HEFCE response to BIS consultation on ‘Applying Student Number Controls to Alternative Providers with Designated Courses’
1. HEFCE welcomes the proposed improvements to the course designation framework, and in particular the benefits it will have for students and the reputation of alternative providers. More robust and transparent checks will offer greater assurances to students, impact positively on student choice and enhance the high-quality provision of the English higher education sector generally.
2. We also support the rationale for creating a more level playing field of regulation between providers. We believe that the new designation system will go some way towards achieving this and, in the absence of legislation, creating a single regulatory framework. In our view, the new criteria will help to protect student interests more effectively than the current system. Introducing student number controls for alternative providers will offer more assurance that funding (in the form of student loans) is being used appropriately. However, we have concerns about the different regulatory models being proposed and what this will mean for protecting student interests and fair access, as well as practical issues about operability and timing, which are outlined in more detail below.
3. Overall, we support the direction of travel set out in the consultation document but consider that more could be said about how the Government’s original ambitions, as set out in the 2011 White Paper ‘Students at the Heart of the System’, will be achieved.
4. The consultation questions are predominantly aimed at alternative providers; therefore we have decided not to respond to the questions, but to highlight some key points of principle.
Different regulatory models
5. The revised approach being taken means that there will be a different regulatory system for alternative providers compared with that of the existing publicly funded sector. This poses a risk as it will result in different levels of assurance and accountability. Our response outlines a number of differences, and it will be important that these are clearly articulated to ensure that students and the general public are informed of the levels of assurance available and how these differ between providers. We believe that some form of information gateway about the differences should be developed, which would create greater public transparency. The HEFCE web-site could potentially be used for this purpose and we would be keen to work with BIS to try and develop such a gateway.
6. In the longer term, we would very much support a move to a single regulatory framework as originally envisaged in the 2011 White Paper. This would address any anomalies between the two systems, thus helping to level the playing field and offer a more consistent approach to safeguarding student interest and choice. We believe that a consistent approach would also have benefits for alternative providers, enabling them to be seen as equals in a competitive HE sector and part of its high-quality brand.
7. While the current proposals appear to provide greater ‘protection’ to students compared with the present system, they do not achieve the levels of protection set out in the 2011 White Paper. For example, while BIS is suggesting alternative providers voluntarily subscribe to the Office of the Independent Adjudicator, there is no formal requirement for them to do so. Nor is there any requirement to publish robust and comparable information for students. There would be benefits in considering whether subscription to the Office of the Independent Adjudicator could in some way be made compulsory, and also whether more information could be made available to prospective students (perhaps through Key Information Sets). This approach would ensure that students at alternative providers have access to the same routes of appeal and public information as students studying at HEFCE-funded providers.
8. We note that students studying on designated courses at alternative providers are unable to access tuition fee loans above £6,000 a year, though they may be charged a higher amount. This is not comparable to the financial support given to students in the publicly funded sector. While, on the face of it, there may be less need for financial control, due to the lower levels of public financial exposure, the cap on loans means that alternative providers are not required to hold access agreements with the Office for Fair Access. As a result there is no formal mechanism for promoting and monitoring fair access to alternative providers. It is important that the social mobility objective set out in the White Paper is monitored and assessed, in particular the equality impact on certain groups including those from less advantaged backgrounds.
Student number controls
9. While we support the move to align the controls with the existing sector, there are differences in the operations of the proposed systems for publicly funded and alternative providers. The proposed methods set out in the consultation document currently lack detail as to how the number control will be implemented in practice. The methods proposed for setting and monitoring student number controls need to be carefully examined for unintended consequences. This is particularly true of Method 2, which is very different from HEFCE’s current approach and therefore has not been tested. BIS needs to ensure that this method does not conflict with the student interest – there is a risk, for example, that it could incentivise institutions to discourage students from claiming student support.
10. There will need to be further consideration given as to how any additional student numbers are allocated between new and existing alternative providers. It is not clear whether any change to student number controls for alternative providers would impact on the publicly supported sector and vice versa. In addition to the allocation of student numbers there will need to be confirmation about whether any processes, such as core and margin or high grades policy (or similar), will be put in place to allow new providers to enter the system. Thought also needs to be given to whether alternative providers would have similar flexibility to that of the public sector around the student number controls. The earlier this can be clarified the easier it will be for providers and HEFCE to implement the new system.
