Higher education: audit of providers website information provision

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1 Which? Investigation Higher education: audit of providers website information provision Summary With undergraduate higher education fees averaging 8,900 a year in 2015/16 and students overall average debt totalling over 45,000, the decision whether to go to university is the most significant financial decision many young people will take. Prospective and current students are protected by consumer protection legislation, including the Consumer Protection from Unfair Trading Regulations 2008 (CPRs) and the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (CCRs). In March 2015, the Competition and Markets Authority (CMA) published advice on consumer protection law to higher education providers. The advice included direction on the information which should be given to prospective students in order for providers to meet their legal obligations under the CPRs and the CCRs. Which? has undertaken a review of the information that providers are making available to prospective students applying for the 2016/17 academic year on their websites, in order to assess the extent to which providers are complying with their legal obligations. We found that over three in four universities in our sample are breaching the law by not providing or making easily accessible all the necessary information on their websites for prospective students such as information about fees, how students will be assessed, and the contact hours that students will have with staff. These failures to comply with consumer law were found in the same month that UCAS applications opened for entry, and five months after publication of the CMA s advice. Within our sample of 50 universities we found that: Nearly two-thirds (64%) of providers failed to provide updated information about tuition fees on their website. 38 providers (76%) are breaching the law by failing to provide at least one piece of material information; No provider is uniformly adopting good practice in relation to information provision across all categories of information; Three providers are consistently adopting unlawful practice by failing to provide approximately 30% of the material information required; Only one in four providers (24%) are meeting the minimum requirements in the CMA s advice across all categories of information; There are elements of best practice adopted across universities but it is often not applied consistently as an approach to information provision. The CMA s advice makes clear that the non-provision of any material information is unlawful under the CPRs and/or CCRs. Each university breaching the rules should alter their practices immediately. Good information is critical in empowering prospective students to make an informed choice. In addition, transparency of information helps drive competition between institutions and ensures that regulators and others are able to use it to hold the sector to account. In a survey conducted

2 between March and April of students due to start university in the 2015/16 academic year, over a fifth (22%) of applicants said the research process was not straightforward and that course content was one of the most important factors when making their choice of university (77%). Students must have access to information on a number of points in order to make an informed choice on where and what to study. The CMA s advice states that this should include the number and type of contact hours a student should expect during the course, the core modules that will be taught, the methods of assessment, the level of qualifications of the staff that will deliver the course, the location, and whether the course is accredited so that they may pursue a career in their chosen field. Our survey 1, conducted between March and April 2015, shows that the majority of students (75%) use the university website or prospectus to make their first and insurance choices. Without access to up-to-date material information before confirming their university choices with UCAS for 2016 entry it is possible that some prospective students have not been able to make a fully informed decision about their course choice. Our report into the higher education market A degree of value published in November 2014, found that 58% of all students surveyed reported experiencing a change to their course, such as a change to the course content, the location that the course was being taught, or an increase in fees, where a third (35%) of those students felt the change to their course was not fair. Students need to be fully informed about their course before applying in order to assess whether the course structure is suitable and worth their significant investment, but also to ensure that the course advertised is what they will receive while at university. Providing detailed information about the course upfront does not prohibit higher education providers from making necessary adjustments to a course. Flexibility is rightly given to providers to update teaching tools or make changes to subject-related theory and practice to the benefit of students. However the CMA s advice makes clear that this should not greatly vary the course as advertised and be restricted to minor and/or necessary adjustments that are unlikely to have a negative impact on students. In the event of an unavoidable detrimental change, students should be given clear information about the variations and afforded the right to change higher education providers. In recent months we have met and discussed progress with a number of university Vice-Chancellors and sector representatives. From our engagement with the sector it is clear that many universities have recognised the importance of compliance with the law and are committed to achieving this. We recognise that progress is being made by the sector and there are intentions to improve. Our research shows a snapshot of the information provided by the universities from a key point in the application process when prospective students are considering what course they may wish to study. Providers legal obligations The CPRs prohibit a number of unfair commercial practices, including providing information that is misleading (a misleading action ) or failing to provide material information that consumers need to make an informed decision (a misleading omission ). A misleading omission might occur where a trader fails to provide important information at all, or where that information is provided in a way that is unclear or ambiguous, or is provided too late to be of use. The CMA s advice makes it clear that a failure to provide material information that students need to make an informed decision about a course of higher education could constitute a misleading omission in breach of the CPRs. This applies at all stages of a provider s interaction with current or prospective students, including at the point where prospective students are researching the courses offered across the market via public sources, such as providers websites. The CMA s advice states that: When prospective students are considering which courses and HE [higher education] providers to apply to, you need to ensure that you comply with the CPRs by providing them with the material information they need to make informed decisions.

