North East Midlands Open College Network
February 2000

Web site for North East Midlands Open College Network

Contents

• Foreword
• The AVA context
• Governance and committee structures
• Management, organisational structures and administrative arrangements
• The development, validation and evaluation of Access programmes
• Assessment, moderation and award of certificates
• Learner experience, standards and progression
• Conclusions
• Recommendation to the ARLC
• Conditions
• Recommendations

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Foreword

1 The Quality Assurance Agency for Higher Education (QAA) is responsible to the Department for Education and Employment (DfEE) 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 'kitemarked' 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 of a major review of the AVA function of the North East Midlands Open College Network (NEMOCN) undertaken by QAA. QAA is grateful to NEMOCN and to those who participated in the review for the willing co-operation provided to the review team.

Aims and objectives

3 The aims of the system of AVA review are:

i to provide the basis for an informed judgement by the ARLC about the fitness of the AVA to continue as a licensed agency;

ii to promote public confidence in Access to HE as a properly regulated and respected route into higher education by assuring:

• the quality and adequacy of AVAs' systems and procedures
• the quality, comparability and range of AVAs' operations
• the adequacy and comparability of AVAs' standards for approval, moderation and monitoring of programmes
• consistency across AVAs in the operation of criteria for the granting of the Access to HE award;

iii to stimulate reflective and self-critical perspectives within AVAs, as an instrument to promote quality enhancement;

iv to provide an opportunity to identify and disseminate good practice of AVA operations;

v to provide a mechanism for ensuring necessary, and encouraging desirable, improvements and developments in AVAs.

4 The objectives of each AVA review are:

i to examine, assess and report on:

• the development of, and changes in, the AVA since its last review or initial licence, and its plans and targets for the future
• the organisation's continuing viability and robustness and the ways in which the AVA demonstrates sound governance
• the efficiency and effectiveness of the AVA's operational and quality assurance systems
• the range and scope of the AVA's activities, and the appropriateness and value of these activities
• the ways in which the AVA approves and monitors programmes and the ways in which these processes take account of the need for consistency and comparability
• the ways in which the AVA satisfies itself of the adequacy and comparability of standards achieved by students gaining the 'kitemarked' Access award
• the evidence available to indicate the AVA's success in achieving its aims and targets;

ii to identify and report on:

• strengths and good practice in procedures and operations
• areas which would benefit from further development
• areas requiring attention.

Outcomes

5 Following the review of an AVA, the reviewers' report is presented to the ARLC by a member of the review team. The Committee then makes one of six decisions:

i unconditional renewal of licence for a specified period;

ii conditional renewal of licence with conditions to be met by specified dates;

iii provisional renewal of licence with conditions to be met and further review visit by specified dates;

iv suspension of licence until specified conditions are met;

v withdrawal of licence for operation as an AVA;

vi temporary renewal of licence with request for further information by specified date (decision suspended).

The review process

6 The review was conducted in accordance with the process detailed in the QAA Recognition Scheme for Access to Higher Education in England, Wales and Northern Ireland and approved by the ARLC. The preparation for the review of NEMOCN included an initial information visit to NEMOCN by the QAA Assistant Director with responsibility for Access to HE matters to discuss the requirements for the Analytical Account and the process of the review; the preparation and submission by NEMOCN of its Analytical Account, together with a selection of supporting documentation; a meeting of the review team to discuss the Analytical Account and supporting documentation and to establish a draft programme for the review visit; and negotiations between QAA and NEMOCN to finalise the programme and other arrangements for the review visit.

7 The review visit took place on 9 and 10 November 1999. The visit to NEMOCN by the review team consisted principally of meetings with representatives of the OCN including: OCN officers and support staff; members of the Management Board, Executive Committee and Quality Assurance Committee; Access to HE moderators; Access to HE programme leaders; former and current students from Access to HE programmes; and admissions staff from the OCN's HE member institutions.

8 The review team consisted of Dr Peter Easy, Assistant Director (Academic), Cheltenham and Gloucester College of Higher Education, and Ms Sue Georgious, Director, Open College Network for Central England. The review was co-ordinated for QAA by Ms Kath Dentith, Assistant Director (Access), Institutional Review Directorate.

The AVA context

Background

9 The AVA was established in 1989 as a result of a collaborative development between a group of local higher education institutions, (HEIs) and further education colleges in the North East Midlands, and adopted the name the North East Midlands Access Partnership (NEMAP). During the first four years of operation, the AVA operated with a modest infrastructure which relied on the support of its HE member institutions, each in turn providing administrative support. In 1993, the AVA became a full member of the National Open College Network (NOCN) and the Higher Education Quality Council (HEQC) review of the same year focused on issues resulting from the transition from AVA to OCN. The period from 1993 to 1996 was a critical period of development for the OCN, with the establishment of a centralised administration, including the appointment of a full time Co-ordinator, and the revalidation of Access to HE provision using the OCN accreditation framework. In 1997, the Management Board of NEMAP agreed to a change of name to the North East Midlands Open College Network (NEMOCN), in order to reflect clearly the OCN's relationship with NOCN. NEMOCN is situated in premises in Long Eaton, Nottinghamshire, and serves providers across a large geographical area which includes Nottinghamshire, Derbyshire, Leicestershire, and parts of Staffordshire and Lincolnshire.

