Open College Network Eastern Region

NOVEMBER 2007

RG 350 02/08

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Contents

• Foreword
• The AVA context
• Principle 1 - The organisation has governance structures which enable it to meet its legal and public obligations, to render it appropriately accountable, and to allow it to discharge its AVA responsibilities securely
• Principle 2 - The organisation is able to manage its AVA responsibilities effectively, and to maintain an appropriate structure to support them
• Principle 3 - The organisation is able to assure the quality and fitness for purpose of Access to HE programmes at the point at which they are granted formal approval, and to have effective means to develop, evaluate and review the Access to HE provision for which it has responsibility
• Principle 4 - The organisation is able to secure the standards of achievement of students awarded the Access to HE qualification
• Audit trails
• Conclusions
• The AVA licence
• Appendix - Aims and objectives of AVA review

Foreword

1 The Quality Assurance Agency for Higher Education (QAA) is responsible to the Department for Innovation, Universities and Skills for the recognition of Access to Higher Education (HE) courses. QAA exercises this responsibility through a national network of authorised validating agencies (AVAs), which are licensed by QAA to recognise individual Access to HE courses, and to award Access to HE qualifications to students. The AVAs are responsible for implementing quality assurance arrangements in relation to the quality of Access to HE provision and the standards of student achievement. QAA has developed a scheme for the licensing and review of 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 committee of the QAA Board of Directors.

2 The ARLC is responsible for overseeing the processes of AVA licensing and periodic review and relicensing. The criteria applied by the ARLC and by review teams operating on the Committee's behalf, in reaching judgements about whether and under what terms an AVA licence should be confirmed or renewed, are provided within the Recognition Scheme documentation. These criteria are grouped under the four principles that provide the main section headings of this report.

3 Following an AVA review, a member of the review team presents the team's report to the ARLC. The Committee then makes one of four decisions:

• unconditional confirmation of licence for a specified period
• conditional confirmation of licence with conditions to be met by a specified date
• provisional confirmation of licence with conditions to be met and a further review visit by a specified date
• withdrawal of licence for operation as an AVA.

4 This is a report on the review for Open College Network Eastern Region (OCNER). QAA is grateful to OCNER and to those who participated in the review for the willing cooperation and assistance provided to the review team.

The review process

5 The review was conducted in accordance with the process detailed in the Recognition Scheme. The preparation for the event included an initial meeting between OCNER representatives and QAA's Assistant Director to discuss the requirements for the Overview Document (the Overview) and the process of the event; the preparation and submission by OCNER of its Overview, together with a selection of supporting documentation; a meeting of the review team to discuss the Overview and supporting documentation and to establish the main themes and confirm the programme for the review; and negotiations between QAA and OCNER to finalise other arrangements for the review.

6 The review visit took place on 13 to 15 November 2007. The visit to OCNER consisted principally of meetings with representatives of OCNER, including AVA officers; members of the Board of Trustees, the Quality Committee, the Access to HE Committee; moderators for Access to HE programmes; and Access to HE providers and receivers.

7 The review team consisted of Dr Elizabeth Briggs, independent, Mrs Sally Powell, Assistant Registrar (University of Oxford), and Mr Keith Fletcher, Director of Access to HE (Open College Network South West Region) and lead reviewer. The review was coordinated for QAA by Mr Matthew Cott, Assistant Director.

The AVA context

Background and major developments since the last AVA review

8 OCNER was formed in August 2005 by the merger of OCN Anglia and OCN North and East London and Hertfordshire (NELH). It was awarded a provisional AVA licence in April 2006. OCNER has its head office in Colchester at the University of Essex, which acts as its host organisation and with which it has formal contracts for specific services.

9 OCNER operates as an AVA across the East of England. It has a strategic aim to become the sole AVA within the region, although it currently also validates courses for seven providers outside that region.

10 The amalgamation of the two predecessor organisations to form OCNER has benefited from their well-established and long history of AVA operation. The relatively short period since OCNER became a registered company has been one of rapid change management and consolidation in response to its Business Plan for 2006-09.

11 Developments include strengthening the role of OCNER as a regional AVA and the implementation of the new Access to HE Diploma and credit specifications. A significant proportion of the AVA's courses already meet the new Diploma specification; and OCNER was the first AVA to award the new Diploma to students.

12 There has been much progress in the consolidation of the management structure and embedding systems for the approval, development and review of programmes, together with staff development to support new staff roles and responsibilities.

Members and provision

13 Membership comprises community, voluntary and private sector organisations, 25 further education colleges delivering Access to HE courses and the University of Essex, Anglia Ruskin University, the University of East London, Middlesex University, the University of Hertfordshire and the University of Bedfordshire. Regional stakeholders include the East of England Lifelong Learning Network (MOVE), adult education providers and Aimhigher.

14 The learner profiles for the AVA's students indicate diverse backgrounds and age ranges. The curriculum offer includes Access to HE courses in nursing, midwifery and education, which attract a large number of mature female students, as well as other vocationally-related provision such as business, information technology and computing courses. In the experience of the AVA, providers are attempting to ensure that courses are relevant to employment needs and higher education progression. The success rate of students on Access to HE courses is approximately 50 per cent, with a further 20 per cent continuing studies or having achieved partial credits. Progression data based on approximately half of the known cohort destinations show that nearly 80 per cent of successful learners have progressed to higher education. Detailed statistical comparisons with previous years are complicated by the recent merger and changed membership of the AVA.