3 The CCRs also contains specific requirements in relation to the information that must be given to consumers before they enter into a contract. The CMA s advice makes it clear that, in the context of higher education, information required to be provided under the CCRs must be made available to students before they accept an offer of a place on a course. Once an offer is accepted, any precontractual information provided to the student pursuant to the CCRs becomes a binding term of the contract between the student and the provider. The CMA s advice sets out the types of information that will be material for students when choosing a course and which should therefore be available to students when researching or comparing courses. Review methodology We reviewed the website of each higher education provider in our sample between 14 and 25 September Courses reviewed In order to assess the information made available by providers against the information specified in the CMA s advice, we compared information on providers websites for one single course Psychology, in the 2016/2017 academic year - across 50 UK higher education institutions. We selected Psychology as indicative of a typical undergraduate degree. Psychology was in the top five most applied for courses for the academic year 2014/2015 according to official UCAS data, with over 106,000 applications made that year, and is widely provided by 123 higher education institutions in the UK. The information made available to prospective students of Psychology will therefore affect a wide pool of potential applicants. The higher education providers included in our assessment were: 22 higher education providers that we found adopting unlawful practice in our review of all higher education providers student terms and conditions in February 2014, and offered Psychology as an undergraduate course; and 28 additional higher education providers selected at random that offered Psychology as an undergraduate course. Categories of information tested In line with the CMA s advice, we assessed whether or not the following categories of information were available on providers websites: a. The entry requirements which students must meet to be eligible for the course; b. The core modules which students can expect to be taught; c. The number of contact hours which students can expect to have with university staff; d. The workload which a student could expect the course to involve; e. The teaching qualifications of the university staff delivering the teaching; f. The manner in which students could expect to be assessed i.e. exams or coursework, or a combination of both; g. The award which students could expect to receive upon completion of their course; h. Where the course is taught; i. How long the course will last; j. Whether or not the course is accredited (in relation to Psychology, it is expected that courses would be accredited by the British Psychological Society). k. The fees which students could expect to pay; and l. Any extra costs (in addition to fees) which students may have to pay to complete the course. Review approach