Financial position, structures and income sources

10 Since the last review, the OCN has developed from an organisation operating on the basis of mutual support from its members to a financially independent organisation with a current budget of almost £400,000 per annum. Annual income comes through membership subscriptions (12 per cent) and from charges made for the accreditation service offered (78 per cent), mainly through programme registration and certification fees. Some additional income is derived from project and consultancy work. Financial management and planning are overseen by the Management Board, which approves the annual budget.

Membership, provision and size

11 Prior to 1993, the formal membership of NEMOCN consisted exclusively of four HEIs and 15 FE institutions (although two local education authorities and two local Training and Enterprise Councils were also represented on the Management Board). As the OCN has grown and developed, membership has become more widely defined, and three categories of membership have been recognised, identified by three bands (A, B and C). Inclusion in any one band is made according to the number of the member organisation's full-time equivalent learners and determines the rate of membership subscription charged. The Analytical Account lists 67 organisations in membership at January 1999: 42 members in Band A, 20 in Band B, and five in Band C.

12 In 1993, 29 Access to HE courses were approved, offering mainly one-year full-time programmes of study. With the development of OCN credit-based provision, many programmes have now developed into multi-modular Access courses containing a wide range of pathways, each focused on a particular progression route. Of the 24 programmes running in 1998-99, 20 were identified as multi-modular programmes with the remainder offering specialist provision in engineering/technology, agriculture and creative arts.

13 The number of Access programmes offered has remained relatively stable through a period when other OCN provision has increased significantly. Of the 427 programmes registered in 1998-99, 24 were identified as Access to HE courses. This represents 5.6 per cent of provision. The increase of other OCN provision is also reflected in the learner registrations. Of 26,045 learner registrations for 1998-99, 1,189 were for Access programmes, 4.5 per cent of the total number of registrations. This contrasts with 50 per cent in 1994-95, the first year in which growth of other provision was evident in the network.

14 Recent trends show a decline in Access registrations since the peak figure of 1,750 in 1996-97, despite the increased range of opportunities offered through modular Access provision. NEMOCN identifies this as a matter of concern and attributes the decline mainly to external factors, including the introduction of tuition fees in HE. The review team recognises the possible impact of such factors but would recommend that NEMOCN explores the reasons for this trend further, in relation to local circumstances and curriculum developments. Strategic consideration of extending or developing the range of pathways and modes of delivery available to learners may need to be informed by a more detailed examination of the reasons for declining enrolments on Access programmes.

Achievement

15 NEMOCN has systematically collected data relating to Access since 1991 and is to be commended for this. The data relating to achievement indicates that in 1998-99, 49 per cent of registered learners achieved kitemarked Access certificates. Although there have been fluctuations in this rate (from 35 per cent in 1996-97 to 63 per cent in 1992-93), this percentage is almost identical to that for 1990-91 (49.7 per cent) and to the average for the whole nine-year period (49.8 per cent).

16 As credit-based provision has become firmly established, the percentage of learners whose achievements is certificated has risen significantly, and 77 per cent of all learners on Access courses in 1998-99 were awarded NOCN credit certificates. The promotion and development of pre-access programmes since 1997 is also regarded as a key factor in improving learner achievement.

Aims, objectives and strategic planning

17 The stated aims of the OCN include the facilitation of 'access to further and higher education particularly for those people who have benefited least in the past from educational provision' and the promotion of 'good practice and collaboration between member organisations'.

18 NEMOCN is currently in the final year of the three-year period of its existing Strategic Plan, for 1997-2000. The Management Board of the OCN approves the Strategic Plan, which is drafted by the Director and informed by the operational activity of the officers and feedback from the various committees, advisory groups and fora. A timetable has been identified for the consideration and development of the new plan during 1999-2000, and this will be presented to the Management Board for final approval in autumn 2000.

19 The current Strategic Plan sets out seven strategic aims for the network for the three-year period. Annual strategic objectives and performance indicators are identified against the aims, and the annual report evaluates and records the OCN's progress in achieving these. The annual report is considered by the Executive Committee before presentation to the Management Board, which is responsible for approving both strategic aims and operational objectives.

20 The review team was not able to identify explicit references to the place and role of Access to HE within either the constitutional aims or the Strategic Plan of the Network. Officers and members of the OCN claimed that Access nevertheless remained central to the ethos of the OCN and was intrinsically embedded within its aims and objectives. However, the lack of specific references within the strategic aims or any of its associated detailed objectives, particularly those concerned with the accreditation service; extension and accessibility of learning opportunities; and quality enhancement and collaboration, does not appear to reflect the central role attributed by members.

21 The development of Access within NEMOCN has evolved alongside the development of other OCN provision. However, the review team considered that operational targets in relation to Access provision were limited in scope and contributed to a lack of specific developmental direction and action in this area. The team recommends that future strategic plans articulate more specifically the place of Access within the overall strategy for the network, in order to address its particular needs, and to enhance and secure its future position and status.

Target groups and targeting policies

22 NEMOCN identifies adult learners, 'particularly those who have benefited least in the past from available provision', as the key target group for its activities, and Access is clearly regarded by members as an important progression aim for those learners engaged in provision at lower levels. In particular, members of the Management Board stressed the structural importance of Access within the progression routes offered. Member institutions are responsible for identifying specific target groups for recruitment in their submission documentation for Access programmes, and the OCN officer provides advice and guidance during submission development. The statistics indicate that, in the period since the last review, there has been little change in the profile of learners recruited on to Access programmes. In 1998-99, 71 per cent of registered learners were women, and 69 per cent of registered learners were white, compared to 60 per cent and 75 per cent respectively in 1990-91. The majority of learners on Access programmes are aged between 21 and 35 years. A small number under the age of 21 years have been registered each year, with 28 (2.35 per cent) being recruited in 1998-99.

