? The complication is the legal name – what we all know as ‘New College’ is ‘The College of St Mary of Winchester in Oxford, commonly known as New College’. It’s ‘new’ to distinguish from another St Mary’s college – except that one is ‘The House of the Blessed Mary the Virgin, in Oxford, commonly called Oriel College, of the Foundation of Edward the Second of famous memory, sometime King of England’. This was followed by the College of St Mary Magdalen, which tends just to be called Magdalen.

So, to follow that with OfS providers I think* there are two people that more than one place is named after. They are both saints called John. 

UKPRN	Provider title	Person
10000291	Anglia Ruskin University Higher Education Corporation	John Ruskin – writer and art critic gave the opening address at the Cambridge School of Art in 1858
10008899	The Ashridge (Bonar Law Memorial) Trust	Andrew Bonar Law was Prime Minister, a memorial fund established a college
10007760	Birkbeck College	George Birkbeck established the Mechanics Institute in 1823
10007811	Bishop Grosseteste University	Robert Grossteste was bishop of Lincoln in the 13th century
10000961	Brunel University London	Isambard Kingdom Brunel, civil and mechanical engineer
10001165	Cardinal Newman College	St John Henry Newman, Educator and Cardinal
10026921	Christ the Redeemer College	Jesus Christ
10007761	Courtauld Institute of Art	Samuel Courtauld was an industrialist and art collector
10015688	David Game College Ltd	Dave Game started a college in 1974
10001883	De Montfort University	Simon De Montfort, earl of Leicester in 13th Century
10067355	Dyson Technical Training Limited	James Dyson is an industrialist, his company established the institute
10032288	The Edward James Foundation Limited	Edward James gave his estate to the West Dean College
10088214	S P Jain London School of Management Limited	Sahu Shreyans Prasad Jain was an Indian businessman and parliamentarian
10040812	Harper Adams University	Thomas Harper Adams bequeathed the estate in 1892
10003193	Hugh Baird College	Hugh Baird was a longstanding councillor on Bootle Council
10003212	Hult International Business School Ltd	Bertil Hult founded EF in 1965, the Arthur D Little School of Management was purchased and renamed in 2003
10003284	Inchbald School of Design	Michael Inchbald – then huspand of the founder
10009527	Istituto Marangoni Limited	Giulio Marangoni, started a fashion school in Milian 1935
10082570	Kaplan International Colleges U.K. Limited	Stanley Kaplan founded a college preparation company in Brooklyn
10003957	Liverpool John Moores University	John Moores, founder of Littlewoods
10030391	London Churchill College Ltd	Presumably Winston Churchill
10009612	Luther King House Educational Trust	Martin Luther King, minister and activist
10004432	Morley College Limited	Samuel Morley endowed a college for working men and women
10030129	Nelson College London Limited	Presumably Horatio Nelson
10007832	Birmingham Newman University	St John Henry Newman, educator and cardinal
10004930	Oxford Brookes University	John Brookes, long-serving principal of Oxford Technical College
10005072	Peter Symonds College	Peter Symonds, a 16th century merchant, gave money for an almshouse which became a school
10007775	Queen Mary University of London	Queen Mary, consort of George V
10005378	Rambert School of Ballet and Contemporary Dance	Marie Rambert founded a dance company that the school developed from
10005523	Rose Bruford College of Theatre and Performance	Rose Elizabeth Bruford established a Training College of Speech and Drama in 1950
10005553	Royal Holloway and Bedford New College	Thomas Holloway was an inventor of patent medicines
10006093	Spurgeon’s College	Charles Spurgeon founded a pastors college in 1856 it was renamed after him in 1923
10037449	University of St Mark & St John	St Mark and St John the Evangelists
10007843	St Mary’s University, Twickenham	St Mary
10030776	St Mellitus College Trust	St Mellitus was bishop of London in 604
10007782	St. George’s Hospital Medical School	St George, patron saint of England
10008017	Trinity Laban Conservatoire of Music and Dance	Rudoph Laban, dance innovator, founded a guild in 1945
10005736	Unified Seevic Palmer’s College	William Palmer founded a charity school in 1706
10007713	York St John University	St John the Evangelist

