Open College Network Kent and Medway
March 2001

Web site for Open College Network Kent and Medway

Contents

• Foreword
• The AVA context
• Governance and committee structures
• Operational management and administrative arrangements
• 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 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 of a major review of the AVA function of the Open College Network Kent and Medway (OCNKM) undertaken by QAA. The Agency is grateful to OCNKM and to those who participated in the review for the willing cooperation 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 Access to HE 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 date;

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

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. The preparation for the review included an initial meeting between OCNKM officers and the QAA Assistant Director with responsibility for Access to HE matters to discuss the requirements for the Analytical Account (the Account) and the process of the review; the preparation and submission by OCNKM of its Account, together with a selection of supporting documentation; a meeting of the review team to discuss the Account and supporting documentation and to establish a draft programme for the review visit; and negotiations between QAA and OCNKM to finalise the programme and other arrangements for the review visit.

7 The review visit took place on 8 and 9 November 2000. The visit to OCNKM consisted principally of meetings with representatives of OCNKM, including OCN officers; members of the Members' Council, Board of Trustees, Quality Committee and Access to Higher Education Quality Committee; moderators for Access programmes; Access programme leaders; HE admissions staff; and former Access students now studying in HE.

8 The review team consisted of Dr Pete Johnston, Head of Access and Associate Director of Overseas Relations, University of Essex; and Mr Malcolm Barry, Director of Continuing Education and Head of Professional and Community Education, Goldsmiths College (University of London). The review was coordinated for QAA by Ms Kath Dentith, Assistant Director (Access), Institutional Review Directorate.

The AVA context

AVA statistics 1999-2000

9

Providers offering Access to HE programmes - 10

Access programmes available 32 Access programmes running - 29

Access learner registrations - 720

Access to HE certificates awarded - 467

Background

10 Open College Network Kent and Medway (OCNKM) originates from the Kent Access Consortium (KAC), which was recognised as an AVA in February 1990.

11 At the time of the last review of the AVA, undertaken by HEQC in May 1994, the KAC was actively considering the impact of moves towards development of an OCN in Kent. The Critical Self Appraisal prepared by the AVA for that 1994 review records as the final recommendation that 'in 1994/95 Kent TEC and the HE Colloquium have agreed to fund a development project in collaboration with KAC which will examine the issue of an OCN'. The outcome of this project was the recommendation that an OCN be established in Kent which would incorporate the AVA activity of KAC.

12 In 1996, Open Access in Kent (OAK) was formally established as an Associate Member of the National Open College Network (NOCN), incorporating KAC and maintaining responsibility for its AVA function. In 1998, under the new designation Open College Network Kent and Medway, the organisation achieved three significant milestones in its development: it was incorporated as a private company limited by guarantee; it acquired charitable status; and it was awarded full membership of NOCN.

13 The Account includes a concise summary of the recommendations from the HEQC 1994 review and of the AVA's response to these. All the recommendations have been addressed by specific AVA action or been overtaken by national developments in Access to HE provision and, in particular, by the AVA's move to OCN status and the delivery of credit-based unitised provision. This last development is discussed in further detail below (see paragraph 68).

Membership and provision

14 OCNKM's 20 member organisations are drawn from a range of sectors including further and higher education; community, voluntary and private organisations; and local councils. There are three higher education institutions in membership of the OCN: the University of Kent at Canterbury; Canterbury Christ Church University College; and the University of Greenwich.

15 Access to HE provision validated by OCNKM is delivered by all six of its FE members (Canterbury College, Mid-Kent College, North West Kent College, South Kent College, Thanet College and West Kent College) and by three Adult Education Centres (Dartford Adult Education Centre, Medway Adult and Community Learning Service [Gillingham Centre] and Tonbridge and Tunbridge Wells Adult Education Centre) specialising in Access to Art. Additionally, two of the HE members are Access to HE providers, namely the University of Kent at Canterbury, and Canterbury Christchurch University College, which provides a specialist music programme. In the Account, the AVA comments that its Access provision 'is offered in what might now be termed "traditional" mainstream centres' and accordingly aims to 'promote the development of Access provision in new centres and in innovative ways'. As a particular initiative, it quotes the interest of the Kent Adult Education Service 'in developing a service wide suite of Access provision offered at its countywide network of centres'.

16 Since the time of the 1994 HEQC review, there has been a trend towards large modular programmes in contrast to the discrete programme structure which dominated in the early years of the AVA, and this has contributed to a reduction in the total number of programmes. The AVA holds the view that this trend has probably been accelerated by the move towards the unitisation of programmes. The AVA's approach to the process of unitisation has only required a provider to unitise and adopt the credit framework when the existing period of validation expires. As a consequence of this policy and the fact that 'informal feedback from providers...shows that this conversion [to expression in a unitised credit-based format] has created some tensions for individual tutors who have shown some reluctance to embrace the unitised format', in 1999-2000 the majority of programmes in Kent remained outside the credit framework. The AVA intends that this position will be reversed in 2000-01.