23 The Analytical Account states that 'the full potential of Access provision as a route to HE has yet to be achieved' and makes the observation that NEMOCN needs to take a more pro-active role in relation to promoting and marketing Access, in order to increase significantly the awareness and uptake of provision amongst learners. While fully endorsing the OCN's objective to take a more pro-active role, the review team noted that no strategic objectives in the current plan have been identified with regard to this, and no specific targeting policies currently exist. To date this has been largely undertaken on an institutional basis. The team therefore considers that the OCN should continue to develop strategies for improving the promotion and development of Access either through OCN activities or by active support of member institutions.

Future developments

24 The Analytical Account identifies the work of the Derbyshire Regional Network and the ADAPT project as significant areas for future development. Both of these initiatives involve further development of credit-based provision in the FE, HE and employment sectors within the region.

25 Discussion with representatives of the OCN in review meetings identified the development of part-time Access provision, promotion of Access opportunities more widely, and the need to be more forward-thinking in relation to Access developments as immediate concerns for the OCN. The review team considers that these and other issues should be placed more clearly within the strategic planning and review structures operating within NEMOCN, in order to ensure effective evaluation of progress in relation to the AVA responsibility for Access within the wider scope of OCN developments.

Governance and committee structures

Legal and constitutional status

26 NEMOCN is an unincorporated association governed by a constitution which places ultimate responsibility and authority with its Management Board. The constitution was last reviewed and amended in 1998 and includes the aims of the organisation, details of membership, and the remits and terms of reference of committees. Changes to the constitution may only be agreed by the Management Board.

Representation of members

27 The three bands of membership distinguish, in general, further and higher education institutions (normally Bands B or C), from voluntary and community organisations, local authorities, private trainers, and other representative bodies (Band A). Representation of members in the OCN's governance structures is formally determined according to their place within these different membership bands. In constitutional terms, Band C members are entitled to two representatives on NEMOCN's Management Board; Band B members have one representative. Those members who fall into Band A are represented on a separate Advisory Council which meets annually. In addition to having a role in informing the overall management, development and direction of NEMOCN, this Council acts as an electoral college: its Chair and two other nominated members join the Management Board and its Executive Committee.

Management Board

28 The Management Board meets three times a year and is supported in its work by an Executive Committee and a Quality Assurance Committee. One of the main purposes of the Management Board is to determine the strategic direction of the OCN and the constitution describes its broad remit as the 'overall policy, planning and financial management of NEMOCN'.

29 Given the Management Board's authority as the ultimate decision-making body, with whom responsibility for the AVA licence is firmly located, the review team met a number of its members and considered the minutes of its recent meetings. It noted that some organisations appeared to have a larger representation at the Management Board than allowed in the constitution. At least two Band C members, for example, are listed in the most recent minutes as having three representatives rather than two, and one Band B member appeared to have two representatives rather than one. These anomalies may be the result of substitutions or co-options, although this is not indicated in the minutes.

30 The review team heard that members of the Management Board were expected to represent the interests and views of their own organisations. In this context, the team noted that there is no apparent requirement in NEMOCN's constitution that nominated representatives to the Management Board should be of any particular seniority within their own organisations.

31 Attendance at the Management Board is, on average, some 30 per cent of eligible members. NEMOCN's constitution does not specify a quorum for the Management Board or any of its sub-committees. While this may not be a particular issue for the normal business of the Board, the review team noted that the constitution of NEMOCN had been amended in 1998 with just over a third of Management Board members present. In the context of more standard governance procedures, this might be considered as unusual.

32 The review team heard that an important function of Management Board members was to act as a channel of communication between NEMOCN and their organisations. Given the relatively low attendance at Management Board meetings, there is the potential for this route to be inconsistent or not to function at all. In one clear example, QAA's advice on age restrictions for entry to Access programmes issued in May 1999, it was apparent that guidance had not reached the level of all Co-ordinators for Access provision accredited by NEMOCN.

Executive Committee

33 The Executive Committee is established on an annual basis by the Management Board to oversee the day-to-day operation of NEMOCN. Membership comprises the Chair and Deputy Chair of the Board; the Chair of the Quality Assurance Committee; one representative from higher education and two representatives from further education nominated by the Board; and the Chair and two other members of the Advisory Council. The Committee has established a separate Staffing and Remuneration Committee for the detailed consideration of the contracts and pay of NEMOCN's officers.

34 While its remit for the day-to-day management of the OCN might indicate more frequent meetings than those of the Management Board, the Executive Committee also meets three times a year. Although minutes demonstrate the detailed level of some of its business, the periods of time which elapse between meetings also suggests the difficulty which it might experience in fulfilling its remit. The review team heard that a good deal of interaction took place between Executive Committee members and NEMOCN officers outside scheduled meetings. As an operational method this is doubtless effective but, in terms of governance, it also has the potential to call into question the balance between those decisions it makes as an established body, and those which are made on a more ad hoc basis.

Quality Assurance Committee

35 Acting with delegated authority from the Management Board, the Quality Assurance Committee carries the responsibility for the oversight of all quality assurance processes within NEMOCN, including service standards, programme recognition and evaluation, moderation, and certification. Its membership is reviewed on an annual basis by the Board and includes representatives from further education, higher education, and the voluntary/community sectors.

