Richard Harrison, writing on Wonkhe, recently presented a good reminder of the “quality wars”  as they reignited in the mid-2010s. As he notes though, David Watson in coining the phrase, was referring to the battles during the 1990s involving the sector, the Quality Assurance Agency (the QAA) and the Higher Education Funding Council for England (HEFCE) about the shape of quality assurance which should operate. We should stress at this point (notwithstanding the new OfS advice on content warnings) that no-one was actually physically harmed in this war or any of the skirmishes which followed.  The only damage inflicted was on good sense and rationality.

This all stemmed from the bringing together of the established and public sector strands of UK higher education sector following the 1992 Further and Higher Education Act. Although there was, in principle, a unified HE structure after that point, it took many more years, and a great deal of argument, to establish a joined-up approach to quality assurance. But that settlement did not last and there are still major fractures in the regime as Harrison sets out.

One particular incident he picks out is the departure of the Quality Assurance Agency as Designated Quality Body in 2023 and the decision by the Office for Students to take on the assessment of quality itself. I recently proposed that it was time to redesignate QAA as the DQB in order to address, among other things, the excessive regulatory burden the current structure entails. It’s fair to say that this proposal has yet to progress.

Anyway, it seems as good a time as any to explore one particular campaign during the quality wars of the 1990s, the origins, establishment and work of the Joint Planning Group (JPG) in seeking to bring together two separate systems of quality assurance. The JPG played a small but significant part in the history of quality assurance in UK higher education. It is now nearly 30 years since the JPG undertook its work and it does seem as if we are living in a different version of the problematic quality landscape the JPG was established to address. In that context, it seems appropriate, if not timely, to look back at this group and its recommendations which led to the establishment of the QAA and set the direction which led to the current unsatisfactory quality assurance regime.

The differing traditions of the CNAA and the established universities

The UK higher education sector’s current quality assurance architecture has its origins in two quite different traditions. One is the public sector model of the Council for National Academic Awards (CNAA) which oversaw the former polytechnics from 1964 through to its abolition in 1993. The other is the much more internally-focused and largely tacit model of the established universities. Both traditions operated the very long-standing external control mechanism of external examining which, perhaps surprisingly given the huge changes which have taken place in higher education over the last century, can be seen as a continuous system, developed and refined over the years but still not that far removed from its original purposes. 

It is striking that, after decades of little change, in the decade after 1990 the established universities moved from a position where only the most minimal formal quality assurance processes were evident to one where their systems resembled those of the late period of CNAA regulation of the polytechnics.

Historically, the established universities depended, implicitly and explicitly, on the ability, professionalism and integrity of academic staff, supplemented by the external examiner system, to assure the quality of provision. In the case of the CNAA sector, the raft of external controls was the primary vehicle but the self-criticality of the academic community was also seen as a vital component. As CNAA began to relax its controls in the late 1980s the established universities began to put in place procedures and processes which edged them towards the CNAA model. Beyond the 1986 Reynolds guidelines which were the first such substantive gesture, the Committee of Vice-Chancellors and Principals (CVCP, since renamed Universities UK) established the Academic Audit Unit (AAU) in 1990. The AAU was not about seeking convergence but represented a belated and, as it proved, inadequate attempt to head off anticipated Government intervention.

But Academic Audit, which operated under the auspices of the CVCP, must have seemed too collegial, relaxed, cosy and far too consensual for Government. The reports of Audit visits were not published and there did not appear to be anything, beyond the most modest peer pressure, which was actually holding universities to account for the quality of provision. 

Moreover, only a third of universities had been visited by the AAU under the first round of Audits by the time of the 1992 Act and very few reports produced. It is debatable whether anything the CVCP could have done, even assuming it had managed to achieve consensus for a much firmer quality set-up, would have averted the inspectorial thrust of the 1992 Act. Government at that time was perhaps disinclined to accept anything the universities proposed themselves, probably believing they had had it too free and easy for too long.

Ending the divide: The 1992 Further and Higher Education Act

The 1992 Act wrought fundamental change, abolishing the CNAA and allowing the polytechnics to rename themselves universities and to award their own degrees. The Act also created Teaching Quality Assessment (TQA) under the auspices of the funding councils, placing them under a statutory obligation to ‘secure that provision is made for assessing the quality of education’ and led to the separate establishment of the Higher Education Quality Council (HEQC), putting some distance between the CVCP and the quality assurance function of Audit and enshrining a modest degree of independence from the universities.

The introduction of TQA, which was to have such a profound impact on universities in the decade which followed, was based on the somewhat simplistic notion that the only way to test the quality of provision is to observe the teaching of courses. The funding councils chose to interpret the Act as requiring the councils themselves to undertake assessment and to do so on a subject by subject basis and delivered a mechanism at the polar opposite of the cosy consensualism of Audit. 

The 1992 Act, therefore, resulted in an enforced convergence of external quality assurance systems for the public and established university sectors. From very different traditions, which had been edging closer together during the mid-80s to the beginning of the 1990s – with the polytechnics gaining greater autonomy and the established universities introducing some CNAA-style systems – the newly unified sector now had the same external framework. 

