Foreword
1 The Quality Assurance Agency for Higher Education (QAA) is responsible to the Department for Education and Skills (DfES) for the recognition of Access to Higher Education courses. QAA exercises this responsibility through a national network of authorised validating agencies (AVAs), which are responsible for the processes of individual course recognition and the award of Access to HE certificates to students on QAA's behalf. QAA has developed a scheme for the licensing and review of the AVAs, the principles and processes of which are described in the QAA Recognition Scheme for Access to Higher Education in England, Wales and Northern Ireland. The Recognition Scheme is regulated and administered by the Access Recognition and Licensing Committee (ARLC), a sub-committee of the QAA Board of Directors.
2 This is a report on the consideration of the application for an AVA licence made to QAA by the Bedfordshire Access Consortium (BAC) and the Chiltern Region Open College Network (CROCN), with a view to the establishment of a new AVA formed by the merger of these two organisations. The licensing team appointed by the ARLC to consider this application consisted of Dr Pete Johnston, formerly of the University of Essex, and Professor Antony Chapman, Principal, University of Wales Institute, Cardiff. The licensing visit was coordinated for QAA by Ms Kath Dentith, Assistant Director (Access), Institutional Review Directorate.
3 The procedure for the consideration of the application for an AVA licence included an initial meeting between BAC and CROCN officers and the QAA Assistant Director to discuss the requirements for the application and the process of the licensing visit; the preparation and submission by BAC and CROCN of the Licence Application (the Application) together with a selection of supporting documentation; a meeting of the licensing team to discuss the Application and other documentation, and to establish a draft programme for the licensing visit; and negotiations between QAA, BAC and CROCN to finalise the programme and other arrangements for the visit. Following the licensing visit, the reviewers' report was presented to a meeting of the ARLC. The Committee made its decision about the award of an AVA licence on the basis of the licensing team's report on the Application and licensing visit.
4 The licensing visit took place on 13 June 2001. The visit consisted primarily of meetings with representatives of the AVA and OCN, including BAC and CROCN officers; representatives of BAC and CROCN governing bodies and from Buckinghamshire County Council; members of the Merger Steering Group; and senior managers from providing institutions. The Agency is grateful to BAC and CROCN and to those who participated in the preparation of the Application and in the licensing visit for the willing cooperation provided to the licensing team.
Background and previous experience
5 Chiltern Region Open College Network and Access Consortium (CROCNAC) is the proposed new organisation to be created through the merger of the Chiltern Region Open College Network (CROCN) and the Bedfordshire Access Consortium (BAC). CROCN and BAC have fully approved the merger within their individual organisations and are committed to it, and the formal merger is planned to proceed as soon as the QAA licence to operate as an AVA has been secured.
6 CROCN was established in 1993, as Buckinghamshire Open College Network. Full membership of the National Open College Network (NOCN) was granted in 1994 and CROCN was awarded a full unconditional licence by NOCN, under NOCN's new licensing arrangements, in 2000. CROCN has steadily developed its business, and in 1999-2000 it awarded a total of 25,837 credits to 17,410 registered learners. Of this volume of credits, 15 per cent were awarded at level 3. Furthermore, although CROCN is not an AVA, it has recent experience with the development of Access to HE programmes as a consequence of its work with Open College Network South East Midlands (OCNSEM) to accredit Access to HE programmes at Milton Keynes College over the past four years.
7 BAC was awarded AVA status in 1990. This was reviewed by HEQC in 1992 and by QAA in 1999. The 1999 review report expressed serious concerns about BAC's governance structures and quality assurance procedures, and about its ability as an unusually small AVA to remain viable and to exist as an independent entity. BAC responded by undertaking extensive, thorough and sustained work to address the conditions set in the 1999 report. It introduced new, and appropriate, governance and quality assurance arrangements, and, on the important matter of viability, it formulated an action plan with the objective of achieving a merger with CROCN by the end of 2000-01.
Legal status and constitution
8 CROCNAC will be an unincorporated association of its members, governed by a constitution. This specifies that membership of CROCNAC entails commitment to the aims and principles of CROCNAC. The licensing team noted the appropriateness of these obligations on members, in particular the requirement to uphold and implement the standards established by CROCNAC, NOCN and QAA quality assurance processes.
