by Tim Brown
Consultation Questions on Degree Awarding Powers
1. The detailed proposed criteria for the granting of degree awarding powers are set out at Annex A of the main document.
Question 1 (Overall framework for revisions to DAP criteria: paragraph 3.1 of main document) Do you have any comments on the overall framework for the proposed criteria on the granting of taught and research degree awarding powers?
We identify with the need to set appropriate criteria partucularly for smaller institutions seeking to bring in degree awarding powers with the scope to become a University. Governance, academic standards and teaching competence are all appropriate to include and we have added further suggestions in this response where appropriate.
The main area we are concerned about is the overlap between a taught and Master's degree and a research degree (which does not only apply to doctoral degrees). We are concerned that the criteria changes do not consider the need for many Master level degrees to require access to research due to their specific nature. Further to this we are concerned that little attention has been paid to the need for research degrees to have procedures for effective supervision and training of research students as well as being placed within a suitable research environment. Such requirements are in many ways more important to effectively deliver research degrees, which are not reflected in the research and assessment exercise.
We continue to re-iterate our opposition to the title of "University" being allowed for teaching only institutions. We are also concerned that reducing the minimum number of subjects will completely contradict the principle of a University and do not support any move to relax these regulations.
Question 2 Do you have any comments on the detailed criteria on the granting of taught degree awarding powers? (Taught DAP criteria: paragraph 3.2 of the main document)
Question 2a Criterion A: Governance and Academic Management
We are in support of structured governance and useful guidelines as to how this should be implemented with regards to institutions seeking to award degrees. There is little evidence, however, that the governing structures recommend opportunities for representation and feedback both from undergraduates and postgraduates where applicable. We would recommend that this is in place so that there is opportunity to communicate with students at the receiving end as well as faciliate effective representation and feedback at course level also. We would also note there is little evidence here to hold back any unecessary bureaucracy in governing structures, which is encouraged by the higher education white paper. We would therefore wish to ensure governing procedures are considered in terms of their value and benefit to students and staff in a higher education institution.
Question 2b Criterion B: Academic Standards and Quality Assurance
We support the use of the QAA codes of practice as helpful guidelines on maintining consistent quality assurance and academic standards, and would recommend further extension of QAA's guidelines if necessary. We have always argued that standards are one thing, although their implementation and transparency is another. We would encourage good practice from any regulations and code of practice be promoted to staff and also explained clearly to students in course handbooks and any promotional material as necessary. We are particularly concerned that this is made clear in terms of examination requirements and complaints procedures to ensure any problems are avoided or resolved. It is also important that accessible feedback mechanisms are in place, and that the representation or feedback from students is valuded and has the appropriate impact on academic practice.
The idea of self assessment outlined in B4 is a principle we do not support, since we find it difficult to consider how an institution can critically assess its course delivery. Any such assessment should be subject to further critical review with the involvement of students and external auditors.
Question 2c Criterion C: Scholarship and the Pedagogical Effectiveness of Academic Staff
In respect of a vast majority of taught postgraduate degrees, especially ones where research is carried out such as the MRes or MSc by research, we are concerned that institutions without sufficient access to research (as would be required for doctoral degrees) could be granted unacceptable awarding powers. We appreciate the requirement is specified with respect to engagement in advanced scholarship and/or research for such degrees, but this has little to do with weather the staff are within an appropriate research environment or support for research based degrees.
We would also like to re-iterate here as in our response to the white paper that postgraduates are largely regarded as doctoral students and that research degrees are considered as doctoral. This is not at all the case and there is a wide variety of research degrees including the Master of Philosophy (MPhil), which some institutions offer as an alternative research degree. It is therefore highly necessary that specific regulations are in place to allow an institution to award such degrees.
Question 2d Criterion D: The Environment Supporting the Delivery of Programmes
We are in support here of the proposals presented as they will clearly benefit the student. It appears, however, that to include student feedback mechanisms with representation structures would be a suitable addition. We would also support appropriate tutoring systems and points of enquiry for the student, which would need to be implemented within an appropriate heirachy for the course structure.
Question 3 (Taught DAP criteria: paragraph 3.2 of the main document) Are the proposed criteria for taught degree awarding powers clearer than the current criteria?
We are not sure
As we are not involved in the delivery of courses we would not feel it appropriate to comment.
Question 4 (Taught DAP criteria: paragraph 3.2 of the main document) Do the proposed criteria strengthen the requirements for the granting of taught degree awarding powers?
We are not sure
We would give the same response here as to the previous question.
Question 5 (Research DAP criteria: paragraph 3.3 of the main document) Do you have any comments on the detailed criteria on the granting of research degree awarding powers?
Again we would re-iterate our interpretation of research degrees being not only that of doctoral degrees. We would therefore wish to re-emphasise our concern that research degree awarding powers consider the interests of other research degrees including the new route PhD, EdD and professional doctorates which will require suitable engagement with industry and appropriate teaching resources. The emphasis is clearly focusing on the research quality of an institution and on the research activity or advanced scholarship of the academic staff.
It is as important if not more so that as well as a good research environment there are well structured training programmes and assurance of good supervision that will allow research students to be competent researchers and equipped for employment. The current proposals do give reference to the framework being developed by the research councils to improve standards in research degree programmes, although the importance of these standards is not emphasised. It is therefore necessary that evidence of competence in these areas is presented, which are not evidenced by the research and assessment exercise.
Question 6 (Granting of DAP for renewable terms: paragraphs 3.4 - 3.6 of the main document) Do you agree that, in future, degree awarding powers should be issued on a renewable basis, subject to a satisfactory external audit?
We are not sure
Again, we would consider this mainly a question for current institutions offering degrees. We would consider only recommending that this is undertaken for such institutions recently in receipt of degree awarding powers. Older institutions may be better targeted in terms of whether specific degree programmes they offer are suitable to continue or subject to reform since their institution wide criteria may already be monitored sufficiently by institutional audits.
Question 7 (Granting of DAP for renewable terms: paragraphs 3.4 - 3.6 of the main document) If you agree with fixed terms for the awarding of degree awarding powers, is six years an appropriate term?
We are not sure
Again we are not sure whether this is suitable in terms of administration.
Consultation Questions on Proposed Criteria for University Title
2. The detailed proposed criteria for the granting of university title are set out in Section 4 of Annex A with commentary in section 4 of the main document. We were grateful for the views of respondents to the principle of granting university title on the basis of taught degree awarding powers, as set out in the White Paper, The Future of Higher Education. The views expressed were mixed on the merits of the proposal. We have noted those views but if you wish to make further comments please do so in the box on the next page. Questions 8 and 9 below seek views on the detailed criteria for the granting of university title.
Question 8: (Granting of university title: paragraphs 4.1 - 4.2 of the main document) We have removed the requirement for organisations seeking university title to have students in five subject areas. Do you think that organisations specialising in one subject area should be eligible for university title?
We do not
We do not support this as we consider it to take away the meaning of a University providing a "universal" nature to an institution and inter disciplinary teaching/research with a wider range of resources that a large enough group of students and diversity in subjects can allow. We therefore do not support this move and consider specialist institutions (which tend not to be large in any instance) as not appropriate for such a title.
Question 9 (Granting of university title: paragraphs 4.1 - 4.2 of the main document) Do you think maintaining the current student numbers required for eligibility for university title is right, or that the numbers required are too high or low?
We think that the maintaining the current numbers is right
As already pointed out, we consider there to be a need for a minimum number of students in a University to provide appropriate resources and diversity.