HEA response to QAA consultation on the UK Quality Code for Higher Education: Chapter B3, Learning & Teaching
NB- this response will be submitted through online survey.
General questions
1.Name
Ceredig Jamieson-Ball
2. Provider/Organisation name
The Higher Education Academy
3. Are you responding to the consultation as:
On behalf of your provider/organisation
4. Which of the following best describes your role:
From an HE sector body (not a civil servant)
5. Does the content of this Chapter adequately reflect its title?
No
The challenge with learning and teaching is that it could be considered to embrace everything in the Quality Code –revising the title to ‘teaching and supporting learningthrough all modes of study’ might provide a slightly tighter focus?
In addition, and more importantly, the HEA believes that this chapter fails to fully recognise the relevance, importance and status of the ‘UK Professional Standards Framework for teaching and supporting learning in higher education’ (UK PSF) as the only framework for learning and teaching in UK higher education which is owned by UUK, Guild HE, the four funding councils and the National Union of Students.
6. Is this Chapter sensitive to the diversity of higher education providers, higher education students, and modes of learning?
No
The introductory section clearly outlines the scope in terms of diversity of mode and student – i.e. it sets out the inclusivity of the chapter. Page two states that ‘this Chapter applies to students at all academic levels covered by Chapter A1: The national level 5 of the Quality Code’. It would be helpful to explicitly mention therefore that this chapter refers to undergraduate, postgraduate taught and postgraduate research students asthere is no explicit mention of this throughout the Chapter.
The HEA is concerned that the chapter does not effectively reflect the diverse nature of the UK higher education sector in that it fails to adequately acknowledge and address differences between HE provided in the four nations of the UK and differences in HE in FE.
7. This Chapter will replace the Code of practice for the assurance of academic quality and standards in higher education (the Code of practice) Section 2: Collaborative provision and flexible and distributed learning (including e-learning) (2010), Part B: Aspects specific to flexible and distributed learning, and the Code of practice, Section 9: Work-based and placement learning (2007). Does it adequately capture the content of these two documents?
No
The HEA does not believe that it is helpful to present the Learning and Teaching Chapter as replacing other sections. Of course there are synergies between the content of this new Chapter and other previoussections of the Code of Practice so some cross referencing is helpful but ultimately this is a new chapter and the HEA believes it should be presented as such. The inclusive approach, as outlined in the introduction and referred to in the previous question, does however address areas covered by the stated sections of the Code – see also comment in relation to question 15.
Expectation
8. Do you agree with the wording of the Expectation for this Chapter?
The HEA believes that the expectation is bland and is not sufficiently aspirational. It would benefit by being extended to include ‘achievement of the learning programme’ and ‘enable every student to achieve their potential’.
Suggested alternative:
‘Higher education providers, working in partnership with their students, create and systematically review and enhance learning environments and teaching practices to provide opportunities for every student to achieve their full potential in their chosen programme through active, engaged and independent learning.’
Indicators 1 to 4
Indicator 1: Higher education providers articulate, implement and monitor a strategic approach to learning and teaching, and promote a shared understanding of that approach among all their staff and students.
Indicator 2: The design of learning and teaching activities provides every student with an equal opportunity to monitor their progress towards and achieve the intended learning outcomes.
Indicator 3: An understanding of the learning process informs learning and teaching practices, which use evidence-informed approaches derived from the outcomes of research, scholarship and the evaluation of professional practices.
Indicator 4: Information is collected, analysed and used to assure and enhance learning and teaching activities and the learning and teaching environment. The questions below relate to these four Indicators.
9. Do you agree with the wording of these Indicators?
No
In relation to the wording of these indicators, the HEA suggests the following amendments:
- Strengthen Indicator 1 by adding ‘all’ before ‘learning and teaching’.
- Indicator 2, add ‘and delivery’ after ‘design’ as without it the HEA believes this indicator is too limited. This change would also need to be reflected in the accompanying explanatory text.
- Indicator 3 – the wording of this indicator is confusing as there appears to be duplication in having both ‘evidence-informed’ and ‘outcomes of research’. The HEA suggests deleting ‘evidence-informed’.
10. We would like to expand the explanatory text accompanying these Indicators. This could include adding signposts to further information (see Indicator text boxes for examples).Do you have any suggestions for additional explanatory text or signposts to further information it may be helpful to include?
The HEA recognises the fundamental importance of ‘Themes which cross subject and discipline boundaries’ and fully supports the development of such key graduate attributes, however, it believes that this section, as written, is confusing and does not clearly relate to Indicator 2. Furthermore, listing only a few ‘themes’ is selective and may result in the Chapter failing to stand the test of time. The HEA therefore suggests that ‘inter-disciplinary’ and ‘cross-disciplinary’ are added to the final bullet on Page 6 that also relates to the ‘planning and design of learning and teaching activities’. This bullet would read: ‘provide effective teaching of subject-specific, inter-disciplinary, cross disciplinary, transferable, practical and professional skills.’ Examples to illustrate each of these areas could then be provided within the explanatory notes or as footnotes.
