---
layout: post
title: "HE Green Paper: response to question 7"
categories: [HE, green paper, politics]
tags: [HE, green paper, politics]
published: True

---

This post is part of an [ongoing series](https://martineve.com/GreenPaper/) where I intend to develop my full _personal_ (_not_ institutional) response to the HE Green Paper. Comments are welcome to refine this.

The Green Paper asks in Question 7:

> How can we minimise any administrative burdens on institutions? Please provide any evidence relating to the potential administrative costs and benefits to institutions of the proposals set out in this document.

Provisional response:

There is no central system of audit that can be administratively and financially free of costs. Indeed, in order to compete institutions will likely spend a great deal of their valuable time and resources optimising their TEF submissions and trying to "game" the system. I here present the case that the proposed system will likely cost the sector around £50m per year.

By way of evidence, consider the following. Firstly, the Green Paper states that "Costs have been estimated at £246 million for REF2014, of which £232 million were costs to the higher education sector". There is no reason to suspect that it will be easier to measure and appraise teaching than to measure and appraise research, so the costs and administrative burden will likely be similar. If anything, the challenge is far harder and requires more of the kind of contextual and narrative work that is seen in the "impact" portion of REF (which is decried as expensive in Chapter 2 of the Green Paper). Indeed, the Paper states that "we recognise that these metrics [proposed for TEF] are largely proxies rather than direct measures of quality and learning gain and there are issues around how robust they are. To balance this we propose that the TEF assessment will consider institutional evidence, setting out their evidence for their excellent teaching". "Institutional evidence" is both _vital_ in this context (there are no "direct measures of quality and learning gain") but also _expensive_. To coordinate a cross-institutional portfolio of narrative evidence that contextualises the findings in a robust manner will be very hard work.

By contrast, using a purely metricised system would certainly reduce administrative burdens and costs for institutions. But it would also be perverse, damaging and unacceptable. The Green Paper itself acknowledges that there are "issues around how robust" such metrics are and to pursue this would be entirely detrimental to the reputation of the UK's HE sector. Furthermore, the recent independent review of the use of metrics in research, chaired by James Wilsdon, demonstrated just how large these "issues" loom in research. They will be equally, if not more, problematic in measuring teaching since the outward facing elements of practice here are not "on the record" as they are for research.

In short: to measure teaching quality requires narrative evidence to be presented alongside quantitative data. Neither will suffice on its own. To coordinate this type of portfolio in a high-stakes audit exercise underpinned by financial and reputational motivation will incentivize institutions to take on substantial administrative burdens and staffing costs (which some institutions can afford, while other new institutions cannot). I see no evidence that this will cost less to institutions than REF, which was estimated at £232 million for the sector over a five year period (£46.4m per year). The proposed Teaching Excellence Framework is a big-State intervention that will massively increase red tape, administrative overhead and will waste precious resources at a time of scarcity. It is surprising that a Conservative government would pursue such strategies when deregulation is such a core part of other areas of the Green Paper.