Concerns about standards and quality in higher education AA Hamilton College Ltd, April 2015 Introduction and background 1 The Department for Business, Innovation & Skills (BIS) sent to the Quality Assurance Agency for Higher Education (QAA) information about AA Hamilton College Ltd (the College) by a person who wished to remain anonymous. 2 The anonymous informant alleged that: student assignments are 'manufactured' by the College in return for payments of ' 100 [per] assignment' students' 'attendance is less than 10 per cent' at the College; sometimes proxies attend on their behalf; and the College confirms attendance for students who are not present documents required for the awarding body's standard verification visits, and QAA review, are 'manufactured' by a 'specialist'. 3 On the basis of this information, QAA initiated an investigation in line with the procedures of its Concerns Scheme. Following an initial inquiry QAA launched a full investigation into the allegations and also reserved the right to investigate any other matters regarding the management of academic quality and standards which came to its attention during the course of the investigation. The investigation process 4 The QAA concerns team made three visits to the College, on 25 November 2014, 8 December 2014 and 19 January 2015. The team comprised Alan Hunt (investigating officer and reviewer), Professor Peter Bush (reviewer), and Ms Siobhain O'Mahony (notes and documentary analysis). Ms Hayley Burns replaced Ms O'Mahony for the first and third visits to the College. 5 The concerns team, at its first visit on 25 November 2014, met students, teaching staff and senior managers. Due to the scale and complexity of the investigation, two further visits took place on 8 December 2014 and 19 January 2015. At the 8 December visit the team met a further group of students and read documentary evidence; on 19 January it read additional documents and met twice with senior managers. Findings 6 The concerns team concluded that there was no evidence to support the original allegations. However, the team identified a number of significant weaknesses and areas of risk for the College's management of academic quality and standards. 1
Governance and management functions at the College 7 The concerns team found that distinctions between governance and management at the College are not always clear. Some senior staff had multiple roles and job titles which made it difficult to be clear where responsibility rests, and did not demonstrably assure an appropriate separation between commercial and academic matters. The concerns team concluded that there was a lack of clarity around key roles and responsibilities for the academic management of the College. clearly distinguish, define and unambiguously document the respective responsibilities and levels of authority of its institutional governance and management. Deliberative bodies: the College's committees 8 The concerns team found that minutes of the main academic committees were mainly brief and general in nature. They frequently reported little content of academic discussions, nor the evidence on which decisions were made. For example, some minutes of the Academic Committee were limited in scope and unclear; they contained inaccuracies and were not reviewed at subsequent meetings. A meeting of the Assessment Board in September 2014 received and confirmed students' assessment results for 2013-14, but the minutes recorded no discussion of these results. The team concluded that the operation and minuting of some key committees fell short of accepted professional standards. ensure that all committee minutes are comprehensive, clear and accurate, and definitively reflect decisions, recommendations and key points from discussions, together with reports on actions from previous meetings, to ensure that the committee practice and minutes meet accepted professional standards. Student admissions 9 The concerns team found that some students had been admitted without clearly documented evidence that they have met the College's entry requirements for the HND Business, and thus without a demonstrable basis of confidence that they are able to complete their HND programmes. Indeed, records of student performance suggest that many are unable to perform at the required academic level. There is also insufficient documented evidence of a consistently rigorous and well-documented English testing procedure for applicants. 10 The concerns team has considered these matters in relation to the UK Quality Code for Higher Education (the Quality Code), Chapter B2: Recruitment, Selection and Admission to Higher Education. The Expectation of this Chapter is that 'Recruitment, selection and admission policies and procedures adhere to the principles of fair admission'. These principles include a statement that 'a fair admissions system should enable higher education providers to select students who are able to complete the programme as judged by their achievements and their potential'. The team concluded that the College does not meet the Expectation of Chapter B2. 2
review and clearly document procedures for recruiting and admitting students, and clearly document their implementation for all applicants, so as to provide unambiguous evidence that all students admitted are appropriately qualified to study at higher education level, in English. Information provided for students and prospective students 11 The concerns team found that all information provided for prospective and current students is produced by 'a designated person', who derives this information from the Principal and the Programme Leader. The College also makes contextualised use of material produced by Pearson, the awarding body. Students met by the concerns team said that information which they had seen on the website before entry, and other information such as handbooks supplied at induction, was accurate and helpful. Nevertheless, the concerns team found significant inaccuracies in the information provided for prospective HND students including information about study location, intake points during the academic year and discrepancies between the College's website and information leaflets, sometimes undated, provided for students. The concerns team concluded that the information provided by the College for prospective students does not meet the Expectation of the Quality Code, Part C: Information about Higher Education Provision. ensure that all information provided for prospective students is comprehensive and accurate, and is regularly monitored and updated, to avoid any risk of prospective students being misled and/or disadvantaged. Student attendance 12 The concerns team found that the College has made some progress in the monitoring of attendance. However, overall policy and practice for the management of student attendance are not clearly documented in relation to each other. Senior managers and teaching staff did not give consistent accounts of the policies. Some information the College provides to students on attendance requirements does not accurately reflect formal College policy: for example, there are inconsistencies between the College's formal Attendance Policy and what is communicated to students in the Student Handbook, Programme Handbook and induction guidance material as to the attendance threshold below which the College reports unsatisfactory attendance. The team also observed that total numbers of students reported to the Student Loans Company for non-attendance/ non-registration/withdrawal are high. s review and clearly document policy and practice for the management of student attendance, so that criteria for the identification and reporting of unsatisfactory attendance are transparently and consistently defined, publicised and applied develop and implement a strategy to reduce its high combined rates of non-attendance/non-registration/withdrawal. 3
