My Lords, when we last met, and as the noble Lord, Lord Lipsey, said, we had a useful and wide-ranging debate on the TEF, and I value a further debate on this important subject.
The Conservative manifesto committed that we will,
“introduce a framework to recognise universities offering the highest teaching quality”.
During last Wednesday’s debate, I was pleased that, as the noble Lord, Lord Watson, noted, all noble Lords who spoke were in favour of improving teaching quality and of having a teaching excellence framework in some form.
Before discussing the specific issues raised today, I should like to clear up what appear to be some misapprehensions about how the TEF will operate. Before doing so, I should say that I will write to the noble Baroness, Lady Wolf, who raised a number of detailed points. I think it is best if I address those specific points in another letter. I should reassure noble Lords that I have just signed a letter relating to our previous day in Committee, and that should arrive on their doorsteps shortly.
It is important that when we discuss the TEF we do so in the context of the framework that has been set out, in detail, by the Government. To be clear, this framework has been designed over the past year and a half with the sector, through two consultations, and using the input of experts such as HESA and the ONS.
First, the TEF is not only—not even primarily—about the NSS, as I think the noble Lord, Lord Lipsey, acknowledges. The NSS is just one of three principal sources of metrics data being used, and we have explicitly said that the NSS metrics are the least important.
Secondly, the TEF is about much more than metrics. Providers submit additional evidence alongside their metrics, and this evidence will be given significant weight by the panel. The work of the panel will be driven as much by judgment as by metrics, ensuring that the distinctive character of institutions, as well as the diversity of missions and approaches across the sector, are recognised in the ratings awarded. Furthermore, final decisions on TEF ratings will be taken by a peer review panel, not by Ministers or civil servants.
We also consider it vital that judgments are based on a combination of core metrics, with additional and qualitative evidence, wedded together by expert peer judgment. It is for providers to determine what and how to teach, and excellent teaching can take many forms. However, great-quality teaching, defined broadly, increases the likelihood of good outcomes. In our consultation, over 70% of those who responded welcomed our approach to contextualising the data and provider submission.
I reassure noble Lords that we are not naive about the use of metrics. Chris Husbands, the TEF chair, has noted that the approach that the TEF takes is realistic about the difficulty of assessing teaching quality. He said:
“It does not pretend to be a direct audit of the quality of teaching. Instead, it uses a range of evidence to construct a framework within which to make an assessment—looking at a range of data on teaching quality, learning environments and student outcomes”.
Turning to Amendments 187, 197 and 190, that is why the development of the TEF, including metrics, is a phased process of development. Our consultation on the metrics included a table of the potential unintended consequences and our proposed mitigations. We will continue to collaborate and work with the sector to make further improvements, learning lessons from the initial, trial year. The aim is to instil and gain the confidence of the sector, and I believe we have made a very positive start. As Dame Julia Goodfellow, president of Universities UK, said:
“The government’s response to the Teaching Excellence Framework consultation demonstrates that it has consulted and listened to the university sector”.
I am concerned that some of the amendments in this group add a level of process which could reduce the incentive to make further changes to the scheme or the metrics by requiring that they are laid before Parliament as they change. This reduction in flexibility is not required by other schemes supported by many noble Lords, such as the research excellence framework.
I now turn to amendments to prohibit the use of the National Student Survey. We are listening carefully to concerns on the NSS, but we cannot ignore the only credible, widely used metric that captures students’ views. We are not using the general satisfaction ratings in the TEF; rather, we are using specific questions related to teaching quality. My noble friend Lord Willetts highlighted that point. However, as the noble Lord, Lord Lipsey, acknowledges, we recognise the limitations of the NSS and have taken steps to mitigate these, including directing TEF assessors not to overweight the three NSS-based metrics and making them aware that NSS scores can be inversely correlated with stretch and rigour. Looking at three years-worth of data will mitigate concerns about the effects on small providers. It will also help to address the concerns of the noble Lord, Lord Lipsey, about spikes created by a non-response. The need for care when interpreting results for small providers has been drawn to the attention of the TEF assessors. However, overall the panel will be encouraged in its assessment to reward and recognise quality wherever it finds it, without being bound by guideline distributions of gold, silver and bronze.
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On the standards that the OfS will apply in using statistics, I reassure noble Lords that the statistics and metrics are, and will continue to be, published—as are details such as where statistics have been combined to create indicators—without legislative duties forcing this, as the underlying purpose of the TEF is to provide students with better information about their chosen providers.
I hope that this debate has been of some use to noble Lords and that it has provided some reassurance about our collaborative approach to metrics and assessment. However, in wishing to attract participants to the TEF, it is not in our interest to impose metrics that lack credibility or to see information handled
other than with the highest standards of professionalism. I believe we have already put suitable mitigations in place, without legislation, to ensure that that is the case.
The TEF addresses an unacceptable information gap in the provision of higher education, using clear ratings to inform students and incentivise excellence. It will support the propagation of good practice across the sector without stifling innovation. It will also provide clear benefits to UK businesses by ensuring that graduates enter the workplace with the skills and knowledge that can be provided only by excellent teaching.
I should like to address some points—raised notably by the noble Baroness, Lady Lister, and my noble friend Lord Lucas—that focused on the gold, silver and bronze ratings. The general gist of the noble Baroness’s question was whether the bronze rating would be considered less valuable. As I said in the previous debate, the TEF ratings assess the quality of teaching over and above the high-quality baseline that we expect providers to attain. Even to be able to apply for TEF, providers must have passed this baseline—and, by the way, many do not. However, we are not complacent about the risk of miscommunication, and we are working very closely with the British Council and others to ensure that the TEF ratings are communicated effectively internationally, emphasising the high overall quality of the UK provision. We will have a joint communication plan with them in place by the time the TEF ratings are published.
The noble Baroness, Lady Lister, asked how often the assessment would take place. I think the implication of her question was: if a provider happened to be rated as bronze, how long would it be before that rating could change? I reassure her that a TEF lasts for three years but providers can reapply the following year if they are unhappy with their award and can be reassessed. I hope that provides some reassurance on this matter, not only for the noble Baroness but for the Committee.
My noble friend Lord Lucas, supported by the noble Baroness, Lady Wolf, spoke about percentages, the implication being that there were quotas. I reassure them that, when it comes to the spread of how providers are rated, there is no quota. For example, the 20% figure that was mentioned is not a quota. It would be up to the assessors to decide what percentages of bronze, silver and gold would be awarded. Benchmarking has the support of the sector and I would be concerned about removing this contextualisation, with the disadvantages that could have. For example, providers that take a large number of students with low prior attainment might be disadvantaged. I should like to focus on this point in my next letter to clear up any misconceptions.
With that, I ask the noble Lord to withdraw his Amendment 187.