Many more higher education providers have formerly been named after people. Owens, Mason and Hartley became Manchester, Birmingham and Southampton. The waves of mergers in the 1960s and 1970s on the formation of polytechnics and then consolidation of teacher training colleges saw the end of Constantine, Lanchester and Rutherford (Teesside, Coventry and Northumbria). The process went on in the 2000s with King Alfred being dropped.

Although there are colleges at Oxford and Cambridge named after Jesus Christ, I’m holding that only one provider is named after him. I think that Canterbury Christ Church University is named after the cathedral, so I’ve left it out on the same grounds I’ve left out St Helens College as its named after the town and not directly the saint. The same applies to Leeds Beckett – the name is after the park which was named after a banker – but not a person himself you’d want to name a university after. I’m also leaving out Brierley Price and Prior as although BPP have retained that as the brand, the university just refers to the initials now.

A clear contrast with the US here is that, excluding owners of colleges or linked companies, very few English providers are still named after pure benefactors – just Courthald, James, Harper Adams, Holloway, Palmer and Symonds.

* Ok – so I’ve broken the rules I set out. The University of Essex online, which is a separate provider, is run by Kaplan Online Learning (Essex). It does its best not to look like a separate provider, so I’ve cheated.

This may be updated as people point out mistakes – I left out Rose Bruford & S P Jain for example.

A year of Registrations

The OfS register is at the heart of the regulatory system. Getting onto the register requires a considerable process, one that the OfS currently reckons will take 50 weeks to complete. We don’t have data on how long it has taken, but it appears to have taken longer than 50 weeks for many new providers. This is a look at progress in 2023 (an update on this blog from 2022).

It’s important that the registration process is rigorous. A proposed scheme to come up with a third category of registration for LLE, which might be lighter (and quicker) than the current Approved and Approved (fee cap) categories has not yet appeared. Way back when the registration scheme was first mooted I was among many who were against the ‘Registered Basic’ category as that looked completely light touch.

In November 2018, when the spreadsheet of registered providers was growing, I started noting when new providers went on the register and posting a tweet. I’m still adding to the thread five years later. I thought the register was important and wondered why OfS didn’t announce new arrivals. Latterly it has been noting registrations in the Monthly bulletin, but there’s still a lag. The OfS register that we can see in the spreadsheet or in the ‘beta’ web version (why is it still in beta?) doesn’t tell you when a provider joined the register. I’ve turned my twitter thread into a chart, mapping the progress of registrations.

The OfS annual review notes that 18 new providers were added to the register in 2023. These are 17 new additions: LIBF got a new entry on the register, having been sold and having a new corporate status but its previous existence was removed – so no net change. Three FE colleges were removed from the register, two as a result of mergers and one because it appears to have focused on L3 education only. The OfS doesn’t include the length of time it takes to complete a registration as an operational measure, but it does include the number of applications open. In the last quarter of 2022 there were 56 open applications to join the register, so if only 18 joined, then you could assume 38 have taken longer than a year to resolve. The latest update to the measures also shows that OfS ‘resolved’ 18 applications to join the register in the first two quarters of 2023 (five of the new providers’ registrations were announced in July and August). OfS haven’t published any refusals since it created a page on May 2022 to collect them, but ‘resolved’ could mean an unpublished refusal or a provider withdrawing from the process.

Here are the 17 new providers: a branch campus of an overseas university, a bible college, three performing arts colleges and 12 office-block based providers offering a range of Business and Health & Social Science HNDs & degrees and the diploma in education and training*. Two of these already have branches and several who are Approved offer franchised degrees from Approved (fee cap) providers at £9250.