AVA statistics 2006-07

15 The AVA reported the following statistics in its annual report to QAA for 2006-07:

Providers offering Access to HE courses 28

Access to HE courses available 95

Access to HE courses running 88

Access to HE learner registrations 2,531

Access to HE certificates awarded 1,224

Principle 1 - The organisation has governance structures which enable it to meet its legal and public obligations, to render it appropriately accountable, and to allow it to discharge its AVA responsibilities securely

Governance structure and accountability

16 OCNER's governance structure grew out of those of its precursor OCN/AVAs, which were well established and similar to each other. OCNER has a Board of Trustees with three sub-committees: the Finance Committee, the Access to HE Committee, and the Quality Committee. Each committee is chaired by a trustee and is accountable to and reports to the Board. The Board and its committees are expected to operate according to the Nolan Report, Seven Principles of Public Life.

17 From its examination of documentation and discussions with Board members, staff, providers and receivers of Access to HE students, the review team concluded that the governance structure suited the AVA's operational needs, met its licensing obligations, and ensured an appropriate level of formal accountability. In addition, the team concluded from the evidence provided that the commitment and unity of purpose at both governance and management levels, had underpinned the successful management of the change process surrounding the recent merger.

Members and membership procedures

18 OCNER has formal membership regulations which detail the criteria that organisations must satisfy to become members. Member organisations are drawn from across the eastern region and London, and include most further education colleges in the area, six higher education institutions, community and voluntary organisations, and private sector organisations. All Access to HE providers have an automatic right to become members and all members are entitled to participate in the AVA's governance structures.

19 The procedures for general meetings, including the election of members are clearly set out in the Memorandum and Articles of Association. It is possible for the Board to withdraw membership from organisations which do not fulfil the AVA's requirements.

Governance, reporting lines and accountability

20 Trustees are elected to the Board by the annual general meeting for a three-year term, but there is no restriction to the number of times they can be re-elected. In the interests of good governance, the review team recommends that the AVA limits the number of times that trustees can be re-elected. A minimum of seven and a maximum of 16 trustees are allowed. The Board includes representatives from a range of organisations which share the AVA's aims. From discussions with trustees and other stakeholders, the review team formed the view that trustees identify with the values of OCNER, support its mission, and see Access to HE as an important part of the organisation.

21 The review team found that attendance at Board meetings was satisfactory, included both further and higher education representation, and that meetings were always quorate. The team agreed with the AVA's own appraisal, however, that there was a need for broader geographical representation. The team noted that the AVA is actively seeking new trustees, in particular from strategically placed organisations in the region. The Board acknowledges its responsibility for the development and approval of the AVA's policies and strategic direction. The team recognises the significant contribution that trustees make to the AVA, both as members of the Board, and as chairs and members of its sub-committees.

Committees' responsibilities, operation and effectiveness

22 OCNER is keen to ensure that its AVA function has a distinct identity within its wider operations. To this end, there is a clear separation between the remits of the Quality Committee and the Access to HE Committee, with the latter having full responsibility for quality assurance of Access to HE. The Access to HE Committee's remit states that the Committee 'has the authority for confirming QAA recognition on Access to HE programmes delegated to it by the Board of Trustees. It has primary responsibility for ensuring the quality assurance and quality enhancement of Access to HE programmes within OCN Eastern Region'.

23 The Quality Committee has a similar brief for non-Access provision but in addition has a wider responsibility for 'approving, maintaining and reviewing policy and procedures on quality issues' across the organisation including self-assessment processes.

24 The AVA ensures that the work of the two committees is aligned with each other through sharing minutes of meetings and through their shared membership. Meetings of the Quality Committee are not quorate unless a member from the Access to HE Committee is present.

25 The Access to HE Committee is chaired by a trustee nominated by the Board. Membership includes between six and 10 representatives from Access to HE providers and all higher education institution members of the AVA. The review team concluded from its consideration of the evidence, that the Committee was fully aware of, and exercised, its responsibilities for Access to HE efficiently and well.

26 The AVA has been through a period in which it has had to look very closely at its financial situation and agree a deficit budget without support from the Finance Committee. Part of the Finance Committee's remit is 'to receive and consider in detail the OCN's revised business plans prior to consideration by the full Board of Trustees, making recommendations as appropriate'. The Finance Committee did not meet during the 2006-07 academic year, and although the review team formed the view that the Board had received enough information to inform their judgements in this period, records of these discussions, and of how decisions were reached, were inadequate.

27 The AVA has scheduled two meetings for the re-formed Finance Committee for 2007-08, and, in October 2007, appointed a chartered accountant as their new Director of Finance and Operations. The review team agreed with the view expressed by members of the Board, that these measures should ensure that a suitable level of expertise and support is now consistently available to inform the OCN's financial and business decisions.

Locus of authority for Access to HE responsibilities

28 Within the governance structure of OCNER, the locus of authority for the AVA licence is with the Board of Trustees. The Board delegates responsibility to its Access to HE Committee for ensuring that AVA quality procedures meet QAA licensing requirements. From their examination of the Access to HE Committee and Board minutes, and discussions with Board and committee members, the review team concluded that this responsibility was transparently located and satisfactorily exercised.

Constitution and legal identity

29 OCNER is a company limited by guarantee and a registered charity, responsible and accountable to its members. The AVA's Memorandum and Articles of Association serve as its formal constitution, containing details of its legal identity, function, aims and structures, and limit the legal liability of members and their representatives.

30 OCNER operates in accordance with the regulations of the Companies Act. A fully audited set of accounts is prepared each year by the auditors and approved by the Board before submission to Companies House. OCNER has established contracts for a range of services with external agencies, which are legally binding agreements. These organisations include the University of Essex with which it has a Memorandum of Understanding and formal contracts for personnel and information technology services.

31 The National Open College Network and QAA licences set the framework in which the AVA operates. Beyond this, the review team formed the view that there is no restriction on the independent decision-making or operation of the AVA.

