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Code of practice for the assurance of academic quality and standards in higher education

Section 2: Collaborative provision and flexible and distributed learning (including e-learning) - September 2004

Foreword

1 This document is a second edition of a code of practice for collaborative provision, and incorporates a revision of the Guidelines on the quality assurance of distance learning. It is one of a suite of inter-related documents which forms an overall Code of practice for the assurance of academic quality and standards in higher education (the Code) for the guidance of higher education institutions subscribing to the Quality Assurance Agency for Higher Education (the Agency).

2 The overall Code and its 10 constituent sections were originally prepared by the Agency between 1998 and 2001 in response to the Reports of the National Committee of Inquiry into Higher Education and its Scottish Committee (the Dearing and Garrick Reports). The Code supports the national arrangements within the UK for quality assurance in higher education. The Code identifies a comprehensive series of system-wide principles ('precepts') covering matters relating to the management of academic quality and standards in higher education. It provides an authoritative reference point for institutions as they consciously, actively and systematically assure the academic quality and standards of their programmes, awards and qualifications.

3 The Code assumes that, taking into account principles and practices agreed UK-wide, each institution has its own systems for independent verification both of its quality and standards and of the effectiveness of its quality assurance systems. In developing the Code, extensive advice has been sought from a range of knowledgeable practitioners.

4 The Code does not incorporate statutory requirements relating to relevant legislation, for example the Special Educational Needs and Disability Act 2001. It assumes that institutions have an overriding obligation in all such cases to ensure that they meet the requirements of legislation. However, where a section of the Code is related to legislative or similar obligations, efforts have been made to ensure compatibility between them.

5 Since 2001, a number of developments in UK higher education have encouraged the Agency to begin a revision of individual sections of the Code. In undertaking this task the Agency has also decided to review the structure of the sections and, in particular, to replace the original 'precepts and guidance' format with a 'precepts and explanation' approach, using the explanations to make clear why the precepts are considered important and reducing opportunities for a 'checklist' approach to the Code. In doing so the Agency has sought to meet recommendation 4 (part 4) of the Better Regulation Task Force in its report Higher Education: Easing the Burden, November 2003.

6 Revised sections of the Code are therefore now structured into a series of precepts and accompanying explanations. The precepts express key matters of principle that the higher education community has identified as important for the assurance of quality and academic standards. Individual institutions should be able to demonstrate they are addressing the matters tackled by the precepts effectively, through their own management and organisational processes, taking account of institutional needs, traditions, culture and decision-making. The accompanying explanations show why the precepts are important.

7 The Code is a statement of good practice that has been endorsed by the higher education community. As such it is useful in the Agency's audit and review processes that consider the extent to which an institution, in developing and implementing its own policies, has taken account of the Code and its precepts.

8 Institutions may find the explanations useful for developing their own policy and for allowing some flexibility of practice at subject level, depending on local needs. It is important to emphasise that the explanations do not form part of the Agency's expectations of institutional practice when Agency teams are conducting audits and reviews.

9 Academic staff in departments and schools do not necessarily need to be aware of the detail of the various sections of the Code, although they might well be expected to be familiar with the institutional policies it informs and any parts which are particularly relevant to their own responsibilities.

10 To assist users, the precepts are listed, without the accompanying explanations, in Appendix 1 to this section of the Code.

11 The first version of this section of the Code, and of the Guidelines on the quality assurance of distance learning, were published in 1999. The publication of this second version follows consultation with staff in institutions, who have helped to update the Code to take account of institutions' practical experience of using the guidance contained in its predecessor.

Introduction

12 This document is a code of good practice for the academic management of collaborative arrangements entered into by UK higher education institutions. It also serves as a code of good practice for the academic management of learning delivered, supported and/or assessed through flexible and distributed arrangements, whether in collaboration with a partner or not. Since many flexible and distributed arrangements are supported through information and communication technology (ICT), the term 'e-learning' will be used here to refer to modes of learning that are ICT-based.

Definitions used in this code

13 In this section of the Code, collaborative provision denotes educational provision leading to an award, or to specific credit toward an award, of an awarding institution delivered and/or supported and/or assessed through an arrangement with a partner organisation (see Glossary of terms, page 39). Flexible and distributed learning (FDL) denotes educational provision leading to an award, or to specific credit toward an award, of an awarding institution delivered and/or supported and/or assessed through means which generally do not require the student to attend particular classes or events at particular times and particular locations. Further discussion of the scope of FDL as interpreted within this section of the Code can be found in paragraphs 22 to 26 below.

14 The inclusion in these definitions of 'specific credit toward an award' has raised questions of the type 'how much specific credit is needed before this code is applied' to a particular collaborative or FDL arrangement. Such questions are for an institution itself to answer by using this section of the Code as a reference point against which to consider and test its own arrangements. There are no boundaries to the applicability of a particular section of the Code. Instead, the Agency wishes to emphasise that the Code as a whole should be regarded as a reference to widely agreed approaches to good practice in the relevant areas, not as a document specifying required compliance by institutions. What is important is that institutions should carefully consider whether and how a precept should be applied in their own particular circumstances, bearing in mind the explanation of the precept given in the Code. It is equally important that the precepts should then be used in a way that can provide the institution with justified confidence in the effectiveness of its management of the quality of its provision and the security of its academic standards.

Collaborative arrangements and FDL arrangements

15 This section of the Code is divided into two parts. Part A is concerned with the responsibilities of a UK higher education institution in respect of collaborative arrangements that lead to its academic awards. Where the precepts also apply to FDL arrangements, this is identified. Part B is concerned with particular aspects specific to the academic management of the delivery, support and assessment of FDL programmes, whether or not these involve a collaborative partner. The rationale for addressing both collaborative and FDL arrangements in this section of the Code is that they have many common features in the context of the management of quality and standards. In practice, FDL arrangements are often 'blended' (see below, paragraph 24) with more 'traditional' collaborative arrangements, so it is logical to consider their management as a whole. Nevertheless, the precepts that relate to FDL arrangements are intended to be used as reference points for the academic management of all FDL arrangements, not only those associated with collaborative arrangements.

