South of England Open College Network
July 2001

Foreword

1 The Quality Assurance Agency for Higher Education (QAA) is responsible to the Department for Education and Skills 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 committee of the QAA Board of Directors.

2 This is a report of a major review of the AVA function of the South of England Open College Network (SEOCN) undertaken by QAA. The Agency is grateful to SEOCN 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:

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

to stimulate reflective and self-critical perspectives within AVAs, as an instrument to promote quality enhancement;
to provide an opportunity to identify and disseminate good practice of AVA operations;
to provide a mechanism for ensuring necessary, and encouraging desirable, improvements and developments in AVAs.

4 The objectives of each AVA review are:

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

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:

unconditional renewal of licence for a specified period;
conditional renewal of licence with conditions to be met by specified date;
provisional renewal of licence with conditions to be met and further review visit by specified date;
suspension of licence until specified conditions are met;
withdrawal of licence for operation as an AVA;
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 SEOCN representatives 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 SEOCN 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 SEOCN to finalise the programme and other arrangements for the review visit.

7 The review visit took place on 22 and 23 March 2001. The visit to SEOCN consisted principally of meetings with representatives of SEOCN, including AVA officers and other staff; members of the Executive and Quality Committees; members of recent Access validation panels; moderators for Access to HE programmes; Access to HE practitioners; representatives of the University of Brighton; senior managers from providing institutions; higher education admissions tutors; and former Access students now studying in HE.

8 The review team consisted of Mr Anthony McClaran, Deputy Chief Executive of the Universities and Colleges Admissions Service, and Ms Sue Georgious, Director of the Open College Network for Central England. The review was coordinated for QAA by Ms Kath Dentith, Assistant Director (Access), Institutional Review Directorate.

AVA statistics 1999-2000

Providers offering Access to HE programmes	15
Access programmes available	52
Access programmes running	43
Access learner registrations	786
Access to HE certificates awarded	462

The AVA context

General background

10 The origins of the AVA lie in the Southern Access Federation (SAFE) which was formed in 1989 and received its licence from CNAA/CVCP in 1991. In partnership with the Sussex Open College Network, SAFE created the South of England Accreditation Network (SEANET) in 1993-94, and in 1998-99 SEANET became the South of England Open College Network (SEOCN).

11 SEOCN is based in Brighton, and since 1991 has been located in premises owned by the University of Brighton. It operates across the counties of East and West Sussex, Surrey, Hampshire and Kent, and the Brighton and Hove unitary authority. The area covered shows some dramatic contrasts: alongside communities which have benefited from the long-term financial prosperity of the South East are seaside towns with significant unemployment and rural areas which have not escaped the economic and infrastructural difficulties which have affected all rural economies. During the various organisational changes which the AVA has experienced since its foundation, a strong thread of continuity has been provided by the Co-ordinator, who has served in this role since 1989.

Developments since the last review

12 The last review of the AVA was conducted by the Higher Education Quality Council (HEQC) in November 1994. The review took place at the time of the formation of SEANET and this was reflected in the conditions which were stipulated: a document was required setting out the implications of the merger and details of proposed operational arrangements, and a monitoring report was required after 12 months of SEANET's existence. HEQC was subsequently supplied with these documents and formal confirmation that both conditions had been met was given in May 1996. Since then, the main policy development has been the introduction of the unitisation of the AVA's provision as part of SEANET's, and then SEOCN's, implementation and development of an OCN structure. A credit-based curriculum model was adopted in 1994, leading to the transfer of some Access provision then validated by the AVA to neighbouring AVAs. Access provision has also been transferred into SEOCN as a result of the closure of other, non-OCN, AVAs in neighbouring areas. The process of unitisation has been the subject of research by the AVA, which has taken note of the report's findings that there is still further work to be done in the development of unitised Access.

Mission, aim and objectives

13 SEOCN regards Access to HE as part of its commitment to widening participation in the region, and the mission for the AVA is embedded in the Network's common mission statement: 'South of England Open College Network aims to promote access to lifelong learning through education and training opportunities for learners in the region, particularly those who have benefited least from available provision, through the provision to its members of a high quality, flexible, quality assurance and credit-based validation service'. The Strategic Plan for the period 2000-03 is structured around three broad strategic aims, each of which has a number of related objectives for 2000-01, and 'milestones' are given for each objective, indicating dates by which it is intended that key actions will have happened.

14 Following a strategic seminar held for its Executive Committee in October 2000, the AVA adopted a new planning and review model. For the first time, and as the result of a deliberate planning decision reflecting the AVA's belief in the integration of the different parts of its activities, SEOCN's current strategic plan does not include a discrete strategic aim related to the AVA and Access to HE provision. The AVA's Executive Committee has chosen, rather, to plan Access to HE provision within the broader strategic context provided by the OCN's mission and its three strategic aims:

'To ensure the OCN/AVA fulfils its mission and abides by the principles of widening participation, tackling social exclusion, supporting lifelong learning and raising levels of achievement.'
'To ensure the effective positioning and promotion of the OCN with key stakeholders in the region and nationally.'
'To ensure a high quality, efficient and cost effective service to members.'