36 Since the last formal AVA review, the working methods of the Quality Assurance Committee have been subject to evaluation and consequent change. The volume of provision within NEMOCN initially led the Committee to request summary reports from officers rather than to scrutinise, for example, all annual reviews or moderator reports on an individual basis. The Committee did not, however, consider that this method provided a sufficient level of evidence for it to fulfil its remit. NEMOCN thus developed a more distinctive audit approach for the Quality Assurance Committee that was implemented in 1997-98.

37 The audit methodology involves individual members of the Quality Assurance Committee taking a lead responsibility for auditing a particular aspect of the OCN's operation. Currently there are five such aspects: programme recognition, certification, moderation, organisation, and the general AVA function. In most cases, another member, or members, of the Committee assists the lead auditor.

38 In discussion with members of the Quality Assurance Committee, the review team heard that, typically, the equivalent of two days a year might be spent by auditors in reviewing their assigned area of the OCN's operation. This could include sampling of the work of officers, seeing appropriate reports and reviews, and a more general review of the process in question. At the end of each cycle, a report is made to the full Quality Assurance Committee.

39 While the Management Board must necessarily keep in mind the nature of this work when making nominations to the Quality Assurance Committee, there is no guarantee that all members of the Committee have prior experience or knowledge of audit methodology. The review team heard that a comprehensive induction pack was made available and that officers were uniformly helpful in guiding auditors as they undertook their work. However, there is no formal training programme to prepare members of the Committee to undertake their auditing duties. Given the often specialist nature of such work, and the crucial importance to NEMOCN of the audit approach to quality assurance, the OCN may wish to consider whether such a training programme should be introduced.

40 As a relatively new process, the audit approach of the Quality Assurance Committee has yet to be formally evaluated, although the details of its operation are discussed on a continuing basis by the Committee itself. The advantages of the method, as expressed by NEMOCN, are the opportunity for Quality Assurance Committee members to become thoroughly familiar with one aspect of the OCN's operation, and the provision of an identified Committee member to act as a source of advice and guidance for issues which may arise during the year. The review team would recommend that a formal review of the audit process is planned for the near future and that some particular consideration is given to the issue of whether Committee members can act as both advisors and auditors without a potential conflict arising between those two roles.

Advisory Council

41 NEMOCN established the Advisory Council to provide an opportunity for its Band A members to contribute to the work of the OCN. In particular, its role is to advise the Management Board on the interests of the smaller member organisations. In theory, the Council can play a powerful role, particularly since it has the right of direct representation on the Executive Committee, potentially supplying three of its nine members.

42 Originally meeting on the same schedule as the Management Board, the Advisory Council now has a single annual general meeting. This does not appear to have improved attendance (five representatives attended the last two meetings of the Council out of over 40 Band A organisations). More importantly, at its meeting in November 1998, the Council was unable to find sufficient nominations to fill its eligible membership on the Management Board and Executive Committee.

43 Despite the best efforts of NEMOCN to give a voice to its smaller member organisations, and with no reflection on the quality of the advice which is currently offered by those who participate, the Advisory Council does not appear to be an effective part of the governance structure of the OCN.

Access to Higher Education Forum

44 In most respects, the AVA function of NEMOCN has been absorbed fully into its general committee structures. However, the OCN does facilitate an Access to Higher Education Forum, which meets annually in the form of a conference addressing a particular theme related to Access provision. At each conference, an annual general meeting of the Forum elects a steering group chiefly to be responsible for the organisation of the following year's event.

45 The value of the Forum as an opportunity for Access practitioners to discuss areas of mutual interest is undoubted. However, the Forum has no other role in the governance of NEMOCN (unlike the Advisory Council, it does not, for example, have particular representation on the Management Board or the Executive Committee). The review team saw evidence in the minutes of the Forum's Steering Group meeting in June 1999 that it wished to become more active in this respect, particularly as regards the scrutiny of standards in Access programmes. Amongst other proposals was the establishment of a Quality Assurance Task Group to carry out audits of Access programmes within NEMOCN's provision and a general intention 'to be proactive and responsive [to] the changing Access environment, whilst ensuring rigorous maintenance of standards and comparability across the region'.

46 Although the Forum has the discretion to report directly to any of NEMOCN's committees, it is not apparent how such proposals might be considered formally. At the time of the review, it was not possible to ascertain whether they had been placed before the Quality Assurance Committee. However, the proposals do in themselves raise for NEMOCN the question of whether Access provision - as a minor but identifiable proportion of its work - has an adequate voice in its governance structures.

Committee structure: summary

47 In many respects, NEMOCN experiences the same governance and committee structure issues as any multi-member consortium. It is determined to maintain a strong sense of partnership and governance through common purpose, but also seeks effective and efficient methods of business operation for which its officers must take responsibility.

48 The review team heard that, at present, NEMOCN had no particular plans for an evaluation of its governance structures. The team would recommend that the Management Board does undertake some formal evaluation of governance: this might include some further consideration of the frequency of, and attendance at, meetings; the question of whether a quorum should be introduced for its committees; the use of Management Board representatives as a channel of communications with member organisations; the future of the Advisory Board; and the role and formal place of Access more generally in the committee structure.

