Bogus Colleges (9) the Home Office’s big claim

The release of the ONS update on International student migration research came wrapped by two Home Office announcements; first the review by the Migration Advisory Committee and then their own report confirming Tier 4 were the most likely to leave on time.

Away from the very good news that Tier 4 has the best record of migrants returning home (we really do need to have longitudinal data on how many convert to Tier 1 or 2, retaining their skills in the UK) both the ONS and Home Office data showed how student migration has changed over 10 years.

The Home Office report goes into more detail on that trend, charting the ‘abuses’ it had dealt with, including:

From 2010 onwards a new sponsorship scheme was introduced, which required sponsors to apply for accreditation on an annual basis. This was originally through receipt of Highly Trusted Sponsor status, which was replaced with the Basic Compliance Assessment in 2015. Following this or as a result of subsequent enforcement action, licences were not renewed for over 900 FE colleges which were then not able to sponsor international students. In many cases these were colleges where there were concerns over compliance.

Here is the area that appears to have made the biggest difference to the overall numbers.  They include charts which show student numbers in universities stay level, but those in Language Schools and especially ‘Further Education’ decline sharply.

The Home Office has the data on students’ sponsorship and there’s a very clear picture that the sharp rise and fall in ‘Further Education’ was in places that subsequently left the Tier 4 register.


This was reiterated in the Home Office’s press release about the MAC review:

Since 2010, this has included taking away the ability of more than 900 – often bogus or low quality – colleges to bring in international students.

And it featured in their messaging about the reports:


My attempts to understand the data on providers who have had their licences revoked means I’m interested in the number used.  In the three documents it’s stated as ‘more than 900’ providers, ‘over 900 FE colleges’ and ‘over 920 low quality or bogus institutions’.

I know any of these aren’t true.  The data the Home Office has sent me shows that while there are over 900 providers who have left the register, many of the names on the list are duplicates, or places that returned to the register, or perfectly reputable providers that either gave up or were turfed off the list because of the onerous requirements.  It is good that the Home Office has stopped using the blanket label of ‘bogus’ for everyone, but ‘low quality’ won’t wash for places like Hereford Cathedral School or Magdalen College School – examples of the kind of places that have been temporarily dropped from the register.

Further more, the Home Office must be perfectly capable of drilling down into the ‘Further Education’ sector it describes.  How much of the decline in sponsorship comes from small privately owned colleges that offered ‘diploma’ courses through accredited arrangements, but who stayed outside the standard FE or HE frameworks.  If these were the targets – ‘low quality or bogus’ – then they should stop publicly doing down those providers who operate reputably.  These include FE Colleges, whose ability to recruit international students arbitrarily curtailed because of a category they’ve been dropped into.

The Home Office should properly review the impact of removing providers in the 2010-2015 period.  It should stop using an inflated number of ‘bogus’ colleges – especially to avoid it seeming they are doing so to distract from the discovery they’d been using an inflated number of over-staying students.

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Remuneration Committees and Vice-Chancellors’ Pay.

Lord Adonis has successfully drawn attention away from the student finance ‘debate’ with the issue of Vice Chancellors’ pay.  In effect, he’s thrown that ‘dead cat’ into a fees debate that he himself has done well to keep going after the election.  As the Newsnight segment about fees on results day showed, the debate keep coming back to VCs’ pay (whether that’s egregious or a fraction of a footballer’s wage).

As autonomous bodies, Universities have got to engage with this issue – OfS can’t tell them what to do, or how much to pay, but they can impose conditions as part of registration – so they need to engage now.  There is an existing means of supporting Councils and Boards of Governors, who are additionally autonomous, through the Council of University Chairs (CUC).  They have a helpful guide to remuneration Committees, which (a) each university should check it has engaged with and (b) should use as a thorough overhaul.


CUC Illustrative Practice Guide to Remuneration Committees 2015

The guide gets straight to the point:

It is probably fair to say that in the eyes of wider society the reputation of Higher Education (HE) can be significantly damaged by pay packages for senior staff that are perceived as out of kilter with pay and conditions elsewhere. The Remuneration Committee faces a difficult challenge in responding to the global market for talent while ensuring that pay is clearly linked to performance and that increases are sustainable. This is very much a reputational issue and therefore an issue for the governing body.