15 The AVA claims in its Account that 'it has a clear strategy for its Access provision' and draws attention to 'a series of milestones integrated within the OCN's activities'. The review team noted that some strategic objectives included reference to SEOCN's AVA activities, and that one milestone exclusively related to the assessment of Access provision, suggesting valuable attention given to the evaluation of developments. Nonetheless, it was not clear to the review team how the individual milestones reflected a 'clear strategy' for Access to HE provision, and it was difficult to locate within the Strategic Plan an explicit structure for responding to the specific challenges faced by Access to HE within SEOCN's geographical area.

16 The team recognised the legitimacy of the AVA's integrated approach to strategic planning, but had concerns that the current processes did not secure the place of Access to HE or its development as a particular area of activity, and that the responsibility for the development and monitoring of a strategic agenda explicitly for Access to HE within the AVA's structures was uncertain. As a particular example, the team noted that the action points provided in the AVA's annual reports to QAA did not appear to have any formal relationship to the OCN's overall Strategic Plan. Additionally, the structures through which they would be monitored and which would ensure that they were met, particularly in any circumstances which presented competing pressures on staff and resources, were not clear. While not wishing to understate the extent and value of SEOCN's current and recent developmental activity in relation to Access to HE, the team concluded that future strategic planning should include specific consideration of the further development of SEOCN's AVA responsibilities and Access to HE provision. The results of this process should be reflected in discrete and specific strategic objectives, in order to secure the place of Access within SEOCN's overall strategic framework.

17 Outside the context of the strategic plan, some Access activities flow from informal sources, such as practitioner meetings and the annual Access staff conference (see paragraphs 25 and 39-40, below). The operational implications of the suggestions produced by such means are dealt with by the AVA's officers. In addition, senior managers from providing institutions noted that Access to HE provision remained a 'major plank in the ladder of progression', and it was clear that members and officers of the AVA believed that Access to HE remained an important part of the OCN's overall provision.

Membership and provision

18 Eighty-two organisations are currently in membership of SEOCN, including four HEIs, 11 FE and tertiary colleges, seven sixth form colleges, 21 community colleges/adult education centres, six schools, 23 voluntary organisations, seven private training providers and three local authorities. Since the HEQC's visit in 1994 there has been an increase in the number of non-statutory sector organisations in membership, although the recent decision to remove free membership for such organisations has now led to some of them leaving. The terms of membership are governed by a service level agreement, which sets out clearly the respective responsibilities of SEOCN and the member organisations. Membership is diverse and is drawn from across the regions served by the AVA. However, some further education institutions are not in membership and SEOCN is concerned that this might reduce the effectiveness of initiatives requiring sector-wide collaboration.

19 Validated Access to HE provision is available and running in 12 institutions within the AVA for 2000-01. A further three organisations have validated provision but have not offered it during 2000-01 and another two colleges offered validated provision but did not recruit. There has been a small reduction in the number of centres offering Access provision in recent years and the AVA is concerned that it no longer has any courses delivered in community colleges. The providing institutions are drawn from across the AVA's region and include two sixth form colleges and one higher education institution. In the current year, they offer between them 56 Access courses covering a range of curriculum areas. In 1999-2000, 64 per cent of all enrolments were for courses in the arts, humanities and social studies areas and 25 per cent were on science-based Access courses.

Targets and achievements

20 Within the overall context of the OCN's activities, Access courses currently constitute 5 per cent of learner registrations. Access registrations increased by 15 per cent (from 668 to 786) between 1998-99 and 1999-2000, although they have yet to reach the figure of 897 achieved in 1997-98. In 1999-2000, 681 learners completed Access courses; 462 were awarded the Access to HE certificate; and, of those for whom an intended destination was known, 324 indicated that they intended to progress to higher education. Students from ethnic minorities accounted for 6 per cent of the total, compared to the 2 per cent which minority ethnic groups constitute within the region's population. (This latter figure, however, masks the fact that within some areas the minority ethnic population can be as much as 40 per cent). Some 18 per cent of the AVA's learners were registered unemployed in 1999-2000, a slight increase from 16 per cent in the previous year.

21 A concern with targeting runs explicitly throughout the procedures of the AVA: Access providers must include target groups in their submissions for validation; validation panel members are asked to focus on targeting; moderators are required to comment on targeting in their reports; and the AVA monitors the position both by scrutinising moderators' reports and receiving data from providers. Although the Account indicates that there have been no incidences of moderators reporting that providers have not recruited according to their approved missions, it is nevertheless the case that the AVA's annual conference for Access staff last year recognised the extent to which its Access provision in widening participation is not as clear as might be wished, and there is a recognition that further consideration needs to be given to determining what data is gathered from Access learners. The AVA currently uses the FEFC's postcode-based 'uplift index' data and, in attempting to analyse the success of its widening participation strategies, it intends to review the means by which success might be measured in the light of clearer information about the data requirements of the Learning and Skills Councils. The review team supports the AVA's intention to conduct further work in this area and further suggests that the development of explicit milestones for success in targeting might flow from the development of explicit strategic aims and objectives for Access provision.

Financial position, structures and income sources

22 SEOCN's income is derived from the annual fee paid by all its members and the charges levied for accreditation services. The fees payable by the various categories of members, the accreditation service charges and moderation fees and expenses are all set out clearly in a charging policy document. The finances of the OCN are sound: in 1999-2000 gross income was nearly £290,000, over 45 per cent greater than the budgeted amount. The OCN was able to add £10,000 to its separate reserve account (bringing it to £55,000) and to carry forward over £46,000 as an operating contingency fund for 2000-01. The remainder of the surplus was earmarked for the costs of two additional full-time members of staff and anticipated costs of any possible relocation to new premises, together with office refurbishment.