11. While we are committed to working with Government to implement the new system of course designation and student number control, we have concerns about the feasibility of fully introducing the new system in 2013-14. For the HEFCE-funded sector we have already announced the student number controls for 2013-14 as institutions will now be making offers to students who intend to begin their studies in September, bearing in mind that the UCAS deadline, of 15 January, has already passed. It would not be possible to give alternative providers this certainty for 2013-14, as the new system will not be in place in time. If it is necessary to introduce student number controls in time for 2013-14, we recommend that a simple method of student number controls is implemented in 2013-14, which can be implemented as quickly as possible, in order to provide some clarity for alternative providers and their students. This could be developed further, if appropriate, in 2014-15.
12. The consultation is clear that student number controls will not apply to non-designated courses, which gives alternative providers the continued freedom to increase privately funded (‘off quota’) student numbers. This freedom is not available to institutions from the existing sector, and may come under challenge at some point. This approach might also work against the objectives of fair access and social mobility.
13. While the consultation is focused on alternative providers, one consequence might be that existing HEFCE-funded institutions look to set up new entities that could follow the alternative provider route to course designation. In the short-term we do not feel this is a significant issue but as the quantum of HEFCE funding for teaching reduces, the incentives for different corporate forms and structures will increase. This might be desirable in some instances but it means that levels of protection for students could reduce.
14. The transitional arrangements for the existing alternative providers with designated courses will need further development. Considerable thought needs to be given to the impact of an existing alternative provider not meeting the new criteria for course designation, and to the consequences for its students who already access the student finance system. There are some significant implications of, for example, withdrawing course designation yet enabling students to complete their courses of study. The interests of existing students must be paramount in this, and it is not yet clear how such issues will be addressed. We note that BIS is due to publish detailed guidance on the overall designation process, and we would be happy to provide further advice.
15. Currently a number of non-HEFCE funded providers who receive funding from other government departments or agencies receive automatic designation of eligible courses. This includes some further education colleges and some initial teacher training providers. We understand that some consideration has been given to how these providers will be treated in the new system, but that the issue is unresolved. This needs to be finalised quickly, and the relevant providers informed accordingly.
16. BIS will need to decide how the system will be monitored, including its impact on protected groups and on the student interest in general. (Non-completion rates may be particularly relevant, as this may affect not only students but the rate of debt write-off.) It will be important that sufficient information is collected to allow this monitoring to take place. In our view this will require Higher Education Statistics Agency (HESA) data returns from most or all providers whose students have access to student support. The type and volume of information that HESA would need to collect would not necessarily replicate that submitted by HEFCE-funded providers. We appreciate that this would incur a cost (currently unspecified) for providers, but this has to be balanced with the wider public interest in the effective stewardship of the whole higher education sector. Some providers already submit information to HESA or the Further Education Data Service, which may mitigate any transitional costs.
17. The consultation includes a short section on sanctions, appearing to suggest that providers should make a voluntary contribution to any cost to Government resulting from over-recruitment. While this will be an appropriate sanction linked to the student number control, it will also be important for BIS to consider actions it may take in response to other shortcomings linked to course designation (such as academic quality or financial sustainability) and whether or not these need to be consistent with those applied to HEFCE-funded providers. We would be happy to provide advice on this.
18. In addition, the complexities of alternative providers in the devolved administrations operating in England have yet to be addressed. The new process will apply to any providers who want their courses designated to allow any English-domiciled students access to the student finance system. This means that non-English-based providers may apply to have courses designated. Some of these providers may already have been assessed by other devolved administrations or government departments. It will be important to ensure that there is clarity over responsibilities and consistency in decision-making.
19. There is an expressed desire for the arrangements to be ‘proportionate’ for small providers. Exactly how this will be achieved while also fulfilling the requirement to control finances and support the student and public interest is not clear enough in the consultation document. We would be happy to work with BIS colleagues and smaller alternative providers to develop these arrangements.
Implications for HEFCE
20. The process being considered differs from HEFCE’s role with the existing funded sector, and therefore the assurances we can give in our advice on alternative providers may be more limited. We are committed to working with these providers to improve our understanding of their operations and to support them in delivering high-quality education to students. However the regulatory and accountability framework will be different under the proposed arrangements, and BIS needs to be aware of the limits to our role and what we can deliver. It will be critical for HEFCE that we work within our current legal powers at all times and establish open and effective relationships with alternative providers.