New Provider	Region	Subjects
Peking University HSBC Business School	South East	Business & Management
International Business College Manchester	North West	Business & Management
London School of Science and Technology	London, West Midlands & East of England	Business & Management Subjects Allied to Medicine
International College of Music Theatre	London	Design & Creative and Performing Arts
Commonwealth College of Excellence	London	Business & Management
London College of Business Studies	London	Business & Management
Doren Bird College of Performing Arts	London	Design & Creative and Performing Arts
UK Business College	London	Business & Management
Stratford College London	London	Business & Management
Newham College of Further Education	London	Computing
Caspian School of Academics	London	Education and teaching
Fairfield School of Business	London, West Midlands & East Midlands	Business & Management Subjects Allied to Medicine
Birmingham Christian College	West Midlands	Historical, philosophical and religious studies
Anglo Skills College	East Midlands	Business & Management
Higher Rhythm	Yorkshire	Design & Creative and Performing Arts
School of Information Risk Management	London	Business & Management Education and teaching

Clearly London-based providers are well-represented in the new arrivals, as are those who focus on business and management courses. It’s not immediately obvious that these are adding much to the diversity of the sector in the way that the ministers favourites of Dyson, NMITE, LIS, or TEDI are. It may be that the registration process is not encouraging more innovative provision, in particular the length of time it takes requiring particularly deep pockets.

* Afterthought
We are waiting to see the outcome of a DfE consultation on the Diploma in Teaching and Education (DET). They had ‘concerns about the quality and value for money of some pre-service FE ITT courses’ and proposed that no student support should be available for the DET at providers without degree awarding powers. One of the new providers appears only to offer the DET as a HE qualification.

The London School of [Something to do with business]

Are there too many higher education providers in London? From time to time, this question gets asked. But there are more and more providers within the M25. There’s the members of the University of London, a wider series of universities, branches of UK universities, branches of international universities, and a wide range of public and private sector colleges including most of the UK’s world-leading specialist providers. But maybe there’s another question, are there too many higher education providers, the London Schools (or Colleges) of [something to do with business].

Historically, for several centuries too many providers in London meant not having one. Gresham College might not have been intended to be university, but Oxford and Cambridge made sure. Although the education offered at the Inns of Court and the medical schools were described as a third university, they were not. Bursts of new provision, say in the 1820s when both the mechanics and the ‘middling rich’ got colleges, and then again in the 1890s when the London County Council co-ordinated a burst of polytechnics and Sidney Webb and R B Haldane reformed the University of London and brought into being the London School of Economics.

The returning question of too much provision, or too many providers, has prompted rationalisations in the past. In the late 1960s the formation of the new polytechnics saw the merger of many specialist providers into large general institutions. Further consolidation of teacher training colleges in the 1970s followed. In the 1980s and 1990s there was a wave of reorganisation within the University of London, with many mergers and redistributions reducing the number of separate providers. The question was also asked in the late 1990s and 2000s regarding the new universities, reflected in the merger of London Guildhall and North London to form what became one of England’s largest universities.

If you wanted an answer to whether there are too many providers in London, then the branch campus movement would seem to offer a clear answer – ‘no’. Although some have moved back from having a campus, others continue to open and we now have branch campuses from universities already in London.

So how many providers are there? There are 38 members of London Higher, with 13 branch campuses in their centres group and 2 further associate members. The OfS Geography of HE data set has 194 teaching provider campuses in London – 131 defined as being in inner London. Some providers have multiple campuses (BPP is listed as having 5) and the teaching provider is not a registered provider in OfS terms (The British Army and the Royal Air Force are on this list). There are enough students: the DfE cohort has participation in London 12.8 percentage points higher than the average for England.