23 Draft annual budgets are initially set by the AVA's Co-ordinator and Operations Manager, with support from a link person provided by the University of Brighton's Finance Department to ensure adherence to financial regulations. The Executive Committee approves the draft budget. The AVA acknowledges the outstanding need to provide a register of assets, appropriate operational plans for action in the event of a cessation of the OCN's activities and a balance sheet. It intends to address these matters during the current financial year, utilising external financial expertise where appropriate.

24 The evidence available to the review team led it to conclude that the financial affairs of the AVA are well managed, and its finances are clearly robust. Nevertheless, the surplus achieved in 1999-2000 was considerably in excess of the budgeted amount and the absence of a strategic financial plan meant that it was not entirely clear whether this had been the result of deliberate policy and, if so, precisely what, beyond funding the costs of additional staff and having a general sense of financial security should the AVA's circumstances change in some significant way, the purpose of the policy might be. The team recommends that a clear statement of the medium-term financial strategy of the AVA be developed so that the financial policy can be placed in a strategic context, particularly in relation to plans for the surplus, contingency fund and special reserve account.

Planned developments

25 Development of Access to HE provision within the AVA is based on a reflective approach which is largely driven by practitioners and officers and informed by careful and critical data analysis. The locus of the AVA's developmental activity resides firmly with a committed and well-informed practitioner group and officers of the OCN. The annual Access conference is also a vehicle for guiding the AVA's developmental agenda as evidenced by the summer 2000 conference entitled 'Facing up to the Failure of Access'. The outcomes of this conference and subsequent practitioner discussion have explicitly informed the development of what was frequently referred to during the visit as 'new Access'.

26 SEOCN has identified new Access as the key response to developing Access provision, widening participation and combating any decline in numbers. This major development planned by the AVA for the current year involves, essentially, the development of a model for 'stand-alone' units of Access provision. The concept rests on providing a more flexible approach to both the structure and context for Access programmes including outreach, part-time provision and more flexible delivery modes. Exploration of on-line delivery is underway as part of what the AVA describes as its 'ambitious developmental agenda'.

27 The concept is based on the development of the possibilities already inherent in the unitised provision adopted by the AVA as part of its OCN development and will involve ensuring that stand-alone units are available in a wider range of geographical settings within the region and at times which ensure that the provision is accessible to adults who have been excluded from participation. The AVA is planning to hold a conference on outreach later this year and during the spring term intends to present a paper to key stakeholders on its vision for stand-alone provision.

Governance and committee structures

Legal status and constitutional position

28 SEOCN is an unincorporated association governed by a constitution which states that it is a membership organisation operating within the terms of its membership and service level agreement, charging policy, strategic plan, operating statement and to the quality standards of the National Open College Network (NOCN) and the QAA in respect of its Access to HE provision. As has already been noted, (see paragraph 11, above), the AVA has occupied premises at the University of Brighton since 1991 and there is currently a draft Memorandum of Agreement with the University which specifies the nature of the relationship between the AVA and the University, and is intended to confirm the University's recognition of SEOCN as an autonomous association of which it (the University) is a member. The draft Memorandum explicitly states that 'the University recognises the separate legal identity of the OCN with its members sharing collective liability' and goes on to make clear that the University will not seek to influence or constrain the OCN in any way which goes beyond its entitlement as an ordinary member of the association. This fundamental position was stated with equal clarity to the review team by the Director of the University of Brighton during the review visit. In addition to being a member of the OCN, the University is, of course, also its landlord and, in addition to performing that role, gives the AVA considerable support in kind. The University provides professional personnel and financial services, office accommodation and facilities services, and post and information/telecommunication services (including the internet) at no charge. The University does make some charges for consumables and, in the Memorandum of Agreement, reserves the right to agree charges on an annual basis for those costs directly attributable to the AVA.

29 Although all AVA staff are employed on individual, fixed-term contracts of employment with the University, they are appointed by the OCN's Executive Committee, in liaison with the University. Similarly, staff are subject to annual review under the University's staff development and review policy, but all reviews of AVA staff are conducted by the Co-ordinator (who is accountable to its Executive Committee) or by the Operations Manager. The Co-ordinator, who combines his 0.5 role in that capacity with a 0.5 University appointment, is, in his Co-ordinator's capacity, reviewed by the Chair of the AVA's Executive Committee. Although the Memorandum of Agreement is currently in draft form the review team was assured that the Memorandum, which has now been through several iterations, expresses the relationship to which the University and the AVA are committed and that, subject to guidance that may emerge from the QAA, both parties confidently expect to be able to confirm it in due course.