Parallel developments

Following the introduction of Audit in 1991 and TQA in 1992, both evolved throughout the 1990s. Why did the sector continue with Audit following the introduction of TQA and subject itself to this additional quality mechanism? Some at the time argued that the universities should simply abolish Audit because it had not served its purpose of preventing assessment and that retaining it represented an unnecessary additional burden. However, because of the case made by the CVCP and others, the process of Audit was, ultimately, retained.

Therefore, both Audit and TQA continued despite the overlaps and additional burden a dual system presented. Audit evolved into Continuation Audit and spawned Overseas Audits and Collaborative Audits too. TQA became Quality Assessment and then evolved into Subject Review from 1995. This amended model also entailed universal rather than selective visits, a reduced emphasis on direct observation of teaching and a much greater stress on documentary evidence.

It took several years of running this dual, overlapping and burdensome system before the first moves were made to bring them together under a single organisation. They were, eventually, taken on together under the QAA in late 1996 following protracted consideration by the JPG.

The Joint Planning Group – not actually that memorable

The story of the JPG is notable for its length, for the efforts invested to deliver such a modest outcome and for the lack of influence by the universities on the final result.

The JPG process effectively started on 2 December 1994 (although the JPG itself was not formed for nearly another 12 months) when the Secretary of State for Education, addressing the CVCP, reported that she had invited HEFCE to develop proposals to bring together Quality Audit and Quality Assessment: ‘preferably [my emphasis] a way forward which has been agreed with representative bodies in higher education’. Nearly two years later, commenting on the Joint Planning Group’s draft final report, the (successor) Secretary of State stated that her initial reaction was that the proposals ‘provide a basis for effective and efficient quality assurance arrangements in higher education’.

Circulars and skirmishes

In April 1995 Tim Boswell (then Minister for HE) issued an invitation to CVCP to reconsider its earlier (1994) proposals for quality assurance. He believed that the separate processes of Audit and Assessment would continue unless such proposals were developed further. The very next day, HEFCE published Circular Letter 20/95, a discussion document prepared following discussions with representatives of CVCP and SCOP in the previous December and February.  The circular included a covering letter from Graeme Davies of HEFCE in which he referred to the options put forward in the document for a new single system. It was observed that alternatives, whilst welcome, would need to be tested against the requirements for quality assurance as defined by the Secretary of State, Gillian Shepherd, in her speech to the CVCP on 2 December 2004. As Shepherd put it quality assurance:

must respect academic autonomy while having an external element. It must respect academic diversity and freedom while at the same time addressing value for money and public accountability. It should encourage the enhancement of quality and the dissemination of good practice. Last but not least, it should be cost-effective and avoid unreasonable burdens on institutions.

The main part of the HEFCE document set out these requirements which had a strong emphasis on the demand for accountability in various forms (but did acknowledge a need for institutional autonomy). Davies also stressed that HEFCE was ‘not engaged in a formal consultation with the sector’ on these proposals. 

On 24 April 1995, Kenneth Edwards responded to Davies on behalf of CVCP offering an amplification of the previous framework as requested.  The emphasis in the proposals was on (rather vaguely articulated) internally generated reviews and the paper sought to minimise the impact of quality assessment and show how self-regulation with some external input could meet all the ‘requirements for quality assurance’ specified by HEFCE and the Government. 

On 17 May 1995, the Higher Education Quality Council (HEQC) circulated a paper which set out certain principles and functions of a single body which could meet ‘not only the interests of external stakeholders but also those of the academic community’ (with the emphasis very much on the latter).

It was already too late though. The terms of the debate were entirely driven by circular letter 20/95 and HEQC was bypassed as became evident when CVCP and HEFCE issued a joint press release reporting ‘further progress…on agreeing proposals for the future arrangements for quality assurance’ at a meeting on 23 May.  The release also reported that HEFCE Council on 17 May agreed that proposals in Kenneth Edwards’ letter of 24 April ‘provided a basis for further discussions’.

A Process of Quality Assurance (a different PQA)

In early June 1995, HEFCE submitted a report to the Secretary of State setting out proposals for an integrated ‘Process of Quality Assurance’ (PQA), the essential features of which were:

• an end to Quality Audit
• the evolution of organisation – a Joint Planning Group to be established by HEFCE by October 1996
• assessments would be conducted under the PQA from 1998
• responsibilities to be transferred to new Quality Assurance Agency by 2000-01.

A CVCP note of 12 June 1995 contained an extract from minutes of one of its Committees which noted a wide range of concerns about the HEFCE proposals and agreed to stand by CVCP’s (extremely vague) May 1995 position. 