9 Buckinghamshire County Council (BCC) acts as host organisation for CROCN and it is intended that this position will continue when CROCNAC is established. A formal agreement between CROCN and BCC, dated May 2000, states that CROCN, and hence CROCNAC (see paragraph 10, below), is recognised by BCC as an autonomous unincorporated association (of which BCC is a member) with a separate legal identity and with its members sharing collective liability. This statement originates from the fact that BCC 'initiated the establishment' of CROCN and has contributed substantial direct and indirect support throughout the development of CROCN towards the status of an autonomous organisation. April 2000 marked the beginning of a new financial era and the end of an era when BCC had contributed direct block grant aid to CROCN. It also marked the implementation date for the above-mentioned formal agreement between BCC and CROCN, confirming the relationship between BCC and CROCN with regard to 'the scope of its legal identity, operational independence and the scope of services provided by BCC'.
10 The agreement is for a three-year period and so is subject to renewal in April 2003. BCC has deemed it transferable to CROCNAC, and the licensing team heard that BCC and CROCN have already agreed that discussion will begin in March 2002 to explore the future nature of the relationship, in particular whether BCC should continue to act as host or whether an alternative host should be found, and whether CROCNAC should explore company status. BCC itself supports the 'weaning' of CROCN (and hence CROCNAC) and evidence of the growing maturity of CROCN (and hence CROCNAC) can be seen, for example, in the establishment of a specific contingency fund in case of withdrawal of services in kind by BCC.
11 In addition to the provision of premises free of charge, BCC also provides professional personnel and financial services and ICT services, free of charge. Staff are employed on BCC pay and conditions of service. The team found evidence both in the documentation and in discussions during the visit that the support provided by BCC since the inception of CROCN is greatly valued and that there is no indication that CROCN's independence is compromised.
12 As regards the particular role of BCC as employer for CROCN(AC) staff, the team asked for clarification of the meaning of statements in the formal agreement that 'BCC reserves the right to take any appropriate action to avoid a deficit. While not seeking to influence the autonomous nature of CROCN, in the event of its failure to meet the agreed annual business plan, all BCC decisions relating to financial and staffing matters will be final and binding' and 'the appointment of new staff will be subject to approval by BCC, as part of the business planning process'. While reassured by the response to these enquiries that the statements referred entirely to ensuring that CROCN applied proper financial discipline as regard staffing levels, the team recommends that there be an accompanying statement which specifies that representation from any 'host' organisation should be in a minority on CROCNAC staff selection and appointment panels. This recommendation is made with particular reference to the possible conflict of interest which may arise for the 'host', for example as regards redeployment of its own staff.
Members, Access to Higher Education providers and provision
13 The current members of BAC and CROCN are included within the putative membership of CROCNAC. Presently, four Access to HE providers are members of both BAC and CROCN: Barnfield College, Bedford College, Dunstable College and the University of Luton. Luton Sixth Form College is presently a member of BAC; and Milton Keynes College is a member of CROCN. Additionally, CROCN has a further 24 members, including continuing education consortia and community colleges; charities and voluntary groups; and prisons and secure establishments. The team was assured that the establishment of CROCNAC would not otherwise impact on the operation of other AVAs, though its activities will be spread through a wide geographical area, including Bedfordshire and Buckinghamshire, as well as parts of Hertfordshire, Northamptonshire, Oxfordshire, and the London Borough of Hillingdon.
14 While having some concerns about the limitations for an AVA of having a single higher education institution in membership, the licensing team was content that the proposed membership for CROCNAC was sufficient for the viability of the organisation and its ability to implement sound quality assurance procedures. The team noted that additional higher and further education institutions within the region were being approached to join the AVA, and that some interest had been shown. The team particularly welcomed CROCNAC's intention to extend the base of its HE membership and looks forward to developments in this area.
15 Applications for membership of CROCNAC will be considered from higher education, further education and adult education providers, voluntary organisations, schools, training providers and employers. CROCNAC's commitment to members is specified in a membership leaflet which was made available to the licensing team in draft form. There will be three categories of membership: 'Full Members', 'Associate Members' and 'Affiliate Members'. Full Members (to include further and higher education institutions) will have full voting rights and will be entitled to send a representative to CROCNAC's Governing Council, and to elect members to its committees. They will pay fees and will have access to the complete range of CROCNAC's recognition, accreditation and support services. Associate Members will be able to send an observer to attend the Governing Council, but will have no voting rights. They will have access to CROCNAC's recognition and accreditation services, but will pay no fees and have more limited access to facilities. Affiliate Members will be entitled to send an observer to the Governing Council and to attend staff development events and conferences, and they will receive information bulletins, but they will have no access to CROCNAC's accreditation facilities.