Principle 2 - The organisation is able to manage its AVA responsibilities effectively, and to maintain an appropriate structure to support them

Strategic planning

32 Both the OCN's senior management team and the Board of Trustees demonstrate full engagement with strategic planning. They have developed a new Business Plan 2007-10 which builds upon foundations created by the predecessor OCN/AVAs. Away days are held to focus on planning matters, although plans are regularly updated as required. OCNER has developed a discrete Regional Access to HE Strategy, which is led by the Director of Access. The Director of Access has a specific role to raise the profile of Access to HE provision within the entirety of OCNER's operation. The latest version of the Regional Access to HE Strategy was, at the time of the visit, subject to consultation in relevant committees. The review team was told that Access to HE had to date been fully integrated into the OCNER Business Plan but with discrete actions related to Access to HE. Current AVA priorities within the Business Plan include increasing presence in strategic networks, both regionally and nationally, and increasing the number of providers.

33 OCNER shows a high degree of responsiveness to the external environment and, within the established committee structure, has appropriate mechanisms for addressing new issues as they arise. The successful roll-out of the new Access to HE Diploma among the AVA's providers was a clear example of a productive flow, taking account of stakeholder input, between strategic and operational management. Minutes of meetings at Board and sub-committee level demonstrate how issues and action points are identified and tracked. The review team was, however, made aware that some significant discussions between the management team, which contributed to the decision-making processes of senior committees, were not always fully minuted. The team therefore recommends that the AVA records more fully the informal discussions that inform decisions subsequently taken in key business areas.

Promotion and development

34 Access to HE provision has a high profile within OCNER, facilitated by the dedicated infrastructure under the leadership of the Director of Access. The review team found that the ongoing developments (identification of new roles and workbase location, for example) consequent upon the mergers of predecessor AVAs, were continuing to offer appropriate and effective support to providers and other stakeholders. The personal support provided by the Director of Access and business development managers is clearly valued by providers and other stakeholders. The nature of Access to HE provision was seen as dynamic and responding flexibly to local needs, raising aspirations of school leavers and meeting the challenges of the skills agenda. The team was told by stakeholders that OCNER was 'pivotal' to driving progression.

35 The Chief Executive and the Chair of the Board of Trustees are particularly active at a national level, and are therefore strongly placed to contribute to and engage in national initiatives at a local and regional level. OCNER has, for example, been at the forefront of the implementation of the new Access to HE Diploma and credit specifications.

36 The intention of OCNER to expand its membership to include other higher education institutions and providers in the region appears to be indicative of a desire to address Access to HE issues within a regional context. There is already a rich mix of stakeholders involved with OCNER who have a variety of mechanisms by which they can exchange ideas and information. The importance of information technology in facilitating this function is well recognised by OCNER, which is developing its use of internet technology, and has invested in a new information technology infrastructure.

37 Annual self-assessment reports are received from providers and a useful summary of their content is prepared by the Director of Access. This is examined by the Access to HE Committee. The establishment of the separate Access to HE Committee ensures that specific attention is given to quality matters relating to Access to HE.

38 Data to support the monitoring of Access to HE provision are primarily collected through the OPUS system. This provides 'global' datasets for OCNER across their provision, which are examined in relevant committees. Individual provider data are recorded in moderators' reports, but do not have a standardised format through which useful comparisons between providers could be made. Some of the data are limited in its scope. The review team was informed of OCNER's intention to continue to strengthen its data collection mechanisms, and of interest in pursuing comparative analyses in the future.

Operations and management

39 As previously mentioned (see Principle 1), there is a clearly set out deliberative structure with a separate Access to HE Committee. The review team was provided with evidence that this structure was working effectively and efficiently to address targets set out in the Business Plan, even though there had been a hiatus in the work of the Finance Committee during the year prior to the visit. This was the result of the retirement of the Deputy Chief Executive and the resignation of the previous Director of Operations. During the intervening period, the Chief Executive assumed responsibility for financial control, reporting directly to the Board of Trustees on these matters. At the time of the review visit, a new Director of Finance and Operations had just taken up post. The Board and Chief Executive had taken a number of measures to ensure the appropriateness of the job description and the person Specification, including the involvement and advice of external auditors in the process, prior to the appointment. Meetings of the Finance Committee were planned to resume imminently. In meetings, the team sought reassurance on the AVA's future financial management and was informed that monthly management accounts would be reintroduced with immediate effect and that preparations for the annual external auditing of accounts were well in hand.

40 A risk register is maintained by the Board of Trustees but risk assessment is, as yet, relatively undeveloped as a management tool. The review team noted, for example, that business projections lacked detail and gave a rather optimistic view of the future financial position. No indications were given in the risk register of how a possible reduction in student numbers might adversely affect the organisation. The intention to grow Access to HE business and to expand the geographical scope of OCNER would suggest that it would be advantageous to introduce a more in-depth risk assessment method in the near future. The team recommends that the AVA introduces a more in-depth risk assessment method.

41 OCNER employs a particularly energetic and committed team of high-quality staff who are clearly valued by their stakeholder community. The staff welcome proposals to increase formal staff development opportunities over the coming months, although they have benefited from effective mentoring and shadowing arrangements to date.

42 Accommodation for the OCNER offices is leased from the University of Essex, with service-level agreements to support their function as necessary. OCNER has, during the past year, reviewed its use of peripheral premises and has introduced a home-working policy for a number of staff who operate in the more distant parts of the OCNER area. This appears to be a practical and effective solution to coverage of the region, and is supported by an appropriate policy.

43 OCNER has maintained and updated all required policies and procedures relating to the operation of their Access to HE work, in keeping with the requirements of the Diploma specification and common credit framework. These are published on their website and have recently been assembled into a hard-copy Quality Manual: an initiative requested, and much appreciated, by providers. Exemplar material is included for the guidance of those developing and seeking approval of Access to HE courses. Communications with providers are timely and efficient, with email correspondence being supported by formal letters in record of significant matters of business or policy, and informal or formal meetings being held in a purposeful and effective manner.