Management, organisational structures and administrative arrangements

49 In respect of its administrative organisation, NEMOCN contracts financial and personnel services from the University of Derby. All NEMOCN staff are formally employed by the University. However, while the University offers advice and guidance on staffing and contractual matters, it does not influence pay scales or the number and nature of appointments. Staff appraisals are conducted by the Chair and Deputy Chair of the Management Board. It appeared to the review team that the relationship between NEMOCN and the University of Derby was focused clearly on the provision of paid services and did not unduly encroach upon the independence of NEMOCN as a separate organisation.

50 The internal management and operation of the OCN is the responsibility of the Director, who is accountable to the Management Board for, inter alia, strategic and financial matters, staff management, and external liaison. A Senior Development Officer, who manages all development support to member organisations, is also designated as Deputy Director.

51 Four other full-time posts have been established reflecting the needs of NEMOCN: a Quality Assurance Officer, a Finance and Information Officer, a Senior Administrative Officer, and a Development Officer (who carries a particular responsibility for Access courses). The staff team is completed by eight other administrative and clerical staff.

52 In addition to undertaking the standard operational work of the OCN, some officers have vital roles to play in matters related to quality and standards. These activities are accentuated by the particular audit methodology adopted by the Quality Assurance Committee. Considerable responsibility is placed on officers to ensure that an appropriate balance is maintained between their individual, executive action and matters which might properly be referred for discussion and action by the OCN's committee structure.

53 In general terms, it appeared to the review team that NEMOCN was well served by its administrative and clerical staff. In particular, methods and arrangements for data collection are sound and the OCN is in the process of developing an enhanced database capable of responding fully to the requirements of external agencies including its annual report to the QAA as an Authorised Validating Agency.

The development, validation and evaluation of Access programmes

Development and validation of new provision

54 NEMOCN has designed a thorough process covering all aspects of programme development and recognition. In the initial stages, a Development Officer works with tutors to ensure that submission documents are accurate and comprehensive in preparation for a more formal recognition or validation event. Detailed pro formas are issued by the OCN to cover individual unit specifications as well as more general programme and provider information. Separate documents are employed where a broader credit framework is offered for recognition together with more streamlined submission for additions to such frameworks which are already recognised. In each case, NEMOCN also issues helpful notes for guidance.

55 Acting on behalf of the Quality Assurance Committee, it is the responsibility of the assigned Development Officer to approve the readiness of a proposal to progress to a formal recognition panel. In respect of proposed Access programmes, this panel's membership includes representation from further and higher education providers. The OCN provides general guidance to recognition panels and, specifically, to those undertaking the validation of Access programmes. Such guidance is detailed and includes a set of principles to which a proposed programme must adhere, together with advice on specifications for the award of the kitemark, notes on the approval of individual programmes of study, and arrangements for the accreditation of prior learning.

56 A formal recognition panel report records the decisions of the panel, including any recommendations or conditions. In the latter case, recognition is withheld until such conditions have been met. This process is usually undertaken by a NEMOCN officer, although a recognition panel has the discretion to request and receive responses for final approval. Examples of recognition panel reports considered by the review team demonstrated the detailed and careful consideration given to submissions. However, the team noted that such reports for Access programmes do not formally record that they have been approved as meeting all the requirements for the award of a kitemarked Access certificate. The OCN may wish to consider the inclusion in the report of a formal note to this effect, where appropriate.

57 In summary, and on the evidence of recognition panel reports and discussions with both officers and tutors from providing organisations, the review team was able to confirm the thorough and robust nature of the programme recognition process operated by NEMOCN.

Monitoring, evaluation and review of programmes

58 The OCN requires an Annual Evaluation and Review report for each of the programmes which it recognises (a further summary report is also required where a provider operates programmes through a broader credit framework). A common format for such reports is encouraged which, in particular, requires the tabulation of major issues, the action proposed, responsibility for such action, and the timescale by which it will be achieved. Review reports are considered by officers of NEMOCN and, where necessary, issues are raised with providers or, where relevant, with moderators for the programme in question. In discussion with Access programme leaders, who generally confirmed the value of the annual review process, the review team heard that such feedback is usually provided promptly.

59 The Quality Assurance Committee is informed in the case of late submission of reports and considers the reasons for delay. Minutes of the Committee demonstrated that this responsibility was taken seriously, with some programmes being subject to additional monitoring in the subsequent year. Providers are also given notice that the withdrawal of recognition is a possible consequence of not fulfilling the requirement to submit reports on time. Discussions as to the reasons for late reports have also prompted the OCN to review the current format: a revised version is to be introduced to give more emphasis to issues of concern and the proposed action to address them.

60 Given that it is not the practice of the OCN to have a standard period of approval for its recognised provision beyond the one year specified at the Recognition Panel, the Annual Evaluation and Review report is an important opportunity to confirm the continuing health and viability of a programme. The review team was able to confirm that the process of annual review was conscientious and carefully managed, with the OCN actively enhancing its systems through evaluation of the outcomes of each round.

61 In many senses, Triennial Moderation Review serves a similar purpose of 're-validation'. Introduced in 1996-97, this process was designed to test whether programmes remain fit for purpose at the end of a three-year period, and whether consistency was being achieved across programmes offered by different providers in similar curriculum areas. In the 1998-99 exercise, 12 panels were convened and considered 49 individual programmes. While some difficulties were experienced where the appropriate moderators and tutors were unable to attend an event, the review team saw evidence that Triennial Moderation Review had been conducted in a methodical and constructive manner which had led not only to the confirmation of the majority of programmes but also to the referral of others for development support and re-submission to a recognition panel.