Changes to the OfS Register in 2023 reflect the dynamic nature of London’s HE scene. In April, the London Institute of Banking & Finance ‘transferred to a new entity’ LIBF on being sold to a German university group and Richmond upon Thames College’s merger with HCUC group means it came off the register. In March the Commonwealth College of Excellence (based in North Finchley but with a branch in Enfield coming soon) joined the register as did the London College of Business Studies (Ilford). There’s two ongoing conditions applied to the LCB. The college is currently small, but some of the providers in London have shown capacity to grow quickly. What Chris Hackly noticed was it’s another provider with a title in the London College/School of X mode. Companies House has records for 110,000 bodies using ‘London’ and ‘College’ in their title. ‘College’ is not a protected work in that way that ‘university’ (or ‘polytechnic’) is and clearly it, and ‘school’, been used over and over again.

The UK register of learning providers ‘does not quality assure or accredit the learning provision of the registered providers in any way’ as I have noted before. However, there is a formal step to join it, certainly necessary for engagement with the government. It records the following places using ‘London’ as the first word of the name and having business, management, economics or commerce in its name or subject provision. I’ve included the London School of Barbering, just because, but the London School of Waxing isn’t on the register (and may be a phantom in internet searches). I know that the London School of Science and Technology does Business and Health Science courses, despite its name. Sadly, the London School of Academics‘ only HE course is the C&G Diploma in Education & Training so they’re left out.

Name on the register (Bold indicates OfS registered)	UKPRN
London Academy Business School Limited	10082092
London Academy for Business and Law Limited	10089948
London Academy of Business and Management Ltd	10085150
London Bridge Business Academy Limited	10013109
London Business and Management School Ltd	10064865
London Business House Limited	10053193
London Business School of Training and Development Limited	10091369
London Business School	10007769
London Churchill College	10030391
London College for Humanities and Business Studies Ltd	10084285
London College of Business & IT Limited	10024502
London College of Business and Law Limited	10008379
London College of Business Limited	10042120
London College of Business Studies	10019368
London College of Engineering & Management Limited	10026886
London College of International Business Studies Ltd	10004023
London College of Management and Technology London Limited	10090217
London College of Management Sciences Limited	10091626
London College for Vocational and Technical Education CIC	10034263
London Education Foundation (Kensington College of Business)	10091464
London Education Management Limited	10082106
London Graduate School Ltd	10086189
London Graduate School of Management Limited	10004037
London International College of Business and Technology Ltd	10092205
London Management Centre Limited	10004046
London Marketing Set Ltd	10084771
London Nautical School	10004050
London School of Academics	10032594
London School of Barbering Limited	10039149
London School of Business & Commerce Limited	10037272
London School of Business & Computing Ltd	10089011
London School of Business & Education Ltd	10086923
London School of Business & Enterprise Limited	10068159
London School of Business & Entrepreneurship Limited	10068188
London School of Business & Finance (UK) Limited	10004060
London School of Business & Innovation Limited	10085927
London School of Business & Managerial Sciences Ltd	10090343
London School of Business & Technology (Lsbt) Limited	10030950
London School of Business and Communication Ltd	10091914
London School of Business and Management Studies Limited	10082100
London School of Business and Research Limited	10083701
London School of Business and Social Sciences UK Ltd	10090139
London School of Business Ltd	10068494
London School of Commerce & IT Limited	10023434
London School of Counselling and Management Ltd	10045520
London School of Design and Marketing Limited	10087366
London School of Digital Marketing Ltd	10068037
London School of Education and Management Limited	10056040
London School of Fashion Business and Entrepreneurship Limited	10090400
London School of International Business Limited	10062390
London School of Law and Management	10065683
London School of Management and Economics Limited	10064150
London School of Management Education Limited	10022285
London School of Media and Management Ltd	10052788
London School of Planning and Management Limited	10063255
The London School of Economics and Political Science	10004063
London School of Science and Business Ltd	10084830
London School of Science and Technology	10008362
London School of Social and Management Sciences Ltd	10057043
London School of Social Enterprise and Sustainable Economics Ltd	10089956
London School of Wealth Management Limited	10085898
London Vocational College Ltd	10043813
St Prian’s School (trading as London School of Commerce)	10017760

Clearly, not all of these providers are offering higher education. Indeed, some (with websites with stock images) are offering higher education that turn out not to lead to a UK degree. Some are offering in-person and some online. For example, the London School of Business & Finance has moved away from in-person HE (having previously had large numbers of HND registrations) and offers online degrees validated by the University of Law.