21. There are resource implications for HEFCE in supporting the new system. We are being asked to lead on the main operation of the new course designation process, which will create a significant amount of new and additional work for the organisation. Currently we fund and monitor 128 higher education institutions and fund 187 further education colleges, with over 100 alternative providers currently with designated courses, and many more providers applying. This gives an indication of the scale of the challenge we are considering. To discharge our new responsibilities in a professional way we are likely to require further resource. Download HEFCE’s response to the consultation.
When universities and colleges recruit new students, they cannot simply take as many as they might like. This is because the Government needs to control the level of publicly-funded student loans and grants for fees and maintenance. Based on guidance from Government we set each institution a limit – or ‘student number control’ – on the number of students they may recruit. This limit is only designed to control the number of students entering university or college. It is not designed to influence decisions about the suitability of candidates. Universities and colleges are autonomous organisations and these decisions are entirely up to them. They have always admitted students on the basis of academic excellence and potential, and they should continue to do so.
The ‘high-grades’ policy
Not all students are included in the student number control. The Government is keen to encourage popular and successful universities and colleges to expand, and to improve student choice. So it has decided to allow universities and colleges to recruit as many students with high grades at A-level and certain equivalent qualifications (broadly defined each year by government policy) as they wish, and are able to, outside of their student number control. We call this the ‘high-grades’ policy. We are responsible for putting the high-grades policy into practice and for identifying the high-grade qualifications from which institutions may recruit applicants without limit. Read more...
But this forecast, in the latest OECD Economic Outlook, is not written in stone – it assumes that governments continue with reforms to set their economies and societies back on the path to sustainable recovery – and that means sustainable socially, economically and environmentally.
One risk was averted in January, when the US Congress agreed to extend the country’s debt ceiling for a further three months until May, avoiding potential inability to pay its bills. But this decision also sent a message that Congress is taking seriously the need to find a more permanent solution than repeated debt rollovers – if lawmakers have not produced a budget bill by mid-April, they will not be paid until they do.
The key to recovery is to push ahead with reforms that will pay dividends in the medium-term, in areas such as education, innovation, taxation, jobs OECD Secretary General Angel Gurria said at Davos. This is not a case of ignoring the present, however -- "If you really want to go for a durable recovery, you really have to go for the fundamental measures," Mr. Gurria said in an interview with Bloomberg. "Some of these take a long time to get results but today, paradoxically, your best short-term policies may be your best long-term reforms.” Read more...
To mark the occasion of the 50th anniversary edition of the OECD Observer, we take a brief look at how the information world and the global economy have transformed since the OECD’s first secretary-general, Thorkil Kristensen, launched the magazine in November 1962.
In the last two decades we have lived through a veritable information revolution that has changed the world forever. Have these changes improved our lives or made our work easier? The answer is: yes, but!
Take the Internet. Breakthroughs in information and communication technologies (ICT) have enhanced access to markets, spurred innovation and created new business opportunities. Technologies contributed to progress in energy, education, food and health, improving the well-being of a larger number of people worldwide. They have also helped emerging economies to become global powerhouses and locomotives of the world economy.
The information revolution has changed the way our economies function and laid the foundations of a knowledge-based world. It is on this new landscape that policymakers should focus more of their attention. Read more...
In 2008, the OECD launched the AHELO feasibility study, an initiative with the objective to assess whether it is possible to develop international measures of learning outcomes in higher education.
Learning outcomes are indeed key to a meaningful education, and focusing on learning outcomes is essential to inform diagnosis and improve teaching processes and student learning. While there is a long tradition of learning outcomes’ assessment within institutions’courses and programmes, emphasis on learning outcomes has become more important in recent years. Interest in developing comparative measures of learning outcomes has increased in response to a range of higher education trends, challenges and paradigm shifts.
AHELO aims to complement institution-based assessments by providing a direct evaluation of student learning outcomes at the global level and to enable institutions to benchmark the performance of their students against their peers as part of their improvement efforts. Given AHELO’s global scope, it is essential that measures of learning outcomes are valid across diverse cultures and languages as well as different types of higher education institutions (HEIs). The purpose of the feasibility study is to see whether it is practically and scientifically feasible to assess what students in higher education know and can do upon graduation within and across these diverse contexts. The feasibility study should demonstrate what is feasible and what could be feasible, what has worked well and what has not, as well as provide lessons and stimulate reflection on how learning outcomes might be most effectively measured in the future.