16 This section of the Code is based on the key principle that collaborative and FDL provision, wherever and however organised, should widen learning opportunities without prejudice either to the academic standard of the award or the quality of what is offered to students. Further, the arrangements for assuring quality and standards should be as rigorous, secure and open to scrutiny as those for programmes provided wholly within the responsibility of a single institution and through 'conventional' class-based modes of teaching. The assurance of quality and standards in collaborative arrangements as well as in FDL arrangements creates particular challenges for awarding institutions in the management of the potential risks associated with the complexity of such arrangements. This section of the Code is intended to help institutions to manage these risks effectively, and to ensure that the quality of their collaborative provision and FDL provision, and the academic standard of the awards to which such provision lead, are adequately safeguarded.

17 UK HEIs' collaborative links encompass many types of organisation in the UK and overseas, are frequently complex, and often reflect the slow maturing of long-standing and successful partnerships. Over the years, levels of trust may have developed which might appear to render some of the more formal aspects of this section of the Code's precepts unnecessary. The best of these mature relationships are characterised by equity, integrity and honesty. Nevertheless, it is important to recognise that the formal responsibility of an awarding body for its awards and qualifications places upon it an obligation to make certain that its academic standards are secure. This does suggest a conscious formality in some aspects of the management of a collaborative relationship, which may sometimes seem to run counter to the notion of the equality of the partners. But the formality offers protection to all, students as well as collaborating organisations, and its adoption in this spirit should help to bolster, not undermine, mutual confidence in the operation of partnerships.

Outcomes vs. process

18 Part A is a revised version of Section 2 of the Code, first published in July 1999. The revision takes account of the development, since the earlier version, of the UK-wide Academic Infrastructure. In particular, references in the earlier version to the 'equivalence' of aspects of collaborative provision have largely been replaced by making use of the reference framework offered by the Academic Infrastructure. With this new approach, there is no longer a need to find ways of expressing the 'equivalence' of collaborative programmes to UK-wide expectations for quality of provision and academic standards of awards. This approach removes the need to categorise different types of collaborative arrangement by a type of process, such as 'franchise' or 'validation', or to refer to different types of collaborative relationships, such as 'accreditation' or 'articulation'. Overall, the revision may be characterised as moving from the 'process-based' style of the earlier version to a more 'outcome-based' approach. The focus now is on ends rather than means. Institutions that have made use of the earlier version in developing their quality assurance procedures will see that the basics remain in the content of the revised version but will, it is hoped, appreciate the flexibility now offered by the greater attention to outcomes.

19 That having been said, it would be a pity not to take the opportunity to consider 'equivalence' of learning opportunities when collaborative or FDL provision does have an equivalent 'home' programme leading to the same named award. In such cases, an institution could well find value in considering how the learning opportunities available to students compare between the collaborative or FDL provision and the 'home' provision. For example, in comparing the appropriateness of physical learning resources, the question to consider is not whether there are identical resources available to the two groups of students, but whether one group is being significantly disadvantaged in learning opportunities relative to the other (taking into account different learning contexts and environments). If so, this suggests that there could be a difference in 'process' that might impact upon equivalence of 'outcome' and should be investigated further.

Serial arrangements

20 A 'serial' arrangement is one in which an awarding institution enters into a collaborative arrangement with a partner organisation which, in turn, uses that arrangement as a basis for establishing collaborations of its own with third parties, but offering the awarding institution's awards. The Agency's experience in audits of collaborative provision leads it to believe that the safeguards offered by the precepts of Part A cannot be fully provided through serial arrangements that limit the awarding institution's ability to control the academic standards and quality of the provision which leads to its awards. If it is to discharge its awarding responsibility properly, and to be in a position to manage potential risk, an awarding institution should have an effective link, as described in precepts A19 and A20, to the assessment of the academic achievement of students on all programmes that lead to its awards. While this responsibility may be readily manageable through a direct relationship with a partner organisation, it becomes much more difficult once the chain of responsibility is extended. Serial arrangements can seriously jeopardise an awarding institution's ability to know what is being done in its name.

Language of study and assessment

21 Some awarding institutions choose to offer collaborative programmes in languages other than those in which they ordinarily work. While this may extend the range of students they can reach, it raises important questions about the capacity of an awarding institution to satisfy itself about the quality of the provision that leads to its awards. Similarly, assessment of students' work in a foreign language poses serious challenges to the ability of an institution to be in proper control of the academic standards of awards made in its name. Institutions which do permit assessment in languages other than those in which they ordinarily work will need to be confident that they have a continuing availability of external examiners who are both able to work easily in all the languages concerned and fully trained to perform their role effectively. Any intervention between the examiner(s) and the work produced by the student, such as language translation, introduces another level of risk in making reliable and valid judgments about student achievement. An awarding institution will need to be especially vigilant in ensuring that students are neither advantaged nor disadvantaged by the use of translations of assessed work 1.

Flexible and distributed learning

22 Much of Part B of this section of the Code is derived from the Agency's Guidelines on the quality assurance of distance learning, published in 1999. This revision has also taken account of the development of agreed reference points offered in the assurance of quality and academic standards by the Academic Infrastructure. It recognises that modes of learning that are capable of being flexible and distributed are neither confined to distance learning nor to ICT-based learning. The methodologies commonly referred to as 'distance learning' and 'e-learning' are therefore included within FDL in terms of the management of quality and standards. Again, the revision has moved from a process-based to an outcome-based approach.

23 'Flexible and distributed learning' is used here to characterise approaches to teaching, learning and assessment that:

  • do not require a student's place of study to be physically located within the institution (the awarding institution) whose academic award is being sought through successful completion of the programme of study;
  • do not assume that a student's programme of study is necessarily delivered directly by the awarding institution;
  • do not assume that a student is necessarily directly supported by staff of the awarding institution;
  • do not assume that a student is routinely working with other students; and
  • do not necessarily require assessment of a student's achievement to take place at the location of the awarding institution.

A continuum of arrangements

24 The variety of approaches represented by FDL in the UK and elsewhere is now considerable, and embraces a continuum of pedagogical opportunities. At one end of this continuum programme delivery, learner support and assessment are all provided directly by staff of the awarding institution at the awarding institution. The other end of this continuum could be represented by an individual 'distance-learner' who may have no direct contact with the awarding institution, its staff or other students, whose programme of study may be delivered through an organisation (the programme presenter) which is not the awarding institution, and whose support for learning may be available from an organisation (the support provider) which is part neither of the programme presenter nor the awarding institution. Between these extremes is a spectrum encompassing various FDL elements as part of on-campus study, and a range of forms of arrangements involving the awarding institution and, perhaps, support-providing and/or collaborating partner organisations. In addition, wherever located, the student might be engaged in learning, support and/or assessment which are ICT or internet based, in which case the learning element of the mode might be referred to as 'e-mode' learning. This suggests that it might be possible to envisage a space within which a student's experience of learning at any one time could be represented as a function of the size of the group of learners, the location of learning and the mode of learning.