16 Among criteria for all categories of membership will be the following: the member must be a provider of education, training or staff development opportunities in the public, private or voluntary sector; the member must demonstrate a commitment to the values of CROCNAC and to widening participation in education and training; the member must state and demonstrate a commitment to uphold the quality assurance requirements of CROCNAC; the member must have a student complaints and appeals procedure; and the member must have a published commitment to equal opportunities.
17 All members will be required, inter alia, to recognise credits awarded by all members of NOCN; to take responsibility for upholding and implementing agreed standards; and, generally, to engage in the work and administration of CROCNAC, notably in its governance and in the maintenance and operation of its quality assurance mechanisms. Additional requirements and expectations are to be placed on Full Members; for example, they will be required to release staff to serve on appropriate committees and advisory forums. The team considered that the terms, obligations and rights of membership were appropriate and were specified in adequate and appropriate detail.
18 All current Access to Higher Education work of the two organisations will be acquired by CROCNAC. This will include the programmes currently recognised by BAC, and the Milton Keynes College Access to HE programmes, OCNSEM having formally agreed to the transfer of responsibility for the moderation and certification of this provision. As an indicator of the total volume of Access to HE work which CROCNAC is likely to acquire, in 1999-2000, 441 Access learners were registered with BAC and 69 at Milton Keynes College.
19 It was reported to the licensing team that a prime objective in developing CROCNAC is to increase Access provision from its present base. For its first year of operation (2001-02), extrapolating from 1999-2000 data from BAC and CROCN, the team was told that CROCNAC would deliver Access-related activities at approximate levels of 1.5 per cent of learners and 19 per cent of total credits (or equivalent). Increased activity is expected to result from the development of new programmes and pathways and from the involvement of more providers in the delivery of Access to HE programmes.
Governance and committee structures
20 A Governing Council, meeting at least three times per year and reporting to an Annual General Meeting, will be responsible for CROCNAC's constitution, mission, strategic planning and financial matters; and it will approve the annual report to QAA. At least two members, in a membership of not less than eight and not more than 18, will be providers of Access to Higher Education programmes or receivers of Access students in higher education. The team noted that the large maximum had been chosen to accommodate the possibility of substantial expansion in the total number of members of CROCNAC.
21 An Executive Committee, also meeting at least three times per year and reporting to the Governing Council, will approve policies and decisions regarding the operation of CROCNAC. It will advise the Governing Council and make recommendations on a variety of matters, including the budget and business plan, membership, the QAA licence, and the annual report to QAA; and it will advise the Coordinator. The Executive Committee will include either one or two members from higher education, by election from the sector. The licensing team noted that, in addressing a concern about broad-based representation on the Executive Committee, CROCNAC's Constitution allowed that Committee, with a maximum of 10 and minimum of six members, to be larger than the Governing Council and for there to be considerable overlap in the two memberships. The team would recommend that CROCNAC reconsiders the membership of the Governing Council and Executive Committee as specified in its constitution, and considers appropriate amendments which will prevent these potentially unsatisfactory positions from arising.
22 A Quality Assurance Committee, meeting at least three times per year and reporting normally to the Governing Council, will be responsible for CROCNAC's policies in relation to quality assurance matters, in terms of approving and developing policies and monitoring their implementation. The Quality Assurance Committee will be supported by three sub-committees: an Access Sub-Committee, a Recognition Sub-Committee and a Moderation Sub-Committee. The licensing team noted that the demarcation lines between these sub-committees, defining their respective areas of responsibilities, had been carefully and appropriately drawn. The team sought and was given reassurance that sufficient senior staff would be able to give the time and commitment necessary for the committee structure to operate effectively.
23 The Access Sub-Committee will meet at least three times a year and will advise on policy relating to Access to HE, and will oversee its implementation. It will report directly to the Executive Committee on financial, organisational and management issues. Access Sub-Committee members will normally be Access practitioners and managers from organisations offering Access to HE courses or representatives from member higher education institutions. CROCNAC's proposed Constitution requires the Sub-Committee's maximum membership of 12 to include one, two or three representatives from higher education. The licensing team noted with concern that, as proposed, meetings of the Sub-Committee could take place without representation from higher education. While the team appreciated that the work of the Sub-Committee should not be delayed because particular individuals were unavailable, it would recommend that CROCNAC considers the implications of the Sub-Committee's terms of reference in this respect, and makes an appropriate amendment to ensure cross-sector representation at meetings.