The outcomes of the feasibility study will be presented in the following ways:
- this first volume of the feasibility study Report focusing on the design and implementation processes;
- a second volume which will be published in February 2013 on data analysis and national experiences;
- the feasibility study Conference which will take place in Paris on 11-12 March 2013; and
- a third and final volume to be published in April 2013 on further insights (and which will include the conference proceedings).
Download the new quality teaching guide for higher education institutions.
Approaches to Internationalisation and Their Implications for Strategic Management and Institutional Practice
Why focus on internationalisation?
Internationalisation of higher education is not new. Many of the earliest scholars travelled widely in Europe, but in the early modern era the focus on national development and internationalisation became marginalised. Nonetheless, initiatives such as the Fulbright Scholars Program in the United States and the Erasmus Mundus Programme in Europe have aimed to promote mutual understanding and encourage collaboration among higher education institutions. Today, however, the accelerating rate of globalisation has focussed attention once again on student mobility, international research collaboration and education as an export industry.
In today’s age of global knowledge and technology, an interconnected network and global awareness are increasingly viewed as major and sought-after assets. With the current labour market requiring graduates to have international, foreign language and intercultural skills to be able to interact in a global setting, institutions are placing more importance on internationalisation. The number of students enrolled in higher education outside their country of citizenship practically doubled from 2000 to 2010 (OECD, 2012a) and this trend is likely to continue.
However, student mobility is simply the most visible part of a greater topic, namely internationalisation, which is more complex and multifaceted. One aspect, sometimes referred to as internationalisation at home, consists of incorporating intercultural and international dimensions into the curriculum, teaching, research and extracurricular activities and hence helps students develop international and intercultural skills without ever leaving their country (OECD, 2004; Wächter, 2003). Other fast-growing forms of internationalisation are emerging (e.g. transnational education sometimes delivered through off-shore campuses, joint programmes, distance learning, etc.) and suggest a more farreaching approach, especially where higher education is now seen as an integral part of the global knowledge economy.
Globalisation has major implications for the higher education sector, notably on the physical and virtual mobility of students and faculty, information and knowledge, virtual access, and sharing of policies and practices. In many OECD countries, the transition from elite to mass participation in higher education is virtually complete. As the size of the 18 to 25 year-old age group declines, some of these countries are facing a decrease in domestic enrolments and attracting foreign students is increasingly seen as a way to compensate. Simultaneously, in emerging economies – especially China, India and in Southeast Asia – there is an ever growing demand for higher education and internationalisation may be regarded as a costeffective alternative to national provision (OECD, 2008).
The landscape of internationalised higher education is rapidly evolving. New countries and institutions are entering the global talent pool and challenging the established position of the traditional champions of international education. The English language is dominating new programmes and campuses are being built to welcome an increasing number of students from emerging economies. New forms of institutions, programmes and teaching methods are being set up. In addition, the effects of the economic and financial crises are far-reaching and long-lasting, changing the flows of students and faculty across continents as well as brain circulation.
Expected benefits of internationalisation
One of the main goals of internationalised higher education is to provide the most relevant education to students, who will be the citizens, entrepreneurs and scientists of tomorrow. Internationalisation is not an end in itself, but a driver for change and improvement – it should help generate the skills required in the 21st century, spur on innovation and create alternatives while, ultimately, fostering job creation. Yet the current economic climate calls for a closer examination of the tangible benefits of internationalisation for the economies and societies of, and beyond, the OECD.
Today, internationalisation functions as a two way street. It can help students achieve their goals to obtain a quality education and pursue research. It gives students an opportunity for “real world, real time” experiential learning in areas that cannot simply be taught. Institutions, on the other hand, may gain a worldwide reputation, as well as a foothold in the international higher education community, and rise to meet the challenges associated with globalisation. The top five reasons for internationalising an institution (Marmolejo, 2012) are, in order of importance, to:
- improve student preparedness
- internationalise the curriculum
- enhance the international profile of the institution
- strengthen research and knowledge production
- diversify its faculty and staff
Despite dramatic variations between countries and institutions, there is a general consensus that internationalisation can – when part of a broader strategy – offer students, faculty and institutions valuable benefits. It can spur on strategic thinking leading to innovation, offer advantages in modernising pedagogy, encourage student and faculty collaboration and stimulate new approaches to learning assessments. With the infusion of internationalisation into the culture of higher education, students and educators can gain a greater awareness of the global issues and how educational systems operate across countries, cultures and languages. Research is inherently internationalised through collaborations and partnerships amongst teams, and most scientific projects can no longer remain nationally-bound.
