End of Green Paper Consultation.

So after a few  months where policy wonks have pored over the fine details of the Green Paper consultation, on Friday the music stopped, and everyone had to submit their reponses. (actually the music stopped on the 10th).

Interestingly, there seems to be a high degree of consensus for once, between the various mission groups and representative bodies, particularity in relation to the proposed Teaching Excellence Framework.

Despite comments from Jo Johnson prior to release of the consultation, that “teaching was lamentable”, this view of a dysfunctional sector is not recognised by pretty much everyone else in it, and so such a toxic comment might be more the view of an individual, or small number of individuals who can see fault in one small part of the sector, rather than take a holistic view to see what those problems are in context.

The general response is that groups and individual institutions welcome the Green Paper and the commitment to supporting excellence in both teaching and research

Universities UK

The UUK response states that UUK:

  •  commits to working with the government to develop an effective Teaching Excellence Framework.
  • recommends that the second proposed iteration of the TEF be a pilot that gathers evidence on implementing teaching excellence
  • evaluates how this information can be usefully presented to students
  • disagrees with proposals for linking fee caps to multiple levels of TEF
  • proposes that the Office for Students should be called the Office for Students and Higher Education to reflect a broader mandate covering teaching funding, overview of research and third-stream activities.
  • Degree awarding powers should be based on four year track record and there should be a public interest test for granting university title
  • raises concerns about moving quality-related research funding (QR) into Research UK and asks for a clear commitment to protect dual support and the distinctiveness of the funding councils and Innovate UK


The GuildHE response again “welcomes the government’s focus on raising teaching standards and improving access to higher education.” and recognises that TEF “provides a real opportunity to enhance teaching within universities and raise the profile of good teachers but there are clearly many potential pitfalls along the way that we need to avoid”.

The problems around using existing metrics are articulated and:

This points to an evolution of TEF as something driven by the conversation around the teaching and learning opportunities that are delivered to students, i.e. TEF should become less about the metrics than about this conversation. There are very interesting parallels here to the current method of quality assessment – also configured as a conversation. Synergies between the new TEF intentions and the existing QA process should be identified and harnessed


Our own mission group, million+ has responded, “highlighting concerns in a number of areas and urging the Government to work with the sector to ensure that any changes introduced are in the interest of students, universities and employers” and again identifies problems with the existing metrics to populate TEF:

“Linking fee increases with a Teaching Excellence Framework (TEF) based on metrics that are proxies for teaching quality, is unlikely to provide students or employers with an accurate picture of the rich and varied teaching and learning environments that universities offer. This risks damaging the reputation of the higher education sector in the UK and is why we recommend that the government defer the introduction of a multi-level TEF in 2018 until further work has been undertaken to determine the best way to promote teaching excellence.”


Finally to be covered here, the Council for the Defence of British Universities has responded, and not surprisingly, is not supportive of much of the Green Paper:

the Teaching Excellence Framework (TEF) – is put forward to address putative problems, without providing any evidence that these problems exist. The proposed TEF would be an expensive and bureaucratic system that would entail increasing complexity and disruption for years to come. The use of proxies, such as the NSS or graduate income, for teaching excellence is at odds with the ethos and values of education and scholarship. Both the content and the methodology behind the Green Paper come across as counter to the academic values that lie at the heart of any university worthy of the name. These values include reliance on reason, argument, and evidence; critical and creative thinking; rigorous analysis of data; and precise and meaningful communication. There is no recognition in the Green Paper that the primary purpose of universities is to foster these values; instead, universities are equated with businesses, value is defined purely in economic terms, and students and staff are set up in opposition as consumer and vendor respectively, working to serve conflicting interests (to pay as little as possible for the product purchased and to charge as much as the ‘customer’ will take).


For those who would like a critical nuanced exposition of the Gren Paper, then I’d recommend the ever excellent Stefan Collini, writing in the London Review of Books with an article titled “Who are the spongers now?”, where on TEF he concludes:

“So what will the TEF actually produce? At a minimum, the following: more administrators to administer the TEF; a greater role for business in shaping the curriculum and forms of teaching; a mountain of prose in which institutions describe, in the prescribed terms, how wonderful their provision and procedures are. It also seems pretty certain to produce more efforts by universities to make sure their NSS scores look good; more pressure on academics to do whatever it takes to improve their institution’s overall TEF rating; and more league tables, more gaming of the system, and more disingenuous boasting by universities about being in the ‘top ten’ for this or that.

What is it unlikely to produce? Better quality teaching”

So we seem to have stakeholders from across the sector, saying pretty much some of the same things:

  • the metrics proposed as proxies for teaching excellence, can’t be relied upon to show teaching excellence
  • changes to the routes for new providers are being regarded with some suspicion
  • the time allowed to develop and implement TEF is too short
  • there is concern about linking fees to varying levels of TEF
  • dual support of research should be supported

What will be interesting now is to see how government responds to a sector who know themselves well, and who have identified where more work is needed to translate policy proposals into actions – with this overwhelming amount of agreement, it will be hard to push ahead exactly as outlined in the Green Paper. Lets’s leave the last words to Collini again:

“But don’t worry: the Green Paper is only a ‘consultation’ document. That must mean that if cogent objections are put forward to the premises, reasoning and conclusions it contains, none of these proposals will come to pass. Well, mustn’t it?”