4 We reviewed the website of each higher education provider in our sample. As a starting point, we looked at the course page for Psychology, which was usually accessible via a course finder tool of some kind. If certain material information was not present, we then looked at additional pages of the provider s website. Specifically, we also looked at: Webpages or downloadable documents signposted on the course page as containing material information; Course guides signposted on the course page; School of Psychology or Department of Psychology pages; Specific pages relevant to particular material information: i. For fees, we looked at pages specifically devoted to the provider s fees; and ii. For course location, we looked at general pages relating to life at that institution, such as Campus Life, Student Life and About the University. Where information was not found on one of these areas of the website, we considered the information to be omitted from the website for the purposes of the CMA s advice and the CPRs. It is reasonable to expect that material information about a particular course would be found in one of the above areas, as students could not be expected to know that they should look outside those areas for important supplementary information. Each provider was then assessed in relation to the quality of information provision across each category of material information. For each category of information, the provider was given one of three ratings: 1. Unlawful. This rating was applied where we considered the provider to have failed to meet the requirements specified in the CMA s advice for compliance with the CPRs and (where relevant) the CCRs. 2. Poor practice. This rating was applied in cases where it was at least arguable that sufficient information had been provided to meet the requirements in the CMA s advice, but that more could be done to make the position clearer for students. For example, this grade was applied where the information was ambiguous, given without any explanation or context, or significantly less useful than information provided by other providers in the market. 3. Good practice. This rating was applied where the information provided not only met the minimum standards set out in the CMA s advice, but was complete, coherent and easily located. A more detailed guide to how this grading system was applied for each category of information is set out in Annex 1. Main findings We identified 257 (43%) pieces of the information audited that fell into our unlawful and poor practice categories of assessment. The full results of our research can be found broken down by the numbers of universities within each rating category, by category of information (Annex 2), and the rating of each category of information by university (Annex 3). In particular, we identified specific trends for certain categories of information where a higher proportion of universities were falling short, which we believe could cause particular problems for prospective students when researching courses. 1. Course fees for 2016/17 not provided. Despite our review taking place when prospective students for the 2016/17 academic year would be researching courses, we found that just under two thirds (64%) of providers had not updated the information about fees on their website for the 2016/17 academic year, or did not make it clear to students whether or not the website had been updated. The level of fees payable for a course will be a significant

5 factor in a student s decision-making process and this information should therefore be up-todate and unambiguous. Universities which fell into the unlawful category for failing to provide updated course fee information Anglia Ruskin University Southampton Solent University Bath Spa University University of Bedfordshire Birmingham City University University of Bolton Bishop Grosseteste University University of Cambridge Buckinghamshire New University University of Central Lancashire Canterbury Christ Church University University of Chichester Cardiff Metropolitan University University of Huddersfield Glasgow Caledonian University University of St Andrews King s College London University of Sunderland Kingston University University of West England (Bristol) Liverpool John Moores University University of Westminster London South Bank University University of Winchester Middlesex University University of Wolverhampton Newman University University of Worcester Plymouth University University of York Queen Margaret University York St John University 2. Extra costs. Four in five providers websites did not state or provide enough clarity on whether students would incur any compulsory extra costs for participating in the course over and above the course fees. For the purposes of our review, we have assumed that where no extra costs are specified on the website then no extra costs will apply (and thus we have not rated a failure to specify whether additional costs apply as unlawful ). However, where information about additional fees is entirely absent it is difficult for students to determine whether that is due to an omission on the part of the provider or whether in fact no additional fees will be incurred. In our view, good practice requires that providers inform students that no additional fees will be payable where that is the case, so that students can accurately make comparisons between courses. Universities were categorised as unlawful if the possibility of extra costs on some courses were mentioned in generic fee information but failed to provide clarity on whether the extra costs would be incurred for this particular course. Four universities which fell into this category were Canterbury Christchurch University, Glasgow Caledonian University, Loughborough University and London South Bank University. This is important for prospective students to be aware of all costs for the duration of the course and be able to arrange the appropriate financing, particularly when it is stated that costs will not be covered by standard student finance arrangements. An example of unlawful practice: Some courses include field trips, additional teaching sessions and registration to an external body. These need to be paid for separately and are not covered by the Student Loans Company either by tuition fee Grant or Loan." (London South Bank University). 3. Information provided via a Unistats link to KIS data without additional context. The Higher Education Funding Council for England (HEFCE) collates information about courses across higher education institutions in the Key Information Set (KIS), which is makes available via the Unistats dataset and website. Providers are required by HEFCE to display this information on individual course webpages via a widget, containing a rotating display which links to further information on the Unistats website.

