Universities Scotland has responded to the consultation on the the UK Government’s Higher Education Green Paper, Fulfilling our potential: teaching excellence, social mobility and student choice.

The response addresses those consultation questions where there are particular implications for the sector in Scotland. Given that many of the proposals in the Green Paper will have direct or indirect implications for the higher education sector across the UK, we encourage a continuation of close consultation with institutions and governments across the devolved nations.

Key points:

• On the Teaching Excellence Framework (TEF), it is important that Scottish institutions are included in this evolving discussion of a matter that will have effects on UK Higher Education as a whole. The introduction of TEF, whatever its final form, will have implications for Scottish institutions. It will influence student choice within the UK and beyond and the decisions of potential collaborative partners.
• We believe that a prioritisation of enhancement, whilst explicitly allowing for diverse forms of excellence, should be the focus for the development of TEF findings beyond a basic threshold for determining fee uplifts.
• We strongly believe in the importance of research informed teaching and therefore research teaching links are important.
• On the proposed approach to the evidence used to make TEF assessments, we believe that the three proposed metrics, which are outcome focused, are not direct indicators of excellence in learning and teaching and are not currently collected for this purpose. We suggest that further work will be required to identify and refine any data sources.
• On the proposals to further improve access and success for students from disadvantaged backgrounds and black and minority ethnic (BME) backgrounds, we believe this aim is laudable but we are concerned that no evidence has been cited to support it and therefore there is a risk of making changes at some cost with no benefit. We therefore encourage engagement with UCAS and with admissions networks across the UK to develop proposals that support the full breadth of widening access work.
• On the proposed risk-based approach to eligibility for degree awarding powers (DAPs) and university title, we have some concerns that the new process may not give sufficient weight to track record. There is a reputational risk for the UK brand of HE if this goes wrong, and, critically, there is a risk for the students involved.
• On simplifying the higher education architecture, some of the bodies mentioned including QAA and HESA operate across the UK and are sector owned. Any changes, whether legislative or policy-driven, must therefore take account of the needs of the sector across the whole UK.
• On reducing complexity and bureaucracy in research funding, our key aims are to maintain the robustness of the dual support system; and ensure appropriate representation of Scottish research and involvement with UK-level decision making processes.

Read Universities Scotland’s Green Paper consultation response