62 It was less evident that Triennial Moderation Review was achieving its objective to act as a method to ensure consistency of standards across a range of programmes. While the guidelines for the exercise emphasise this aim, the ensuing reports appeared to focus largely on the status and viability of individual programmes with little overt reference to comparisons across the range of OCN-accredited provision. In its own evaluation, NEMOCN acknowledges that the absence of some moderators and tutors from specific events had not been helpful in this respect. The OCN may wish to undertake some further analysis of how this particular objective of Triennial Moderation Review can be more fully achieved.

Assessment, moderation and award of certificates

Assessment

63 Assessment standards were separately identified by NEMOCN in April 1999 as part of the quality audit arrangements within the network. Comprehensive guidance documentation provided by NEMOCN for tutors developing submissions clearly identifies the requirements for assessment for each individual programme submission, and recognition panels consider the appropriateness of the management, methodology and evidence requirements for assessment as part of the approval process. The pro forma for completion by submitting tutors, relating to assessment, was significantly revised recently, as a result of the continuing evaluation of procedures within NEMOCN.

64 The importance of reporting on assessment is manifest in the moderator reports and annual review documentation for Access programmes. Evidence presented for the review demonstrated that NEMOCN requires rigorous and appropriate assessment as a key focus within Access provision and operates sound monitoring and reporting procedures to ensure that this takes place within individual programmes.

Selection, appointment and training of moderators

65 The management of moderation within NEMOCN is the responsibility of the Quality Officer supported by the Senior Administrative Officer. Currently there are 48 Access moderators contracted by the network and of these 38 per cent are drawn from the HE sector. 56 per cent of all Access moderators moderate on one programme only, with the others moderating up to four programmes in one year.

66 All moderators are required to complete an application form giving information about their relevant experience and suitability to undertake moderation duties on behalf of the OCN. Comprehensive guidelines are produced for all moderators and selection criteria are clear. Moderators are appointed to a named programme/pathway and this is usually endorsed at the recognition panel and confirmed in the panel report. Where an appointment is not made at the panel, the OCN Officer identifies a moderator at a later date. The review team suggests that a process to confirm the suitability of an appointment in these circumstances should be considered by the OCN to ensure the consistent application of the appropriate criteria and standards.

67 All new moderators are briefed by an OCN Officer and NEMOCN is to be commended for the individual attention given to new appointees through briefing sessions. All moderators are required to attend the training sessions held regularly by the OCN, and attendance at these sessions appears to be satisfactory.

68 Moderator contracts are issued on an annual basis and payment for moderation activities occurs on receipt of a claim accompanied by the annual moderator report, a system which appeared to work satisfactorily. Moderators are appointed to a named programme or pathway for a period of three years. However, the review team was concerned to learn that a number of moderators had operated with the same programme for much longer periods, in one instance for over 10 years. While fully acknowledging that this length of service demonstrates commendable commitment by the moderators concerned, the team recommends that the OCN clarifies its policy about the permitted length of appointment to any one programme, and applies this policy consistently across its Access provision.

69 With the development of complex framework provision, it is clear that the OCN has considered carefully the arrangements for assessment and moderation and is developing systems and support to ensure that these are applied effectively.

70 One key external development influencing models of moderation has been the introduction and increasingly widespread use of internal verification (IV) within further education. The use of IV within Access programmes is still evolving and the review team noted some concern expressed by moderators as to the effectiveness and consistency of application of IV practices for Access. OCN guidelines have been produced with regard to IV but, with continuing developments in this area, these will need careful monitoring and there may be a need to strengthen the support and guidance available to providers and moderators, in order to ensure consistency of moderation practice in Access provision in relation to the use of IV.

Moderator reports and responses

71 Clear and detailed guidance is provided to moderators in relation to the production of annual and triennial review reports. All reports are read by officers and points for action identified. Copies of annual reports are forwarded to programme tutors by the moderator. Selected reports are seen by the Quality Committee representatives assigned to oversee moderation as part of the internal quality audit arrangements. The review team heard that Quality Committee auditors made their own selections of reports for audit purposes, and ensured that the sample included reports on Access programmes.

72 Matters identified for action are dealt with by the OCN officer or the Quality Officer in liaison with the institution, and where this is inappropriate the matter is referred either to the auditor for moderation from the Quality Committee or to the whole committee for consideration and action. The audit methodology has the potential to prevent the Quality Committee from taking an overview of general issues arising from moderator reports. The review team recommends that, in reviewing its audit approach, the OCN gives particular attention to the effectiveness of the method in identifying generic issues which have been noted in individual moderation reports, and reporting these systematically to the Quality Committee of the OCN.

Moderation, comparability and standardisation

73 The terms of reference for the Moderation Forum identify consideration of strategies for consistency and benchmarking activities as important areas. The review team heard, in discussions with tutors and moderators, that the twice-yearly meetings of the Forum were regarded as key mechanisms for the consideration of matters such as standardisation and comparability. The team noted that the most recent Forum was structured to provide information and offer opportunities to discuss moderation issues, but that only six out of 30 of those attending were Access moderators. These moderators have recently identified a need for dedicated fora which would allow greater emphasis on the particular issues relating to Access. The team strongly supports the OCN's intention to establish Access moderator fora, and also to set up subject/curriculum task groups which will include moderators with particular remits around standardisation and consistency.

