It is amusing playing around with words. We may, indeed, want to return to this on Report: I would not want to go any further than that. However, I hope that the warmth of the words gives an indication of the direction we wish to go in. It is right that I keep my comments on this group of amendments relatively brief. In addition, I am happy to write to noble Lords on this matter to provide further clarification. I hope that noble Lords will have received quite a long letter from me today, based on the last day in Committee. I hope that all the points raised were helpful.
My noble friend Lord Lucas made some helpful comments on Amendment 192. I reassure him that the OfS can already collaborate with others as part of this assessment. HEFCE, which currently administers the TEF, has collaborated with the QAA and others without specific legislative provision allowing them to do so. HEFCE currently undertakes an important role in assessing standards as part of its quality duty. As my noble friend Lord Willetts said, standards are currently part of the QAA’s quality code. However, I acknowledge that the current lack of an explicit mention for standards has created uncertainty. That is why standards are mentioned on the face of the Bill. I hope we can all agree that it is essential that the Office
for Students can ensure that providers are genuinely offering qualifications of a suitable standard to be considered higher education, even if we need to discuss precisely how we have achieved that within the current drafting.
The noble Baronesses, Lady Brown and Lady Garden, spoke about separate quality and standards. I understand the points raised on the difference between the two. However, decoupling quality and standards is not the approach taken by the sector in the UK quality code. Any assessment of quality and standards may need to consider both in order to protect the value of a qualification. However, the OfS can apply a condition on quality or standards: it does not have to apply both. I hope this provides some helpful clarification on that front.
On degree classification and grade inflation, I agree that the sector needs to do more here. We are committed to supporting them in this: HEFCE’s work with the Higher Education Academy to implement approaches to training external examiners, and the teaching excellence framework, which will recognise providers that are genuinely stretching students and delivering good outcomes for their students, are examples of important actions in this area.
We do not want to undermine the prerogative of providers in determining standards. As the noble Baroness, Lady Garden, said, this is about ensuring that all providers in the system are meeting the threshold standards that are set out in a document endorsed and agreed by the sector, as she mentioned—Frameworks for Higher Education Qualifications. I reassure the Committee that there is no intention to rate standards in the TEF. However, part of excellence in teaching is ensuring that students are stretched to achieve their full potential. One of the TEF criteria is, therefore, the extent to which course design, development, standards and assessment are effective in stretching students to develop independence, knowledge, understanding and skills that reflect their full potential. For this reason, we believe that the inclusion of standards is crucial to ensuring that the TEF can make a true, holistic assessment of teaching excellence.
I repeat that the standards that are regulated against should be, first and foremost, standards that are set by the sector, rather than prescribed narrowly within legislation. As I have said, I will be reflecting carefully and expect that we will return to this issue on Report. I therefore ask that Amendment 63 be withdrawn.