Medr’s Quality Framework: next steps

Medr’s recent consultation on the regulatory approach included a number of questions on our proposed Quality Framework. The Framework aims to minimise the burden placed on providers while ensuring a good quality learner experience across the tertiary education sector. Our ambition is that any learner, no matter where they are in the tertiary education sector, can be assured of the common expectations on providers.

The drafting reflects the provisions within the Tertiary Education and Research (Wales) Act for Medr to publish a framework to set out policy and practice in relation to:

• Criteria for assessing quality.
• Processes for assessing quality.
• The roles and responsibilities of those assessing quality and providers in relation to quality.

One of the main themes that emerged from the consultation was a need for greater clarity and understanding on the intended application of the Framework and how it would work alongside existing approaches (such as those delivered by Estyn and QAA).

The second phase of our regulatory consultation begins this autumn. As part of this, we will be sharing a revised version of the Quality Framework reflecting many of the points raised in responses. However, we wanted to address some of the central questions now in the hope of maintaining a dialogue with stakeholders and informing our future revisions to the Framework.

How does the Framework reflect or interface with existing approaches to quality?

The Framework is not intended to duplicate the activities undertaken by Estyn and QAA. It is instead intended to clarify the common expectations on providers across the entire tertiary sector, and to explain how Medr will assess compliance against our regulatory condition on quality.

At the centre of the Framework is a series of pillars that cover areas such as the need for external quality inspection or review, the importance of self-evaluation, and the role of governance in quality. In different parts of the tertiary sector, the activities that will ‘map’ onto those pillars will look different. For example, in the case of further education providers we would expect Estyn inspection to fulfil the requirements of the externality pillar, and the self-evaluation process to fulfil the requirements of the self-evaluation pillar.

To look at another example, in the case of higher education we would expect the National Student Survey to fulfil the proposals under the Learner Voice pillar to use data and outcomes from national surveys.

Some of the pillars do relate to ‘new’ activity. For example, the Learner Engagement pillar aligns with the proposed requirement for providers to comply with the forthcoming Learner Engagement Code. This specific instance reflects broader work being undertaken by Medr to meet our responsibilities under the Tertiary Education and Research (Wales) Act. The inclusion of the Code in the Framework is intended to ensure our system is joined up. The Code and its accompanying condition will be consulted on in the Autumn.

In time, we would expect the future development of inspection frameworks and quality enhancement review methods by Estyn and the QAA to reflect the Framework.

How does this link to regulation? Will you be regulating continuous improvement?

Our regulatory consultation sets out Medr’s broader regulatory approach, including how intervention will work and the principles that we will operate under.

Providers will need to comply with the quality condition whether they are on the register for providing higher education or regulated through terms and conditions of funding. This means that Medr will monitor – for example, through inspection and review outcomes, as well as data returns and other sources of information –  whether providers are compliant.

However, the regulatory approach and statement of intervention also set out how we would expect our engagement with providers to work. For example, if Medr were to believe there may be a risk of non-compliance, then informal engagement with the provider to understand the particular context would usually be the first step. We are committed to recognising the diversity of providers, and regulating in a risk-based and proportional way.

A number of responses set out concerns about the continuous improvement pillar and, in particular, whether there might be a regulatory intervention if providers were not improving year on year. From our perspective, what matters is that providers are undertaking the types of self-reflection, planning and action intended to identify and develop areas for improvement across their delivery. We will clarify these expectations in the revised Framework and related condition.

Where institutions are engaging in continuous improvement activities, we would not expect to intervene provided performance was satisfactory.

Definitions within the Framework

Many responses raised questions around definitions, including the definition of quality and the definition of key terms like reasonable needs and threshold standards.

We are considering how to clarify the definition of quality to address the concerns raised while also ensuring that we have a definition sufficient to capture the breadth of teaching and learning approaches across the tertiary sector. Our intention is for the definition and scope of quality to focus on aspects of the learning experience that are within the influence of the provider.

On the wider set of definitions, we will publish a glossary setting out definitions in the phase 2 consultation in the autumn.

Who is responsible for data collection? How will data be used?

Responses raised a number of questions on who is responsible for collecting, analysing and acting on data. Medr already utilises a range of data to inform our ongoing engagement with providers, drawn principally from the Lifelong Learning Wales Record (LLWR), the Post-16 Data Collection and HESA records along with, in the case of higher education, the National Student Survey.

Medr is committed to consulting on performance indicators within the next two years, we would anticipate that this consultation would consider how benchmarking and/or thresholds could be used. Until then, we would anticipate using the existing measures to inform our consideration of quality.

Does the Framework reflect the diversity of providers?

The Framework is intended to reflect the diversity of providers within the tertiary education sector. That is why it is structured so that the different arrangements across the sector can be incorporated and reflected within the pillars. While some responses have asked for a more prescriptive Framework, our view is that doing so would make it harder for us to accommodate the contextual differences across providers.

We understand and recognise that the needs and expectations of learners differ, and when we discuss the importance of learner outcomes we agree that there is a contextual dimension to outcomes that should be considered. We will reflect this in the Framework and it will inform out wider commitments on performance measures.

We have an opportunity in Wales to support a tertiary education sector which is aligned in ensuring a good quality learner experience at every stage. This Framework is intended to support that aim.

Next steps

Over the coming weeks we will further consider the outcomes of the first phase of consultation.  We will then provide the updated Quality Framework as part of the documentation in our autumn consultation, giving readers the opportunity to consider the documentation holistically.

We will also continue to engage with a wide range of sector groups. We would welcome further dialogue ahead of the next phase of the consultation.

We will also look to provide further clarity on some of the specific points raised in the consultation, particularly as they relate to other areas of our activity in the coming weeks.

For a conversation on these or any other issues related to the Framework, please email [email protected].