The Secretary of State (21 June 1995) wrote asking for CVCP’s views on the HEFCE proposals and the implications for HEQC’s non-Audit activities. Responding, CVCP expressed its concerns about the model and submitted its own proposals. Meanwhile, HEQC had published its own proposals for a single system. Two months later (21 September 1995) the Secretary of State’s reply to Gareth Roberts welcomed the CVCP’s response in ‘building on the proposals offered earlier by the HEFCE’, stated that the ‘proposals form the basis for an agreed solution’, and that a Joint Planning Group should be established as soon as possible. However, this was qualified by the assertion that the funding councils must exercise their statutory responsibilities in respect of quality assessment – ‘I could not contemplate a solution which relied mainly on self-regulation.’ In essence the Secretary of State was actually rejecting CVCP’s concerns in favour of the original HEFCE proposals whilst stressing the compatibility of positions which were, in fact, quite different.

The Joint Planning Group is launched

Six weeks later a letter was sent by the Secretary of State (9 November 1995) confirming that he was happy to accept the CVCP and HEFCE proposal that Sir William Kerr Fraser would chair the JPG. The CVCP’s press release on this issue claimed, somewhat surprisingly, that the proposals for the JPG were developed from the CVCP line.

The membership of the JPG included five vice-chancellors and principals together with funding council representatives (all, to a man, men). The terms of reference included the following aim:

3  The aim of the group will be to develop in detail proposals for a new Agency submitted to the Secretary of State for Education and Employment on 20 July, and to produce an agreed implementation plan. The primary function of the new Agency will be to provide a service for assuring the quality of higher education and the standards of programmes and awards for HE institutions in England, Northern Ireland and Wales, and if appropriate, HE institutions in Scotland. The aim is to start the new Agency by January.

4  To achieve this the group will need to:

draw up the specifications for an integrated quality assurance process which will supersede the current audit and assessment processes carried out by HEFCE’s and HEFCW’s QAD and HEQC, address issues concerning educational standards and the enhancement of teaching and learning, and ensure the availability of appropriate public reports;

10 months later, after an interim report and much consultation, the draft final report of the JPG was produced. It essentially recommended the continuation of Assessment and Audit under different names and by a single agency.  Some modifications to Assessment processes were proposed but there was nothing here which deviated in any significant way from the original HEFCE proposals except for the retention of Audit.  The method would apply in England only and the non-Audit activities of HEQC would be included in the single agency’s remit.

From TQA and Audit to, er, TQA and Audit

The establishment of Academic Audit in 1990 represented the sector’s attempt to deal with quality and accountability but this was simply not enough for the Government. The failure of the sector to adequately address accountability demands led to Teaching Quality Assessment, which rapidly came to dominate the discourse.  Looking at the JPG final report, it started with Assessment and Audit and ended up with Assessment and Audit. HEFCE, in its June 1995 report to the Secretary of State, proposed an assessment driven system which disposed of Audit. The concessions achieved by the sector throughout this whole process were, at best, modest and comprised: the retention of Audit, the retention of the non-Audit work of HEQC, greater institutional say in the timetable of Assessments and membership of Assessment teams. Not a great result.

The grounds for the JPG debate set by HEFCE in Circular 20/95 laid down the Government’s requirements and described these as the criteria for quality assurance. These fundamental assumptions were never really challenged by the sector and the CVCP throughout the period maintained its demands for self-regulation backed up by external inspection. HEQC published well-argued critiques of the HEFCE proposals and alternatives but, as with the CVCP ideas, it had already missed the boat. Whilst it could be argued that the sector has consistently failed adequately to address the demands for accountability, in attempting to promote self-regulation as the solution it has demonstrated that it had not learned the lessons of the failure to prevent TQA. Consequently we ended up with a botched compromise which retained the major elements of the Assessment and Audit regimes and a new, more remote body to administer them. The claim that HEFCE, the JPG and CVCP had delivered something new and streamlined rang rather hollow.

Overall the outcome of the JPG process showed the strength and determination of HEFCE and Government and the inadequacies of the sector’s response. The dominance of accountability mechanisms over self-regulation and quality enhancement can be attributed at least in part to the failure of the sector to address demands for any accountability until it was too late. This is a lesson worth learning.

A lasting ceasefire?

Following the establishment of the QAA and the reshaping of its JPG-set agenda after the Dearing recommendations, it would be several further years before the first components of the new regime began to be introduced in 2002. In the years that followed the QAA developed into an organisation which was, it is not unfair to say, pretty much wholly unloved by the sector it regulated.

Over the past decade though the QAA has changed from being the target of sector ire to a much-liked and well-respected partner in the quality domain and the OfS now seems to be filling the slot the QAA previously occupied as unloved regulator.

The regulatory landscape is now fragmented more across national boundaries in the UK and has grown in breadth and depth in England since the Higher Education Research Act in 2017. It does need major surgery to get it into a position where it actually delivers what is required for all stakeholders whilst reducing the excessive and ever-growing burden on HE institutions. We don’t want to repeat the failed regulatory compromises of the JPG of three decades ago but we do need a bold approach to delivering the right level of accountability, maintaining institutional autonomy and significantly cutting the bureaucratic burden

You can find the much longer version of this piece covering as originally published in 2016 on Wonkhe here.