This ‘London Graduate School of Management’ may not be the one on the UK register

Those who might complain that there isn’t a market or much competition in offering higher education, should look at the breadth of provision in London. It contains many of the UK’s best providers and most of its World-Leading specialist providers. There’s a suspicion that some others might not of the highest quality; providers in London are over-represented in the list of places that OfS has refused to admit to the register (including a couple on the above list). Although we never got to the bottom of which providers were really ‘bogus colleges‘ for visa purposes – again London was over-represented as a location for them.

In June we heard that the Advertising Standards Authority had censured the London School of Planning and Management (LSPM) for advertising MBAs when it didn’t have an arrangement to teach them (or the BA, BSc, MA or MSc courses also on its webpage). The LSPM is owned by the same person who owns the London School of International Business and the London School of Business Research (as well as 4 other companies that look like providers). Having checked their website, they are quite quite happy to keep emailing me about degrees they don’t offer.

The 2022 micro company accounts for the LSPM show it has £5197 in assets. However, there are also some very profitable providers. At the other end of the scale, St Prinan’s School trades as the London School of Commerce and had tuition fee income of £52 million in 2021, made a surplus after tax of £22 million on that and was able to offer their owners a £11 million dividend. This month the OfS has concluded a quality assessment of the University of Bedfordshire which included its partnership with the London School of Commerce (which is on the UK register but not on the OfS Register).

So, while the provision of higher education in London is certainly the most diverse and extensive its ever been, it really looks like there’s an opportunity for providers to differentiate their titles a bit more. It is the case that if you want to set up a college or two to offer education or training, then that’s ok. Cavate Emptor applies as usual. Offering proper higher education, whether a provider is on the register or teaches students registered at a provider that is on the register, is something we should celebrate. It’s likely that there will continue to be a need for more provision in London.

So, we’ve noted there’s a LSA, several LSBs, a LSC, a LSDM all following a LSE. There’s a need for more provision, but maybe for more diversity in naming conventions?

Time for an update on Head of Provider Pay?

We have had various rounds of anger about Vice-chancellors’ pay. Back in 2017 this was focused on Bath, and at the time I worried that there was some snobbishness going on, even though Bath had done well in league tables and was winning prizes.

Well, now we have a regulator that has incorporated a range of providers into its systems, which includes disclosing information on senior staff pay. This offers an opportunity to look across a much wider range of providers for comparison

Let’s look at a private provider. It makes some play that it is run on a not-for-profit basis. It’s on the OfS register as ‘approved’, has a 2023 TEF outcome and its financial statements for 2121/22 say that it has 1,196 FTE students. They are charged a maximum of £6,165. Turnover (ie income) reported for 21/22 was £7,363,595 (which is exactly what you’d expect for 1194 students paying £6,165). The provider made a profit before tax of £2,474,971 – which is 33.6% of the income. That was available for reinvestment (this is not-for-profit).

The provider is managing to teach its students on a variety of HNC/D and degree top-ups spending two thirds of the £6165 fee. The financial statements shows that it spends 22% of income on staffing, but there’s a note that 25-30 self-employed teachers and other technicians are additional to that (sales and administration is a term used in companies house accounts and won’t mean those staff are all in marketing).

That brings us back to the issue of the pay of the head of the provider. It notes the necessity of having regard to the CUC remuneration code. The directors do not consider the salary of the CEO to be ‘excessive’ and, by way of explanation they also ‘consider it to be comparable to other officers in this position’.

The CUC guide talks about choosing comparators carefully. They note:

Remuneration Committees need to consider market position – typically by looking at a set of comparator institutions/organisations. The choice of these comparators will usually be linked to institutional strategy.