17 Access to HE learner registrations for 1998-99 totalled 804, whereas the corresponding figures for 1997-98 and 1996-97 were 966 and 815 respectively. The review team heard that recruitment to and retention on Access programmes had become more difficult, and this perception has some support in the decline in numbers of Access learner registrations since 1997-98, although there does not seem to be a significant decline over the longer peiod. The AVA regards the advent of increased employment opportunities in the north west of its region as one major factor contributing to this decline, and it would appear from the uneven experience by providers of declining numbers that this may well be a significant factor in recruitment. It is, however, a complex picture, and the AVA's intention to review the data currently collected about Access students, as indicated in the Access to HE Action Plan 2000-2001, may give it the opportunity to analyse these trends more fully.

Financial matters

18 Whereas in 1994 KAC was an unincorporated association subsidised by the University of Kent with regard to premises, and dependent on 'in-kind' financial support from its member institutions, OCNKM is a separate legal entity with its own bank accounts, budgetary and financial systems. As a private company it is limited by guarantee, and as a charity, is subject to external scrutiny by Companies House and the Charity Commissioners. The statement of accounts for the period 6 March 1998 to 31 July 1999 shows that of the £182,243 of incoming resources, £82,608 (ie 45 per cent) was through grant support from Kent County Council, Medway Council and Kent TEC. The other major components of income were:

i accreditation charges - £58,296 (ie 32 per cent);

ii role in supporting accreditation of a NOCN national qualification - £19,971 (ie 11 per cent);

iii membership fees and subscriptions - £15,550 (ie 8.5 per cent).

19 The Account states that the 'medium term strategy of the OCN is to reduce its reliance on income from relatively high membership fees for key stakeholders and grant income from local authorities. This will be achieved by generating a higher level of income through accreditation services and by ensuring that charges for these services are sufficiently realistic to cover the costs of the OCN'. The need to generate a higher level of income implies a significant increase in the number of learners receiving OCN accreditation, and the review team was informed that the OCN was seeking a threefold increase in student numbers over a three year period. With restricted potential for further growth in the FE sector, the OCN is looking for diversification in its offer and alternative areas for development.

20 As an interim measure, it has requested and secured additional funding from the major constituencies of its membership, namely the FE college members and the Kent Adult Education Service. The proposal from OCNKM (of May 2000) to the Kent Association of Further Education Colleges (KAFEC) for additional funding support for OCNKM 2000-02 was submitted in the context of OCNKM's application for the award of an NOCN licence. It makes explicit reference to OCNKM as 'the smallest and one of the newest OCNs', 'still in the early stages of development' with limited potential to generate increased revenue from the existing business base. OCNKM therefore asked 'KAFEC to provide an additional, short-term injection of funding to OCNKM to support its development' to the sum of £18,000 for 2000-01 and £12,000 for 2001-02. Additional funding was also secured from Kent Adult Education Services (KAES) through a service level agreement to provide dedicated support for the development of OCN accreditation across the curriculum offer of KAES.

21 The unapproved minutes of the Board of Trustees' meeting of 3 November 2000 record the Company Secretary's report that 'an operating profit of £6,218 (excluding reserves) had been made for the period 1999-2000'.

22 Given this context of continued reliance on pump-priming funding and OCNKM's current vulnerability as the smallest and one of the newest OCNs, OCNKM has engaged in discussions with the South of England Open College Network (SEOCN) regarding contingency arrangements. The document Strategic and Business Planning 2000-2003 records the fact that 'in the event of unforeseen events destabilising either OCN [ie OCNKM or SEOCN], provisional discussions have been started re supporting learners on a mutual basis. Both OCNs are Access to HE AVAs and the compatibility of ICT systems and charging structures would support emergency arrangements should they prove necessary'. The compatibility of ICT systems is a direct consequence of the fact that OCNKM uses the OCN database developed by SEOCN, and the general influence of SEOCN derives from the fact that SEOCN acted as mentor to OCNKM when it was an associate member of NOCN.

23 As regards the formal status of these discussions, the minutes of the Board of Trustees' meeting of July 2000 record that 'formal talks were planned with SEOCN, the neighbouring OCN, in order to draw up a Memorandum of Agreement in the event of something unforeseen happening to either OCN. The intention would be to draw up an exit strategy to best serve the interests of the learners of the respective OCN. It was noted that this agreement would be submitted to the Board for final approval'.

24 With reference to the above, it is relevant to note that the OCNKM Memorandum and Articles of Association specifies that 'in furtherance of the objects but not otherwise the Charity may exercise the following powers...to amalgamate with any companies, institutions, societies or associations which shall be charitable by law and have objects altogether or mainly similar to those of the Charity and prohibit payment of any dividend or profit to and the distribution or any of their assets among their members at least to the same extent as such payments or distributions are prohibited in the case of members of the Charity by this Memorandum of Association'.