6 We consider there to be a number of difficulties with this approach, for example: The display scrolls through a series of different types of information. If a student is not looking at the display when certain material information is presented, they are unlikely to realise that it is available. Canterbury Christ Church University provided a link to the HEFCE website which was broken. This is particularly concerning when a university is relying on the widget to provide material information for the course. Plymouth University provided the link at the bottom of the course page below other banners that contained advertising or other immaterial information, despite HEFCE advice stating that there should be no break in content before the widget that would discourage the user from scrolling. In most cases, the link was provided without any explanation of what the KIS is or how it can be helpful for students. While a display linking to further information on the Unistats website could be helpful to students, it should be used in a way that is complementary to, and not a substitute for, expressly setting out material information on the provider s website in areas where a student is likely to see it. Regardless of HEFCE s requirements, it is the responsibility of providers to ensure that they are providing material information as set out in the CMA s advice and meeting their obligations under the CPRs. As such, universities were categorised as following poor practice where the Unistats widget was displayed without contextual information on how to use the KIS data. 4. Indicators of quality. 47 out of 50 universities were categorised as following poor or unlawful practice for failing to provide one or more pieces of information that are indicators of quality for the course, or demonstrating over-reliance on the HEFCE widget to provide this information. This amounts to 71% of information on quality of the course across all universities in the sample not being provided to students. This includes information detailing contact hours (number and type), expected workload, level of qualifications of staff delivering and methods of assessment. The poorest performers in these categories were University of Stirling and University of Huddersfield, which failed to provide information on three out of four indicators of quality of the course. Examples of good practice Whilst no provider consistently provided good practice across all areas, we found a number of providers employing practices that we would encourage all providers across the sector to adopt. Universities that more consistently demonstrated good practice across a number of areas were Leeds Trinity University and University of Greenwich. Examples of good practice in each category of information are set out below. 1. Entry requirements: University of Bristol provides a clearly presented table of entry requirements for all types (A level, Welsh Bacc, EB, language requirements) and provides well-signposted links to more entry information directly below. 2. Core modules: University of Greenwich clearly presents information in a dedicated course content tab on the main course page, with each module listed within full-time and part-time study sections. Further information is provided on linked individual module pages, including: module code, academic level, number of credits for the module, designated school, name of course coordinator, full specification of module (aims, learning outcomes, content, activity, detailed assessment info including weighting).

7 3. Contact hours: Coventry University provides the number and type of contact hours with detail of expected minimum amount/description of a typical teaching week. Additional details on optional office hours with tutors are also provided. Information is well presented and easy to find, with clear titles and signposting. It provides prospective students with a good picture of overall contact hours for the course to expect. 4. Expected workload: University of Cambridge provides details of expected workload on the course page including what a typical day will look like for a student on the course. University of Greenwich provides a breakdown of hours for lectures, seminars and guided independent study on the main course page. 5. Staff delivering: London South Bank University lists all staff on the main course page, including details of their name, job title, and department on the course page, with a direct link to individual biographies that include what areas/modules they teach on the course. Leeds Trinity University lists programme coordinators within individual module pages with a direct link to full biographies, which includes information on level of qualifications. This is particularly good practice as some students may choose a course based on the experience of certain experts in the field. 6. Assessment: University of Greenwich includes comprehensive detail on assessment types within module descriptions on the course page with details of weightings towards module grades. This is easy to understand and locate. University of Sunderland provides details of assessment against each module in a table in the programme specification document, which is linked from the course page. 7. Award upon completion: It is most easy to understand and locate the award upon completion when it is included in the course title - BSc (Hons) Psychology. The majority of universities provide information in this format. 8. Location of course: Kingston University provides the location of the course with a Google map widget on the main course page. 9. Length of course: University of Portsmouth provides information on the length of the course for full-time, part-time and an optional sandwich year for work placement/study abroad years clearly on the course page, with the use of icons and included in its Key Facts section. 10. Accreditation: Details of accreditation should be stated clearly on the course page with a link to the accreditation body. The majority of universities in the sample follow this practice. 11. Fees: University of Portsmouth provides fee information for UK/EU/Channel Islands and Isle of Man, and International students for year of entry 2015/16 and 2016/17 on the main course page. It also states that tuition fees may be subject to an annual increase, with a link to the fees terms and conditions to explain how fee increases are calculated in clear and simple language. 12. Extra costs: University of Coventry provides a list of any additional costs under a clear heading 'No hidden extras' on the main course page, with a link to the University s No hidden extras policy which is presented in a clear and simple format. Southampton Solent University includes graduation costs on the main course page. University of West England includes details of extra costs alongside fees information on the main course page. For more information,

8 contact Neena Bhati on or OCTOBER YouthSight, on behalf of Which?, interviewed 992 applicants (due to start university in September 2015), online between 27th March and 2nd April Data were weighted to be representative of the applicant demographic.