Variety of approaches - mode and location of learning and size of groups

25 These levels of flexibility make it difficult, and not necessarily useful, to structure Part B of this section of the Code in a framework that reflects traditional organisational functions. Instead, Part B is structured from the viewpoint of a student experiencing an FDL programme, supplemented by consideration of the particular responsibilities of the awarding institution in the management of an FDL programme that leads to one of its academic awards. Part B is therefore grouped into three separable elements:

  • the delivery of an FDL programme of study;
  • the support of students as learners on that programme;
  • the security of academic standards of the award and assessment of the achievements of those students.

26 While Part B refers to a 'programme' of study, that is the whole teaching and learning structure that leads to a specific award, a student will frequently experience only elements of a programme - modules or units - approached through FDL methods. Again, readers are reminded that the purpose of this section of the Code is to provide a reference which can stimulate questions about academic management, in this case questions about provision that employs elements of FDL among other modes of learning. There is no 'volume of FDL' above which this section of the Code 'applies' and below which it does not. What is important is that consideration has been given to the applicability and relevance of the precepts to the provision in hand.

Part A: The responsibilities of an awarding institution in respect of collaborative arrangements that lead to its awards, and in respect of FDL arrangements where appropriate

Responsibility for, and equivalence of, academic standards

A1 The awarding institution is responsible for the academic standards of all awards granted in its name.

The legal power of a higher education institution in the UK to grant awards and qualifications carries with it a responsibility to ensure that the academic standards of all its awards and qualifications are consciously and carefully secured.

A2 The academic standards of all awards made under a collaborative arrangement should meet the expectations of the UK Academic Infrastructure. This applies equally to awards made as a result of FDL arrangements.

The UK's Academic Infrastructure provides a set of common reference points that enables comparable academic standards to be established in different higher education institutions, without jeopardising their autonomy and diversity. Explicit use of the Academic Infrastructure enables awarding institutions, their students, employers and the general public to have confidence that an award or qualification is of a standard recognised and acceptable within the UK.

The aims, learning outcomes, teaching, learning and assessment methods of a collaborative programme of study can be described in a 'programme specification' that shows how the programme content relates to relevant subject benchmark statements, and that the award is appropriately located within the relevant Framework for Higher Education Qualifications (FHEQ).

Because the awarding institution is a UK institution, and the award a UK award, it is appropriate to make reference to relevant UK subject benchmark statements. There may, however, be cases where the cultural context of an overseas collaboration requires some divergence from the UK-centred subject benchmark statement and, indeed, cases where points of reference other than UK references legitimately apply to cross-border collaborative and FDL arrangements. This may be entirely reasonable, as it might equally be reasonable in a collaboration within the UK, but such divergences can lead to misunderstandings if not explicitly acknowledged and explained. The programme specification provides a ready means for addressing these matters. Guidance on programme specifications may be found at http://www.qaa.ac.uk/crntwork/progspec/contents.htm

Policies, procedures and information

A3 Collaborative arrangements should be negotiated, agreed and managed in accordance with the formally stated policies and procedures of the awarding institution.

Collaborative arrangements that are firmly based on the commitment and support of both the awarding institution's and the partner organisation's central authorities reduce the risk of the arrangement foundering. By formally stating in writing the policies and procedures that underpin any arrangement, the chances of this happening will be minimised. See also below, precept A10.

A4 An up-to-date and authoritative record of the awarding institution's collaborative partnerships and agents, and a listing of its collaborative programmes operated through those partnerships or agencies, should form part of the institution's publicly available information. This also applies to FDL programmes where these warrant a separate identification.

A higher education institution's public credibility depends in part on its willingness to be open and informative about its activities. Collaborative activities carry risks and can be viewed with suspicion. Public confidence in the awarding institution and its collaborative provision will be enhanced if its activities are conducted openly. In the case of FDL provision, it may be unrealistic for an institution to list all of its programmes that involve some FDL elements, but where a programme is offered entirely or principally through an FDL arrangement, an institution might see merit in identifying it as such as part of its publicly available information.

A5 The awarding institution should inform any professional, statutory and regulatory body (PSRB), which has approved or recognised a programme that is the subject of a possible or actual collaborative arrangement, of its proposals and of any final agreements which involve the programme. This applies equally to programmes for which significant FDL arrangements are developed after the programme has been approved or recognised. In any case, the status of the programme in respect of PSRB recognition should be made clear to prospective students.

PSRBs sometimes limit their accreditation, approval or recognition of programmes or awards to particular modes or locations of delivery. On occasion the status of an award or programme delivered away from the awarding institution and/or through FDL arrangements may not be clear. It is very important that students or applicants are not misled, through accident or design, into thinking that a programme they are applying for, or are already pursuing, is accredited, approved or recognised, when this is not the case. A definitive ruling on this matter can be obtained from the relevant PSRB.

A6 The awarding institution's policies and procedures should ensure that there are adequate safeguards against financial or other temptations that might compromise academic standards or the quality of learning opportunities.

An awarding institution's arrangements with other organisations can on occasion create opportunities for corrupt practices and illegal financial transactions. If these are allowed to happen they inevitably degrade the value of an institution's awards and are likely to damage its own reputation and that of UK higher education more generally. They can also give rise to heavy legal costs. Financial considerations may also have a bearing on standards and quality in matters of recruitment and progression, and in policy and practice in resourcing. The introduction of safeguards against these opportunities occurring may therefore be seen as a basic requirement of any sound collaborative arrangement or FDL arrangement that involves third parties.

A7 Collaborative arrangements should be fully costed and should be accounted for accurately and fully. This applies equally to FDL arrangements.

The purpose of this precept is to remind awarding institutions that financial risks associated with collaborative or FDL arrangements can be considerable, especially if they provide an important element of an institution's income. It is incumbent on an institution to ensure both that its financial management arrangements are strong enough to manage the risks effectively, and that the financial arrangements themselves do not jeopardise the integrity of the academic standards and quality of the provision or the interests of students.