Mission, aims, objectives in relation to Access to HE provision and planned developments

25 OCNKM's mission is to 'promote credit based education and training at all levels, including entry to higher education in the region with a particular emphasis on those people who have benefited least from prior education and training'. This is appropriately represented by the set of Objects of the Company and as regards Access to HE provision, specific reference is made in the following objects:

l Object (1) 'Provision of an Open College Network, which is also an Authorised Validating Agency (AVA) under licence from the Department for Education & Employment which works on behalf of its membership to approve programmes of learning';

l Object (7) 'Improving access to higher education by establishing, carrying on and conducting the work of the National Open College Network (NOCN) accreditation system in Kent and elsewhere and conducting the work of Open Access in Kent as an Authorised Validating Agency under licence from the appropriate agency within the Department for Education and Employment';

l Object (8) 'Improving the recognition of educational qualifications by issuing nationally recognised Access Certificates and credits, for learning achievements by persons completing approved programmes of learning, which are awarded independently of the providers of such courses'.

26 These are then represented appropriately in Aim 3 of the Strategic Plan for 2000-03 with objectives to 'maintain a licence as an Authorised Validating Agency' and to 'promote the use of existing kitemarked Access courses and assist in the development of new Access provision', and also in Aim 4 where the objective is to 'maintain and develop quality assurance mechanisms to meet the Quality Standards and Codes of Practice laid down by relevant external bodies such as the National Open College Network, The Qualification and Curriculum Authority and the Quality Assurance Agency for Higher Education'.

27 In turn, these aims are represented in the aims of the Operational Business Plan for 2000-01. One such aim which is featured in the Account is to develop 'benchmarking' procedures to ensure a consistency in the outcomes and quality of Access provision in the region.

28 In considering mechanisms for monitoring progress towards objectives set, the review team noted that the Board of Trustees had, when discussing monitoring of the Business Plan at their meeting of
5 July 2000, 'agreed that the Board would in future monitor the Action Plan against achievement of targets'.

29 The OCN also has a separate document: Access to HE Action Plan 2000-2001, which details 15 separate actions relating to Access activity. Taken together, these actions suggest considerable and wide-ranging review and developments of the AVA processes and Access provision within OCNKM. However, at the time of the review visit, it was too early to assess the AVA's likely success in meeting the target dates for these actions.

Target groups and targeting policies

30 As specified in OCNKM's programme submission guidelines, any programme accredited by OCNKM 'must clearly identify the target group of learners for whom the programme is designed', and 'For Access to HE Programmes the target group is primarily those who have not previously been able to take advantage of progression routes into higher education. Access learners must be over 21 years of age prior to the commencement of their degree level course'. The Account acknowledges that OCNKM has not devised specific guidelines for the development of targeting policies by individual providers and that 'it may be that OCNKM should develop a more proactive policy with regard to the targeting of programmes', although the AVA has previously regarded it as 'the responsibility of the centres to identify the appropriate target groups for their areas'. The Account also records, however, that 'additional monitoring of the social profile etc of learners enrolled on Access programmes would be desirable' and the AVA includes a review of its procedures for monitoring the social and ethnic profile of Access learners in the Access to HE Action Plan.

31 The team would wish to encourage the AVA in undertaking activities which critically examine the effectiveness of providers' targeting policies, to enable it to support providers in providing opportunities to widen participation through the design and provision of appropriate Access programmes.

 

Governance and committee structures

Status

32 OCNKM is a private company limited by guarantee and not having a share capital, and is registered as a charity. Object (1) of OCNKM's Memorandum of Association specifically empowers it to act as an OCN and as an AVA.

Members' Council

33 The members of the Company meet as a Members' Council. The quorum for such a meeting is specified as 10 in the Company's Articles of Association, but this was reduced to five at a meeting of the Members' Council on 2 February 2000. At that meeting it was also agreed that the number of such meetings be reduced to one per year, the immediately preceding meeting having been held on 18 March 1999.

34 The review team noted that, in addition to the Members' Council EGM held on 2 February 2000, the Company also held on that day its first annual general meeting, and because this was beyond the due date (within 18 months of incorporation) required authorisation from the Members' Council.

Board of Trustees

35 The Board of Trustees is the locus of authority for the AVA licence, and has ultimate authority for Access to HE matters.

36 Trustees are appointed by the members at the AGM or EGM of the Members' Council, with provision for appointment by the trustees to fill a vacancy or add trustees, subject to various constraints. The number of trustees is 'not less than three but (unless otherwise determined by ordinary resolution) shall not be subject to any maximum' and the quorum for transaction of their business is not less than a third of their number or two trustees, whichever is the greater. With the addition of an extra trustee in February 2000, there are now six trustees. The review team noted the commitment and relevant experience and expertise of these Trustees and their representation of FE, HE and AE sectors.

The committee structure of OCNKM

37 OCNKM's Rules & Regulations, designed as a supplement to the Company Memorandum and Articles of Association, make reference to three committees, namely the Quality Committee, the Access to Higher Education Quality Committee and the Finance Committee.

38 Although reference is made in the July 2000 meeting of the Board of Trustees to the formation of a Finance Sub-committee and the need for reports from Sub-committees including Finance to be considered as standing agenda items of the Board of Trustees, the minutes of their meeting of 3 November 2000 record the following decisions: 'the planned formation of a finance sub-committee to be postponed'; and 'a member of the Board of Trustees to take responsibility for providing financial support and advice'. And in a revised version of the Rules & Regulations provided during the review visit but not yet approved by the Board of Trustees, reference is made to a Finance Advisory Group to be convened from 'time to time' to support that Trustee (Finance).

