January 2013

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The importance of consulting

Harriet Barnes and Janet Bohrer - Quality Assurance Agency for Higher Education in the UK (QAA)

QAA's mission is to safeguard standards and improve the quality of UK higher education. To do this, we evaluate how well universities and colleges meet their responsibilities as self-regulating institutions by carrying out external reviews, and publishing reports on what we find. The basis for the judgements which are made in the course of these reviews is the reference point known (since December 2011) as the UK Quality Code for Higher Education (previously the Academic Infrastructure), which QAA maintains on behalf of the sector. Rather than being a rulebook, the Quality Code sets out high-level "Expectations" which universities and colleges are required to meet through their internal systems of quality assurance.

As an organisation, QAA is committed to transparency in its work. This is reflected for example in the way we publish all our review reports, and the handbooks that explain the review process. It is also demonstrated in our commitment to a process of public consultation wherever possible. Our organisational policy on consultation is aligned with the consultation principles for government and public bodies.1 We follow this process for many areas of our work, including the development of methods of review, but the rest of this article focuses on the development of the Quality Code, for which there has been a period of intensive activity since the autumn of 2011 that is still ongoing.

To produce many of our publications, and particularly policy documents such as the Quality Code, we draw initially on advice and guidance from experts within the higher education sector and from others with an interest in higher education, including students, who offer expertise on their own learning experience.2 A draft document is then put forward for public consultation. We actively promote the consultation and its closing dates through various news channels, especially QAA's regular email newsletter and other social media. We hold a series of discussion events in different parts of the UK, which enable delegates to discuss the document, learn more about how it has been developed and share practice on the topic. Delegates represent the full range of higher education providers in the UK and in many cases attend the event on behalf of their organisation, thereby enabling the organisation to submit a fully informed formal written response. All comments made to us through the consultation process, whether at events or in written form, are taken very seriously in finalising the publication.

For QAA, this is a well-established model for the development of the documents that form the definitive reference points for the quality assurance of UK higher education, and it has also been used in the creation of the Academic Infrastructure from 1997 onwards. Nevertheless, in order to maximise the efficiency of our processes and to reflect the speed and volume of work undertaken on the Quality Code, an online dimension was added at the end of 2011 for collecting consultation responses. This takes the form of a survey for each consultation exercise, which is hosted by a commercial survey company, with a series of closed questions and open text boxes for more detailed comments.

To date, we have completed or have in progress seven consultations using this method. We have received over 660 responses to the consultations completed so far, almost all via the online form. On the whole, responses come from universities, but 10-15% of responses to each consultation come from others with an interest in higher education, including further education colleges, alternative providers of higher education, professional, statutory and regulatory bodies, sector bodies and student representative bodies, as well as individuals, as illustrated in the diagram as an example for one Chapter.

The online method of collecting consultation feedback has made it much easier to analyse the often very detailed and quite substantial amount of information received. Firstly this is because we ask targeted questions rather than one open generic question, and secondly we can collate and organise the information much more easily. We have also had to solve some challenges along the way however. Some respondents told us that they did not have the time or inclination to respond to a lengthy survey when they only had a one small point to make; we have also collected a number of incomplete survey responses. As the majority of the responses are not made by individuals but on behalf of an organisation, one process or other will have been followed to create that response, such as consideration at appropriate committees or focus group discussions. Finally, as many of the issues covered by the Quality Code are informed by the wider political and social context in which individual higher education providers are working, respondents reported to us that it was helpful to know what issues were being raised by others at the discussion events before making their final response.

We have therefore adapted some of the practical aspects of our consultation process over the past year. This includes publishing the questions included in the consultation survey separately so that respondents can use them to collect feedback from colleagues. We have also introduced a dedicated email address for the Quality Code, and at the discussion events we promote its use for anyone who wants to raise a particular issue. We aim to publish a summary of feedback from the discussion events on the website before the end of the relevant consultation period. This allows delegates and others to see the main issues that have been raised at events held in different geographical locations and helps to inform their formal response.

Alongside the final version of the document, a report is published outlining the main themes that have emerged from the consultation, which are reflected in changes made to the final publication. It is not unusual for a document to change substantially as a result of the consultation process, and anecdotally, respondents have told us that they have seen changes in the final version that reflect their feedback, which has shown them the value of engaging in the consultation. For QAA, the consultation process enables us to embed the sense of sector ownership of the reference points, which is crucial in a context where higher education providers are independent and self-governing. The validity of the Quality Code as a reference point for UK higher education depends on the way in which it takes account of the views and expertise of those who will use it, and we see the consultation process as making this possible.

1 QAA's consultation policy is available from: www.qaa.ac.uk/AboutUs/corporate/Policies/Pages/QAA-policy-on-consultations.aspx. Consultation principles for government and public bodies in the UK are available from: www.cabinetoffice.gov.uk/sites/default/files/resources/Consultation-Principles.pdf

2 The development process is set out at: www.qaa.ac.uk/AssuringStandardsAndQuality/quality-code/Pages/development.aspx


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