44 The OPUS database is used to record and track learner progress and achievement through the work of the dedicated Registration and Awards team. Confirmation of award of credit is undertaken on behalf of the AVA by the centre moderator. The first Access to HE Diplomas were awarded to students in July 2007. Records stored in OPUS are backed up by paper and local electronic records. Work on populating the databank for Access to HE units is continuing.

45 OCNER has fulfilled requirements for reporting to QAA in a timely manner and has introduced improvements to data collection with a specific view to enhancing the quality of these reports. It is clear that OCNER intends to continue to develop its data collection processes.

46 To date, monitoring of provider websites and publicity materials has been undertaken by the Marketing Officer, usually as part of approval or annual review of the Eastern region directory of Access courses. A refinement to this process, involving centre moderators in assessing publicity materials, is currently being introduced. The review team considered that this would be a positive step in developing the process and ensuring the overall accuracy of information provided to prospective Access to HE learners. The team recommends that the AVA monitors the implementation of the centre moderators' new role in verifying the accuracy of promotional literature related to approved Access to HE provision, and the proper use of the authorised QAA logo.

47 OCNER has both an approved equal opportunities policy and an approved complaints and appeals policy. It has considered the interface of these policies with those of its providers and stakeholders, updating documentation as necessary in accordance with new legislation.

Principle 3 - The organisation is able to assure the quality and fitness for purpose of Access to HE programmes at the point at which they are granted formal approval, and to have effective means to develop, evaluate and review the Access to HE provision for which it has responsibility

Programme development

48 The AVA has guidance documents, including the new Access to HE Quality Standards (revised and approved by the Access to HE Committee, November 2006), to ensure consistency across its provision. The review team heard from tutors that they value the proactive approach of the Director of Access and the development managers for their constructive and timely guidance, curricular and assessment advice and support for programme development. The Overview noted, and higher education representatives confirmed, that it is an explicit requirement that the higher education representatives are involved in curricular development and validation processes. Regional stakeholders, for example MOVE and Aimhigher, provide valuable information to the AVA on areas for possible programme development to meet skills and employment shortages. They also offer some funding for research and developmental projects of potential benefit to the AVA. The team concluded that there is a strong and effective working relationship between the AVA, its providers and stakeholders in the development of Access to HE programmes.

49 The AVA has incorporated clear and comprehensive procedures for programme development, submission and validation into its Quality Manual. Representatives of the Access to HE Committee and Access to HE tutors commented positively on their experiences of working with these procedures for programme development and approval. The review team considered that during a time of rapid change, the AVA has managed its procedures effectively to assure itself of the quality of its provision. The team found no obvious statement within the relevant documentation that QAA recognition may be given only to programmes delivered in the UK. The AVA issues guidance on the common credit framework and has already revalidated Access to HE courses leading to the award of the Access to HE Diploma.

50 The review team saw examples of programme submission documentation using AVA templates in the audit trails. The submission documents contain relevant information, including programme aims, objectives and structure; unit credits; GCSE equivalences; target groups and marketing strategies; admissions procedures and guidance; accreditation of prior learning; teaching, learning and assessment strategies; learner resources, staffing and support; programme management and progression routes. The AVA provides an explicit set of quality assurance guidelines for internal and external moderation, and for the monitoring, evaluation and review of its programmes. Programme tutors confirmed that they are giving priority to the development of programmes designed to attract under-represented groups in their local areas. Learners are required to complete 60 credits, at least 45 at level 3 and the remainder at level 2. The team noted that the AVA's guidance document included reference to '500 notional learning hours'. It is a condition of licence that the AVA amends its Guidance on course development and approval document to include a statement that QAA recognition may be given only to Access to HE courses which are delivered in the UK, and so that references to '500 notional learning hours' are removed.

Programme validation

51 Development managers play a key role with the providers in determining when programmes are ready for submission according to the annual schedule for validation and revalidation set by the Director of Access. Validation procedures require the inclusion of units for approval, rules of combination and reference to the revised Access to HE Diploma specification. Providers are formally notified of the confirmed date, for the external validation panel meeting. Six to eight weeks prior to the validation panel date, there is an internal panel meeting to consider and review draft submission documentation. Internal panel scrutiny by two development managers, one of whom has been involved with programme development with the provider, the Director of Access and an AVA development support assistant, is intended to ensure the quality and completeness of all sections of the submission pro forma. Access to HE tutors confirmed that they found these processes helpful and straightforward.

52 The AVA recognises that it has not implemented the separate unit approval process fully, but is working towards achieving this aim in parallel with operational improvements to the unit database. Tutors who met the review team confirmed that they would welcome progress to make the unit database accessible to all AVA providers as an important enhancement to future programme design. The team endorses this view and considers that ready access to approved units will ensure a greater consistency and comparability of outcome in relation to the quality and academic standards across the provision.

53 There is clear guidance on the composition, membership and conduct of validation panels. Discussions with providers and higher education representatives indicated that higher education membership of validation panels is a standard requirement. The review team viewed the procedures as largely satisfactory, but was not convinced that the selection criteria and process for proposing and agreeing validation and revalidation panels are sufficiently robust to assure the AVA that panel members are independent from the submission team. The team recommends that the AVA review its procedures to ensure appropriate externality in the membership of validation and revalidation panels.

