By Vicky Gunn

Higher Education teaching policy is a devolved matter in Scotland, yet the TEF has amplified the paradoxes created by the jurisdictional plurality that currently exists in the UK. Given the accountability role it plays for Whitehall, TEF’s UK-wide scope suggests an uncomfortable political geography. This is being accentuated as the Higher Education and Research Bill (at Westminster) establishes the new research funding contours across the UK.  To understand how jurisdictional plurality plays out, one needs to consider that Higher Education in Scotland is simultaneously subject to:

• Scottish government higher educational policy, led by the Minister for Further Education, Higher Education and Science, Shirley-Anne Somerville (SNP), and managed through the Scottish Funding Council (or whatever emerges out of the recent decisions from ScotGov regarding Enterprise and Innovation), which in turn aligns with Scottish domestic social, cultural, and economic policies. The main HE teaching policy steers, as suggested by recent legislation and commissions, have been to maintain the assurance and enhancement focus (established in the Further & Higher Education (Scotland) Act, 2005) and tighten links between social mobility (Commission for Widening Access 2015) and the relationships between the economic value of graduates and skills’ development (Enterprise and Skills Review 2016).

• Non-devolved Westminster legislation (especially relating to Home Office and immigration matters). In addition to this is the rapidly moving legislative context that governs how higher education protects its students and staff for health and safety and social inclusion purposes as well as preventing illegal activity (Consumer Protection, Counter-terrorism etc.).

• A UK-wide QA agency with a devolved office (Glasgow) (recently restructured) which has (from 1997 until now) had an agreed role in assuring the UK-wide HEIs’ coordinated duty (i.e. owned by the HEIs rather than a statutory body) to assess academic standards. The new QA-TEF mechanism in England changes this duty, removing ownership for standards from HEIs. Scotland has yet to respond to what this means for Scotland’s 19 HEIs. This in turn ties into a HEFCE-commissioned project on External Examiners (essential part of any assurance of academic standards), led by HEA, with devolved input.

• An increasingly anachronistic relationship between TDAP/ RDAP and the Privy Council. Scottish institutions looking for either must still (unlike RUK) submit their intention to the Privy Council. If and when the Higher Education and Research Bill (Westminster) is passed and the Office for Students established, only Scotland will have this Privy Council link.

• A UK-wide reporting of metrics ecology that includes NSS, DLHE, HESA, and ILR which emerged primarily in design terms for three-year specialist undergraduate degrees, not for four year, major-minor mix degrees in the Scottish context (should you want to see just how much of a misfit this is, it is worth looking back at conversations about Unistats and Key Information Sets in the Scottish context[1]).

Additional to the initial design of the instruments underpinning the metrics data, one could argue that there are significant emerging locational paradoxes regarding metrics. DfE oversees the TEF specification and the policy behind the best-fit metrics for it. During the inception of TEF2 it was clear that Whitehall had poor understanding of the diversity of how higher education teaching metrics work across the UK. The Scottish sector is still informing on the misalignments of the data-set instruments and the metrics generated.

Perhaps more worrying for the devolved administration in Scotland is that the social mobility and employment data sets are non-aligned (Holyrood uses Scottish Index of Multiple Deprivation (SIMD) and Whitehall uses POLAR), but these are still being visualized as comparable in the TEF assessors packs. This records social-economic categories for ScotGov in quite a different way to the POLAR system used by the DfE in Whitehall. For one set of information (associated with widening participation), SIMD has been accommodated. For the highly skilled employment information, however, POLAR is a universal for all institutions in the UK. There are grave concerns about a potential message suggesting a real terms deficit in Scotland’s actually good record on widening access when compared with POLAR based institutions in England.  (There are conversations, for example, about Scotland having less expected movement in terms of the percentage accessing higher education and highly skilled jobs because they start from a slightly higher base line percentage-wise.  If ScotGov isn’t careful, the simple rhetoric that flourishes under these conditions will undermine the evidence-base being used for government decision-making in Holyrood). Furthermore:

• UK-wide league table influences that rarely remind readers of just how different the Scottish sector is, particularly in terms of faculty entry and four year degrees.

• Influences of the UKPSF as a UK-wide agreed framework overseen by the Higher Education Academy.

• An FE sector in Scotland in which individual institutions are not quality assured in their own right, at the same time as HEFCE not owning enough data on them. So, whilst TEF is FE-HE wide in England, it only relates to the 19 HEIs in Scotland (not HE in Scottish FE). Practically, articulations between FE, HE in FE, and HE involve significant relevant numbers of students related to widening participation. This group will potentially be invisible in the TEF, yet this is a central thrust of ScotGov’s widening participation agenda.

• A context in which higher education teaching policy research has been heavily influenced by a Research Excellence Framework (REF) that prioritizes international reach rather than Scottish domestic impact for quality outputs. This has led to a vacuum in domestic HE teaching policy research (except perhaps in the analysis of the different cultural ghosts in the respective Scottish and English HE sectors’ recent histories).

There is a gap in domestic (Scottish) higher education teaching policy research and there is no formalized devolved governmental direction for a Scottish approach to the TEF. This leaves Scottish HEIs in the unenviable position of trying, firstly, to reconcile two very different methods for accountability and compliance related to teaching in higher education and, secondly, to assess the relative merits burden of engaging in two systems. The situation is facilitating opportunistic informal policy co-creation across the Scottish institutions themselves. This largely conversational ‘governing narrative’ (emerging as the sector tries to coordinate responses to DfE consultations) operates like a semi-autonomous social field.

Speculations are controlled and amended as the sector attempts pragmatically to assess what the likely outcomes will be (including assumptions about loan book access, immigration, future developments of metrics’ instruments). Within this field, the Scottish HEIs are trying to establish rules which protect all that is good about the Scottish Quality Enhancement Framework from the perversions likely to be effected by the TEF, at the same time as assessing what the cost/benefit ratio of entering the TEF might be. This is all happening while we also try to second-guess new policy developments in the Scottish legislature (particularly relating to the Commission on Widening Access, but also on the future of the SFC and ScotGov’s narrative of economic sustainability).

The sands of devolved higher education policy underneath my feet seem to be in continual motion at the moment. My hair is standing on end. Only time will tell what the positive and negative impact of a semi-autonomous (social) informal policy field is within the context of devolution, but hopefully an enthusiastic educational researcher somewhere will come and interview us all.

SRHE Member Professor Vicky Gunn is Head of Learning and Teaching at the Glasgow School of Art. Follow her on Twitter @StacyGray45

[1] Some of the backstory to concerns regarding Unistats are touched on here: https://www.hesa.ac.uk/collection/c12061/sfc_letter.pdf/