74 The development of credit framework initiatives and the modularisation of large Access programmes have highlighted the need to define clearly the roles and responsibilities of moderators. The OCN has, as a result of review, redefined the role of Lead Moderators for Access to HE. The review team commends this development and the clarity of documentation to support it.

75 The review team concluded that, overall, moderation practice within the OCN in relation to Access was comprehensive, sound and well supported.

Certification

76 Award of 'kitemarked' certificates is underpinned by rigorous systems and procedures. All Award of Credit forms are signed off by the moderator following moderation meetings and moderator signatures are checked on receipt in the OCN office. A reference sheet has been produced for each programme to enable office staff to check individual achievement requirements before certificates are issued and dispatched. The review team concluded that certification procedures were sound and that administrative practices in relation to these were appropriately prudent and thorough, and were operating within acceptable timescales.

Learner experience, standards and progression

Learner experience

77 The evidence available to the review team from meetings with students, Access moderators, and receiving HE admissions tutors, indicated that Access courses generally prepare students well for progression to higher education. Students currently studying in HE institutions reported that credit-based Access provision helped develop their skills and self-confidence through appropriate delivery patterns, pace of learning and assessment mechanisms, and praised tutors for the guidance and support provided to students. HE admissions tutors also reported favourably on the preparedness of students coming from Access courses. The review team concluded that students on Access to HE courses approved by NEMOCN were well equipped to cope with the varied demands of studying in higher education.

78 The 'kitemark' standard achieved by successful students is understood and well respected by HE institutions locally. HE tutors make offers based on successful achievement of the 'kitemark' with more detailed credit requirements applying for some HE courses.

79 Providing member institutions within NEMOCN implement regular reporting and monitoring systems to evaluate student feedback. These vary across institutions but appear to be effective in informing organisations about the effectiveness of all aspects of Access students' experience and the quality of provision. The OCN receives this information through the annual moderator reports and annual programme reviews. Much of the current monitoring appears to be institutionally-led rather than directed by the OCN, and though this may be effective for individual programmes, sharing of this information across the network may be important to ensure the consistent development and enhancement of Access provision.

Progression

80 Guidance for learners on HE requirements and admissions procedures, and opportunities for them to visit HE institutions, are provided by the individual FE institutions. The OCN does not appear to provide or direct activities in this area. The review team recommends that NEMOCN should consider ways in which it could adopt a more pro-active approach to supporting admission through provision of information for learners and events promoted by the OCN.

81 A particular area of difficulty in admissions was reported by tutors and students in relation to HE courses in nursing. This relates to the national requirement for applications which are made centrally to Dip HE nursing courses to be made post-qualification. In some instances, this requires students to wait 12 months between completion of an Access course and entry to a nursing course. HE admissions tutors also reported some concerns with teacher training admission requirements in relation to Access. Currently, such matters are dealt with through communication between HE and FE on an individual basis. HE admissions tutors indicated that they would welcome more opportunities to discuss matters related to admissions directly with the OCN, and the review team suggests that the OCN considers mechanisms by which concerns could be communicated through the OCN and discussed more widely across the network, in order to keep students, tutors and admissions staff informed and updated.

82 The team noted the good practice adopted by the Derbyshire Regional Network in relation to admissions activities and liaison between FE and HE institutions within the framework.

83 Despite some difficulties experienced in collection of information, the OCN has, commendably, collected progression and destination data regularly since 1993, and has progression data from 1991. The figures for 1991 to 1994 show progression rates of over 90 per cent for each of the four years. Since 1995, progression rates have been less consistent, and in 1999 the rate dropped to 72 per cent. The OCN's efforts in the collection of these statistics of progression and destinations of Access students do not yet appear to have been matched by any substantial analysis which might be used to inform future planning and development.

Conclusions

84 NEMOCN is a large and diverse OCN which has responded effectively to the need to bring accreditation to previously non-accredited provision, thereby extending and expanding the range of its accreditation services and the focus of its development activities. It has proved itself a robust and flexible organisation through its ability to accommodate, over a relatively short period, this variety of provision and its different needs, and to respond to demands from a wide range of sources, both those brought by local providers and other members, and those brought by a number of national developments.

85 The substantial growth in non-Access provision has resulted in a situation in which Access to HE now occupies a relatively small part of the OCN's total business. At the same time, there has been a decline in numbers of registrations on NEMOCN's Access programmes. This may be, as the OCN perceives it, attributable in part to external factors which are beyond the OCN's control: nonetheless, there have been few attempts by the OCN formally to explore or address the reasons for this decline. Indeed, there are few signs of growth in any areas of NEMOCN's activities relating to Access, and the necessary attention given to other areas of primarily pre-Access provision appears to have contributed to a concomitant lack of dedicated attention to the development of Access provision or its particular and changing needs.

86 As the OCN's activities have expanded, it has developed thorough quality mechanisms to fit the range of its provision. The OCN is alert to the importance of adequate and effective quality assurance systems, and this is exemplified by its close attention to NOCN quality standards. The quality of the Access provision for which NEMOCN holds AVA responsibility appears to be sound, and it is subject to an appropriate range of mechanisms for quality assurance which are applied systematically. In terms of the supervision of the processes of recognition, moderation and evaluation of Access programmes, the OCN discharges its responsibilities effectively. Processes and procedures are supported by thorough documentation and guidance available to providers and other users of the OCN's services.