54 Normally the Director of Access chairs validation panels, although it is the stated intention of the AVA to share this role among Access to HE Committee members from 2007-08. Validation reports record any approval conditions and are agreed by the panel Chair before circulation to the Access to HE Committee. It is a requirement that the Access to HE Committee must approve the panel decision and record in its minutes the meeting of conditions prior to the start of the programme. The Director of Access communicates the panel decision and any approval conditions in writing to the provider, and notifies it when the conditions have been met. Following final ratification of a programme, the definitive programme document is produced and approved units are entered into the unit database. Programmes are normally approved for a period not longer than five years. The review team was able to track several examples of the validation process from initial submission through the approval process to the final approved programme document, and found the process to be rigorous and effective. Following the merger to form OCNER, the AVA began the revalidation of all programmes within the provision to Access to HE diplomas, a process that involved the same procedures as for programme validation.

55 The AVA advises its providers on the need to ensure the accuracy of entry requirement guidance for students intending to study an Access to HE course leading to professional higher education courses, for example, initial teacher training and social work. Learners are expected to have the opportunity to gain GCSEs or equivalences to meet the requisite entry requirements of the professional body. The AVA is currently revising its scheme for GCSE equivalent units for Access to HE courses in English, mathematics and science. Evidence available to the team suggested that the guidance is clear and appropriate and kept under review.

56 Modifications to existing programmes are well regulated by the procedures outlined in the Guidelines on Access programme amendments. The AVA draws clear distinctions between minor programme changes and modifications to units, and substantial amendments that are likely to affect the coherence and integrity of the programme. For minor modifications, the process involves initial discussion between the provider, the centre moderator, and the Director of Access or the relevant development manager. The provider submits the notification of amendment pro forma for approval by the Director of Access and final ratification by the Access to HE Committee. When more substantial amendments are proposed, the final stages involve consideration by an Access to HE approval panel whose decision is ratified by the Access to HE Committee. Significant modifications include the addition of a new programme pathway; changes affecting more than 20 per cent of the programme units; the addition of approved units constituting more than 30 per cent of the programme; or the addition of two new units. The review team found that these procedures acted as an appropriate safeguard to maintain the coherence of programmes.

Review and development of Access to HE provision

57 The AVA has a systematic process for the annual review of courses through subject moderation, centre moderation and self-assessment reports by providers. Examples of reports were available to the review team, together with a summary overview of issues and recommendations across the provision. While the subject and centre moderator reports were generally evaluative and constructive, the team noted that self-assessment reports were inconsistent in both presentation and analysis of data. The AVA is aware of the need to ensure accurate and robust data for quality assurance and enhancement purposes, and has introduced two data collection points in the year to improve the reliability of programme statistics. Urgent matters and recommendations raised by the centre moderation process are scrutinised by the Access to HE Committee. The centre moderator is then required to report on how the resulting action plans have been addressed in the next annual report. Centre moderators and staff who met the team commented favourably on the manner and speed with which the AVA responds to their recommendations, and the effectiveness of communications.

58 Providers are given appropriate guidance for the preparation of their self-assessment reports. They are expected to include commentary on responses to issues raised by moderator reports; student feedback and satisfaction; the student learning experience; student achievement, retention and progression; and the effectiveness of recruitment strategies. On the basis of evidence seen, the review team agrees with the AVA that it would be useful to adopt a more consistent approach to the collection and analysis of statistical information from providers. The team recommends that the AVA develops its capacity to take a comparative statistical overview across its Access to HE provision.

59 The AVA processes for moderation and self-assessment require the identification of good practice in Access to HE provision. Good practice is disseminated in a variety of ways, for example, by making available exemplars of completed documentation on the OCN's website. Summaries of self-assessment reports and of moderation are circulated to all providers and moderators for information. The review team heard that tutors appreciate the use of Access tutor forums to share good practice. The last Access tutor forum was held in June 2007, and the AVA intends to offer them in the current academic year as part of its staff development for providers on the use of virtual learning environments and online learning and assessment. The outcomes of annual programme review are used by the AVA to inform programme development and to enhance the quality of programmes, and are reported in the annual AVA report to QAA.

Promotion of Access to HE within the East of England

60 The AVA has a long and active history of the regional promotion of Access to HE through its predecessor AVAs. It held four Access quality forums in 2006-07 to provide staff development for tutors and moderators on the implementation of the Access to HE Diploma specification as well as subject moderation processes. Staff development plans include specific sessions with university partners to promote the AVA's Access to HE Diploma and to clarify its relationship with higher education admission policies. AVA staff contribute significantly at regional and national levels to conferences and committees on Access to HE activities and their promotion. The review team commends particularly the clear leadership demonstrated by the AVA in the implementation of the common credit framework and the Access to HE Diploma.

61 The review team was informed about the AVA's close working arrangements with the regional Learning and Skills Council and Regional Development Agency, and the involvement of MOVE and Aimhigher. It has regular meetings with MOVE and Aimhigher as key stakeholders to discuss and promote Access to HE strategies. One current project with Aimhigher and Foundation Degree Forward is examining the potential role of work-based learning.

62 The review team formed the view that the AVA has a strong regional focus, which involves its stakeholders in the promotion of Access to HE and has a clear commitment to widening participation. The team commends the AVA for its promotion and development of Access to HE and its engagement in local, regional and national initiatives for this purpose.

Principle 4 - The organisation is able to secure the standards of achievement of students awarded the Access to HE qualification

63 External programme monitoring and assessment ('moderation') is provided by a combination of centre moderators who are appointed for each provider, and subject moderators who are assigned to specific provider(s) to moderate at subject level. A number of subject moderators also act as centre moderators. In addition, subject moderators focus on the standardisation of assessment in specified curricular areas across several providers, producing a summary report of the results for the AVA. This additional arm of the moderation process represents a revision to the process of subject moderation for 2007-08 and, at the time of the review, the impact of this change had yet to be fully evaluated. Subject moderation reports are available to centre moderators and these reports directly inform their annual reports to the AVA on individual courses and providers.