Institutions that are subject to the financial regulations of public funding bodies may find that there are specific requirements or limitations in respect of the use of publicly-provided resources for the purpose of collaborative arrangements and other similar activities. Likewise, institutions may be subject to statutory financial obligations in some foreign jurisdictions.

Selecting a partner organisation or agent

A8 The educational objectives of a partner organisation should be compatible with those of the awarding institution.

A relationship where educational objectives are well matched can enable both the partner organisation and the awarding institution to achieve developments and benefits that neither could gain alone. Equally, basic incompatibility of values, outlook, objectives and methods between partners can lead to an unsatisfactory relationship with serious adverse consequences for students, programmes and awards.

A9 An awarding institution should undertake, with due diligence, an investigation to satisfy itself about the good standing of a prospective partner or agent, and of their capacity to fulfil their designated role in the arrangement. This investigation should include the legal status of the prospective partner or agent, and its capacity in law to contract with the awarding institution.

There are a number of areas where experience has shown that due diligence enquiries are needed to ensure that a satisfactory relationship can be established with a reliable and effective partner. These include:

  • the public and legal standing of a prospective partner organisation or agent in their own country;
  • the standing of a prospective partner organisation or agent in the UK determined in the light of experience of other UK institutions and from public documents such as reports of the Agency and its predecessor bodies on collaborative arrangements with UK institutions;
  • the financial stability of a prospective partner organisation;
  • the ability of the prospective partner organisation to provide the human and material resources to operate the programme successfully;
  • the ability of the prospective partner organisation to provide an appropriate and safe working environment for students on the programme;
  • in the case of overseas collaborative or FDL arrangements, the ability of the awarding institution to operate within the legislative and cultural requirements of that overseas country and, at the same time, address the points of reference offered by the UK's Academic Infrastructure.

Written agreements with a partner organisation or agent

A10 There should be a written and legally binding agreement or contract setting out the rights and obligations of the parties and signed by the authorised representatives of the awarding institution and the partner organisation or agent.

Partnerships are more likely to succeed when all partners fully understand their rights and responsibilities. For this a written and legally binding agreement or contract is indispensable. Institutions will, of course, want to take advice from their legal advisers on the content of all agreements and contracts. The following list highlights some important matters which relate particularly to academic standards and quality and that may, with advantage, be borne in mind when considering the drafting of an agreement or contract for a collaborative partnership or an FDL arrangement that involves other parties:

  • the need to distinguish between those aspects of the arrangement that relate to the institutional-level relationship between the parties, and those aspects particular to the programme(s) of this collaborative arrangement;
  • clarification of the extent to which the agreement represents the approval of the partner organisation to engage in collaborative activity with the awarding institution and/or approval to deliver specific programmes leading to named awards;
  • the need to agree on the source and location of any published quality-related information that may be required, eg by a funding council;
  • the need to define the role, responsibilities and delegated powers of any agent in each arrangement;
  • the need to be secure in respect of matters relating to copyright and intellectual property rights;
  • specification of the role of external examiners in ensuring that the awarding institution can fulfil its responsibility for the academic standards of the awards;
  • termination and mediation provisions and financial arrangements to be followed if the arrangement ceases;
  • specification of the legal jurisdiction under which any disputes would be resolved;
  • inclusion of provisions to enable either institution to suspend or withdraw from the agreement if the other party fails to fulfil its obligations;
  • specification and adequacy of the residual obligations of both parties to students on termination of the collaborative arrangement, including the obligations of the awarding institution to enable students to complete their studies leading to the award;
  • the possibility of establishing a formal agreement of responsibilities between the student, the awarding institution and the collaborative partner(s).

The list is not meant to be exhaustive, but may be helpful as an aide-memoire.

A11 The agreement or contract should make clear that any 'serial' arrangement whereby the partner organisation offers approved collaborative and/or FDL provision elsewhere or assigns, through an arrangement of its own, powers delegated to it by the awarding institution, may be undertaken only with the express written permission of the awarding institution in each instance. The awarding institution is responsible for ensuring that it retains proper control of the academic standards of awards offered through any such arrangements (see also paragraph 20 of the Introduction).

'Serial' arrangements can severely curtail the ability of an awarding institution to ensure that the academic standards of awards made in its name are being safeguarded. The financial value of a UK higher education qualification can make the possibility of 'sub contracting' a programme to a commercial enterprise particularly attractive and it can be very difficult to unpick these arrangements once they have begun. The purpose of this precept is to alert awarding institutions to the potential risk if a partner organisation is authorised to offer an arrangement of its own that leads to an award of the awarding institution. The responsibility of an awarding institution to exercise effective control of awards made in its name is paramount, although it might choose to delegate some of its responsibility for the management of the quality of provision (see precept A12 below). A significant risk in serial arrangements is that the 'chain' of information is too long for the awarding institution to be in a position to have full confidence in its ability to control its academic standards effectively.

Assuring academic standards and the quality of programmes and awards

A12 The awarding institution is ultimately responsible for ensuring that the quality of learning opportunities offered through a collaborative arrangement is adequate to enable a student to achieve the academic standard required for its award. This applies equally to learning opportunities offered through FDL arrangements.

An awarding institution is responsible for assuring the quality of the learning opportunities of programmes that lead to its awards, but it might choose to delegate operational aspects of this responsibility to a partner organisation where it has confidence that the partner has the capacity to accept and discharge that responsibility. The purpose of this precept is to remind an awarding institution that it should be able to satisfy itself, and stakeholders, on a regular basis that any delegated responsibility is being properly discharged. An awarding institution needs to consider carefully the distinction between responsibility for some aspects of quality management, which it may choose to delegate, and responsibility for the security of the standard of the award, which remains with it at all times.

A13 An awarding institution that engages with another authorised awarding body jointly to provide a programme of study leading to a dual or joint academic award should be able to satisfy itself that it has the legal capacity to do so, and that the academic standard of the award, referenced to the FHEQ (the SCQF in Scotland), meets its own expectations, irrespective of the expectations of the partner awarding body.