CUC The Higher Education Senior Staff Remuneration Code p5

I can’t immediately find a remuneration committee report, but I’ve chosen my own comparator to consider. The provider’s degrees are all awarded by one university. The 2021/22 financial statements show that university had an income of £198 million, 20,000 students, and spent £121 million (61% of its income) on staffing. That university reported a ‘challenging year’ making a £18.4 deficit. The vice-chancellor had a salary of £247,781 which, with pension contributions, came to a total renumeration of £307,520. That’s six grand less than the £313,448 paid to the CEO of a college with less than 4% of the university’s income and less than 6% of its student numbers.

The OfS has published two reports on senior staff pay; one in February 2019 looking at 2017-18 data and the last one in November 2021 which looked at 2019-20. Since then a significant change has happened; a number of private providers have been registered and have now had long enough to have to follow the accounts direction, which requires the disclosure of senior staff pay. I’m hoping this is a biennial report and OfS will be able to put comparative information about 2021-22 in the public domain. Although, if the directors of a college with 1200 students don’t think its ‘excessive’ to pay their CEO £300k, we might be in for a round of pay inflation.

Waiting for OfS Board Papers – the outcome

The Office for Students has a commitment to transparency with the sector it regulates. One small part of this is the publication of the papers that go to its Board. This is helpful as it shows the broad area of both policy development and action. Over the years this has revealed some of the thinking at the highest level of the OfS, particularly as issues can be tracked as they are presented as papers or as part of the CEO’s report. You might not read them yourself, but you might have seen a commentary from Jim and/or DK on Wonkhe.

Back in the Spring, I’d spotted that we’d not had any for a while, so I tried to see if there was a pattern to when the papers where published. That appeared not to be the case. Sometimes they’d appeared before the next meeting, twice they appeared on what had been the day of the next meeting, and increasingly they’d appeared some time afterwards. It took 124 days for the December 2022 Board papers to be published (along with the February 2023 papers). And then it all stopped for a while.

The great news is that on 11 and 12 October 2023 three sets of papers were published and then on 18 March 2024 two more sets with another on 9 April. This blog has been updated to reflect this. Where there is a change – the text is in italics.

Since the inception of the OfS there’s been a stable pattern of when the Board meets. There were some extra meetings during the Pandemic, but it’s been pretty consistent. There was probably a meeting in March, May and July 2023. We’ve not had papers from those. There might have been a board by now in September, but we don’t know. What’s clear is that the time taken for the papers to be published is lengthening.

2020 Average time to publication 49 days
2121 Average time to publication 68 days
2022 Average time to publication 79 days
2023 Average time to publication 129 days

We now know the date of the March 2023 board meeting, it took 195 days for the papers to be published.

Meeting	Date Papers Published	Days after the Board	Relationship to next board
13th meeting, 28 January 2020	20 February 2020	23	25 days before next board
14th meeting, 16 March 2020	6 May 2020	51	15 days before next board
15th meeting, 21 May 2020	6 July 2020	46	4 days after next board
16th meeting, 2 July 2020	5 August 2020	34	50 days before next board
17th meeting, 22 September 2020	27 October 2020	35	35 days before next board
18th meeting, 1 December 2020	18 March 2021	107	43 days after next board
19th meeting, 3 February 2021	18 March 2021	43	9 days after next board
20th meeting, 9 March 2021	4 June 2021	87	42 days after next board
21st meeting, 22 April 2021	29 July 2021	98	70 days after next board
22nd meeting, 13 May 2021	5 August 2021	84	16 days after next board
23rd meeting, 13 July 2021	23 September 2021	72	Same day as next board
24th meeting, 23 September 2021	15 November 2021	53	10 days before next board
25th meeting 2 December 2021	13 January 2022	39	21 days before next board
26th meeting, 3 February 2022	24 March 2022	49	Same day as next board
27th meeting, 24 March 2022	1 June 2022	69	5 days after next board
28th meeting, 26 May 2022	5 September 2022	102	54 days after next board
29th meeting, 13 July 2022	23 September 2022	72	7 days before next board
30th meeting, 30 September 2022	29 November 2022	60	8 days before next board
31st meeting, 8 December 2022	11 April 2023	124	67 days after next board
32nd meeting, 3 February 2023	11 April 2023	67	12 days after next board
33rd meeting, 30 March 2023	11 October 2023	195	139 days after next board
34th meeting, 25 May 2023	12 October 2023	140	101 days after next board
35th meeting, 4 July 2023	12 October 2023	101	14 days after next board
36th meeting, 28 September 2023	18 March 2024	172	97 days after next board
27th meeting, 12 December 2023	18 March 2024	97	58 days after next board