The duties of the committee are set out and the guide notes that ‘processes by which it reaches its decisions need to be clearly available to and understood by all stakeholders’.

The guide explains how a Remuneration Committee should work; it takes performance and benchmarking information.

In its deliberations the Remuneration Committee will need to take account of a range of information. In the case of the head of institution and senior managers this will include evidence of performance against agreed objectives measured by appraisal. It is important for the Committee to differentiate between personal and institutional performance. This is especially relevant where pay rises above the average or performance bonuses are being awarded.

I wonder how many senior managers will have had getting ‘Gold’ in the TEF in their performance objectives?

The other key information is benchmarks; perhaps the key to wage inflation.  Here the guide says:

The Committee should also have a range of benchmark information allowing it to make comparisons with other institutions in the sector. The main sources of such information are the Committee of University Chairs (CUC) Vice-Chancellors’ salaries survey, data provided by the Universities and Colleges Employers’ Association (UCEA) and the annual survey undertaken by the Times Higher Education (THE). It should be noted that the CUC survey (which provides to the Chair detailed comparative information) and the UCEA Senior Staff Remuneration Survey (published every February based on salary data as at 1 November the previous year) are current whereas the THE report is based on data from the previous year. The usual caveats apply to the use of benchmark data, namely that benchmark data gives indications and a framework for the exercise of judgement and should not be used in a mechanistic or formulaic manner.
It is also important for benchmarks selected to be regularly reviewed by the Remuneration Committee.

The problem comes from defining policies based around a combination of performance and benchmarks. Here’s an example of how they combine:

Remuneration Policy aims to provide ‘median’ reward compared to comparator groups when acceptable levels of performance have been delivered. For the achievement of outstanding performance, it aims to deliver ‘upper quartile’ remuneration compared to comparator groups

Admittedly this isn’t actually a university remuneration policy (it’s from RM) but it shows how performance and benchmarks can act as an escalator for wages.  Inside the comparator group, any awards at the ‘upper quartile’ level will shift the whole group up, so even the median will increase.  A committee benchmarking the VC against, say, 23 others will find upward drift.  Of course each year there will be new arrivals to the benchmarking pool – perhaps a new VC getting less than the one before, but often not.  Up goes the median and the upper quartile.

The Guide encourages Universities to publish their policies in an annual report, citing UWE’s as an example.

Since 2012/13 the Committee has defined the Vice-Chancellor’s performance targets in relation to the financial performance of the institution and National Student Survey results. In order for the maximum bonus to be payable the stretch targets for both performance targets must be achieved. The achievement of one of the targets triggers a proportion of the allowable bonus subject to their being no deterioration in the other metrics

UWE July 2014

This is transparent – stakeholders at UWE can see the basis on which the VC is assessed, even if the analysis or the amounts aren’t included.  No doubt some of those stakeholders might have views on the causes of an uplift in the NSS.

There may be other examples of published remuneration committee reports, but they are rare.  Indeed, having been cited by the CUC for good practice, UWE appear not to have published another report since.

I’m comfortable with independent governors running the remuneration process, but I worry that the reliance on benchmarking, coupled with a performance target culture is leading to this inflation of salaries.  Governors have been given good cause to worry about the future of individual Universities, worrying about avalanches and market exits.  The recruiting and retaining of a good vice-chancellor has become crucial for governors, and it’s no wonder that the remuneration committee is at the sharp end of this.

The CUC guide, even as illustrative practice, should be dusted off by every university and reviewed.  Hopefully a flood of committee reports will follow, explaining their policies, perhaps linked to a potential duty to explain exceptional pay to OfS.  Transparency would be a good first step – hopefully paving the way for a greater culture of restraint.

State Funding – a deputation

On 23 November 1918 the President of the Board of Education and the Chancellor of the Excequer received a deputation from Universities in Britain and Ireland to make the case for increased state funding.

The meeting was 12 days after the signing of the armistice, and the War was a theme to the presentations made.  There were 67 people on the university side; lay members of council, vice-chancellors and principals (including Miss Tuke of Bedford College, the only woman present) and committee members of the Universities Bureau of the British Empire.  Cases were made for different disciplines, citing their usefulness and issues for Scottish and Irish Universities were outlined, although their relevant secretaries of state were not present.