30 The review team found evidence both in the documentation from the AVA and in discussions during its visit that the support provided over a number of years by the University of Brighton is greatly appreciated and there is no indication that the AVA's independence is compromised. Conflicts of interest have not arisen so far and, indeed, the team had evidence, not least from the Director of the University, that the University believes it gains a great deal from the relationship with the AVA and the synergy between its aims and objectives and the University's own strategies for widening participation. Nonetheless, both AVA and University recognise that some practical difficulties might arise in the future and that, as pressure on University resources become more intense, the needs of the AVA will need to be weighed alongside other claims. The most obvious area where this might occur is with regard to accommodation: the AVA needs to expand as it increases its staffing levels, while space in the University is increasingly at a premium. The team heard that the possibility that some expenditure might be incurred for accommodation in future, either within the University or elsewhere if the AVA's needs could not be accommodated, was one consideration behind the accumulation of significant surpluses and reserves. The team recommends that this risk be more fully assessed so that this element of financial planning, which seems eminently sensible, be incorporated in the developed financial strategy to which reference has already been made (see paragraph 24, above).

Committee structures

31 The committee structure set out in the SEOCN constitution of 1 August 2000 is the result of a thorough review of the effectiveness of the previous governance arrangements. Formally, SEOCN had been governed by a Governing Council which in theory had supreme decision-making authority and on which all members were represented. The Governing Council was assisted in discharging its responsibilities by a Management Group. The Governing Council as a large inclusive body was judged to be inappropriate as a vehicle of executive management within the AVA since it was never quorate and all decisions had to be ratified by postal ballots. In practice, much day-to-day executive responsibility fell upon officers or the Management Group and there was thus a mismatch between the AVA's constitution and the reality of the way in which authority was exercised. The new arrangements which have now been adopted by the AVA were intended to remedy these deficiencies. The Governing Council was abolished and replaced by a Council of Members which holds an annual general meeting. The Management Group was recast as the Executive Committee, and a Quality Committee was established as the locus of SEOCN's quality assurance arrangements. Members of both committees are elected by the Council of Members at its AGM. The AVA thus has an unusually slim committee structure, with just two committees which address all of the OCN's business, including both AVA and non-AVA matters. Outside the formal committee structure lies the Access Practitioners' Group, which meets termly.

The Executive Committee

32 According to the Account, the Executive Committee is charged principally with the governance of SEOCN. It has responsibility for approving the strategic plan, the annual operating statement, the annual budget, the annual self-assessment report, the charging policy and other initiatives. It agrees organisational structures and staffing, and all changes to operating procedures and practices. The Executive Committee has the authority to approve, refuse, suspend or withdraw membership of SEOCN from individual institutions and it governs the operation of the Quality Committee and any other committees which it may decide to establish from time to time. The Committee is made up of 12 members who are elected annually by the Council of Members. The draft terms of reference specify that the representatives should 'normally reflect the range of different sectors and geographical areas of institutions in membership of SEOCN and connection to one of the key stakeholding groups in the regions that share elements of the OCN's mission'. In addition to the 12 elected members, the Executive Committee may co-opt up to three additional members where a clear rationale has been identified by the Committee of the need for skills, expertise or sectoral representation not available among elected members. With this broad membership, the Committee is intended to constitute a 'virtual reference group'. The Executive Committee's Chair, who, like the Vice-Chair, is elected by the Committee's members, is de facto the Chair of the OCN. The Network's Co-ordinator, Operations Manager and a representative of the development officer team are ex officio members of the Executive and they prepare its agendas, papers and minutes. The Committee meets five times a year.

33 The review team found plenty of evidence in the documentation which it considered and in the discussions which were held during the review that the outcomes of the review of the AVA's governance structures were thoroughly prepared, well-considered and widely supported. The rationale for the changes is clearly expressed and terms of reference and written procedures for arrangements such as the annual elections are all in place, albeit in some cases in draft form. There was, however, some uncertainty about the precise role of the Executive Committee in relation to the AVA's officers and, particularly, its Co-ordinator: for some, the intention behind the changes has been to create a 'chief executive' model, with the Co-ordinator fulfilling that role and the Executive Committee really functioning as a 'strategy committee'; indeed, it was suggested during the discussion with the Executive Committee itself that this might be a more appropriate title for the Committee. The Committee itself has expressed a wish for its members, and the stakeholding organisations which they represent, to have a more direct input into the strategic direction of the AVA. The team notes that the terms of reference for the Executive Committee are still in draft form and it recommends that consideration be given to defining more carefully the relationship between the relative executive and strategic responsibilities of the Co-ordinator and the Committee itself.

34 The membership arrangements for the Executive Committee are deliberately designed to ensure a balanced representation of a range of different areas, sectors and interests within SEOCN. Notably absent, however, from the categories thus represented is Access to HE provision as a distinct area of activity. While the Executive Committee has, to date, always included members with Access to HE experience, this representation is not constitutionally protected. The team concluded that, under current arrangements, the direct representation of Access to HE and AVA issues in the constitutional arrangements of the AVA's executive body is not secure. In order to assure an appropriate representation for Access to HE within the governance structures of the AVA, the team would advise the AVA to consider including a formal requirement in the membership composition of the Executive Committee that there be representatives specifically for Access to HE.

Quality Committee

35 The Quality Committee, which is a committee of the Executive Committee, is responsible for ensuring that internal and external quality standards are met, that external audit guidelines are followed, and that internal regulations and procedures have been adhered to; and for receiving and commenting on the external auditor's report, for hearing appeals against the conduct of validation panels, assessment boards or moderation, and for agreeing the composition of the NOCN audit report. The Committee performs an internal audit role: four OCN programmes will be audited during the course of the current academic year and two of these will be Access to HE courses.

