Creative industries degrees, where graduate employment often includes part time work and portfolio careers as people establish themselves, will be at risk. HE institutions that cannot meet the targets will either have to risk fines, cuts in funding and ultimately de-regulation, or decide to cut courses.
There will be no benchmarking of the 60% target at individual institutions to take account of variations in social backgrounds of students or in regional labour markets.
The deadline to respond to the consultations is 17 March. Read on for more detail on the proposals.
The new proposals are that HE providers be judged on whether they deliver ‘positive outcomes for their students’, replacing the current indicators based on delivering successful outcomes for students. The change in the wording from positive to successful allows for the measurement of success criteria such as employment rather than impact on students.
There would be three outcomes that are measured – continuation, completion and progression.
We propose using the following student outcome measures:
- the proportion of students continuing on a higher education course
- the proportion of students completing a higher education qualification
- the proportion of students progressing to managerial or professional employment, or further study.
There will be targets in relation to the percentage of students meeting the outcomes for each of the three measures.
The above proposals are included in the Consultation on a new approach to regulating student outcomes. The consultation on how they will construct the indicators they use is in Consultation on constructing student outcome and experience indicators for use in OfS regulation, which also has a deadline of 17 March.
There is much concern in the HE sector that the OfS is not relying on an independent outside regulator to construct the indicators and instead is going to make up their own. Read this WonkHE blog for more on this.
Progression measure: graduate employment
For progression the current proposal is the 60% of first degree students need to progress to employment in ONS Standard Occupational Classification 2020 (SOC) major groupings, groups one to three, 15 months after completing their qualification. The indicator will be reported through the Graduate Outcomes survey. OfS is proposing to also count self-employed or voluntary work that maps to SOC 2020 groups one to three.
Group three of the ONS SOC includes Culture Media and Sports Occupations as a subcomponent, and specifically mentions artists. However, given what we know about careers in the creative industries and the length of time it takes for people to establish their careers and the need for portfolio and part time working, we doubt whether this measure will be able to capture appropriate progression outcomes.
There is also the issue that the jobs that some degrees prepare graduates for are not in SOC groups one to three, eg printmaking or shoe design as set out in this 2021 blog.
We will explore all this in our consultation response, but please do email us with any thoughts to email@example.com.
Accounting for provider context – no benchmarking for student background or regional jobs markets
There is provision for taking provider context into account if the thresholds are not met, but the consultation stresses these would be the exception not the rule. In addressing the issues around outcomes for students who have further to travel to meet outcomes, the Office for Students writes:
‘We proposed in our phase one consultation that we would not set different numerical thresholds for students from different backgrounds to account for the known historical variation in performance, because accepting weaker outcomes for some students would not be consistent with delivering our regulatory objectives.’
Foundation degrees are mentioned in this context.
The consultation also hints at how judgements are going to be linked to graduate earnings, something which is a red flag for arts degrees where historically many of the positive outcomes for students and the public do not relate to economic outcomes, but rather to social and personal achievement, wellbeing and quality of life. In the section on taking context into account the consultation says:
‘We anticipate that we may consider this factor relevant in cases where a numerical threshold would otherwise result in students and taxpayers funding higher education courses where the majority of students are unlikely to receive a positive economic benefit from their experience of higher education.’
The OfS has said they expect changes to the regulatory framework ‘would come into force no earlier than September 2022’.
Download the full documents and respond to the consultations by the 17 March. We will share our consultation responses a week before the consultation deadline if you wish to refer to them before you submit your own.