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The minutes of the proceedings set out the arguments made.  A note from Sir Thomas Dyke Acland, a former education minister, set the tone – a nation that had been spending £6-7 million a day on fighting the war could afford £2 million a year to support higher education.

Sir Oliver Lodge spoke first, representing the ‘Modern Universities’. He concentrated on professorial salaries, noting that a large increase was needed for them.

You may be starving the source of the golden eggs by not dealing with this matter in a liberal fashion. Professorships must be established on a better footing.

He then described how the basis of University education must be enlarged, ‘throwing it open to a wider class of the community’, and describing how more activity would require more funding.  He also recounted how Arthur Balfour, then Foreign Secretary, had encouraged the universities ‘to get American students over here and to send our men over there’.  He explained how universities were establishing a new degree ‘having as its object a training in research’ for both home and American students.  But, he noted, these new PhDs would be expensive to teach.

His pitch was for the 1915 review of the grant (which had been planned to double expenditure but didn’t happen because of the war) to be added to a 1920 review (another doubling) but noting that ‘we cannot wait; we want these two doublings put together, we want a quadrupling at once’

Following a statement on Scotland,  Sir Bertram Windle, Vice-Chancellor of the National University of Ireland, spoke of the special needs of Ireland, but also turned to the special contribution of the humanities.

May I emphasise the truth that we have won the War and the Victory on which civilisation depends, not less by moral than by material forces, and that the humanities, as taught in the schools and Universities, have had their own high and necessary contribution to make both to the national appreciation of the issues for which we went to war, and the good conscience with which we fought and endured our sacrifices.

He then turned on German education…

The perverted mentality of our foes which rendered possible their criminal assault upon civilisation was due to the predominant reliance in their systems of education upon material force, to their extremely narrow ideas of intellectual discipline, to the false philosophy of the State taught in their Universities for the last forty years and to their disregard of those moral influences in education of which the humanities are the record and enforcement.

Sir William Bragg, attending for the Universities Bureau, covered the immense contribution of University science to the war effort. In 2017 we might find some ambivalence towards perfecting explosives, targeting artillery or creating new gases, but this was 1918.  He spoke particularly about the struggle against submarines, how applied science had used an idea from pure science to detect them, and how the work would continue such that the submarine could be neutralised.  He said:

What time means in fighting the submarine it does not need any more words of mine to explain. The whole of the grants that we have been asking for to-day might be swallowed up in the sums you can think of in questions like that. The attitude that understands just what science can do and what it cannot do, and how to set it to work in England, and its function, the natural function of a University, to do it; the fruits of a University are seen in the attitude of the people towards knowledge.

Moreover, we must provide men filled with a desire to learn.  We must provide laboratories to teach them in and the staff to teach them.  And so I say that, when we think of the problems of this war and put them together in our minds, we recognise that to a very great extent it is to the development of the University that we must look for the solution to the problems of the future.

The Chancellor, Andrew Bonar Law, was cautious in response, not able to pledge any money there and then. He was sympathetic to the ‘desire that the University should extend right down to the very bottom of our social system’ – here the minutes record ‘(Hear, hear)’.  When he concluded that proposals put to Government would be considered at least sympathetically – the record notes ‘(Cheers)’.

The President of the Board of Education, H A L Fisher, the former Vice-Chancellor of Sheffield, reiterated that the Government would consider their proposal carefully.

I am convinced – and my conviction has been deepened by the impressive mass of testimony which I have heard to-day – of the necessity of a very much more liberal assistance from the State to the higher learning in this country. (Cheers.) And I am equally convinced, from my long connexion  with Universities, of the great value of preserving University autonomy. (Cheers.)

The mechanism for distributing funds, keeping the notion of a quinquennial grant, was entrusted to the University Grants Committee who reported to the Treasury and not to the Board of Education.    The evolution of state support for British Universities could now quicken pace.  The war has slowed down the development of state support, but it demonstrated, as the Deputation showed, how valuable Universities could be to the country.
It should be noted, as Fisher did, that although the Universities were united in wanting more funds, they were divided on the issue of how to handle different costs of degree courses and the fees associated with them.