24 An Annual General Meeting will elect members of the Governing Council, the Executive Committee and the Quality Assurance Committee. Membership on all these committees will be from staff holding senior posts within their organisations.
25 The licensing team was satisfied that these structures would provide an adequate basis for robust governance of CROCNAC and an appropriate framework for the oversight of its quality assurance procedures.
Management and organisational structures
26 A 'Coordinator' will be accountable to the Chair of the Executive Committee for the management and operation of CROCNAC, including the overall coordination and line-management of CROCNAC staff. The Coordinator will provide reports to the Governing Council, the Executive Committee, the Quality Assurance Committee, and the Access Sub-Committee.
27 The licensing team was informed that staffing levels were under review, with the needs of CROCNAC as an AVA a prime consideration. It learnt that there were no permanent BAC staff to be transferred, and that staff in post in CROCN would be assimilated to equivalent posts in CROCNAC. The team also heard with approval that certain members of CROCN staff, consonant with their current roles, were preparing to assume designated responsibilities within CROCNAC: a Systems Manager will initially be the first point of contact for members; a Development Officer will take responsibility for the development and recognition of Access to HE programmes; and a Moderation Officer will integrate arrangements for the appointment of moderators, and will subsequently scrutinise and process their reports.
28 The licensing team was informed that staffing responsibilities in relation to Access would be developed when CROCNAC had been established, but that it had been determined that CROCNAC staff would, for example, work closely with the Access Sub-Committee. The Application also indicated that there would be internal staff development events to prepare staff for duties within an AVA, and a staff development programme was being constructed for 2001-02, to be agreed with the Access Sub-Committee and to be focused on issues bearing on Access to HE.
29 The Application indicated that CROCNAC would be administered from the offices presently occupied by CROCN in Winslow, Buckinghamshire, provided by BCC, those offices being described as 'small but well resourced', although funds have been identified to provide additional accommodation if necessary. During its visit, the team heard that the working space was rather cramped and that an accommodation strategy was under development with a view to obtaining more space, a prime objective within that strategy being to have a single-site arrangement, as now, though not necessarily in the present location.
30 To meet the management-information requirements of an AVA, CROCNAC will develop a management information system derived from that existing in CROCN. It was reported that within three years, through an IT initiative emanating from NOCN, there would be a unified system that included all critical functions relating to Access to HE certification. This system will also enable the AVA to produce the data necessary to meet QAA's specifications for annual reporting.
31 The Access Sub-Committee will be the hub for communication on Access to HE matters and for dissemination of good practice, and it will build upon and expand arrangements developed by BAC members and by Milton Keynes College. It will also play a part, as do some of the existing BAC and CROCN staff, in the Midlands Regional Group of AVAs and OCNs, which is a forum for the development and sharing of good practice. Also in line with existing BAC/CROCN practice, CROCNAC will continue to circulate information and published materials to its Access providers and receivers.
Aims, targets and planning
32 CROCNAC's mission 'to recognise the educational achievements of adults, in particular those who have not benefited from traditional opportunities' is appropriate, as are its general aims, as stated in the Constitution, which include specific reference to the promotion of Access to Higher Education in the region and guaranteeing the standard of the Access to HE award. The licensing team welcomed and endorsed CROCNAC's proposed aims. They are appropriately ambitious and embrace the following: maintaining and developing standards and consistency of Access provision, alongside making progress in the quality, coherence, flexibility and extent of provision; building a proactive and stable organisation for the growth and development of Access provision; exploring a regionally-based credit framework, spanning adult, further and higher education; and contributing to regional widening participation and partnership initiatives.
33 The Initial Development Plan provides appropriate specific short-term objectives for CROCNAC for the period May-December 2001. The licensing team considered the detailed targets and judged them to be appropriate, recognising that the aims specified for CROCNAC may need to be reconsidered during the strategic planning exercise to ensure that they can be achieved against a background of limited resources. The team looks forward to learning of CROCNAC's progress in meeting the targets set, as it will be reported in the AVA's annual reports to QAA.