87 There are some areas that would benefit from further development, particularly in respect of procedures for reporting and review, to ensure that outcomes inform the development and continuing enhancement not only of systems but also of the provision itself, in order to assure the OCN's continuing responsiveness to change and the fitness for purpose of its recognised Access courses. The recent change of role for the Quality Assurance Officer, to cover a wider range of responsibilities than were included in her remit as Moderation Officer, gives more structural emphasis on all quality assurance matters. This may provide the opportunity for an overview of operations as well as a consideration of the details of processes.

88 This role will become especially important in view of the audit model that has been adopted by the Quality Assurance Committee. With a process which essentially divides - rather than shares - responsibilities between Committee members, it will be important to ensure that the Committee does not lose an appropriate overview of quality matters. While this newly established process provides an innovative solution to the identified difficulties of previous systems, it is, in a number of ways, a high-risk strategy. It has the potential to examine in detail the quality systems across the full range of the OCN's operations, but in order to achieve this securely, it could become a time-consuming and onerous responsibility for the individuals involved. Since the model places considerable responsibility on individuals, it creates particular issues of accountability, with committee members' experience and ability to undertake this kind of work being of critical importance. The Committee displays a healthy readiness to evaluate and modify its own processes, and the audit system itself is one result of the Committee's self-critical reflection. In the continuing monitoring and evaluation of its own processes, the Committee will need to consider not only the effectiveness and efficiency of the model, but also to assess whether there are sufficient safeguards against some of the potential difficulties and dangers of such a system.

89 The inclusion within the audit system of a representative from the Quality Assurance Committee with specific responsibility for the AVA function is the one clear place identified for Access within the formal structures of NEMOCN. Other than this, the structures themselves give no defined voice to Access. There is a strong presence on committees of committed individuals who are involved with the delivery of Access programmes and the progression of Access students, but this is largely incidental. The review team heard that it has not been necessary to consider Access separately since it is a natural part of the operation of the OCN. However, in the shifting emphasis of the OCN's work there has been a diminution of a defined place for Access within the larger organisation. While there appears to be some support amongst practitioners for a special place for Access through the functions of an Access to HE committee, there does not currently seem to be similar support for any such change at the centre of the OCN's governance or management.

90 The lack of a clear location for Access within NEMOCN's current structures places it in a potentially vulnerable position. The absence of any specific strategic objectives relating to Access is indicative of this vulnerability: where no formal priority has been given to an area, the risk of its marginalisation increases. The assumption that consideration is given to Access as an implicit part of all processes masks the fact that in structural, and therefore developmental, terms, the specific attention given to Access within the OCN is currently negligible.

91 The review team commends NEMOCN for:

i the sustained and systematic collection and collation of data relating to Access;

ii the thorough and robust nature of its programme recognition process;

iii the conscientious and careful management of the process of annual review;

iv the attention given to the induction of new moderators through briefing sessions.

Recommendation to the ARLC

92 The review team recommends that NEMOCN be granted a conditional renewal of its licence with conditions to be met by the dates specified below.

Conditions

93 Subject to the approval of the ARLC, NEMOCN's AVA licence is confirmed on condition that it:

i undertakes a review and evaluation of the place of the AVA within the governance structure of the OCN, to ensure that the OCN is able to meet fully all of its responsibilities as a licensed AVA, as specified in the QAA Recognition Scheme for Access to Higher Education in England, Wales and Northern Ireland (Part B). The OCN should pay particular attention to the following responsibilities:

• 'the review and evaluation of Access to HE provision within the AVA';
• 'the enhancement and promotion of Access to HE provision within the AVA';
• 'collaboration with institutions of higher education to ensure continuing fitness for purpose of recognised programmes';
• 'the regular review and self-evaluation of AVA processes';
• 'the provision to Access to HE providers of information about changes in QAA regulations or requirements affecting Access to HE programmes'.

As a result of this review, the OCN should identify any necessary structural and operational changes and develop a strategy to implement these changes (by 1 June 2000);

ii develops strategic objectives relating to Access, as a part of its more general strategic planning process (by 1 June 2000);

iii adopts procedures for communications which are effective in ensuring that Access to HE providers are notified about information received from QAA, when this concerns regulatory matters pertaining to provision (by 1 April 2000).

Recommendations

94 The review team recommends that NEMOCN:

i explores the reasons for trends in Access registrations, in order to inform the development of a strategic approach to targeting and to programme initiatives, including provision of appropriate support to providers;

ii plans a formal review of the quality audit process, to take place in the near future and, if the process is to be retained, establishes a formal training programme for Quality Assurance Committee members who undertake the role of auditor;

iii undertakes a review of the governance and committee structure with particular reference to the issues noted in paragraph 48 and the preceding text of this report;

iv makes a formal note in the recognition panel report where an Access programme has been approved, to confirm that it has met all the requirements for the award of a 'kitemarked' Access certificate;

v gives some further consideration to how Triennial Moderation Review is achieving its objective to act as a method to ensure consistency of standards across a range of programmes;

vi reviews the process by which the OCN is alerted to the length of time served by any Access moderator, to ensure that its policy for length of service of moderators is applied consistently;

vii monitors the development of internal verification systems as they affect Access provision, and considers the need for any necessary modifications to the model for moderation within the AVA or for further advice to moderators;

viii addresses the specific development needs of moderators on Access to HE programmes, for example, through the establishment and maintenance of Access moderator fora;

ix considers how it might provide opportunities for progression concerns of Access students, programme leaders and HE admissions staff to be communicated through the OCN, in order to ensure that the OCN is able to address recurrent matters or those with wider implications.