The many aspects and complexity of internationalisation raise various challenges for policy makers (e.g. on optimising mobility flows, equal access to international education, protecting students and quality assurance [OECD, 2008]). Likewise, institutions must be responsive and orchestrate all of these various aspects consistently in order to reap the benefits of internationalisation as well as manage the risks. For example, internationalisation of programmes entails refining support for students and paying closer attention to students with ever more demanding expectations in terms of quality of pedagogy, student assessments and the learning environment.
Internationalisation brings with it many challenges to the status quo. It introduces alternative ways of thinking, it questions the education model, and it impacts on governance and management. It will raise unexpected issues and likely benefits. All of these have a different impact, meaning and import for institutions in countries of varying degrees of social or political development. Key concerns of internationalisation include ways to sustain and enhance the quality of learning and ensure the credibility of credentials in a global world.
The key role of governments in internationalisation
Government policy might be motivated by the desire to attract skilled workers, to export education services, to promote development or to exercise “soft-power”. Governments also know that the nation’s credibility will be affected if its higher education institutions are abusing their international trust. The involvement of governments in internationalisation is therefore twofold: supporting the expansion of internationalisation and safeguarding its quality.
At the same time, whilst institutions are gaining more autonomy, their expansion beyond national borders can be fostered or hampered by government policy. Thus, the synergies and inconsistencies of institutional strategies and national policies on internationalisation should be better understood. Investigating the interconnecting relationships between the various actors, first between institutions and their governments, is of utmost importance to grasp the complexity of internationalised higher education.
Why internationalisation matters for higher education institutions Internationalisation enables higher education institutions to:
- increase national and international visibility;
- leverage institutional strengths through strategic partnerships;
- enlarge the academic community within which to benchmark their activities;
- mobilise internal intellectual resources;
- add important, contemporary learning outcomes to student experience;
- develop stronger research groups.
Why internationalisation matters for governments Internationalisation enables governments to:
- develop national university systems within a broader, global framework;
- produce a skilled workforce with global awareness and multi-cultural competencies;
- use public higher education funds to promote national participation in the global knowledge economy;
- benefit from trade in education services.
Commission’s package includes Youth Guarantee
The European Commission is calling on all Member States to address the problem of youth unemployment, which it says is costing the region billions of euros. On 5 December 2012, the Commission presented a package of measures in its initiative on a Youth Guarantee and a Quality Framework for Traineeships. It wants Member States to ensure all young people are offered work and training. In its Proposal for a Council Recommendation on Establishing a Youth Guarantee, the Commission sets out its aims. The guarantee is designed to ensure that all young people up to the age of 25 receive a good quality offer of employment, continued education, an apprenticeship or a traineeship within four months of becoming unemployed or leaving formal education. The recommendation calls on Member States to establish partnerships with all stakeholders to implement this guarantee, including the provision of intervention services at an early stage. The Commission has promised support through the European Structural Funds. In a communication on 5 December 2012, Moving Youth into Employment, the Commission said that the costs of implementing the guarantee would be outweighed by the long-term savings made through reducing unemployment, economic inactivity and lost productivity. It believes there will be positive returns on investing in a Youth Guarantee. The Commission bases its findings on a major Eurofound study on young people not in employment, education or training (NEET) in Europe which estimates that the annual cost of disengagement of young people from the labour market is currently around 1.2% of gross domestic product (GDP), or €153 billion.
The Commission’s recommendation also proposes that Member States can boost recruitment prospects among young people by reducing non-wage labour costs. It also calls for enhanced mechanisms for supporting young people who have dropped out of activation schemes and no longer access benefits.