36 The Quality Committee is clearly intended to play a key role in the overall quality assurance arrangements operated by the AVA. In support of its internal audit function, the Committee receives a number of evaluative reports prepared by officers on key operational areas such as the moderation process, validation and programme administration. The Committee normally meets three times a year and, like the Executive Committee, operates according to a clearly documented 'cycle of business'. The Account indicates that SEOCN has recently undergone an overhaul on its approach to quality, in which it has attempted to distinguish between the external compliance which is required in relationship to NOCN and QAA and the internal quality assurance, control and enhancement processes. This work is still in progress as the AVA moves towards what it hopes will be a fully integrated approach to quality which deals not only with compliance but also with the identification and enhancement of those factors that promote success.

37 The Committee comprises eight members: the composition is intended to reflect the range of sectors and the geographical spread of the membership, and also includes one external representative from another OCN. The terms of reference of the Committee also specify that at least two of its members should have experience of Access to HE programmes. Members of the Committee are nominated and elected by the AVA's members, and the Committee elects its Chair from among its members. Recently, the AVA has attempted to strengthen the link between the Executive and Quality Committees by appointing a 'link person', a member of the Executive who will also serve on the Quality Committee.

38 In its discussions with members of the Quality Committee, the review team was able to confirm the Account's observation that the current structure for quality assurance is 'not yet fully understood by all those involved', at least in relation to the Committee itself and its understanding of its role. The standard of the papers and reports prepared for the Committee is often high and clearly indicates that much critical self-evaluation is taking place across the AVA's activities, but there is some uncertainty on the Committee's part about the role of some of those elements which play an important part in the AVA's overall approach to quality in relation to Access to HE, such as the 'Quality Circles' which bring together those performing similar roles with regard to different Access to HE programmes in order to encourage standardisation and consistency. The team recommends that, as the AVA continues to develop its quality framework, the Quality Committee should develop documentation which specifically shows how the various elements of that framework link together and the part which the Committee plays in operating them, to guide its future deliberations. The AVA may also wish to consider whether, in operating its electoral system for the Quality Committee through the Council of Members' Annual General Meeting, it wishes to define the requirements for eligibility for serving on the Committee to include significant experience of having operated quality assurance systems.

Access Practitioners' Group

39 The AVA's governance structure does not include a separate Access to HE committee or group. However, Access practitioners (drawn largely from among Access coordinators and link persons from higher education institutions) hold termly meetings to discuss a wide range of issues, and this provides the focus for discussion and development of SEOCN initiatives relating to Access to HE. Sample agendas considered by the review team included reports from Access working groups on particular key areas (APL, key skills in Access and widening participation, for example), reports from the Quality Circles for standardisation and issues of retention, achievement and progression. Access practitioner meetings serve both as sounding boards and as valuable sources of new ideas and developments. Any recommendations or suggestions which arise from the meetings are taken forward by the AVA's officers, being referred to one of the AVA's committees if necessary.

40 The commitment and knowledge of the members of the Group met by the review team was very evident and it clearly constitutes a significant resource for the AVA. While recognising that the current arrangements are operating to the satisfaction of those involved, the team considered that the Access Practitioners' Group also had the potential to make a valuable contribution to the AVA's formal planning and development processes, discussed above (see paragraphs 16-17). The team would suggest that, in order to derive greatest benefit from the experience and expertise within the Access Practitioners' Group, the AVA may wish to consider providing it with a more strategic role, with formal links to the AVA's decision-making structures.

Organisational structures

Management and administrative arrangements

41 SEOCN is supported by the OCN's staff (currently 10 people amounting to 6.37 FTEs), all of whom are involved in supporting SEOCN's Access to HE responsibilities. The staff team is led by the Co-ordinator, who works 0.5 FTE for the AVA and 0.5 for the University of Brighton. The Co-ordinator is supported by an Operations Manager who is responsible for five members of administrative staff. Two 0.5 FTE Development Officers and a recently appointed full-time Innovation and Quality Development Officer are managed by the Co-ordinator, as is the Operations Manager.

42 The roles and responsibilities of all members of administrative staff are well understood and documented. The Co-ordinator provides strategic leadership and has overall responsibility for the AVA's development, coordination and operation. He represents the AVA on external bodies, both regionally and nationally, provides strategic guidance to member organisations and liaises with the host University. The Operations Manager is responsible for managing and developing the OCN's administration, communications, publications, information systems and marketing strategies; for providing financial and budgetary monitoring and control; for providing a secretariat service for the AVA's committees and other meetings; and for management of the administrative staff. The Development Officers, recently strengthened by the new appointment, provide advice, guidance and support in the development of new programmes, and they play a key role in the validation process. The officers also coordinate and support staff development activities across the AVA, and conduct research to support the AVA's activities. The administrative and clerical team comprises an Information Systems Administrator, a Programmes Assistant, and three Administrative Assistants with defined individual responsibility for moderation, validation and assistance to the Co-ordinator.

43 The review team found every evidence that the officers of the AVA provide it with first-rate support. The development and administrative teams are well managed and produce committee documentation and reports to a very high standard. There has been some concern about delays in the production of certain documents but the AVA has taken active steps to address these problems by strengthening its staff and intends to conduct a full staffing review. The team, in its discussion with members of the AVA, encountered repeated expressions of the high regard in which the administration is held, and the AVA is to be commended on the standard it has set.