34 It is intended that a three-year strategic plan (2002-05) for CROCNAC will be developed in autumn 2001. Initial work on this will be undertaken by CROCNAC staff, and the Executive Committee will draw up annual operational targets for Access, for approval by the Governing Council. Targets will be informed through internal monitoring and self-assessment, and a process of action planning will be debated throughout the organisation. This process will encompass AVA issues identified by the Access Sub-Committee.
35 An appropriate target group has been defined for CROCNAC's Access provision, as 'adults (over 21) who have not in the past benefited from educational opportunities'. It is intended that the AVA will also build on BAC's strength in targeting ethnic minority groups. More generally, CROCNAC expresses its intention to work with its members on strategies to develop and target provision for people who are under-represented in higher education. It intends, for example, to promote part-time, accessible and flexible provision. The Application refers to key information to be used in this process, and it identifies data on existing students, current and potential higher education progression routes in the region, demand-data for higher education, both regionally and nationally, and regional demographic information, including labour-force data.
36 The licensing team considered that appropriate aims had been proposed which provided for the development of Access to HE within the AVA, and that the mechanisms for strategic planning would be able to take proper account of members' concerns and of the outcomes of quality assurance procedures.
Finances
37 CROCNAC's financial structures will initially be based on CROCN's, an arrangement which acknowledges the difference in scale of financial operation of BAC and CROCN: whereas BAC's expenditure for the period 1 September 1999 to 31 August 2000 totalled only £3,804, CROCN's expenditure for the year ending 31 March 2001 totalled approximately £190,000. Income will be raised through fees and charges paid by members under the headings 'annual membership', 'annual learner registration fee', 'award of credit', and 'recognition charges'.
38 As indicated above, CROCN has operated and CROCNAC will operate, with a financial year beginning 1 April. It has been agreed by BAC and CROCN that CROCNAC will operate until March 2002 within CROCN's existing approved business plan for the period April 2001 to March 2002. (This plan explicitly addresses the impact of the merger with BAC and the demands of becoming an AVA). However, the strategic plan for CROCNAC will be developed and approved in November 2001, with the business plan for 2002-03 then to be based on the approved strategic plan and associated operational targets.
39 The assets and liabilities of BAC and CROCN will be formally transferred to CROCNAC. BAC's balance sheet of 31 August 2000 records net current assets of £5,320. CROCN's Business Plan for 2001-02 specifies income and expenditure projections for the financial year April 2000-March 2001 of £265,552 and £190,429 respectively. With the inclusion of a carry forward figure of £20,920 from 1999-2000, this produced a carry forward to contingency estimate of £96,043. The plan further records agreement that components of the surplus be earmarked for the following contingencies: £20,000 against the withdrawal of services in kind by BCC; £20,000 against redundancies; £20,000 against a short-term drop in activity; with the remainder earmarked for service developments against strategic targets.
40 CROCNAC will therefore begin operation with a healthy balance and appropriate contingency policy. It will also retain the benefit of professional assistance from BCC in its budgeting and financial planning. Until March 2003, CROCNAC finances will be held as a separate cost centre within BCC with full carry forward facility in accordance with the terms of the formal agreement between BCC and CROCN, which has been deemed transferable to CROCNAC. These arrangements will be reviewed as from April 2002 in order to establish appropriate arrangements before the expiry or renewal of the contract in April 2003.
41 The Governing Council will be responsible for approving the annual budget and charges, business plan and summary of accounts. The Co-ordinator and administrative/finance officer will draw up budget and charging proposals for the Executive Committee, which oversees the preparation and monitoring of the business plan and budget and reports thereon to the Governing Council. Income and expenditure will be monitored internally in CROCNAC on a monthly basis and appropriately regulated through the operation as a cost centre within BCC.
42 The licensing team found these arrangements to be appropriate.
Arrangements for the development and validation of Access to HE programmes
43 The CROCNAC development, validation and revalidation procedures are based on the existing procedures developed and established by CROCN. The team found these to be fully and appropriately documented, with the Access to HE responsibilities specifically and suitably addressed. This is demonstrated by the Access-specific sections in the comprehensive guidance on Developing a Submission for Recognition; the Guidelines for Members of Recognition Panels; the Guidelines for Composition of Recognition Panels; and the Chair's Guidance Notes for recognition panels, which includes reference to the panel's responsibility for confirmation of the requirements for the award of an Access certificate. The CROCNAC specification for the award of an Access to HE certificate is fully and appropriately specified, detailing volume of credit, key skills, credit transfer and APL, exemptions, assessment regulations, time constraint for achievement, and age requirements which are in line with QAA's expectations. All new programmes or existing programmes that require revalidation will be brought within the NOCN credit framework. In particular, all BAC programmes, which currently are not credit-based, will be brought within the NOCN framework by September 2003.