A European quality framework on traineeships
To ease the transition from education to work, on 5 December the Commission also launched the second-stage consultation among cross-sectoral social partners at European level on an initiative intended to help young people gain work experience under safe conditions, Towards a Quality Framework on Traineeships. The Commission said the first stage of consultations had revealed a consensus on the useful role of traineeships. But it also pointed to a lack of quality and widespread misuse of such schemes across Europe, and action needed to be taken on these issues. However, social partner views differed on whether an initiative at European level in this field needed to be taken. In its consultation document, the Commission set out the issues that should be addressed by a European framework. It stated that each traineeship should lead to a written agreement between the trainee and the employer (or the training organisation) covering such aspects as:
professional and learning objectives;
daily and weekly working time;
payment of social security, where applicable, and remuneration or compensation.
The agreement should also set well-defined objectives and offer high-quality learning content to increase the employability of the trainee. A personal supervisor or mentor should be appointed to guide the trainee. Finally, at the end of a course, the trainee should receive a final evaluation that ensures proper recognition of the traineeship. This document would contain information on matters such as the duration of the course, the educational content, the tasks performed, the knowledge, skills and competences acquired and a performance assessment. Traineeships should last for a specified period, for example six months, to ensure that they are not being used to replace regular jobs. The Commission also says that the issue of limiting successive traineeships with the same employer should be addressed. Trainees should be covered by social protection, including health insurance and insurance against accidents at the workplace. The Commission said it was willing to recognise unpaid traineeships. However, if the employer provided compensation or a wage, the amount must be clearly specified in the traineeship agreement. The cross-sectoral European social partners have already begun negotiations on a framework to address youth employment and talks have been going on since the end of 2012. However, these negotiations were not intended to include the issue of traineeships. If the social partners decide not to negotiate on traineeships, the Commission will put forward its own recommendation on this issue in 2013.
European alliance for apprenticeships
Inspired by Germany and Austria, which have the lowest youth unemployment rates in Europe, the Commission also intends to build a European alliance for apprenticeships. This would group the various European initiatives under a common umbrella. The alliance would promote the benefits and elements of successful apprenticeship schemes and recommend ways in which these could be improved. It would also help develop common dual training curricula for various professions, facilitate recognition of apprenticeships undertaken abroad, and promote an appropriate framework. The Commission also plans to promote national partnerships for developing dual learning.
The Commission’s initiatives on the Youth Guarantee can only be welcomed, given the serious situation of youth employment. However, it will be some time before it is implemented. Concrete action is not expected before 2014 in the context of the new financial programme of the European Union. This also applies to the European framework for traineeships. If the social partners decide to negotiate on the Youth Guarantee and traineeships by the end of January 2013, they will have nine months to reach an agreement. There would probably then be a period of implementation, meaning it will be some time before Europe sees any real results from the initiative.
The UNESCO Institute for Lifelong Learning (UIL), on behalf of the UNESCO Education Sector, has taken the initiative in working with Member States to develop the UNESCO Guidelines for the Recognition, Validation and Accreditation (RVA) of the Outcomes of Non-formal and Informal Learning. In June 2012, Mr Qian Tang, the Assistant Director-General for Education of UNESCO, officially approved the Guidelines and invited authorities in Member States to make efforts to implement the Guidelines in line with their specific national context.
Acting upon this initiative, the DVV International Regional Office in Southeast Asia organised a workshop on 7 and 8 January 2013, in Vientiane (Lao PDR) to facilitate the implementation of the UNESCO Guidelines for RVA in the sub-region. Eighteen policymakers and experts from Cambodia, Laos, the Asia South Pacific Association for Basic and Adult Education and the Southeast Asian Ministers of Education Organization Centre for Lifelong Learning participated in the workshop. With the help of DVV International and the UNESCO Office in Ha Noi, the Guidelines were translated into the national languages of Cambodia, Lao PDR and Viet Nam and disseminated to national stakeholders in the three countries. Mr Jin Yang, Senior Programme Specialist of UIL, served as a resource person and made four presentations at the workshop on the following topics:
- Conceptual evolution and policy developments in lifelong learning – A UNESCO perspective;
- The nature of learning and the importance of non-formal and informal learning;
- Synthesis report on RVA in UNESCO Member States, and
- The key messages of the UNESCO Guidelines for RVA
During group work, the country teams elaborated on opportunities/strengths, threats/weaknesses and developed some concrete key action points for implementing the Guidelines in their countries in the next two years. Additionally, the participants also requested UIL and DVV International to continuously support the implementation of the Guidelines through provision of technical expertise and capacity building in developing skill assessment tools and qualification criteria. In all, the two-day Workshop successfully mobilised several key change agents in the three countries for implementing the UNESCO Guidelines, deepened participants’ understanding of key concepts of lifelong learning and RVA, and strengthened their capacity for implementing the UNESCO Guidelines for RVA. These outputs will result in concrete steps for Cambodia, Lao PDR and Viet Nam in constructing a national RVA system.