9 Annex 1 Grading of categories of information CATEGORY OF INFORMATION Entry requirements GRADING Good Practice Poor practice Unlawful Entry requirements are easy to find and tells the student what they need to know. Information can be provided by A-level grade requirements and/or other relevant qualifications required, or by a UCAS points total. Entry requirements are not easy to find for example because the information is buried within long paragraphs, the formatting of the page is unhelpful or the information is otherwise provided in an unclear way. However, the information is present and it does tell the student what they need to know. Entry requirements are not given or confirmed for Core modules Core modules are listed and a description of each module is given. The information is easy to find and tells the student what they need to know. Core modules are listed, but either: there are no details given as to the content of each module; and/or the information is not easy to find for example because the information is buried within long paragraphs, the formatting of the page is unhelpful or the information is otherwise provided in an unclear way. Core modules are not given. Contact hours Contact hours and type are provided. We are of the view that contact hours may be given as a percentage of a student s time, broken down on an annual basis, so long as this is clear. For example, if a course page clearly states that the course is full-time, that 24% of a student s time in Year 1 is spent in tutorials, 25% in lectures and the remainder in independent study, the information will fall into this category. Contact hours are available, but: this information is only provided via a small rotating panel containing a link to the relevant HEFCE data without context; or the information is not easy to find for example because the information is buried within long paragraphs, the formatting of the page is unhelpful or the information is otherwise provided in an unclear way. Contact hours are not provided.

10 However, the information is present and it does tell the student what they need to know. Expected workload Expected workload is detailed with expected self-study time per credit, module or course. Ratio of independent study to time in lectures is provided, but: this information is only provided via a small rotating panel containing a link to the relevant HEFCE data without context; or the information is not easy to find for example because the information is buried within long paragraphs, the formatting of the page is unhelpful or the information is otherwise provided in an unclear way. There is no indication of the workload required. However, the information is present and it does tell the student what they need to know. Qualifications of teaching staff The qualifications of teaching staff are stated clearly, including in a department staff directory, which is clearly signposted with information about which aspect of the course they will teach. The information is easy to find and tells the student what they need to know. The qualifications of teaching staff are stated, but: the information is buried within long paragraphs, the formatting of the page is unhelpful or the information is otherwise provided in an unclear way; or staff names and/or profiles are given but it is not clear who teaches which area; or some staff profiles are given but these are not all teaching staff; or there is a vague statement about staff which does not mention their specific The qualifications of the teaching staff are not given. Information is only provided through a wider staff directory, and it is not easy to locate department staff. We are of the view that it is not acceptable to give only generic descriptions of teaching staff, such as that they are leaders in their fields or research experts, in isolation.

11 qualifications. Assessment The way in which students are assessed (i.e. coursework, exams etc.) is stated clearly. This information is broken down at least by year but can also be broken down further, such as between modules. Details of assessment types are available, but: this information is only provided via a small rotating panel containing a link to the relevant HEFCE data without context; or the information is not easy to find for example because the information is buried within long paragraphs, the formatting of the page is unhelpful or the information is otherwise provided in an unclear way. There is no information as to how students will be assessed. We are of the view that it is not acceptable to give assessment information averaged over a whole course or make a vague statement such as students will be assessed by combination of coursework and exams. However, the information is present and it does tell the student what they need to know. Award The award which students will obtain at the end of their course is stated clearly. The award is not easy to find for example because the information is buried within long paragraphs, the formatting of the page is unhelpful or the information is otherwise provided in an unclear way. Information as to the award which a student will obtain on completing the course is not given. However, the information is present and it does tell the student what they need to know. Location The location at which the course is taught is stated clearly, including on another applicable general page, such as Campus, Student Life, About the University. Course location is not easy to find for example because the information is buried within long paragraphs, the formatting of the page is unhelpful, the information is otherwise provided in an unclear way. However, the information is present and it does tell the student what they need to know. It is not clear whether or not there is more than one The location at which the course is taught is not given. As above, if the information is present on the university website but it is not contained on a page where the student could reasonably be expected to look for this information, it will be classified as not present for the purposes of this review.