Assessment of students 13 The Concerns team found that the College's management of student assessment raises some significant issues. Assessment regulations are not always understood and used consistently. Assessment terminology is not always clearly defined and consistently applied. The system for setting assignments lacks clear academic and managerial direction. Policy for internal verification is not clear, consistent or well understood. The College requires a clearer and more coherent body of policy and procedure to address the broad area of academic malpractice effectively and consistently. Academic misconduct cases are not consistently addressed and documented by the College. 14 The concerns team found significant weakness in students' assessment performance which gave cause for particular concern. Many students progressed from year 1 to year 2 in September 2014 without meeting the College's formal requirement for progression. This in turn reinforces fundamental concerns about the ability of many AA Hamilton students to study effectively at higher education level, and to do so in English, and about the effective management of student recruitment and admissions. The College has not applied for any Pearson HNC or HND certifications since 2011-12: that is, no students have successfully completed an HNC or HND award at the College. 15 Taking account of these matters, the concerns team concludes that the College does not meet the Expectation of the Quality Code, Chapter B6: Assessment of Students and the Recognition of Prior Learning. s ensure that all regulations and procedures for assessment, and assessment-related areas, are clearly and consistently documented and understood by all relevant parties; that they are implemented scrupulously and rigorously; and all assessmentrelated committee business is clearly and consistently recorded. ensure that processes for setting assignments are consistently rigorous and subject to clear academic management ensure that policy for internal verification is clearly defined, documented and implemented develop, document and implement a clear and coherent body of policy and procedure to address the broad area of academic malpractice and misconduct effectively and consistently; and ensure that academic misconduct cases are consistently addressed and documented establish, disseminate and consistently implement a policy defining the nature and level of input which is covered by the term 'formative assessment', including specifically the number of times an assignment draft can be submitted for discussion. Management of quality assurance 16 The concerns team found some of the College's quality assurance documentation to be unsatisfactory. For example, the current Quality Assurance Handbook has significant omissions and is not always clear. The Internal Verification Policy document sent to QAA in October was poorly presented, incomplete and inconsistent. Other policy documents contain unclear and potentially confusing material. There are disagreements between regulatory provisions in the Attendance Policy and what was recently described to the team as current practice. Policy documents and the Programme Handbook are not always in agreement with 4
each other. The team concluded that the College's quality assurance documentation is in a rudimentary stage of development which limits its effectiveness and does not demonstrate an effective institutional approach to quality assurance. develop and implement effective quality management mechanisms for the production of comprehensive and consistent quality assurance documentation which demonstrates an effective institutional approach to academic quality assurance. Conclusions and recommendations 17 Taking account of these matters, and noting the significant number of inconsistencies, inaccuracies and contradictions between and within documents, and between the written and oral evidence seen and heard by the team, QAA concludes that the College does not meet the expectations of the Quality Code: Chapter B2: Recruitment, Selection and Admission to Higher Education; Chapter B6: Assessment of Students and the Recognition of Prior Learning; and Part C: Information about Higher Education Provision. 18 In the light of the concern team's conclusions, QAA will carry out a full Higher Education Review (Plus) to ensure the recommendations in this report have been effectively addressed by the College as a matter of urgency. s clearly distinguish, define and unambiguously document the respective responsibilities and levels of authority of its institutional governance and management (paragraph 7) ensure that all committee minutes are comprehensive, clear and accurate, and definitively reflect decisions, recommendations and key points from discussions, together with reports on actions from previous meetings, to ensure that the committee practice and minutes meet accepted professional standards (paragraph 8) review and clearly document procedures for recruiting and admitting students, and clearly document their implementation for all applicants, so as to provide unambiguous evidence that all students admitted are appropriately qualified to study at higher education level, in English (paragraphs 9-10) ensure that all information provided for prospective students is comprehensive and accurate, and is regularly monitored and updated, to avoid any risk of prospective students being misled and/or disadvantaged (paragraph 11) review and clearly document policy and practice for the management of student attendance, so that criteria for the identification and reporting of unsatisfactory attendance are transparently and consistently defined, publicised and applied (paragraph 12) develop and implement a strategy to reduce its high combined rates of non-attendance/non-registration/withdrawal (paragraph 12) ensure that all regulations and procedures for assessment, and assessment-related areas, are clearly and consistently documented and understood by all relevant 5
parties; that they are implemented scrupulously and rigorously; and all assessmentrelated committee business is clearly and consistently recorded (paragraphs 13-15) ensure that processes for setting assignments are consistently rigorous and subject to clear academic management (paragraphs 13-15) ensure that policy for internal verification is clearly defined, documented and implemented (paragraphs 13-15) develop, document and implement a clear and coherent body of policy and procedure to address the broad area of academic malpractice and misconduct effectively and consistently; and ensure that academic misconduct cases are consistently addressed and documented (paragraphs 13-15) establish, disseminate and consistently implement a policy defining the nature and level of input which is covered by the term 'formative assessment', including specifically the number of times an assignment draft can be submitted for discussion (paragraphs 13-15) develop and implement effective quality management mechanisms for the production of comprehensive and consistent quality assurance documentation which demonstrates an effective institutional approach to academic quality assurance (paragraph 16) QAA1155 - R4508 - April 15 The Quality Assurance Agency for Higher Education 2015 Southgate House, Southgate Street, Gloucester GL1 1UB Tel: 01452 557 000 Email: enquiries@qaa.ac.uk Website: www.qaa.ac.uk Registered charity numbers 1062746 and SC037786 6