Programmes of study that lead to dual awards involve the granting of separate awards by both partner organisations. The two awards are based on the same assessed student work, and an awarding institution will need to satisfy itself that it is content to make an award on this basis, and able to do so within its regulations. Despite the collaborative nature of the study, responsibility for each award, and its academic standard, remains with the body awarding it and cannot be shared between the partners. Because of this it is important that institutions are able to satisfy themselves that the standards and quality of their awards are not jeopardised by the arrangements they have entered into with partners.

Institutions offering dual awards through a credit-based structure will need to be alert to the consequences of each participating institution offering credit for the same piece of work, thereby potentially doubling the credit value (for transfer and accumulation purposes) of a module or unit that has been successfully completed.

Joint awards, where a single award is granted for successful completion of one programme of study offered collaboratively by two or more institutions, raise questions of the nature of the legal basis for pooling or combining powers to make awards. An awarding institution will need to satisfy itself that it has the legal and regulatory capacity to grant awards jointly with other organisations, especially where this involves pooling or combining powers granted within different legal jurisdictions.

A14 The scope, coverage and assessment strategy of a collaborative programme should be described in a programme specification that refers to relevant subject benchmark statements and the level of award, and that is readily available and comprehensible to stakeholders. This applies equally to programmes offered through FDL arrangements.

Students, potential students, employers and other stakeholders need to be able to satisfy themselves that awards obtained through collaborative or FDL arrangements are fully equivalent to other awards offered at a similar level by the same awarding body. To this end, reference via programme specifications to the relevant qualification descriptor and subject benchmark statement will provide useful information and a source of reassurance.

A15 The awarding institution should make appropriate use of the Code to ensure that all aspects of the Code relevant to the collaborative arrangement are addressed by itself and/or the partner organisation, and should make clear respective responsibilities of the awarding institution and a partner organisation in terms of addressing the precepts of the Code. This applies equally to FDL arrangements that involve other organisations.

The purpose of this precept is to emphasise that the Agency's Code offers a point of reference for the assurance of many aspects of the management of academic standards and quality of provision. In the case of provision offered through collaborative arrangements or FDL arrangements that involve partners, an awarding institution will wish to ensure that its partners have an explicit understanding of what is expected of them in terms of the reference points set out in the precepts of the Code.

A16 In the case of a collaborative or FDL arrangement with a partner organisation, or engagement with an agent, the awarding institution should be able to satisfy itself that the terms and conditions that were originally approved have been, and continue to be, met.

The purpose of this precept is to serve as a reminder that the existence of a written agreement is not in itself sufficient to ensure that its terms and conditions are being met effectively. Regular monitoring and review, at institutional or programme levels as appropriate to the original partnership agreement, or agreement with an agent, will help to confirm this. The frequency and nature of monitoring and review may be decided best by reference to 'fitness for purpose'.

A17 The awarding institution should be able to satisfy itself that staff engaged in delivering or supporting a collaborative programme are appropriately qualified for their role, and that a partner organisation has effective measures to monitor and assure the proficiency of such staff. This applies equally to staff engaged in delivering of supporting an FDL programme.

The quality of both teaching and other aspects of learning support is critically important for all students, irrespective of the mode of programme delivery. It is essential that students can rely on the quality of those who teach them and support their learning in other ways. The use of properly qualified staff, and the effective monitoring of their proficiency, are important aspects of an awarding institution's responsibility for assuring the standards and quality of its collaborative or FDL activities. Recognising that inexperienced staff are not necessarily properly qualified from the outset, this precept should be taken to include the responsibility of an awarding institution for ensuring that staff are properly trained and developed.

A18 The awarding institution should ensure that arrangements for admission to the collaborative or FDL programme take into account the precepts of Section 10 of the Agency's Code on Student recruitment and admissions (2001), or any successor document.

The quality of admission procedures is an important aspect of the overall quality of an institution's academic activities. Collaborative provision and FDL arrangements create particular requirements, especially in international contexts. Areas that may require particular care include:

  • entry requirements and academic prerequisites;
  • recognition of foreign qualifications and credits;
  • arrangements for the accreditation of prior learning and the assessment of prior experiential learning (AP[E]L);
  • language proficiency;
  • information about the status of students in relation to the awarding institution;
  • cultural assumptions about higher education learning methods.

Assessment requirements

A19 The awarding institution is responsible for ensuring that the outcomes of assessment for a programme provided under a collaborative or FDL arrangement meet the specified academic level of the award as defined in the FHEQ (or SCQF in Scotland), in the context of the relevant subject benchmark statement(s).

The FHEQ /SCQF, which has been adopted by higher education institutions in the UK, covers all academic provision, wherever and however offered. No distinction is made between provision offered directly by the awarding institution itself, on its own premises, and that offered through collaborative and FDL arrangements. To make sure that this uniformity is maintained, it is important that the assessment of students is carried out consistently, at the appropriate level for the award being assessed, and with appropriate reference to the relevant elements of the Academic Infrastructure - the FHEQ/SCQF and subject benchmark statements.

A20 The awarding institution should ensure that a partner organisation involved in the assessment of students understands and follows the requirements approved by the awarding institution for the conduct of assessments, which themselves should be referenced to Section 6 of the Agency's Code on Assessment of students (2000), or any successor document.

UK higher education institutions that have the power to grant their own academic awards are legally autonomous bodies and can exercise considerable discretion over their assessment practices. A partner body may have little knowledge at the outset of a relationship about the requirements that will be placed upon it in assuring the security of assessments and their effective conduct. In the case of overseas partners or agents, some of these requirements may be considered surprising or unusual in the local context. It is therefore very important that all involved in the assessment of students be given explicit information and briefing about processes, acceptable and non-acceptable practices and the conduct of assessment. It is particularly important that local custom and practice are not accepted where these may jeopardise the integrity of the assessment process or the consistency of its application across the awarding institution as a whole.

External examining

A21 External examining procedures for programmes offered through collaborative arrangements should be consistent with the awarding institution's normal practices. This applies equally to programmes offered through FDL arrangements.

The external examiner system is a defining characteristic of UK higher education and an indispensable way of allowing an awarding institution to be sure that its academic standards are both appropriate and being safeguarded. Consistency of application of external examination procedures in collaborative or FDL arrangements is a central element in maintaining standards and quality in those activities. Any departures from external examiners' normal activity should be thought through very carefully and at the highest level, in advance of their implementation, and accepted only where it is clear that standards and quality will not be jeopardised.