64 In addition to the work of the Access to HE Committee and the AVA's Access to HE team in the monitoring of moderators' performance, the AVA asks providers to evaluate the conduct and outcome of moderation annually, but response has been minimal to date. The review team was encouraged to hear that the AVA will urge providers to make a wider use of this mechanism for checking on its moderation processes during 2007-08 and thereafter.

65 Guidance for moderators is clearly set out in the AVA's Quality Manual which has been introduced for 2007-08 and which brings together all of the key documents supporting the AVA's quality processes. This is a primary source of information on all policies and processes for both moderators and coordinators, and includes guidance on key processes and the appropriate paperwork. This Manual is intended to be updated annually. The review team found the Manual to be well devised and clearly presented. Meetings with tutors and moderators confirmed that each group found it a valuable tool. The team commends the AVA for its useful, comprehensive and accessible Quality Manual and website.

66 From discussions with external moderators (centre and subject) and tutors, and from documentary evidence, the review team concluded that the AVA's moderation system and procedures are well designed and are able to provide the intelligence to support a range of key processes and activities in relation to the standardisation of provision and the enhancement of Access to HE in a wider sense. The team commends the AVA on the quality of its system and processes for moderation.

Appointment and training of moderators

67 The process for the appointment of moderators is clear, and the role and responsibilities of moderators are made explicit from the outset. Moderators are appointed to a pool of moderators and are subsequently allocated to a course when a vacancy arises for which their curriculum expertise is appropriate. Moderators receive a contract and details of the centre and course they will be moderating. A list of moderators and centres is submitted annually to the Access to HE Committee for approval in November.

68 Moderators complete an annual update form in July which confirms their availability for service and notifies the AVA of any changes to key information such as employment details.

69 The AVA makes it clear to moderators (and others) in the Quality Manual that the purpose of moderation includes the maintenance and enhancement of the quality and fitness for purpose of Access to HE programmes; the monitoring of student experience; the verification of standards of student achievement leading to the award of the Access to HE Diploma and credits; and an overview of the conduct of assessment, which ensures the approved programme is being delivered and that students are receiving fair and equitable treatment. From meetings with moderators and members of the Access to HE Committee, and from their examination of moderators' reports, the review team formed the view that, in practice, the moderation process addressed and reported on all of these key items.

70 From meetings with moderators and members of the Access to HE Committee, and from examination of moderators' reports and the AVA's reports on standardisation events, the review team concluded that the AVA's current moderators are experienced and capable and make an important contribution to the AVA's quality assurance of Access to HE provision.

71 Moderators do not normally moderate any one course for more than three years and the AVA's maximum limit is four years. Although the group of moderators who met with the review team did not include anyone who had been newly appointed, the moderators commended the AVA's training which, in their view, complemented the clarity and completeness of the documentation which supports moderation.

72 The AVA did not appoint any new moderators for 2007-08 and is reviewing its training and induction process in 2007-08 to ensure that it is effective and appropriate for future appointments.

73 Moderators who met with the review team were complimentary about the speed with which AVA staff, in particular the Director of Access, responded to queries. They were also pleased with the way in which the AVA kept them informed of changes and developments, in particular the implications of the recent process of merger and the move over to the new Access to HE Diploma. Moderators are aware that a failure to meet contractual obligations could result in dismissal from their position.

Internal moderation

74 The AVA's moderators are tasked with monitoring and approving providers' internal moderation processes and reporting on their operation in their annual reports to the AVA. These reports must include: references to points raised by internal moderation and a summary of the provider's internal moderation reports; judgements on the effectiveness of the internal moderation system in improving assessment and the soundness of the provider's mechanisms for keeping records; a report on sampling and how this meets the AVA's requirements; and a reference to the action plan generated by the internal moderation process.

75 As part of their remit, moderators provide advice on internal moderation to providers when necessary. The emphasis is on the role of internal moderation in improving standards. The AVA states in its Overview that it 'continues to promote robust internal moderation practices and strengthen the connections between internal and external moderation'. The review team verified that evidence from the moderators' reports and from discussions with moderators and coordinators, supported this statement.

Action and feedback to providers on the outcomes of the moderation process

76 The Access to HE Support Officer supports the Director of Access in the processing of reports received from moderators. Copies of moderators' reports are sent to providers' Access to HE coordinators and quality managers. These include the action plans agreed by the moderators and providers.

77 A summary report, containing details of issues raised by moderators for each course and the actions that need to be taken to address them, is submitted to the Access to HE Committee by the Director of Access. Copies of individual reports are also available at the meeting should the Committee wish to refer to them. The Committee considers the report and endorses the proposed actions. Moderators subsequently monitor and report on progress on these actions to the Committee.

78 The Access to HE Committee also considers and approves action on the reports from subject moderators used by the AVA to support standardisation of the curriculum across providers and the promulgation of good practice through development work or through standardisation events such as Access quality forums. Although up to, and including, 2006-07 these have been used to support the standardisation of moderation, from 2007-08, Access tutor forums will also be held for tutors to support the standardisation of assessment.

Award and issue of certificates and diplomas

79 OCNER's Access to HE Awards, certificates and credit transcripts have a standard format which meets QAA licensing requirements, including the proper use of the QAA logo.

80 The review team heard from the AVA's Registration and Awards Manager that, following merger, the AVA had physically checked all of their records in relation to each programme and each centre to ensure that they were accurate and up to date. This was an essential process to allow for the proper implementation of the Access to HE Diploma and credit specifications and the award of the Access to HE Diploma. The audit trails provided evidence that this had been a thorough and successful process.

81 Centre moderators confirm students' learning achievement by signing the completed recommendation for the award of credits forms (RACs) after checking that the required number and level of credits have been achieved in the necessary units. This is also checked by the Registration and Awards team in the AVA office on receipt of the RACs before any certificates are issued to the providers for distribution to students. All students who complete the required learning achievement, as specified in the approved programme documentation, are awarded an Access to HE Diploma and credits.