Care and caution are essential as we proceed with both the student learning discussion and the federal financing discussion. Why? While the academy is not trying to do the government’s work of figuring out federal financing of the credit hour, the government has displayed considerable interest in doing the academy’s work – determining and judging student learning. This emerging development is undesirable, not only for the academy and government, but also for students and the public.
The Student Learning Outcomes Discussion
The discussion about appropriate outcomes of learning, how to achieve them and how to provide evidence for them, has been underway in the academy for years and is well advanced. It includes credit hour considerations, but is much broader. Lately, the discussion has been driven by the emphasis on accountability and public demands for evidence of student achievement from colleges and universities. It is also related to the impact that online learning, competency-based learning and assessment of prior learning have had on the traditional collegiate classroom-based experience which, for most of its history, has defined higher education and thus defined the credit hour.
An outcomes-based approach to the credit hour can be flexible. It can be implemented within traditional time parameters leading to a degree, such as semesters or quarters. Or, it can be done independently of time: Once a student has provided evidence of learning, progress or completion can be formally noted through a credential of some sort. This last helps to explain not only the recent renewed emphasis on competency-based education and assessment of prior learning, but also the emerging interest in educational practices such as private companies offering online coursework at very low prices (StraighterLine) and massive open online courses (Coursera, Udacity).
The Federal Funding Discussion
The time-based credit hour has been used by the federal government to determine how much and for what period of time federal aid such as the Pell Grant, the largest aid program, is available to students. The federal government is spending historically large sums of money on Pell and other programs, some $175 billion each year. The assumption has been that financing adequate time expended to earn credits is a good use of federal funds and financing too little time expended is a misuse of federal dollars.
While the credit hour concept is well embedded in federal law and regulation, government officials are now persuaded that there is insufficient return on investment using the time-based credit hour. The value proposition put forward is that learning outcomes may be a more effective indicator of whether federal money is spent appropriately.
Care and Caution
In 2011, the U.S. Department of Education issued a regulation that provided a federal definition of “credit hour,” accompanied by requiring nongovernmental accrediting organizations to enforce and monitor its use. The federal definition is complex and a work in progress, but allows for either a time-based or outcomes-based approach to the credit hour. Given that definition of credit hour has been the province of the academy for more than 100 years, why, for the first time, is the government defining this concept, superseding the work of the academy?
In 2012, the National Advisory Committee on Institutional Quality and Integrity, advising the Secretary of Education on the recognition of accrediting organizations, released a report examining the effectiveness of accreditation. The report does not focus on the credit hour, but does address student learning outcomes. While not going so far as calling for common outcome measures, the main report does recommend establishing common definitions of outcomes across institutions. The alternative report accompanying the main document calls for institutions to provide common information on some student outcomes. Although both recommendations do not establish and standardize student outcomes, it is a short step from common definitions and common information to national standardization.
Both of these efforts are indications that the government discussion of financing the credit hour is expanding to become a discussion of determining and judging student learning outcomes as well. In some instances, the government taking on this role is assumed. Amy Laitinen’s September 2012 report, Cracking the Credit Hour, offers valuable suggestions about further experimentation with outcomes-based approaches to the credit hour. However, although the report does not directly address financing of the credit hour (the province of government), it does recommend that the federal government provide the leadership for this experimentation (the province of the academy).
We need government officials who understand the importance of turning to the academy for guidance about any transition of the credit hour from time-based to outcomes-based, whether whole or partial. Only after these learning outcome determinations have been made by the academic community is government in a position to decide whether and how funds will be provided. Federal regulations that place authority for student learning outcomes in the hands of government officials and not academics are undesirable and, frankly, likely to be less than effective.
If the government now defines the credit hour, decides the data that are to be used for student learning outcomes and leads experiments in alternative approaches for using an outcomes-based approach to the credit hour, what is left for the academy to do?