44 CROCNAC's recognition process ensures that the relevant issues are addressed, including provision of pre-course guidance, appropriateness of curriculum for target group, balance between academic skills and subject knowledge, range and balance of assessments, provision of academic and personal support, coherence of the programme of study and specification of the requirement for achievement of the Access to HE certificate.
45 After a recognition panel has met to consider an Access to HE programme submission, the recognition panel report will be issued to panel members and forwarded to the Access Sub-Committee. The report will document the panel decision and discussion, any recommendations or conditions, required textual amendments and the requirements for the award of the Access certificate. Panel decisions will be confirmed by the Access Subcommittee, which also has responsibility for monitoring and confirming that set conditions have been met, under delegated powers from the Quality Assurance Committee. The team found these post-panel processes to be appropriate.
Arrangements for the assessment, moderation and certification of Access
programmes
Assessment
46 CROCNAC's assessment policy for Access to HE programmes accords with the relevant general NOCN principles that assessment be fit for purpose, inclusive, reliable and consistent, valid, and authentic. It requires a recognition panel considering a proposal for an Access to HE programme to assure itself that the assessment regime meets these principles and to confirm that the assessment load is balanced, appropriate and consistent with practice within the AVA.
47 As regards consistency of practice across the Access provision recognised within the proposed AVA, the team noted the significance of the recent work initiated by BAC on the development of a common core curriculum, covering, in particular, broad assessment regimes, with accompanying standardisation exercises for practitioners and moderators. This has gone some way towards establishing equivalence between programme outcomes for BAC existing courses and will inform the development of corresponding units in the move towards credit-based provision. The team recommends that CROCNAC attach high priority to sustaining such work, particularly given its additional significance in relation to the move towards unitised Access provision.
Moderation
48 Moderators will be appointed by, and report to, CROCNAC, the Access Subcommittee acting under delegated authority from the Quality Assurance Committee to confirm appointments of moderators. The criteria for appointment of moderators, including externality to the programme and to the providing institution, are clearly stated. The requirements on training (including attendance at an induction course on appointment) and provision of support, to include at least one 'moderator support session' convened during the year for Access moderators, are also clearly stated and were deemed adequate by the licensing team. Access moderators will also be invited to attend regional Access to Higher Education events. The licensing team was informed that it was considered likely that most BAC moderators would apply to act as moderators for CROCNAC.
49 A handbook has been developed which is specifically designed for moderators of Access programmes recognised by CROCNAC. This addresses the fact that CROCNAC's approach to moderation must (i) apply immediately in academic year 2001-02 to all programmes for which it acquires responsibility, both credit-based and non credit based, (ii) apply in the process of revalidation of all non credit-based programmes in unitised and credit-based format and (iii) apply thereafter to all programmes.
50 The Moderators Handbook for Access to Higher Education specifies the general purposes of moderation, namely verification of academic achievement, moderation of student work, verification of programme delivery, support for improvement of the programme, and ensuring consistency in the award. Detailed guidance on the role is given in the Handbook, for example mechanisms to ensure a sample of evidence is representative, and this is accompanied by extensive supporting documents including an annual moderation report form; interim report form; proforma for provider feedback; tutor checklist for assessment; student self-assessment record; procedures to follow if substantial concerns arise including doubts about adequacy, authenticity or validity of evidence; and examination board terms of reference. The team found the Handbook and the systems described therein to be generally appropriate.
51 In accordance with national trends in OCN/AVA arrangements, the documentation includes reference to the intention to use lead moderators and pathway moderators for 'large or multicurriculum area' programmes. The statement provided by CROCNAC as to intentions regarding the introduction of a system of lead and subject moderators for large or multicurriculum programmes were found appropriate by the team, specifically with reference to consistency with the overall purposes and procedures of moderation and the responsibilities of moderators. However, given the impending round of revalidation of former BAC programmes, the team recommends that high priority be attached to the formal confirmation of the lead and subject moderation system.