12 campus and a location for the course is not provided. Length The length of the course is stated clearly. Course length is not easy to find - for example because the information is buried within long paragraphs, the formatting of the page is unhelpful, or the information is otherwise provided in an unclear way. The length of the course is not given. However, the information is present or is clear from the context. Accredited Whether or not the course is accredited by the British Psychological Society is stated clearly. Accreditation is not easy to find - for example because the information is buried within long paragraphs, the formatting of the page is unhelpful, or the information is otherwise provided in an unclear way. Whether or not the course is accredited is not stated. However, the information is present and it does tell the student what they need to know. Fees Fees which students will have to pay for the course are stated clearly, including on a specific fees page. Clearly states any future fee increases and how this will be calculated. If the information is on a specific fees page, then that page is linked to the course page. Fees are not easy to find - for example because the information is buried within long paragraphs, the formatting of the page is unhelpful, or the information is otherwise provided in an unclear way. However, the information is present and it does tell the student what they need to know. Where it is not clear which year the fees relate to, the university will fall into this category. Fees are not stated. We are of the view that it is not enough to provide details of fees for the 2015/2016 academic year, but not the 2016/2017 academic year. Where universities provide only fees for the 2015/2016 academic year only, they will fall into this category. Where it is not stated that there will be a fee increase on a course page or fees page but there is a yes answer to a fee increase by inflation on the Unistats link, universities will fall into this category. Extra costs Whether or not students The university does not The university mentions

13 will have to pay any costs in addition to their fees is stated clearly, including on a specific fees page. make clear whether students will incur any compulsory extra costs for participating on the course. the possibility of extra costs on some courses in generic fee information but does not specify what the extra costs will be for the particular course.

14 Annex 2 Table of results numbers of universities within each rating category, by category of information. Category of information Good practice Poor practice Unlawful Entry requirements Core modules Contact hours (number and type) Expected workload Staff delivering Assessment Award upon completion Location of course Length of course Accreditation information Fees Details on extra costs

15 Annex 3 Table of results - rating of each category by university University Entry requirements Core modules Contact hours - Number/type Expected workload Staff delivering Assessment Award upon Completion Location of course Length of course Accreditation information Fees Details on extra costs Leeds Trinity University University of Greenwich Aston University University of Oxford University of Portsmouth University of Roehampton Liverpool Hope University London Metropolitan University University of Bristol University of Leeds Cardiff University University of Leicester Bath Spa University University of Bolton Coventry University University of Central Lancashire University of Sunderland

16 University Entry requirements Core modules Contact hours - Number/type Expected workload Staff delivering Assessment Award upon Completion Location of course Length of course Accreditation information Fees Details on extra costs Loughborough University University of Sheffield Anglia Ruskin University Middlesex University University of Worcester York St John University Southampton Solent University University of Cambridge University of York Birmingham City University Cardiff Metropolitan University Liverpool John Moores University Queen Margaret University Queen's University Belfast University of Bedfordshire University of Chichester University of Westminster University of Winchester

17 University Entry requirements Core modules Contact hours - Number/type Expected workload Staff delivering Assessment Award upon Completion Location of course Length of course Accreditation information Fees Details on extra costs University of West England (Bristol) London South Bank University Buckinghamshire New University Bishop Grosseteste University King s College London Kingston University Plymouth University University of Wolverhampton Newman University University of Reading University of Stirling University of St Andrews University of Huddersfield Glasgow Caledonian University Canterbury Christ Church University