Final assessment meetings

82 The AVA revised and updated its guidance about the function, process, and appropriate membership of final assessment boards or meetings in 2007. Centre moderators are required to attend final examination boards for all Access to HE courses within their centres, and to attach copies of the minutes of these boards to their annual moderation reports. The review team found the arrangements for final assessment meetings to be appropriate.

Audit trails

83 The review team conducted seven audit trails of OCNER Access to HE providers. The purpose of the trails was to enable the team to assess the effectiveness and consistency of the AVA's quality assurance procedures at provider level.

84 The review team considered an appropriate and representative geographical sample of Access to HE courses, including colleges of varying sizes, adult education service provision, one NHS Trust provider and one college that had recently transferred its provision to the AVA. The selected courses included a wide curricular range, including nursing, teaching, business, computer sciences and information technology, social sciences and media studies.

85 The audit trail files contained a generally consistent set of evidence, including examples of centre approval documentation, moderation, monitoring and self-assessment reports to demonstrate AVA processes. Documentation was available on Access to HE programmes that expired at the time of the OCNER merger and showed the processes of revalidation of programmes following the merger. The documentation included submission documents; the validation report; evidence that any approval conditions had been met; the letter of confirmation that validation conditions had been met; records of programme amendments; the final programme document; internal and centre moderators' reports; learner records and evidence of the AVA's administrative and support processes to track the various stages on an annual basis.

86 In addition to files for each selected provider, the review team consulted centre moderation reports for 2006-07 relating to OCNER, together with reports for OCN NELH and OCN Anglia for 2005-06. These reports enabled the team to assess the impact of the merger on programme moderation procedures. Subject moderation reports for the same two years were also provided. The team learnt that the former OCN Anglia providers did not undertake formal subject moderation prior to the merger, although two further education colleges had piloted the scheme in 2005-06. In the team's meeting with moderators, audit trail evidence concerning the articulation between subject and centre moderators' reports was confirmed, clearly understood and valued as an enhancement to the provision. Minutes and papers of the Access to HE Committee for the past year were a further useful source of information to clarify the approval and revalidation of programmes, including the approval of programme amendments.

87 Centre approval documents and correspondence were available for each of the seven audit trails. The review team noted the role of the development managers in tracking the various stages of the processes leading to centre approval. From the examples examined by the team, it was evident that the procedures were clear and rigorous from application through to final approval. Failure to meet the AVA's published requirements carries with it the potential sanction of withdrawal of centre approval.

88 The review team noted that data collection by providers in the audit trail files was of variable quality and interpretation. However, the AVA has implemented twice-yearly data collection of learner registrations followed by final student performance data. The team saw datasets for 2007 by programmes administered and running which were analysed by gender, ethnicity, disabilities, disadvantage, completions, awards and destinations to clarify improvements in the current academic year. The statistics were based on curricular areas of the Access to HE programmes and were not analysed by the provider. The team considered that comparative data for each Access to HE provider would be helpful both to the provider and the AVA.

89 During the conduct of the audit trails, the review team was guided by the Quality Manual, which is available to all AVA staff and providers. Subsequent meetings with the Access to HE Committee members, representatives from providers and moderators confirmed the value of this key resource containing a comprehensive set of guidelines, protocols and pro formas to ensure consistency of practice across all of the provision. It was also evident that the providers and moderators valued the considerable improvements noted in their self-assessment reports and moderators' reports. These meetings also confirmed evidence from audit trails that the Director of Access and the AVA development managers play effective roles in the conduct of quality assurance processes.

90 Evidence from the audit trails demonstrated the thoroughness with which the AVA oversees programme approval, validation, and review procedures. However, there was no clear evidence in the audit files that the selection criteria and processes for agreeing the composition of validation and revalidation panels ensured the necessary independence from the submission team. The merger to form OCNER meant that Access to HE programmes were revalidated following programme development for target groups within the regional context in accordance with the Access to HE strategy. The AVA has a consultative approach to quality assurance processes with its providers and higher education institutions that ensures fitness for purpose across the provision. Submission documents, validation panel information and reports, records of conditions of approval being met and final programme documents enabled the team to evaluate the consistency and effectiveness of validation procedures. The team also saw examples of mechanisms for programme amendments, and one case where extended programme approval for a short period of time had facilitated the alignment of two parallel programmes for simultaneous revalidation events.

91 The audit trails showed evidence that students are generally well supported by programme tutors, often on a one-to-one basis, with appropriate attention to individual learner needs and pastoral care. Although not all audit trail files included details of student feedback mechanisms, some providers gave information on student feedback that is obtained informally by tutors and formally through student evaluation questionnaires. Tutors who met the team commented that some providers have staff-student forums and both the annual self-assessment report and programme revalidation require the inclusion of student feedback.

92 Examples of publicity materials within the audit trails included the correct incorporation of approved logos. The new requirement that centre moderators should check and report on publicity materials annually will operate in 2007-08. The review team noted one prospectus where an endorsement quotation for a different programme appeared somewhat misleadingly on the facing page to the Access to HE course title.

93 OCNER has a clear set of guidelines for both internal and external moderation of its Access to HE programmes. Reports by subject moderators and the centre moderators are scrutinised by the Access to HE Committee, which ensures that appropriate action plans and responses to issues raised are addressed. Documentation to illustrate the effectiveness of the mechanisms in place confirmed the view of the review team that the AVA is aware of the fitness for purpose of its programmes and is able to safeguard the standards of its awards. The audit trails revealed that while most moderator reports were thorough and evaluative, some were less informative. As a consequence, the AVA has made moderator induction and training on the reporting element of the role a key priority to improve the quality and consistency of moderation reports.

94 The review team also saw examples of the award certificate and credit transcript. These were in accordance with the requirements for the Access to HE award.