The HEA strongly suggests that explicit reference be madeto the UK PSFwithin the explanatory text for Indicator 3. The Framework, developed and owned by the sector, is widely recognised as an indication of sound practice. There should be both a general explanation of the Framework and reference to the fact that it is premised on a student focussed approach to learning and teaching, and to the critical underpinning of research and scholarship to L&T in HE. As well as clearly aligning with the focus of this indicator, explicit reference to the UK PSF would bring the Chapter in line with QAA’s ELIR3 guidance notes published in May 2012 for institutional reviews in Scotland (paragraph 7, External Reference Points).
Indicators 5-7
Indicator 5: Students are supported to understand their responsibility to engage with the learning opportunities provided.
Indicator 6: Every student has opportunities to engage with feedback to further their development as an active and independent learner.
Indicator 7: Students receive clear information that specifies the opportunities for learning available to them; this information is monitored, reviewed and evaluated by students and staff working in partnership.
11. Do you agree with the wording of these Indicators?
No
- Indicator 5 should be reworded to read ‘students are enabled’ rather than ‘students are supported’.
- Indicator 6 – It is not entirely clear whether the engagement is both receiving and providing – or is feedback defined in a glossary? As with the expectation, the HEA strongly believes that this indicator needs to go further and therefore suggests the addition of ‘and to achieve their learning aims’ at the end of the indicator.
- Indicator 7 – There appears to be some overlap with indicator 4 and it is not clear whether different kinds of information are being referred to in these indicators.
12. We would like to expand the explanatory text accompanying these Indicators. This could include adding signposts to further information (see Indicator text boxes for examples). Do you have any suggestions for additional explanatory text or signposts to further information it may be helpful to include?
No.
Indicators 8-10
Indicator 8: Staff involved in teaching and supporting student learning are qualified, supported, and adequately resourced. Indicator 9: Higher education providers assure themselves that for every student both the physical and virtual environments they provide are safe, accessible, reliable and usable and that their use is characterised by dignity, courtesy and respect. Indicator 10: Accessible, adequate and appropriate resources are provided to support the learning of every student. The questions below relate to these three Indicators.
13. Do you agree with the wording of these Indicators?
No
Indicator 8 – The HEA suggests adding ‘appropriately’ before qualified and believes that ‘adequately resourced’ is weak and as an alternative suggests ‘appropriately qualified and well supported by systems and resources’.
Indicator 9 – The HEA suggests a slight rephrase to ‘Higher education providers ensure that they provide every student with safe, accessible, reliable and usable physical and virtual environments and that their use is characterised by dignity, courtesy and respect’.
Indicator 10 – The HEA suggests omitting ‘adequate’ and questions whether ‘resources’ should be more explicit and refer to ‘learning resources’.
14. We would like to expand the explanatory text accompanying these Indicators. This could include adding signposts to further information (see Indicator text boxes for examples). Do you have any suggestions for additional explanatory text or signposts to further information it may be helpful to include?
In relation to Indicator 8, sound practice would indicate a much stronger focus in the explanatory text for the UK PSF. The UK PSF is the sector’s professional development framework which embraces the professional development and readiness for all staff who teach and support student HE learning in the UK and should be highlighted as such. Institutions can demonstrate the way they support all staff to ensure that they are qualified to teach by using the Framework as a reference or benchmark. The framework addresses the four bullet points at the beginning of the explanatory text. Making reference to the Framework here as a critical element of the indicator will provide coherence between the Quality Code and the UK PSF which the HEA firmly believes can only be of benefit to the sector.
The HEA is concerned that the current sections about the UK PSF and the Institute for Learning (IfL) give the inaccurate and inappropriate impression that they are both of equal relevance to HE staff. Their particular relevance should be made more explicit. In order to future proof this section of the Chapter, consideration should be given to the Lingfield review of Professionalism in Further Education and its implications for the IfL.
Further comments
15. Do the Indicators of sound practice in this Chapter adequately set out what a provider might do to meet the Chapter Expectation? Are any aspects missing?
The HEA believes that the monitoring of field, practice and placement learning opportunities is a significant omission from the indicators.
16. Do you agree with the order in which the Indicators have been arranged?
The HEA believes that indicator 8 more logically follows indicator 3. This would place the two indicators with a staff focus together and provide a stronger focus of the importance of staff in teaching and supporting student learning.
17. Please use this space for any further comments on the Chapter. There is NO word limit for this question.
As currently presented the draft chapter puts a strong emphasis on student learning. Whilst the HEA believes that, overall, this appropriately reflects the current climate in HE, the HEA would prefer the role of ‘teaching’ in this chapter to have a little more space. This could be achieved by reordering the indicators (as suggested in question 16) and through giving greater prominence to the UK PSF.
The HEA suggests that more references to the work of the HEA and associated resources be included in the signposts to further information, particularly for Indicators 2 and 3. The HEA has a wealth of resources that support institutions in relation to these indicators which are available at
Further references in relation to indicators 8-10: The HEA suggests the inclusion of references to the AUA and to HEA resources in relation to the reward, recognition and promotion of teaching staff as well as the UK PSF.
The HEA has a range of resources that are relevant to Indicator 9. These are available at . The HEA suggests including a reference to JISC TechDis in the list of ‘Further information and addition references’ given their role in supporting the sector in the use of technology for inclusion ( A further reference could be made to the Equality Challenge Unit (
The HEA would be happy to continue a dialogue with the authors to identify further specific HEA resources that may be relevant to this chapter.