Data management, collection and analysis

44 SEOCN has developed a bespoke database and management information system. An indication of its quality is provided by the fact that four other OCNs have purchased the system. It enables SEOCN to capture data throughout the learning cycle, from registration to progression. Data is also provided on general enquiries about Access to HE and on other essential components of the overall system such as the staff involved in moderation and the revenue generated from Access to HE provision. Trends concerning the number of Access to HE learners and programmes, the profiles of particular cohorts and recruitment to different curriculum areas are available to the AVA and can be used to inform its strategic direction and development. There are still some difficulties: compliance in the provision of data is an issue within SEOCN and attempts are being made to improve the situation through the use of a compliance document which clearly sets out the AVA's expectations. The AVA is aware that it could make more use of the data available from its member higher education institutions and also wishes to provide more data to them, and the arrangements for this are still being established. Nevertheless, the overall position with regard to data is a strong one and reflects credibly on those of the AVA's officers who have been involved in the management and development of the AVA's information systems. The review team, in its discussions with members of the AVA, received a consistent impression of the high value which is placed upon the data services provided by the AVA, and would commend the AVA for its work in this area.

Communication with providers

45 SEOCN communicates with its Access stakeholders in a variety of ways. Reference has already been made to some of these: the Access Practitioners' meetings, for example, are particularly effective and there are also annual conferences for Access staff. The AVA produces a suite of attractive, clear, accessible publications, including an Access courses directory, a guide for students entitled Applying to Higher Education, good practice notes about the UCAS system for Access tutors and guidance notes for HE admissions staff. Discussions with a range of different groups provided evidence that these documents are well known and well used by both students and staff, and they are certainly valued. They undoubtedly contribute to the high profile which SEOCN has as an AVA among its stakeholders. The AVA is not complacent with regard to communication and there is currently some concern about the need to ensure more effective marketing across the AVA. The team would certainly encourage further work to be done in this area but nevertheless commends the AVA for the high standard which it has already achieved in its publications and other forms of communication.

Development, validation and evaluation of Access programmes

Development and design of new provision, standard requirements and advice to providers

46 New programme development is, in the majority of cases, initiated by providers. The process is clearly articulated in comprehensive guidance documentation which identifies the specific requirements for Access to HE submissions. Systems for tracking and monitoring development are robust. Guidance documentation is regularly updated and Development Officers provide support and advice for programme development throughout the process. The requirements for new programme submissions are clearly specified and the review team confirmed that practitioners and Development Officers have a thorough and professional approach to the programme development process.

47 SEOCN has agreed and published minimum requirements for learner achievement for the Access to HE certificate. A minimum of 15 credits at level three and five credits at level two are required and this is applied across all provision and appears to be clearly understood by all involved in Access to HE across the AVA region. There is also a standard requirement for the percentage of the credit target which must be achieved by examination (20 per cent) and this is also applied consistently. These requirements are explicitly stated in all documentation supplied to providers. The review team concluded that the clarity of guidance to support programme development should be commended.

Validation of new and revised provision

48 SEOCN operates standard and well-regulated validation procedures for all new provision. The procedures are clearly described and consistently applied to all Access to HE programme validations. Systems for setting up validation panels are robust and panel members receive comprehensive guidelines and documentation sufficiently well in advance of panel meetings. Representatives from higher education are well represented at Access validation panels and appropriate curriculum expertise is consistently available. This was evidenced through meetings of panel members and moderators during the review visit as well as scrutiny by the review team of recent panel documentation. The AVA monitors panel membership systematically, and the internal audit process operated through the Quality Committee also audits the validation process. The panel is responsible for approving the moderator to the programme and for confirming and approving the detailed specification for the programme.

49 Prior to the validation panel, submission documents are sent to panel members for scrutiny and any issues and concerns can be submitted to the Chair in writing for consideration. In addition, one of the AVA's development officers who has not been involved in the development of the programme reads the submission and prepares a report for the Chair. Issues raised in this way are incorporated into the agenda for the panel meeting. These two processes are intended to provide checks and balances to the panel process and the review team noted comments from practitioners and panel members that chairing was rigorous.

50 All Access validation panels are currently chaired by one of the AVA's two development officers or by the Co-ordinator, although officers do not normally chair panels where they have been involved in the development of the submission. The recognition of a new Access programme therefore involves all three of these officers: one as development officer for the programmes; one as external scrutiniser prior to the panel; and one as Chair of the validation panel. While recognising the benefits of consistency that may derive from this system, this arrangement raised some concerns for the review team about how the AVA was able to ensure appropriate externality of the Chair, and thus the panel itself, from the process of programme development.

51 The review team's concerns about the chairing of panels led the team to consider where ultimate responsibility for the recognition of Access to HE programmes was located within the AVA. The formal position is that the validation panel holds devolved decision-making powers from the Executive Committee for approving Access to HE programmes and for the detail of the Access to HE programme specification, although it was not clear to the team how the Executive Committee oversaw these devolved responsibilities. The authority, therefore, for the recognition of Access to HE courses within the AVA is vested with the panel. Responsibility for signing off approval once any or all conditions are met lies with the panel Chair who is, in all circumstances, an OCN officer. As there is no ratification of decisions within the governance structures of the AVA, the authority for confirming approval of the programme and the Access to HE specification may therefore rest with an officer. The review team concluded that the arrangements for chairing panels and programme approval should be reconsidered, and that ultimate authority for the recognition of Access to HE programmes should be unambiguously located within the governance structures of the AVA.