39 There are accordingly two OCNKM committees in existence, the Quality Committee and the Access to Higher Education Quality Committee (AHEQC).

Quality Committee

40 The terms of reference specified in the Rules & Regulations appropriately cover the OCN general quality systems and with respect to quality assurance specify the Quality Committee's responsibility for the processes of recognition, moderation, award of credit, assessment, appeals and to 'oversee the award of the kitemarked Access Qualification'. With respect to this last responsibility, the Rules & Regulations further stipulate that 'a separate standing committee of the Quality Committee will ensure that the quality of Access to Higher Education provision is consistent with the standards and criteria set by the QAA, NOCN and any other relevant external bodies' and that 'this sub-committee will report to the Chair of the Quality Committee' (see paragraphs 44 to 53 below).

41 The Chair of the Quality Committee is a member of the Board of Trustees and is required 'to report to the Board of Trustees on matters relating to Quality Assurance'.

42 Members of the Committee are 'drawn from a representative cross-section of OCNKM's membership' with members 'appointed annually by the Members' Council' and 'no specified limit to the number of members'. The quorum is set at three members and the Rules & Regulations specify that the Committee will 'normally meet at least once per academic term'.

43 In each of the academic years 1998-99 and 1999-2000, meetings were held each academic term, all of them quorate; the membership was gradually increased to seven (including one external) with the current 2000-01 membership very largely unchanged from the previous year; and, as specified in the Rules & Regulations, a Trustee acted as Chair throughout.

Access to Higher Education Quality Committee

44 The Account states that 'the AHEQC is the central working committee of the OCN in carrying out its AVA function'. The remit specified in the Rules & Regulations submitted with the Account states that 'this shall be the same [as that of the] Quality Assurance [Committee] but relating specifically to Access to Higher Education Programmes' and 'It shall further include monitoring of all issues relating to the application of QAA, NOCN and QCA or other appropriate external bodies criteria for the award of kitemarked Access to HE qualifications'.

45 The Chair of the AHEQC is appointed by the Quality Committee, and the Rules & Regulations specify that membership of this committee must be approved by the Quality Committee and Board of Trustees. The Rules & Regulations also specify that 'in the first instance membership will be invited from Access to HE providers, HE institutions receiving Access students, OCNKM officers (in attendance), at least one member of the Quality Committee, at least one member from another AVA'.

46 The stipulations in these Rules & Regulations on frequency and quoracy of meetings of the AHEQC are succinctly expressed as being the same as for the Quality Committee, ie normally at least one meeting per academic term, and three members required to be present for a meeting to be quorate.

47 Recalling again the statement that 'AHEQC is the central working committee of the OCN in carrying out its AVA function', the review team noted that no meeting of the AHEQC had been held between 26 April 1999 and 26 April 2000 and, moreover, that this latter meeting was inquorate in that it was attended by only two members (and two officers), from a nominal total membership of 11 (again excluding officers). Minutes of the Quality Committee demonstrated that in that one year period in which the AHEQC had failed to meet, the Quality Committee had dealt with Access to HE matters including, in particular, issues arising from the moderation process.

48 The review team also noted that the evaluative component of the Account included the comment that 'As the work of the [AHEQC] committee has progressed in 1999/2000 it has taken the view that this status [as a subcommittee of the Quality Committee] should be reviewed' with specific reference to the inquorate meeting of 26 April 2000 where 'members present were asked to consider whether it would be more appropriate for the two committees to be equal'. Subsequent reference in the Account is made to the AHEQC receiving and approving a paper to modify the reporting structure of the AHEQC, and the consequent need to amend the Rules & Regulations. The team therefore requested a copy of this proposal, and received at the review visit the revised version of the Rules & Regulations, not yet approved by the Board of Trustees. The remit of the 'Access Quality Committee' (sic) in this version is prefaced by the slightly more emphatic statement that 'in all matters relating to Access to HE programmes the Access Quality Committee shall have authority to make policy and other decisions' but is otherwise essentially unchanged, continuing to specify this committee's responsibility for the quality assurance of recognition panels, moderation, award of credit and Access certificates, and assessment and appeals as they related to Access to HE programmes.

49 In spite of the maintenance of this considerable degree of responsibility, the quorum for the AHEQC, as specified in the revised version of the Rules & Regulations, was reduced to two members, this in the context that 'membership [of the Committee] shall be open to any individual nominated by a member of OCNKM which is either a provider of Access programmes or a receiver of Access students' with the above preamble followed by the unchanged statement on membership described in paragraph 45 above, and that the listed membership of AHQEC at September 2000 totalled 11 members (excluding officers).

50 The review team noted that, whereas the first submitted version of the Rules & Regulations specified under the heading 'Reporting' that the minutes of the AHEQC 'will be reported to the Chair of the Quality Committee', the corresponding entry under that heading in the revised version specifies that 'the minutes will be sent to the Chair of the Quality Committee for Information. The Committee will additionally report directly to the Board of Trustees'.

51 Both versions of the Rules & Regulations specified that electable officers of the Board of Trustees 'shall include' not only the Chair of the Quality Committee but also the Chair of the Access Quality Committee [sic]. The team heard, however, that the Board of Trustees had not considered the impact of implementing this clause.

