NUCCAT response to the UKSCQA consultation on the review of the UK Quality Code

NUCCAT has submitted its response to the UKSCQA consultation on the review of the UK Quality Code (13th October 2017).  Should you wish to discuss this any further, please leave a comment below, or drop us an email – nuccat@shu.ac.uk

NUCCAT[1] welcomes the opportunity to contribute to the consultation on the review of the UK Quality Code. The Code provides a necessary reference point, alongside the Frameworks for Higher Education Qualifications.  It is regrettable that where Scotland has an integrated Credit and Qualifications Framework, for England, Wales and Northern Ireland these remain ‘complementary’ rather than cohesive.  The review of the UK Quality Code seeks a ‘coherent framework for quality and standards in UK Higher Education’.  This would be facilitated by a common UK credit and qualifications framework.

Within the consultation document, expectations are articulated in relation to Standards and Quality. NUCCAT’s response is offered to each of these points in turn.


Standards:
‘providers use assessment and classification processes that are reliable, fair and transparent’.

This is an area of long-standing interest to NUCCAT members.  Recent research (undertaken by NUCCAT and the Standards and Classification Working Group – SACWG) has focused on the reliability, fairness and transparency of assessment and classification processes.  We have devised a typology of regulation, where rules governing all aspects of student progression can be articulated as either:

  • Enshrined entitlements (i.e. “you will be granted…”),
  • Earned rights (i.e. “you can be granted, if you satisfy the criteria…”) or
  • Discretionary advantages (i.e. “you could be granted, if the Examination Board decides in your favour…”).

The typology reflects a continuum of clarity and complexity for students: there is greatest clarity and simplicity where regulations comprise enshrined entitlements and almost total obscurity where regulations are grounded in academic discretion and decisions are (entirely) in the gift of individuals or Boards.  Enshrined entitlements may be readily codified in administrative systems to facilitate the smooth and consistent processing of student progression; earned rights can be codified provided they are not too complex, whereas discretionary advantages cannot be systematised.

Harmonising assessment regulations across the sector would improve reliability, fairness and transparency, without doing damage to institutional autonomy.  The process of harmonisation would encourage institutions to compare their regulations systematically with other universities and help institutions to identify the obscurities, complexities, inequities and inequalities in their regulations.

The process might stimulate institutional regulations makers:

  • to consider introducing more enshrined entitlements so that their rules are essentially binary statements or
  • to reduce the complexity of the criteria that students must satisfy to earn a right or
  • to eliminate capricious advantage giving to increase consistency of decision-making.

Notwithstanding the primacy of PSRB regulations governing the award of integrated professional qualifications, among the principles for the harmonisation of the regulations proposed by NUCCAT & SACWG are:

  • Assessment should be designed to maximise opportunities for students to demonstrate their attainment of learning outcomes. It follows that the volume and timing of summative assessment within a course should be designed to facilitate and not to impede progression.
  • The assessment of academic performance should not be conflated with local concerns over student behaviours, such as attendance.
  • The award of credit by compensation, where based on clear criteria that include a marginal fail and good overall performance within the level[2], has been shown (in earlier research) to provide the most effective method of allowing students unsuccessful in modules at Level 4 to complete ‘in-time’. In contrast, the practice of condoning failure without the award of credit challenges the principle of consistency in defining awards by a volume of total credits.
  • Any student who fails a module should be allowed an opportunity for re-assessment, whereas any subsequent re-assessment attempt should be permitted only on the grounds of mitigation. ‘Trailing’ credit should be a managed intervention, based upon a judgement of the student’s ability to cope with the additional workload and should be limited to one module per level.

Quality:
‘….reliable and fair admissions…’

As a member of the ‘UK Credit Forum’, NUCCAT has recently investigated credit practice in England & Wales.  Our research findings indicate that lifelong learning (using Recognition of Prior Learning (RPL) / credit transfer processes) represents a growing area for institutions, but that few have in place procedures for monitoring the different ways in which credit is being used to support flexible study. This might include internal course transfers, progression from partners, direct entry with advanced standing, credit for professional awards giving exemptions from modules, study overseas etc.  Furthermore, Institutions acknowledge that more needs to be done to promote such opportunities to potential students in a manner which is open and accessible.  Without monitoring (or agreement about what we should monitor) we cannot know whether we are being successful in promoting flexible learning opportunities and where the demands for further use are or where the issues lie.

A number of conclusions arose from our 2017 Credit Survey that impact upon ‘reliable and fair’ admissions processes and which should be addressed in the UK Quality Code for Higher Education:

  • A standard set of categories of ‘Recognition of Prior Learning’ (RPL) and credit transfer should be agreed to aid institutional and sectoral monitoring of the nature and volume of credit being awarded / exempted.
  • Institutions should ensure that their approach to RPL meets CMA expectations including that opportunities, processes and fees are made readily accessible to potential applicants and that feedback is provided to unsuccessful applicants.
  • Guidance on the recognition of prior learning, including nomenclature, should be reviewed and revised. This should be facilitated by a wider national debate on the re-use of credit and ‘double counting’ so that the principles that frame this practice are more clearly articulated.
  • Official transcripts of students’ academic achievements should more consistently record information such as the date, volume, nature, location and awarding organisation of the credit contributing to an award.
  • Official transcripts and programme specifications should be made readily available electronically, to standard specifications, to support credit-transfer applications.

The terms compensation and condonement should be defined in the Quality Code as follows:

  • The award of credit by ‘compensation’ is a deliberative balancing process, determining whether elements of performance within an academic level can offset elements of failure, within fixed award credit requirements
  • ‘Condonement’ is tolerance of failure, requiring latitude in interpreting credit requirements for awards (credit is not awarded)
Response endorsed by the NUCCAT Board 13th November 2017
[1] http://www.nuc.ac.uk/
[2] Thereby ensuring that Level Learning Outcomes have been met.
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