Internal verification
52 CROCNAC's moderation documentation specifies that from September 2001 CROCNAC will require that all programmes be subject to internal verification (IV). It states that CROCNAC does not prescribe any single model but requires adherence by providers to core principles, namely consistency and standardisation of both achievement and assessment, good practice in both assessment and record keeping, rigour and quality enhancement, self assessment and quality monitoring. In recognising the need for a transitional period before full implementation of such systems, CROCNAC specifies that whereas 'programmes recognised after January 2001 will contain details of the IV arrangements agreed by the recognition panel in the approved submission document', 'for programmes recognised before this date providers are required to register their internal verification arrangements with CROCNAC who will forward the information to moderators as soon as possible in the academic year'.
53 Noting that the moderator's remit appropriately includes responsibilities in relation to internal verification, including, in particular, 'to agree IV (internal verification) and standardisation arrangements and to report on and respond to their implementation'; visiting the programme to review the general running of the programme; and attending the examination board for the programme and submitting interim and annual reports to CROCNAC, the team found these arrangements appropriate for the first year of the transitional period, (ie academic year 2001-02), but recommends that the planned development of the full IV guidance document specifically for Access to HE programmes be given high priority by CROCNAC.
Award and issue of the Access to HE certificate
54 For all Access to HE programmes, the moderator(s) will attend the provider's examination board as a member. The team found the terms of reference of the examination board to be fully and appropriately detailed (including, for example, requirements regarding the Chair's seniority and expertise, quorum requirement, review of assessment evidence, and responsibility to determine action where a student fails to comply with a course requirement). At the conclusion of the examination board, the Moderator, Chair of the Examination Board, and the course/programme manager must formally sign the list of ratified students' results. This covers both the recommendation of OCN credits (where applicable) and the award of the Access to HE certificate. Again recalling that currently the majority of programmes are not in OCN credit-based format, the licensing team noted that the relevant documentation specifically states that during the transition period (ending 1 September 2003) Access to HE programmes may include units/modules that are not CROCNAC approved and that, correspondingly, the Recommendation for Award of Credit form will not be required.
55 Where programmes are credit-based, CROCNAC administrative staff will check that the credit requirements for the award of the Access to HE certificate are met in full before certificates are printed. The licensing team found these arrangements, as those for the overall procedure for authorisation and issue of Access to HE certificates to achieving students, to be secure.
Arrangements for the monitoring and enhancement of Access provision
56 All providers will be required to register learners, and their profile information, with CROCNAC early in their programme. This information will be entered on to the CROCNAC database, which also will hold information about all Access programmes. This will enable data analysis to be undertaken for AVA monitoring purposes and for reporting to regulatory bodies.
57 In the first phase of the annual reporting and quality assurance cycle, the Access Subcommittee will receive moderators' interim reports. A commendable aspect of CROCNAC's proposed moderation arrangements is the explicit requirement that 'If the first visit is unsatisfactory, then the Moderator will require an additional visit and that an action plan be produced and forwarded to CROCNAC...Serious or unresolved issues must be reported to the Access Subcommittee who will demand explicit action by the provider and warn that the award of credit or an Access certificate may be in jeopardy.'
58 Moderation final reports will be required to be submitted to CROCNAC and, following scrutiny by an officer, these reports will be forwarded immediately to the provider with copies to programme leader/manager and staff member responsible for quality assurance. The CROCNAC moderation officer will produce a composite report and a summary of individual reports for the Access Subcommittee, which considers these alongside the programme evaluation reports which are required from each programme team. Any issues arising from these considerations will be assessed by the Access Subcommittee which will draw up action plans for programmes where serious issues have been identified. These will be forwarded to the programme providers who are required to address the requirements. Responses will be monitored by moderators and recorded through their interim reports to the Access Subcommittee
59 Regular monitoring reports will be given to the Quality Assurance Committee and the Executive Committee (normally biannually). In particular, the Quality Assurance Committee will receive from the Access Subcommittee at its autumn term meeting, a composite report on matters raised in the annual moderators' or programme reports, any specific issues to be addressed, and areas of good practice and underlying development issues.
60 CROCNAC has an explicit mechanism for dealing with issues of substantive concern which may lead to withdrawal of programme approval. The substantive criterion for concern is that the programme is not in accord with the specification approved in the validation documentation. Such concern can be raised through a moderation visit, feedback from students, examination board or any other formal channel. The moderator and programme provider are then notified. The process thereafter features a special interim report by the moderator to the Chair of the Quality Assurance Committee, the possibility of remedial action and report, a composite report to the Quality Assurance Committee, with the ultimate sanction of withdrawal of approval. The licensing team found all such mechanisms to be appropriate.
