There are 392 providers on OfS’ register. One of the concerns raised as the registration process started was that this was less than half the number of providers that had previously been regulated by HEFCE and/or DfE. While SCITTs made up a large number of these, it is clear that many providers still offering higher education have switched from direct regulation to operating via collaborative provision.
Delivering provision via contracting out means that the OfS registered provider remains responsible for the courses and the students. This is made particularly clear in the new OfS consultation on harassment & sexual violence.
… the OfS considers that a provider is responsible for protecting all students registered with it or with other providers delivering its courses under a sub-contractual arrangement.OfS 2020 Consultation on harassment and sexual misconduct in higher education
The OfS register provides a clear record of who is approved (although it’s quite odd that it remains only accessible in a spreadsheet you have to download). There is no such equivalent list for provision available through collaborative provision. The best that has been provided was table 6 in the spreadsheet that OfS posted in 2019 enclosing HESES and HEIFES data from providers. Here was a hint at the rich pattern of provision delivered in collaboration. It also showed the complexity; for example universities have provision delivered by other universities (the University of Cambridge has provision delivered by the University of Oxford).
It also demonstrated the scale of provision. HESES records a provider’s understanding of the ‘assumed countable years’ of students in an academic year as viewed at 1 December. In 2019 there were 58,840 ‘Years of instance taught under subcontractual arrangements by other providers’. The total population in HESES was 2,053,725. Most of the collaborative arrangements are small, but comparing the student numbers with the overall size of the provider shows there are 24 providers whose subcontractual arrangements account for more than 10% of their numbers.
|Holy Cross College||375||375||100.0|
|New City College||1930||1915||99.2|
|Unified Seevic Palmer’s College||325||290||89.2|
|New College Swindon||940||820||87.2|
|Milton Keynes College||610||475||77.9|
|Heart of Worcestershire College||1140||775||68.0|
|Harper Adams University||5695||2800||49.2|
|University of Suffolk||7120||3485||48.9|
|New College Stamford||245||105||42.9|
|Buckinghamshire New University||10040||3715||37.0|
|Birmingham Metropolitan College||275||70||25.5|
|East Sussex College Group||535||130||24.3|
|University of St Mark & St John||2670||630||23.6|
|Courtauld Institute of Art||500||80||16.0|
|University of Worcester||9695||1190||12.3|
Higher education has a lot of experience of contracting out provision – and some of the providers here represent that tradition with multiple FEC partners. Some of the partnerships represent providers with a portfolio of ‘alternative providers’, in addition to its work with FECs and health trusts Bucks New had 2019 links with Global Banking School Ltd, London School of Science & Technology Ltd, Mont Rose College of Management and Sciences Ltd, RTC Education Ltd, and UCFB College of Football Business Ltd.
Sub-contracting provision has been a larger part of the learning and skills sector, and several providers have very large subcontractual links with one other provider. The UK College of Business and Computing has 99% of New City College’s students and David Game College has 85% of New College Swindon’s students. There are also different patterns, all of Holy Cross’ students are taught by Liverpool Hope University.
It will be important that this wider sector, included sub-contracted provision, is regulated on an equivalent basis. One of the concepts that David Watson explored in his writing was that of the “Controlled Reputational Range”. This was the notion that in UK Higher Education, although there could not be exact parity between all universities, there was a framework that meant that no institution was able to behave so badly that it damaged the overall reputation of the sector. This applies here.
There is some concern that, as represented in providers’ public websites, the exact nature of the sub-contracted provision is not fully explained to applicants. Some sub-contracted providers are coy about even having a link.
As an example, Oxford Business College has diversified from awarding just HNDs; it’s not registered with the OfS, so the students must be at another provider if they are to access student loans. It’s not clear which provider that is for its HNDs. It is now offering BA degrees; a curiosity is that it offers two different BAs in Business Management from two providers. There is little on the website to indicate that the regulatory framework for these two courses is different. The students will be registered at two different universities with two different sets of terms & conditions and regulations.
We are now far enough down the OfS registration process that no new students should be able to enrol at an unregistered provider and get student finance support. One provider, St Patricks, is advertising HNDs with a clear indication there are student loans available but makes no mention of the provider at which the students will be registered.
Concerns, often raised by Jim Dickinson on Wonkhe, about parts of the student information provision are amplified in collaborations. If Student Protection Plans appear to have weaknesses when in a provider, that is worse in a subcontracted provider where a corresponding local plan is hard to find.
Table 6 of the HESES return data was a poor proxy for a register of collaborative provision, but it’s not in this year’s data. Hopefully it will not be the last comprehensive listing of provision in England. OfS will have a record of partnerships through its reportable events scheme, but these are private communications. I’d prefer a dynamic, and accurate, register. But, if that’s not coming, OfS should require a commitment that both partners should provide clear information, such that an applicant will be know which provider they will be a student at, especially if there is an award to be made by it.