It had looked look like OfS had a new pattern – it will release papers in two tranches a year, but then it released the February papers in April I’m not necessarily sure this would be an improvement, not least because the number of redacted items seems to be increasing, even if the average time to publish papers is now over 4 months.

Prospects for teacher training as shown by a prospectus

If you take a long-term view, then you can see solutions to present issues in the way things were done in the past. That’s not to create golden ages. If you had to pick a year in the last hundred for a golden age in higher education, you wouldn’t pick 1967. There’s reasons why students rioted. But, in these times of concern about information for students (codified in the CMA’s new guidance but also present in the Lord’s Committee report on the OfS) and student support (abundantly evidenced everywhere) here’s a random example from 1967.

‘Gipsy Hill College was founded in 1917 by Miss Belle Rennie and a group of friends as an independent, undemoninational college for the training of teachers of young children’. These are the first words in the description of the college in a booklet produced by Surrey County Council by way of a prospectus. Before the description has been a list of the governing body and the staff – these details are clearly more important.

The prospectus had been issued at a turning point in teacher training. The Robbins Report had recommended changes to the qualification offered; in 1967 students were still prepared for the Teacher’s Certificate Examination of the University of London Institute of Education but it was noted the first examination for the new Bachelor of Education degree would be held in 1969. It would be possible for students to register for this qualification. In 1967 teacher training colleges were still expanding.

The booklet comes with a selection of photos of the College. The black and white images of buildings and rooms are familiar to modern prospectuses, except there are hardly any people in them.

There’s a clear statement of the minimum entry requirements. There are annotations, presumably from the original owner of the booklet, against the mixture of GCE O and A levels. A distinction is made between passes at CSE which count towards admission for teacher training but not towards degrees.

Students get free tuition. They also get free board and lodging. And a grant. And a travelling grant. Although there’s a parental contribution, the booklet owner’s annotations perhaps showing which categories she is in.

For fans of being clear about the hidden costs of university, the booklet sets out the other expenses. Students are expected to spend at least £35 on books during the course, spend money on teaching practice and obtain ‘physical education clothing’ (at a cost of approximately £12). Students need to provide their own ‘sheets, pillow slips, towels, and rug or eiderdown’.

It’s less clear that the booklet would meet the material information that the CMA might expect. There’s a vagueness to the statement: ‘All students attend such courses on the teaching of the subjects of the curriculum as are appropriate … these courses may vary in length and number according to individual requirements’. There’s nothing much on the format of assessment beyond the threat of 3-hour papers and assessment of teaching practices. At least the list of staff would go some way to meet the need to provide ‘details about the general level of experience or status of the staff involved in delivering the different elements of the course’ (CMA, 2023, p29)

The College had been taken over by Surrey County Council in 1946, when local authorities were charged with finding a large increase in teacher training places, and had been moved 9 miles to Kingston Hill to a 40 acre site. In the reorganisation of teacher training in the 1970s Gispy Hill merged with Kingston Polytechnic and the site is still in use.

References
Anon, 1967, Gipsy Hill College, Surrey County Council Education Committee
CMA, 2023, UK higher education providers – advice on consumer protection law Helping you comply with your obligations Competition and Markets Authority