A22 The awarding institution must retain ultimate responsibility for the appointment and functions of external examiners. The recruitment and selection of external examiners should be referenced to Section 4 of the Agency's Code on External examining (2004), or any successor document.

The recruitment, selection and appointment of external examiners is one of the key ways in which an awarding institution exercises control over assessment practices and the academic standards of awards. Delegation of this activity to a partner may be appropriate in some circumstances, but only where the awarding institution is unequivocally satisfied of the partner's capacity to undertake the task in a fully responsible, reliable and consistent manner.

A23 External examiners of collaborative programmes must receive briefing and guidance approved by the awarding institution sufficient for them to fulfil their role effectively. This applies equally to FDL programmes.

Awarding institutions need to be satisfied that external examiners know exactly what is required of them and have sufficient expertise and experience to enable them to play their role effectively.

External examiners for collaborative and FDL activities should be expected to participate in briefing events provided by either the awarding institution or the partner organisation. The awarding institution should note in particular precept 8 of Section 4 of the Agency's Code on External examining (2004) that, '...external examiners must be properly prepared by the recruiting institution to ensure they understand and can fulfil their responsibilities'. In the case of FDL programmes, external examiners need to be in a position to appreciate the FDL environment in which they will be examining, and to understand any special circumstances relating to particular methods of assessment, such as on-line assessments, where different time zones might add another dimension of complexity.

Certificates and transcripts

A24 An awarding institution should ensure that:

  • it has sole authority for awarding certificates and transcripts relating to the programmes of study delivered through collaborative arrangements. This applies equally to programmes delivered through FDL arrangements;
  • the certificate and/or transcript records (a) the principal language of instruction where this was not English, and (b) the language of assessment if that was not English*. Where this information is recorded on the transcript only, the certificate should refer to the existence of the transcript;
  • subject to any overriding statutory or other legal provision in any relevant jurisdiction, the certificate and/or the transcript should record the name and location of any partner organisation engaged in delivery of the programme of study.

 

* except for awards for programmes or their elements relating to the study of a foreign language where the principal language of assessment is also the language of study.

* Reference in this section of the Code to 'foreign language' or a language that is 'not English' does not include programmes provided and assessed by Welsh institutions in the Welsh language.

Certificates and transcripts represent the main sources of verification of the granting of an award or qualification. They are extremely valuable documents and can be the subject of theft and forgery. The physical security of blank documents is therefore important, as is the authority to issue certificates and transcripts. The ultimate responsibility for the security and accuracy of certificates and transcripts has to lie with the body in whose name they are issued. If the awarding institution wishes to devolve responsibility to a partner organisation for issuing these documents, it should ensure that it has retained the means to exercise proper control over all certificates and transcripts that are issued in its name.

It is important that the information contained on a certificate or transcript should not omit anything that is needed for a full understanding of a student's achievement. The guidelines provided by UUK, SCOP and the Agency on the content of transcripts provides advice on this. The European Diploma Supplement may also be helpful as a guide to international good practice in this area. The principal language of study and/or assessment, where this is not English, is a key piece of information for those who need to refer to certificates and transcripts. Omission of this information is likely to mislead and in some countries may cause difficulties in the recognition of all awards from the awarding institution.

Information for students

A25 The minimum level of information that prospective and registered students should have about a collaborative programme is the programme specification approved by the awarding institution. This applies equally to an FDL programme.

Confidence in an awarding institution's standards and quality is in great measure dependent on the completeness and accuracy of the information available about them. The programme specification provides a ready way of providing this information. It should also offer prospective and registered students a clear and explicit statement of the nature of the programme and its relationship to national expectations about the academic standards and quality of the subject being studied and the award being sought.

A26 The information made available to prospective students and those registered on a collaborative programme should include information to students about the appropriate channels for particular concerns, complaints and appeals, making clear the channels through which they can contact the awarding institution directly. This applies equally for students registered on an FDL programme.

Awarding institutions acknowledge different levels of responsibility for students registered on collaborative or FDL programmes. It is important that all students and prospective students should understand the nature of their formal relationship with their awarding institution, and which organisation is responsible for which part of their learning experience. In the case of complaints and appeals, and to avoid confusion and unnecessary dissatisfaction, the awarding institution should ensure that their own responsibilities, and those of their partners, are clearly distinguished and advertised. See also Section 5 of the Agency's Code on Academic appeals and student complaints on academic matters (2000).

A27 The awarding institution should monitor regularly the information given by the partner organisation or agent to prospective students and those registered on a collaborative programme. This applies equally to students registered on an FDL programme.

Awarding institutions may find that, despite everyone's best efforts, information for students falls short of what is needed by them. A regular check on the information actually being provided, including user surveys, can help to ensure that it remains accurate, complete and up to date.

Publicity and marketing

A28 The awarding institution should ensure that it has effective control over the accuracy of all public information, publicity and promotional activity relating to its collaborative provision, and provision offered through FDL arrangements.

In the competitive world of higher education recruitment, especially in some overseas markets and through FDL arrangements, publicity and marketing assumes great importance. Information designed to attract potential applicants can, on occasion, be over enthusiastic in its desire to establish a competitive advantage. Unsustainable assertions and claims can readily mislead. This is to nobody's benefit as it only causes dissatisfaction and resentment. It can also give a false picture of UK higher education, with adverse consequences for its national and international reputation. Because of this it is important that an awarding institution take responsibility for information about programmes leading to its awards, particularly where the information is published by others on its behalf. The awarding institution should satisfy itself that this control is exercised consistently and fairly and that the public cannot reasonably be misled about the collaborative arrangement or about the nature and standing of the programmes and awards provided under the arrangement.

Part B: Aspects specific to flexible and distributed learning

Introduction

27 This section addresses the management of FDL provision in the context both of the awarding institution's students studying remotely, whether or not through a collaborative arrangement with a partner organisation, and of its students registered for study on its own campus. The delivery of an FDL programme of study to a student, the learning support available to the student and the assessment of the student's achievement might be carried out as discrete functions by the awarding institution, a programme presenter and a support provider, as separate bodies, and this section of the Code will make a distinction between delivery, support and assessment functions. Clearly, all these functions might also be carried out by the awarding institution alone, with, for example, an academic department of the institution in the role of both programme presenter and support provider, but even in this situation the terminology of separate functions draws attention to the need for absolute clarity in a student's - and an awarding institution's - understanding of the different dimensions of the learning opportunities offered through FDL.