52 In discussing the reasons for these changes to the status and remit of the AHEQC, and the stage reached in implementing them, it was evident to the review team that a number of matters remained uncertain or unresolved. In particular, discussions with the Board of Trustees, the Quality Committee and the AHEQC revealed varying understandings of the current status of the committee as a sub-committee of the Quality Committee or as a free-standing committee reporting directly to the Board of Trustees, with varying levels of agreement about the desirability of such a change.

53 Given the above, the review team concurs with the view expressed at the review visit on behalf of the Quality Committee that the AHEQC, as currently constituted, is not in a position to receive full or further delegated responsibility for quality assurance of Access to HE provision. The review team proposes that OCNKM addresses as a matter of urgency the need for a clear specification of effective arrangements whereby the responsibility for the quality assurance of OCNKM Access to HE provision is held by a committee with appropriate expertise, experience and seniority in its membership, with appropriate frequency of its meetings and quorum requirements, and with clear specifications of its reporting line to the Board of Trustees.

Access to HE Forum

54 The Rules & Regulations makes reference to an Access to HE Forum, an advisory group drawn from Access practitioners to encourage the sharing of good practice and described in the Rules & Regulations as meeting 'at least once in any one academic year'. The Account explains that 'the original intention was to establish a regular practitioner forum where ideas could be exchanged, best practice identified etc' but that, owing to difficulties with staff attendance, this had now 'developed into a conference...or into staff development events'.

55 The AVA has subsequently informed QAA that at the inaugural meeting of the Forum, held in October 1998, the Forum agreed to replace meetings with an annual full day Access conference. There was no meeting however of the Forum, whether as specified in the Rules & Regulations or as a practitioners' conference, during 1999-2000.

56 The reviewers heard from Access Programme Leaders with whom they met that they regretted the demise of the Access to HE Forum. In particular, practitioners expressed their recognition of the potential of forums focusing on particular curriculum areas. The team considered that such forums would be able, in particular, to provide support for the continuing process of unitisation of programmes.

Operational management and administrative arrangements

Premises

57 The OCN operates from office space in the University of Kent at Canterbury, rented through a formal lease agreement. The contractual term of the current lease is three years from 1 April 1998. Accordingly, discussions were underway at the time of the review visit to renew the lease; this is in the context that the Company's Rules & Regulations allows any full member organisation to bid to host OCNKM but that the membership wishes to continue the current arrangements whereby the University of Kent acts as the host organisation. The lease agreement covers premises and services with these, including computing services and hire of meeting rooms.

Staffing roles and remits

58 OCNKM employs its own staff and has gradually increased its staffing levels. It now employs five full-time staff: the Director (who also acts as Company Secretary); Operations Manager; Senior Development Officer; Development Officer; Clerical Officer; and a 0.6 FTE Accreditation Officer.

59 The Director has ultimate responsibility for the OCN's AVA functions. As from the current academic year, the Senior Development Officer has formal responsibility for the development of Access to HE provision, while the Operations Manager is responsible for the quality systems relating to validation and moderation of Access to HE programmes. The review team was informed that it was intended that the Operations Manager should take on the role of Company Secretary from January 2001.

60 The Accreditation Officer is responsible for the organisation of validation panels and implementation of procedures regarding moderation, in particular, the appointment of moderators, receipt of moderation reports and information storage. The Clerical Officer has day-to-day responsibility for matters relating to the registration and certification of students.

61 All posts have job descriptions, and roles and remits, both with reference to the OCN in general and the AVA operation in particular, are well understood by members of the staff team.

Quality systems

62 As a consequence of its application for a NOCN licence, OCNKM has developed a range of processes and procedures in response to the evolving quality assurance criteria and Codes of Practice issued by NOCN. OCNKM is currently implementing what it describes as 'a wide-ranging new approach to the continuous monitoring and improvement of quality within its structures' and acknowledges that 'there will inevitably be a period of adjustment to this development' and that this will be closely monitored though the NOCN external audit process.

Data management, collection and analysis

63 Statistics about Access student profiles are collected to provide the standard QAA and NOCN requirements, and centres are required to register all learners with the OCN either electronically or using OCN registration forms. The OCNKM database system covers, in particular, Access learner registration, certification and programme summaries, and the data required for the AVA's annual report to QAA is largely compiled from data held on this database. The review team noted that for the session 1999-2000, the significant majority (93 per cent) of registered Access learners intended to achieve in that session, and, further, that for those in that category, 720 in number, 467 (ie 65 per cent) had in fact achieved an Access certificate.

Communication with providers

64 Although OCNKM issued a newsletter in April 1999 and held an Access conference in June 1999, it acknowledges that it did not succeed in organising a major Access event for providers in 1999-2000 'and is pledged to do so in 2000/01'. This commitment is reflected in the Access to HE Action Plan.

65 As its current major initiative to enhance communication with its providers, the OCN is establishing a web site which will include a section 'dedicated to Access work', with the intention that there will be subsections both for Access programme tutors and for the general public.