95 On the basis of the information available, the review team had confidence that OCNER principles and procedures operate effectively and that the AVA maintains effective oversight of Access to HE programmes delivered by its providers under its authority.

Conclusions

96 OCNER was formed from two well-established predecessor OCN/AVAs in August 2005. It operates, but not exclusively, across the whole of the east of England, having been awarded a provisional AVA licence in 2006. OCNER is self-assured in its role as a regional awarding body for Access to HE: working in a dynamic educational environment, it has a flexible approach to the needs of its stakeholders and has made pragmatic decisions to progress work through a period of considerable change.

97 It is evident that there has been considerable momentum in developing the AVA in the comparatively short period of time since the merger. Building on the positive record of the predecessor AVAs, OCNER has been particularly effective at managing the effects of change on its staff and stakeholders. While maintaining stability for providers and learners, it has at the same time been proactive in its response to new initiatives by, for example, taking a lead on the implementation of the new Access to HE Diploma.

98 The degree of preparedness for the AVA review and the quality of the Overview demonstrated to the review team how OCNER has cultivated a self-critical insight into its systems and operation. A thorough exercise mapping its achievements against the licensing criteria was accompanied by reflective comment and plans for ongoing development.

99 The review team noted that there were some important areas which have, largely for reasons relating to the merger and its consequences, been functioning in a less than satisfactory way. There have been no staff in the post for the financial operations of the AVA for several months and the Finance Committee has not met for most of the past year. Responsibility for financial affairs has been assumed by the Chief Executive who has reported directly to the Board of Trustees. The nature of this reporting has not been as full as would normally be expected for the AVA.

100 The review team considered that business projections were lacking in detail and gave a rather optimistic view of the future financial position. For example, there was no indication of how a possible reduction in student numbers might adversely affect the organisation. Although a risk register is maintained by the Board of Trustees, this does not fully explore possible impacts on OCNER and how these might be addressed.

101 The review team was reassured by the commitment of OCNER to improve this position as soon as possible. A new Director of Finance and Operations, who is a chartered accountant, started in October 2007. Monthly management accounts are being reinstated in December 2007 and preparation for the annual external audit was well under way. Meetings of the Finance Committee were planned to resume imminently. Senior staff are committed to making data collection improvements that will enhance the capability of the AVA to monitor its business operation. The Board of Trustees, who demonstrated commitment and active involvement in the work of OCNER, indicated their interest in developing their risk assessment capability.

102 Access to HE is a prominent part of OCNER's work and is clearly valued by staff and stakeholders alike. There is a designated Director of Access and a separate Access to HE Committee. Stakeholders have a high regard for OCNER, with both new and established partners having a sense of mutual benefit and pride in their cooperative work. The strategic involvement of the AVA at national, regional and local level facilitates effective networking, and has enabled OCNER to spearhead new Access to HE initiatives to meet demand appropriately.

103 The successful operation of both the strategic and day-to-day business of OCNER is facilitated by the energy and commitment of the staff and their internal and external teamworking. Stakeholders commented favourably on the excellent communication systems and the accessibility and responsiveness of OCNER contacts. A particular example of this is the Director of Access and the development managers who work peripatetically within OCNER's Access to HE team.

104 The AVA effectively uses the outcomes from annual reviews of providers to inform future provision and is thorough in applying its clearly defined processes to assure academic standards. The role of the centre and subject moderators in this activity is pivotal. The review team particularly noted how the extensive experience and contribution of moderators contributed positively to the work of OCNER.

Commendations

105 The AVA is commended for the

• effectiveness of its governance and management in bringing about a smooth transition to the newly merged AVA (paragraph 17)
• clearly defined responsibilities for Access to HE at all levels of operation (paragraphs 25, 28)
• prominence of Access to HE within the totality of the OCN's work and its centrality in business and strategic planning processes (paragraphs 32, 34)
• effectiveness of its staff (paragraphs 34, 41, 48, 73)
• useful, comprehensive and accessible quality manual and website (paragraphs 43, 65)
• effectiveness of its communication with stakeholders (paragraphs 43, 57, 73)
• promotion and development of Access to HE and its engagement in local, regional and national initiatives for this purpose (paragraphs 48, 61)
• clear leadership demonstrated in the implementation of the common credit framework and the Access to HE Diploma (paragraph 61)
• quality of its system and processes for external moderation (paragraph 66).

The AVA licence

Review outcome

106 The Open College Network Eastern Region is awarded a confirmation of its full AVA licence, with a single condition to be met by 4 April 2008.

Conditions

107 The licence is confirmed on condition that the AVA:

i amends its Guidance on course development and approval document to include a statement that QAA recognition may be given only to Access to HE courses which are delivered in the United Kingdom, and so that references to '500 notional learning hours' are removed (paragraphs 49, 50).

Recommendations to the AVA

108 The review team recommends that the AVA:

i limits the number of times that trustees can be re-elected (paragraph 20)

ii records more fully the informal discussions that inform decisions subsequently taken in key business areas (paragraphs 26, 33)

iii develops its capacity to take a comparative statistical overview across its Access to HE provision (paragraphs 38, 58, 88).

iv introduces a more in-depth risk assessment method (paragraph 40)

v monitors the implementation of the centre moderators' new role in verifying the accuracy of promotional literature related to approved Access to HE provision, and the proper use of the authorised QAA logo (paragraph 46)

vi establishes selection criteria and a process for proposing and agreeing validation and revalidation panels so that the AVA can assure itself that panel members are independent from the submitting team (paragraph 53)

Appendix - Aims and objectives of AVA review

The aims of the system of AVA review are to:

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

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

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

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

The objectives of each AVA review are to:

i 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 certificate
• the evidence available to indicate the AVA's success in achieving its aims and targets

ii identify and report on:

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

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