EPC Profile picture
Mar 17 26 tweets 12 min read
The EPC has published its responses to two @officestudents' consultations on
#StudentOutcomes: epc.ac.uk/wp-content/upl…
#TEF: epc.ac.uk/wp-content/upl…

Here are some of our key concerns and points made...
On #StudentOutcomes...

🔺We are concerned the proposals will damage access. This is important to the EPC as a greater diversity of engineers is good for those who enter the profession, good for engineering and good for society.
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🔺Contrary to the aim of raising standards, the proposals may lead to grade inflation.
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🔺Rather than raising educational standards through incentives based on outcomes, the need for outcomes may become an excuse for admitting the students who need education least to get good outcomes. This would drive down standards.
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🔺The proposals are incompatible with the forward-looking and flexible model of HE envisaged by the government in its proposals for the Lifelong Loan Entitlement. As such, the proposals are not fit for the future.
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🔺The proposals will duplicate or sometimes be at odds with other regulatory frameworks for certain courses, such as Engineering which is subject to strict regulations for accreditation.
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🔺The proposal estimate the value of higher education too narrowly.
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🔺The proposals will damage efforts to diversify engineering, particularly in terms of gender balance, but other characteristics too.
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🔺By using a poor proxy measure for educational quality, rather than attempting to measure learning gain, the proposals value outcomes that are beyond universities' direct control over the standard of the education provided.
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🔺By seeking to penalise universities for offering courses with supposedly poor outcomes, the proposals may inadvertently make courses with good outcomes, such as Engineering, less viable.
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🔺The proposals may discourage educational innovation.
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🔺The proposals create incentives in opposition to the government's mission to level up. This is a policy area where higher education – and Engineering, in particular – can effect real change, but only if they are not penalised for doing so.
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The EPC calls on @officestudents to abandon its regulation plans for student outcomes and instead to adopt measures of 'learning gain' and 'value added' as a baseline for high-quality higher education.
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Many of the same concerns also relate to the #TEF proposals, along with some others...

🔺Given the proposals for student outcomes baselines, it is not clear what distinctive purpose TEF serves in spotlighting teaching excellence.
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🔺We are unconvinced that a system of badges is a sufficiently nuanced representation of an institution's reputation, which should be viewed in terms of good and bad, but in terms of having a reputation FOR something. The proposals are too reductive to achieve that.
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🔺The proposals for TEF are not likely to improve its previous poor record of usefully informing student choice. In order to be informative it would need to be more granular, but a more detailed TEF would be less appealing and therefore less useful.
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🔺There's a similar inherent contradiction in the proposed periodic cycle of the TEF exercise: in order to be useful it needs to be frequent, but in order for its useful to come close to the burden involved, it needs to be infrequent.
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🔺The 3-band Gold, Silver, Bronze approach to TEF is unhelpfully heuristic. That is to say, a TEF band does not provide anyone with good information, but rather the band is used *instead of* good information.
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🔺The proposed fourth band – "requires improvement" – serves no positive purpose as it undermines reputation without providing any information about what improvement might be required.
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🔺This is particularly damaging as the TEF band will be institution-wide, even when an institution may have pockets of excellence whose staff, students and graduates will be unjustly tarred with the same brush of inadequacy.
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🔺By failing to represent the experience of international students properly, the TEF exercise will misrepresent excellence in certain parts of the sector – such as Engineering courses, in particular, where they comprise an especially significant proportion of students.
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🔺We are concerned that the proposals will further undermine foundation years – a critical pathway to access and successful student outcomes, particularly in Engineering. This is especially troubling when foundation year funding is under threat from government proposals.
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🔺Student insights is important, but they need the framework to provide points of reference so they can be comparative and useful.
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🔺We are concerned that the proposals both for TEF and student outcomes will be unfair to smaller specialist providers in Engineering and other disciplines.
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On both consultations, the EPC was clear that using learning gain would give a more direct and useful measure of educational quality – both baselines and excellence – incentivising desired outcomes rather than unintended consequences.
Learning gain is not easy to measure, but as the hundreds of pages of these consultations demonstrate, @officestudents has not found an easier or better alternative.

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