52 Panel reports clearly identify recommendations and conditions and are circulated to all panel members following panels. In addition, all panel members receive panel evaluation information which is systematically collected. The review team noted this as an example of good practice which was valued by panel members interviewed. The team found that it was difficult in all cases to identify in the reports themselves confirmation of moderator appointment and of the specific programme requirements for the award of the Access to HE certificate. The team suggests that a statement clearly specifying these in the conclusion of the report would be useful and would ensure the consistency of reports.

53 The procedures for amending programmes are clearly detailed in the Validation Processes and Procedures Handbook. Systems and procedures involve both the moderator and Development Officer, and criteria for the types of revisions not requiring submission to a validation panel are clear. These amendments are processed by officers. The introduction of more flexible provision for 'new Access' (see paragraphs 25-27, above) may require SEOCN to consider the systems and procedures currently in place to ensure that consistency and coherence are maintained if programmes are amended to accommodate new approaches.

Monitoring, evaluation and review

54 The appointed moderator has responsibility for monitoring and reviewing programmes following validation. All providers are required by SEOCN to monitor provision through Course Boards and the Final Assessment Board. Clear and comprehensive guidance on the conduct of these is provided by the OCN to ensure consistency of approach by providers. Students are represented on Course Boards and moderators have involvement in both. Annual Course Evaluation Reports produced by providers and Annual Moderator Reports identify issues for concern, examples of good practice and an evaluation of the provision. Members of the Quality Committee attend a sample of the annual Assessment Boards: four members attended Boards during 1999-2000. Reports from these members are presented to the full committee. Evidence presented to the review team indicated that all these processes are systematically applied.

55 In further ensuring that systematic evaluation can take place across all provision, the OCN has recently introduced a pilot 'compliance model' for 2000-01. The compliance agreement is issued to all providers of Access to HE provision and has been put in place to ensure that all documentation required from providers to support the development, monitoring and evaluation of provision is received by the OCN by the dates required. The review team found support for the model with all groups interviewed. Sanctions attached to the model have yet to be fully tested and the model will be reviewed at the end of the year. The team identified this development as further support within the AVA for the continuing development of monitoring and evaluation activities conducted by SEOCN.

56 The OCN has begun to develop systematic self-assessment over the past year in order to ensure it is operating effectively against quality standards and the requirements of the regulatory bodies. The review team noted as a positive development this more formal approach to an activity that has previously been undertaken on a regular basis but not built into formal structures.

Assessment, moderation and award of certificates

Assessment

57 The OCN produces clear and comprehensive guidance documentation for providers on assessment. The submission documentation requires tutors to provide details of assessment methods and evidence for validation. Quality standards ensure that assessment strategies detailed in the submission are 'fit for purpose' in the context of the target group and the programme. In addition, all Access providers are required to provide learners with a handbook detailing assessment requirements for the course. All Access programmes require formal examination, independent study and methods which may be negotiated by the learners. The review team found evidence that these standards and the implementation of appropriate assessment strategies are being adhered to, and the documentation identifies good practice in this area.

58 The introduction of Quality Circles for standardisation with reference to assessment within the OCN is an attempt to develop consistency across provision. The results of the activity of Quality Circles in 1998-99 have been thoroughly analysed, and this year, a Quality Circle activity relating to consistency of examinations has been implemented. This follows the first year's activity which looked at assessment across two curriculum areas. The review team commends the AVA on the introduction of measures to monitor consistency in this way, and recommends that the Quality Committee keep this activity under regular review to ensure its validity and efficiency in relation to outputs.

Selection, appointment and training of moderators

59 Moderators for Access to HE programmes are largely drawn from higher education, and 36 out of 37 moderators are currently working in higher education institutions. Discussions confirmed that representatives from both the further and higher education sectors valued this practice and found that it provided useful opportunities for feedback on the content and quality of Access provision between further and higher education. Seventy-eight per cent of moderators are drawn from higher education institutions in membership of the AVA, and the Account identified this as a potential weakness. The review team found no evidence to support the notion that the current selection and appointment process compromised externality.

60 Documentation to support the moderation process is thorough and clearly identifies the roles and responsibilities of moderators. Access to HE requirements are specifically identified within the guidance documentation. The responsibility of the moderator at the final Assessment Board in relation to the award of the Access to HE certificate is made explicit.

61 Criteria for the selection of moderators are clear and appropriate and moderators for new programmes are identified during the development stage. Nominated moderators are invited to, and usually present at, validation panels, and panels are responsible for confirming the appointment of the moderator. This process involves the scrutiny of the moderator's CV by the panel. The review team noted the view expressed that there were potential difficulties which might result from the scrutiny of moderators' CVs in their presence, and also considered that it was likely that this process would be conducted differently if the proposed moderator was not able to attend the panel. This raises questions of consistency in the appointment process and the team suggests that the AVA may wish to consider reviewing this practice.

62 Newly-appointed moderators are obliged either to attend an initial briefing or may declare themselves to be 'sufficiently experienced', in which case attendance at briefings is not required. In addition, moderators are invited to update sessions and one-to-one meetings with Development Officers 'as appropriate'. It did not appear that there was any regulation of the process of self-declaration and, while paperwork provided for moderators is comprehensive and may provide sufficient guidance for new moderators, the review team was not convinced that the system assured the consistency of preparation of moderators for their task. Moreover, the AVA acknowledged that there have been weaknesses in monitoring the process of self-declaration and there may be moderators in the system who are both 'undeclared' and 'unbriefed'.