E-learning

28 Recent developments in learning that uses information and communications technologies ('e-learning'), have given rise in some quarters to the belief that this approach requires an entirely separate and distinct form of quality assurance. While it is true that some technical aspects of e-modes of learning do require particular ways of meeting specific challenges, it is nonetheless also the case that most of the questions that need to be asked, and answered, about academic management are common to both e-learning and other FDL methods, and may be considered under the headings of delivery, support and assessment. The Agency has therefore decided not to prepare separate guidance on the quality assurance of e-learning, but has incorporated into this section of the Code some precepts and explanations that are the concern of e-learning alone, clearly identifying these instances where they occur in the text. In the case of some entirely technical aspects of the quality assurance of e-learning, reference is made to relevant British Standards Institute publications.

Delivery

29 Precepts B1 and B2 below are concerned with aspects of assuring the quality of the programme of study delivered to a student through an FDL arrangement. The precepts are couched in terms of a student's experience of study through FDL. They do not specify who is responsible for assuring particular aspects of quality of programme delivery. It is the responsibility of the awarding institution to specify the respective responsibilities of the programme presenter, support provider and itself in assuring quality of programme delivery, within the context of the awarding institution retaining ultimate responsibility for quality and standards.

B1 Students should have access to:

  • documents that set out the respective responsibilities of the awarding institution and the programme presenter for the delivery of an FDL programme or element of study;
  • descriptions of the component units or modules of an FDL programme or element of study, to show the intended learning outcomes and teaching, learning and assessment methods of the unit or module;
  • a clear schedule for the delivery of their study materials and for assessment of their work.

 

Students need information before they start their programme of study to enable them to make appropriate preparations for an FDL approach, and to plan the management of their time. Programme specifications, course handbooks and module or unit guides might usefully contribute to such information, as would a schedule which makes clear the sequencing and other relationships between the whole course structure, and individual modules or units. Students need to know about any scheduled opportunities for support by tutors, and about deadlines for formative and summative assessments.

If information is available in a variety of formats, this will help to avoid students being prevented from accessing it through cost, disability, or lack of equipment (see also precept B2).

B2 The awarding institution, whether or not working through a programme presenter, should ensure that students can be confident that:

  • any FDL programme or element offered for study has had the reliability of its delivery system tested, and that contingency plans would come into operation in the event of the failure of the designed modes of delivery;
  • the delivery system of an FDL programme or element of study delivered through e-learning methods is fit for its purpose, and has an appropriate availability and life expectancy;
  • the delivery of any study materials direct to students remotely through, for example, e-learning methods or correspondence, is secure and reliable, and that there is a means of confirming its safe receipt;
  • study materials, whether delivered through staff of a programme presenter or through web-based or other distribution channels, meet specified expectations of the awarding institution in respect of the quality of teaching and learning support material for a programme or element of study leading to one of its awards;
  • the educational aims and intended learning outcomes of a programme delivered through FDL arrangements are reviewed periodically for their continuing validity and relevance, making reference to the precepts of Section 7 of the Agency's Code on Programme approval, monitoring and review (2000), or any successor document.

 

Delivery systems convey course content, and enable participant interaction and learner support. While they need to be tailored to the environment in which students are expected to work, they also need to take account of the lowest levels of technology available to students and students' special educational needs. The piloting or testing of a delivery system before its operational launch will help the presenter to gain a better understanding of the risks involved, and how to manage those risks. In an e-learning environment, it is the responsibility of the programme presenter to ensure that the system is free from contamination by viruses at the point of delivery, and has password-protected access where appropriate.

Consideration should be given to how alternative forms of delivery would come into action in the event of failure of the principal delivery system, or where students are unable to meet scheduled events - students should be able to expect that the system would fail safe. A schedule in advance of the course (see precept B1 above) will, at least, enable students to identify the non-arrival of anticipated materials or events, and access to contact details will enable students to respond quickly to any failure of the principal delivery system.

Students should be able to expect that their FDL study materials are subject to the same rigour of quality assurance as the awarding institution would use for any of its programmes of study.

Learner support

Precepts B3 to B6 below are concerned with aspects of assuring the quality of learner support that is available to a student in an FDL arrangement, whether this is a whole programme or just an element of study. The precepts are couched in terms of what the student might experience. They do not specify who is responsible for assuring particular aspects of quality of learner support. It is the responsibility of the awarding institution to specify the respective responsibilities of the programme presenter, support provider and itself in assuring quality of programme delivery.

In the case of programmes with elements of support through e-learning, an awarding institution may wish to make such use as it thinks appropriate of BS8426: A code of practice for e-support in e-learning systems (BSI, 2003).

B3 Prospective students should receive a clear and realistic explanation of the expectations placed upon them for study of the FDL programme or elements of study, and for the nature and extent of autonomous, collaborative and supported aspects of learning.

Prospective students whose only experience of learning is through directed teaching need to be aware of the different challenges and opportunities of autonomous learning, and of their responsibilities as autonomous learners. They need clear guidance on the characteristics of learning required for their FDL studies, and on the general expectation of time commitment that they should be making.

Particularly in an e-learning environment, students may need time to understand and become familiar with technologies that are new to them. They may need some introductory support, possibly involving access to on-line learning environments prior to the start of the course so that equipment and technical access can be tested and new skills practised. Consideration might be given to the need to assign an identified contact prior to the commencement of study to enable the programme presenter to ensure that the student's induction and preparation have been adequate.

B4 Students should have access to:

  • a schedule for any learner support available to them through timetabled activities, for example tutorial sessions or web-based conferences;
  • clear and up to date information about the learning support available to them locally and remotely for their FDL programme or elements of study;
  • documents that set out their own responsibilities as learners, and the commitments of the awarding institution and the support provider (if appropriate) for the support of an FDL programme or element of study.

 

Academic, technical, or pastoral support to learners in FDL programmes might include face-to-face meetings and/or on-line support. Students need to be well informed about the opportunities available to support their learning. They generally find it helpful if that information is specific about such matters as the frequency of such opportunities, and offers guidance on the anticipated response times from those who may be dealing with technical queries. They need to know about particular technical requirements for e-modes of learner support, or particular modes of required or optional attendance, such as residential classes or field trips.