66 Cooperation with the South of England Open College Network has resulted in the joint annual production of an informative and visually attractive Access Directory which provides details of all Access courses recognised by the two AVAs.

Development, validation and evaluation of Access programmes

67 The development of Access programmes in the region is largely based on the curriculum development of providers. Although the Action Plan states an intention to 'Encourage the promotion and development of existing and new Access to HE programmes using innovative and flexible means of delivery', the review team was not able to identify any clear progress with this particular action point. The main initiative over recent years, in relation to Access programme development, has been the unitisation of Access programmes.

68 A considerable proportion of developmental time and resource has been expended on unitisation, and practitioners met by the review team spoke highly of the support provided by, and approachability of, AVA staff during this process. The team noted with some concern, however, that there appeared to be a lack of clarity among some practitioners as to the purpose and implications of this activity. There was also a perception among some practitioners that the definitions underpinning unitisation and credit-based awards were unclear and impermanent. It appeared to the team that, in spite of the AVA's work in this area and the provision to Access centres of relevant information, there remained a variable degree of understanding of the requirements, the definitions, and perhaps the underpinning concepts, of the system of programme accreditation as expressed in NOCN levels and credit-based form. The team considered that the development process in which the OCN was engaged, and to which it is committed, may require further emphasis on the standard national definitions available, to ensure practitioners' familiarity with, and understanding of, the bases of the OCN's system of accreditation.

69 The written documentation on the development of programmes, applicable to all OCN programmes, but with sections dedicated to Access provision, is clear and comprehensive. Providers are well supported by AVA officers through the processes leading to a validation panel, and evidence available to the review team indicated that panels were conducted in accordance with published procedures. The AVA appears to be successful in generating viable panels in terms of numbers and expertise of participants, and panels are constituted in accordance with the AVA's published criteria; notably, representation from two HE institutions appears to be standard practice for Access programme panels.

70 The review team noted with some concern the absence of a clear, single point of responsibility within the AVA for the final recognition of Access programmes. Although the QAC is notified of all programmes which complete the validation process, it is not clear that the Committee holds any responsibilities in relation to the approval of Access programmes, and there is no documentary evidence to suggest that this responsibility goes beyond individual validation panels. While the evidence presented for the review indicated that panels were properly conducted, the team considered it essential that the process should include verification of consistency by a body with some continuity of membership and holding formal responsibility for the recognition of Access programmes.

71 Access programmes are validated for a five year period, following which programmes are re-validated. The review team noted the procedures for monitoring programmes, but the uncertainty about ultimate responsibility for Access provision and the lack of formal means for reporting to the AVA made it difficult to assess how the AVA as a whole was assuring itself of the robustness of its procedures.

72 Reviewers were not clear how the AVA satisfied itself in terms of programme equivalence, although the 'sampling' of Examination Boards, (see paragraph 75, below), may be the start of a means of ensuring this.

Assessment, moderation and award of certificates

73 Assessment methods and procedures are identified in the programme submission document and thus subject to scrutiny at validation panels. The AVA has only recently agreed to formulate guidance on assessment methods and, while moderation includes consideration of assessment and its appropriateness, reviewers felt that closer attention should be paid by the AVA to this area, not least to ensure standardisation. While the AVA appears to be aware of the need for better and clearer information, reviewers felt that the opportunity for demonstrating equivalence afforded by unitisation had not yet been fully grasped.

74 In addition to moderation, all Access to HE programmes have an Examination Board consisting of the moderator(s), representatives of the provider, and representation from the AVA. Reviewers were concerned to note that there was no standardisation of reporting format for these bodies and that their deliberations appeared to consist of varying topics, for example, in some cases including resource matters, in other cases not. The review team was also concerned to note that, in some cases these were not final boards since there was evidence of the award of certificates subsequent to these meetings. It was also unclear to whom these Boards reported formally, although reports were received in the AVA office.

75 The 2000 round of Examination Boards was sampled by members of the Quality Committee, acting as silent observers of the process on behalf of the AVA. The review team was informed that the purpose of this sampling was to ensure that meetings were taking place in an appropriately formal way and that procedures were being followed properly. There was no formal reporting-back mechanism for this process, however, and the Quality Committee did not expect to receive feedback unless any issues of particular concern arose. While this may provide a minimal form of quality assurance, the opportunity for enhancement, particularly in terms of identifying the degree of equivalence within the process, seemed to have been lost. As reports from Examination Boards do not receive consideration or scrutiny by the Committee, the team considered that feedback from the observers would have a particular value.

76 The region is comparatively small, but the AVA has an extensive network of contacts from which it draws its pool of moderators. There was a commendable lack of institutional reciprocity in terms of moderation, albeit that close institutional relationships, especially between FE and HE, appear to have developed over the past 10 years.

77 Moderators are, in most cases, proposed at validation panels. Their CVs, and, if necessary, references, are checked by AVA staff and, subsequent to panels, they are appointed on a formal contract. Training is provided and encouraged by the AVA. The documentation surrounding the appointment and guidance for moderators is comprehensive and represents good practice in terms of its clear statement of expectations of both moderators' and tutors' responsibilities and duties.