61 The moderation system with use of examination boards (see paragraph 54, above) constitutes an appropriate and effective basis for the monitoring of output standards, with formal reporting and recording of achievement by CROCNAC and records held on CROCNAC management information system. As recorded above, its moderation system is designed to confirm that the programme is being delivered to the approved specification.
Conclusions
62 The Chiltern Region Open College Network and Access Consortium (CROCNAC) is proposed as a new AVA which will be able to build on the experience and expertise of two pre-existing organisations, the Bedfordshire Access Consortium (BAC) and the Chiltern Region Open College Network (CROCN). The two organisations, while serving different purposes in the past, have had congruent aims, and have served an overlapping group of providers in contiguous geographical areas.
63 BAC and CROCN bring complementary experience to this merger, with BAC providing a background in Access to HE work, with well-established courses, experienced Access to HE providers and structures which include consortium arrangements between further and higher education, and CROCN bringing experience of larger organisational planning and management, as well as its secure background in OCN operations. Both organisations have also been active recently in considering the fitness of their quality assurance procedures, and ensuring that they meet the requirements of their separate licensing bodies. It is therefore not only unsurprising, but also entirely appropriate, that the proposals for the structures and procedures of the new AVA should have been developed on the basis of those which have proved successful for the independent operation of CROCN and BAC. Where there have been variations in practice, the commitment of all parties to the merger has provided a readiness to confront and overcome differences, and to produce appropriate compromise proposals.
64 The process of development towards AVA status has involved proper consultation with those individuals and member organisations likely to be affected through a change to the nature of their responsibilities, as well as with those whose work will be affected because of operational changes. Detailed proposals for new structures and procedures have been developed by a joint steering group and agreed separately by both BAC and CROCN, in readiness to be formally adopted by CROCNAC at its inception. There is an appropriate awareness of the status of structures and procedures which have been developed for CROCNAC, recognising that they do not yet technically exist, and cannot be approved until the new organisation comes into being. However, plans are in place which indicate the manner and timescale for their ratification by the appropriate bodies within CROCNAC once it has been established. Those tasked with developing the proposals have given appropriate consideration to current licensing requirements, and these have been realistically addressed, recognising the organisations' present situations and the need for planned development to continue to take place at the same time as the new AVA becomes operational.
65 The resulting proposed structures for the governance and management of the organisation are well-considered and robust and provide for the proper consideration of Access to HE matters, and the potential for the development of this aspect of CROCNAC's responsibilities has been adequately accommodated within the infrastructure for the larger organisation. The responsibilities of an AVA are explicitly acknowledged, and appropriate quality assurance procedures are comprehensive and described in sufficient detail to provide useful guidance for those responsible for the different stages of their operation.
66 It is inevitable that challenges will arise, whether generated by internal or external factors, as the organisation develops and moves to full implementation of its proposals. Indeed, there are some points of detail which will need to be addressed immediately. However, well-defined structures and responsibilities for governance and management, thorough and realistic planning and resourcing, and comprehensive and clearly-specified quality assurance procedures, as well as the experience, commitment and goodwill of those involved, provides confidence in the ability of CROCNAC to address the needs of Access to HE within the region, and to exercise in full the responsibilities of a licensed AVA.
Recommendation to the ARLC
67 The licensing team recommends that CROCNAC should be awarded an AVA licence, subject to the standard requirements of the QAA Recognition Scheme for Access to Higher Education in England, Wales and Northern Ireland. It is recommended that the licence be awarded without conditions.
Recommendations
68 The licensing team recommends that CROCNAC:
- produces a formal statement which specifies that, for staff selection and appointment panels, representation from the CROCNAC 'host' organisation should be in the minority, and that any representative of the 'host' may not chair such a panel;
- makes amendments to the membership specification for the Executive Committee and/or Governing Council to address the current potential for the Executive Committee to be larger than the Governing Council;
- considers the implications of the Access Sub-Committee's terms of reference which allow meetings to take place without representation from higher education, and makes appropriate amendment(s) to the terms of reference;
- attaches high priority to the further development of:
- the work on consistency between programmes initiated by BAC;
- the lead and subject moderation system, and its formal confirmation;
- the guidance document for internal verification on Access to HE programmes.
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