Students should be in a position to appreciate their own responsibilities in terms of responding to requests for information, and for participation in individual or group activities that facilitate learning. They need to know the ground rules and protocols for communication with other students and tutors, and to be in no doubt about which events and activities are compulsory and which are optional.

B5 Students should have:

  • from the outset of their study, an identified contact, either local or remote through email, telephone, fax or post, who can give them constructive feedback on academic performance and authoritative guidance on their academic progression;
  • where appropriate, regular opportunities for inter-learner discussions about the programme, both to facilitate collaborative learning and to provide a basis for facilitating their participation in the quality assurance of the programme;
  • appropriate opportunities to give formal feedback on their experience of the programme.

 

Clarity in the arrangements for feedback to students and guidance on their academic performance and progression is particularly important for a student studying under an FDL arrangement where the awarding institution is not also the support provider.

Where it is appropriate, collaborative learning opportunities can provide a strong dimension of student support, whether through scheduled group meetings or through web-based methods. The planning into the programme of study of such inter-learner discussions would be determined by the nature of the programme, its location (on-site or off-site) and its aims and intended outcomes.

Students should always have formal opportunities to feed back on the experience of their programme on a regular basis, and FDL programmes are no exception. Methods might include feedback from local learner support groups, on-line surveys and web conferencing. The methods used should be checked for fitness for purpose, recognising that there may be questions of anonymity with electronic modes which need to be taken into account. It is particularly important in an FDL arrangement, where the awarding institution is not also the programme presenter or support provider, that it is clear who is responsible for processing feedback from students, and who is responsible for telling the students about any action to be taken as a result of their feedback.

B6 The awarding institution, whether or not working through a support provider, should be able to ensure that students can be confident that:

  • staff who provide support to learners on FDL programmes have appropriate skills, and receive appropriate training and development;
  • support for learners, whether delivered through staff of a support provider or through web-based or other distribution channels, meets specified expectations of the awarding institution for the quality of learner support for a programme of study leading to one of its awards.

 

The 'appropriate skills' for staff involved in FDL arrangements include both technical competence in the use of the relevant delivery systems and pedagogic expertise in design for delivery, learner support and assessment in FDL. Students on FDL programmes should be able to expect that the staff who design their programmes have relevant technological and pedagogical expertise, and awarding institutions should be able to satisfy themselves that this is the case. Institutions might consider the merits of including aspects relevant to FDL in the development programmes that they provide in teaching and learning for newly-appointed staff, and in opportunities for the continuing professional development of established staff.

Students based on an awarding body's campus can normally expect to have ready access to support services such as pastoral support, academic counselling, library and IT support, and careers guidance. An awarding institution will need to consider how it might make it possible for FDL students to access such services. It needs to be clear to students on FDL programmes which services are available to them from the awarding institution and from the programme presenter or support provider, and which are not. Awarding institutions should note where other sections of the Agency's Code refer to the expectation of services being available to its students, for example, as in Section 8 on Career education, information and guidance (2001).

Assessment of students

Precepts B7 and B8 below are concerned with aspects of assuring the security of assessment of students' achievements in programmes of study undertaken through FDL arrangements. They are couched in terms of what students should be able to expect in relation to assessment of academic performance in an FDL programme of element of study.

In the case of programmes with elements of IT-based assessment, an awarding institution may wish to make such use as it thinks appropriate of BS7988: Code of practice for the use of information technology (IT) in the delivery of assessments (BSI, 2002), as well as BS8426: A code of practice for e-support in e-learning systems.

B7 Students should have access to:

  • information on the ways in which their achievements will be judged, and the relative weighting of units, modules or elements of the programme in respect of assessment overall;
  • timely formative assessment on their academic performance to provide a basis for individual constructive feedback and guidance, and to illustrate the awarding institution's expectations for summative assessment.

 

Information on the methods of assessment used to test achievement of intended learning outcomes would normally be included in the programme specification, but is also likely to be supported by more detailed assessment briefs which are related to the individual units of the programme. Precepts 7 and 10 of Section 6 of the Code on Assessment of students (2000) set out expectations for the provision of criteria for the marking and grading of assessments, and for the rules and regulations for progression, final awards and classifications. The early issue of information on assessment methods, criteria and regulations will assist students following FDL programmes in the planning of their work.

Campus-based students have opportunities for face-to-face communication with staff about academic performance. Students studying remotely through an FDL arrangement may require greater planning of opportunities for formative assessment and appropriate feedback on the outcomes of assessment more generally.

B8 The awarding institution, whether or not working through a programme presenter or support provider, should ensure that students can be confident that:

  • their assessed work is properly attributed to them, particularly in cases where the assessment is conducted through remote methods that might be vulnerable to interception or other interference;
  • those with responsibility for assessment are capable of confirming that a student's assessed work is the original work of that student only, particularly in cases where the assessment is conducted through remote methods;
  • any mechanisms, such as web-based methods or correspondence, for the transfer of their work directly to assessors, are secure and reliable, and that there is a means of proving or confirming the safe receipt of their work.

 

Where material is sent electronically, staff need to be sure that students have had clear instructions on the format and security measures that they should adopt. Administrative and ICT systems associated with the receipt and recording of assessed work should be demonstrably robust enough to withstand interception or interference.

Awarding institutions need to consider how they can best guard against potential malpractice (including plagiarism) in remote assessment. In some FDL environments, there may be particular issues relating to the authentication of a student's work, especially when assessment is conducted on-line or remotely. In such cases, awarding institutions may wish to refer to the detailed and technical guidance given in BS7988. As a starting point, students should at least be provided with a statement which explains the awarding institution's position on the use of unfair means and the penalties which may ensue, and requires them to confirm acceptance of the terms of that statement.

The methods used to record the receipt of students' assessed work need to be considered from a fitness-for-purpose viewpoint. There should, at least, be a system to permit students to confirm that their assessed work has been received safely and within deadline. Where this system is devolved to a level below that of the programme presenter, for example, to local tutors, the awarding institution should be in a position to be confident that the system is robust. Even so, it might be wise to advise students who have to transfer their assessed work by mail or electronic means to keep a copy of their work.

Next >> Appendices

 


1 Institutions may find it useful to refer to the Agency publication Guidelines for higher education institutions in Wales for effective practice in examining and assessing in a language other than the language of tuition www.qaa.ac.uk/public/guidance_assessing_lang.htm which contains useful advice on a related matter.

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