78 Although there is supposed to be a role for the AHEQC in the consideration of moderators' reports, as the committee had not met during 1999-2000, there had not been any opportunity for this to be undertaken. There was, however, some evidence of issues arising from moderators' reports, though not the reports themselves, being considered by the Quality Committee. The reports of the Examination Boards are considered in the office of the AVA. There was no evidence that these were considered in any systematic way by any formal committee of the AVA. The review team considered that there was some lack of clarity about the two committees' responsibilities with regard to the receipt and scrutiny of both types of reports, and would recommend that, in clarifying these, the AVA also considers how best to ensure that formal feedback, whether from Examination Boards or moderators' reports, can inform the workings of the AVA.

79 As indicated above, the usual procedure is for the Access certificate to be awarded at the Examination Board. The office procedures for the issue of certificates appeared to be appropriate for both credit-based and non credit-based programmes, with appropriate checks and balances built in to the procedures.

Learner experience, standards and progression

80 Opportunities for students to provide an evaluation of their experience are varied in nature, although students met by the review team did not recall any use being made of formal representation of students on course or college committees. Nonetheless, students commented favourably on other opportunities for feedback and provided examples of occasions on which feedback had affected the institution's practice, in all cases favourably.

81 Comments by students and admissions tutors from receiving institutions confirmed that, in general, outcome standards were appropriate for those students progressing to higher education. Admissions tutors whom the review team met spoke of Access students' preparedness for higher education, in some cases comparing this favourably with that of 'A' level students. While no specific tracking of Access students to final degree results, or in terms of progression, appears to be carried out, the review team noted the very favourable reports of Access students evinced by representatives from higher education.

82 A notable proportion of mature entrants to higher education in the region derive from Access courses, largely those validated by OCNKM. The OCN's Rules & Regulations state that HE receiving institutions which are member organisations 'will normally grant an interview to students from OCNKM Access programmes' and the OCN states that 'This is an integral part of the membership agreement for all member organisations.' Discussions with admissions tutors from HE indicated that, while interviews are guaranteed to Access students from particular colleges, it was not necessarily the case that applicants from all Access programmes within the AVA were provided with the same level of guarantee. Nonetheless, there are examples of successful compact arrangements between some of the AVA's HE institution partners and particular FE institutions which ensure guaranteed interviews are given to students within the compact. In addition, reference was made to the AVA being 'a glue' for the region, assuring a safeguard and a minimum standard of achievement.

83 The review team considered that there were opportunities for the AVA to play a fuller role in bringing its HE and FE partners together to develop mutual understanding of needs and opportunities, and encourage practical action within the AVA to enhance progression opportunities for Access students.

Conclusions

84 Open College Network Kent and Medway (OCNKM) serves a relatively small and well-defined geographical area. Although one consequence of this is that the number of FE providers is smaller than average for an AVA, the total number of Access programmes, registered learners and Access certificates awarded places it well within the AVA average range.

85 Since its establishment as an associate member of NOCN in 1996, the organisation has been faced with a series of challenges, in particular, those of incorporation and the requirements of NOCN licensing. The changed expectations and requirements from a wider group of stakeholders and regulatory bodies has involved for the OCN the introduction of wide-ranging changes to its governance structures and the development of new quality assurance measures. At the same time, it has also been involved in significant curriculum developments, as it has tried to introduce a fully unitised and credit-based range of programmes.

86 The particular challenges which face it now, however, are perhaps more critical than ever. For while previous changes were largely organisational, the immediate situation holds a different kind of challenge. The OCN is aware that within the next year it will have to increase its learner base significantly in order to make the necessary shift away from grant-based funding to financial self-sufficiency. While it has plans to seek new markets in order to grow its business and has set ambitious targets for growth - and is optimistic about its ability to achieve this growth - the OCN recognises that it must 'grow or die'. The targets for growth lie largely outside of the AVA activity, however, and, notwithstanding some intended areas for development mentioned in the Access to HE Action Plan, there is some expectation that Access numbers may continue to see the decline noted already in parts of the OCN.

87 As well as being fairly new as an OCN, OCNKM is embryonic as a company, and the challenge to increase the market for its activity is thus not simply a business challenge, as it presents a further shift of culture for the organisation and its employees. Within this context of real external pressures, the OCN's members and staff have undoubtedly given much time to meeting many different demands. However, at the same time, when the focus has been elsewhere, attention has been diverted away from Access to HE as a specific area of responsibility; the development of its traditional business in this areas has received less attention; there has been some decline in Access activity for practitioners; and some of the AVA's responsibilities as an awarding body have been neglected.

88 Because of its subsidy through grant income, it had not been necessary for the OCN to address the need to change the basis of its operation as early as some others which had similar origins, and the AVA recognises that, until recently, it has not had sufficient professional business and management expertise or advice, either through its officers or through its committees. The recent attempts to address this absence of appropriate experience demonstrate the AVA's awareness of its importance, but the pragmatic and sensible solution presented at the time of the review visit is, as yet, untested and will depend heavily on the availability and assistance of one individual. While the undoubted expertise and experience of the individual involved may prove adequate, given the critical significance of this advice over the coming year, the OCN may wish to consider means to secure and bolster this area of governance.

89 The AVA reports that it has difficulty in recruiting people to committees and ensuring a reasonable level of attendance at meetings, and while the Board of Trustees meets regularly and the individuals concerned have the necessary expertise and seniority to govern the organisation effectively and with appropriate authority, the effectiveness of other committees and groups is undermined by weak attendance. This difficulty has not yet been overcome or formally addressed, but it would appear that the simple measure, as has been introduced for 2000-01, of a clear programme of meetings arranged sufficiently in advance with sufficient notice given to members, could go at least some way to resolving this problem. However, it may be that this particular difficulty also needs to be addressed at a more fundamental level, and that the OCN will need to give further consideration to its expectations of members, for example in relation to participation in the governance of the organisation, and the need to release staff for this purpose.

90 It may also be that this difficulty is exacerbated by the fact that the OCN's new committee structures are not yet well-established or securely embedded. The OCN's newly developed Rules & Regulations are not familiar to committees or practitioners and the different draft versions that currently exist of this document indicate that the matters described, including committees' terms of reference, are still developing and somewhat fluid. As a result, the OCN's committees are not working effectively or to the clear benefit of provision in all areas. The Access to HE Quality Committee, in particular, does not have a record of effective operation. While it is meeting irregularly and with small numbers, and with some uncertainty as to its remit, it is not able to provide a reliable means for the quality assurance of Access provision, and, unless these matters can be swiftly addressed, the decision which appears to have been taken to delegate responsibility for all Access matters to this committee will need to be reconsidered.

91 In addition to the lack of clarity about committees, some of the AVA's quality assurance procedures are new and somewhat under-developed. The involvement of Quality Committee members as observers at Examination Boards, for example, is indicative of a worthwhile initiative to assure quality and standards on Access programmes: the lack of any mechanism for feeding back on this observation, either to those involved on the Examination Boards or to the AVA itself through its committee structures renders the value of the activity less notable.

92 Thus, while some of the individual mechanisms for quality assurance appear to be working well, such as the operation of valdation procedures, the overall quality assurance framework has weaknesses where reporting and follow-up mechanisms are unclear or where the committee structures into which reports should be made are themselves weak or unclear.

93 The review team commends the AVA for:

i the organic connections between the Strategic Plan and the Operational Business Plan;

ii its use and response to interim reports to ensure that early action is taken to rectify problems and deal with difficulties about programmes which are raised during the year.

Recommendation to the ARLC

94 The review team recommends that OCNKM be granted a provisional renewal of licence with conditions to be met by the dates specified below and a further review visit in spring 2002.

Conditions

95 Subject to the approval of the ARLC, OCNKM's licence is provisionally renewed on condition that the AVA:

i undertakes a review of its committee structures as they relate to all matters relating to, and impacting on, Access to HE policy and programmes, and, in particular:

• ensures the appropriateness of representation, optimum numbers and adequacy of quorums for effective and accountable governance and decision-making;
• defines lines of accountability and reporting mechanisms of committees;

ii clearly locates responsibility for the quality assurance of Access to HE provision with a body which has appropriate expertise, experience and seniority, and provides a detailed remit for this body which identifies its duties in relation to the discharge of its responsibilities for the quality assurance of Access programmes;

iii clarifies the means by which expert advice on financial matters, including future budgetary planning, is made available to, and taken into account by, the OCN and its officers;

iv locates ultimate responsibility for the recognition of an Access programme with the AVA itself, so as to meet the need for monitoring and the verification of consistency within the validation process;

v develops the OCN's Rules & Regulations to provide a definitive and accurate public document which accurately expresses the OCN's revised and fully approved procedures and structures;

vi implements the structures and procedures resulting from meeting conditions i - v, to ensure that they are fully operative and effective by the time of the revisit.

Conditions i-v to be met by 31 May 2001.

Condition vi to be met by the date of review visit in spring 2002.

96 Provisional confirmation of licence allows the AVA to continue to operate under licence but makes provision for the immediate withdrawal of the licence if the conditions are not met in the time allowed and to the satisfaction of QAA. Were it to be necessary for QAA to withdraw the licence, the AVA would need to put in place procedures for the transfer of registered students to an alternative licensed AVA.

Recommendations

97 The review team recommends that OCNKM:

i formalises the means by which reports from moderators and Examination Boards are considered within the AVA's deliberative structures, and clearly identifies the relationship between such reporting and consequent planning for the development and enhancement of the AVA's processes and the Access provision for which it has responsibility;

ii specifies the rights and responsibilities of members, in a formally approved and publically available document which clarifies the AVA's expectations in terms of the participation of members in the AVA's processes, with particular regard to contribution to committee and recognition panel membership;

iii reviews mechanisms to ensure practitioners' understanding of standard definitions for concepts underpinning the NOCN system of levels and credit-based awards;

iv considers the mechanisms, including the Access to HE Forum, through which practitioners might be involved in the development and enhancement of Access curricular, with particular reference to measures to contribute to consistency;

v embeds a cycle of business for its committees which will facilitate effective reporting; ensure appropriate frequency of meetings; and allow a forward schedule of meetings to be established and published annually.