63 In discussion with moderators, tutors and officers, it was clear that providers welcomed the use of moderators from higher education, and officers expressed the view that the current system that allows self-declaration assisted the recruitment of higher education staff to this important role, helping to maintain the high level of the sector's involvement. The review team is concerned that the imperative to ensure higher education participation in moderation through permitting some moderators to declare that they have sufficient experience may result in some inconsistency in moderation practice, and thus in moderation outcomes. Indeed, the Account identifies further work as necessary 'in monitoring the extent to which moderators discharge their duties in practice'. While some newly-appointed moderators may, indeed, be sufficiently experienced to undertake the role of Access to HE programme moderator, there is no evidence that the AVA applies any criteria through which it might be able to test the appropriateness or adequacy of a moderator's previous experience. The team notes that more systematic monitoring of attendance at briefings is being undertaken but would strongly encourage the AVA to consider the requirements for moderator training and the process of self-declaration in relation to consistency of practice.

Receipt of, and response to, moderator reports

64 Moderator reports are required on an annual basis and a template is produced by the OCN. Further specification of the template is being developed to allow easier comparison and identification of common issues raised by moderators. All reports are acknowledged on receipt. Monitoring the receipt of reports is undertaken by the Administrative Assistant and the OCN has sound and effective tracking systems in place to follow up the late receipt of reports. Reports are received in the office, where the Administrative Assistant identifies reports where issues for concern have been raised. These reports are passed to the Co-ordinator, who is responsible for communicating with providers and ensuring that issues are resolved. SEOCN has identified that approximately 10 per cent of reports require some action by the AVA and 8 per cent have serious issues that are referred to the Quality Committee. The review team noted that the newly appointed Innovation and Quality Officer would be assuming responsibility for taking up issues from the Co-ordinator as part of the responsibilities of this post. The team noted that follow-up action has not always taken place and the OCN is taking active steps to ensure that this happens.

65 An annual summary report of the moderation process for the OCN, including Access moderation, is presented to the Quality Committee. Details of all those moderation reports identifying action required are included. The evidence presented to the review team indicated that the summary reports are thorough and present a detailed analysis of the process. The team, however, agrees with the conclusion in the Account that a more systematic approach to following up issues raised by moderators needs to be built into the quality framework. The team suggests that a more regular and active involvement by the Quality Committee in monitoring reports and the issues raised would assist in closing the loop in the reporting process.

66 On the basis of evidence gathered during the review, the review team concluded that, currently, moderation for Access provision is effective and robust and that moderators have a sound and thorough understanding of their roles and responsibilities in discharging their duties as moderators.

Procedures for the award of the Access to HE certificate

67 The moderator and the course coordinator must sign off recommendations for the award of the Access to HE certificates at the final Assessment Board and, on the arrival of documentation in the AVA office, the Programme Assistant checks all recommendation forms to ensure that signatures are valid. The systems and procedures relating to Access to HE certification are well understood within the AVA office and the process is well supported by the database. Certificates are dispatched promptly and the review team is assured that the award of Access to HE certificates is reliable, rigorous and secure.

Learner experience, standards and progression

Nature of learner experience and preparation for HE

68 Discussion with former Access students suggested that they had been well prepared for entry to higher education. Higher education admissions tutors supported this and tutors and moderators identified particular strengths of Access students in relation to study skills. Students noted that applications to higher education had been well received with a clear understanding by admissions tutors at local higher education institutions of the requirements for the award of the Access to HE certificate. In all cases, achieving the standard requirement was regarded as sufficient for entry across a range of curriculum areas, and this was further supported in discussions with other groups during the review.

69 Admissions tutors and students also identified that Access students had realistic expectations of higher education and both groups reported the importance of the role of higher education moderators in ensuring that tutors and programme developers from further education were kept informed of developments and requirements in relation to preparing students for higher education. The importance of the role of SEOCN in facilitating an on-going dialogue between further and higher education was identified as a strong feature of the OCN and this was evidenced throughout the review process. It is clear that the AVA has a high profile with higher education in the region and that it promotes Access at every opportunity.

70 Local initiatives such as the Sussex Liaison and Progression Accord ensure strong progression links between further and higher education, thereby facilitating opportunities for Access students to progress. In addition, SEOCN supports progression through the production of comprehensive information for learners and admissions tutors in higher education. The thorough documentation produced by SEOCN in relation to application to higher education (see paragraph 45, above) is informative for students, and the review team noted comments from tutors and representatives from higher education on the usefulness of documentation provided by SEOCN. All of these activities enhance the profile of Access to HE provision and Access students.

71 Former Access students met by the review team suggested that the process of induction into higher education institutions for students progressing from Access to HE programmes was in some cases rather difficult, and SEOCN may wish to consider how it can work with both further and higher education institutions within the AVA to assist in easing the transition period for Access students.

Student evaluation and opportunities for feedback

72 Students on Access to HE programmes have a number of opportunities to provide feedback. Two student representatives are elected to programme Course Boards which meet regularly to review programmes in the institutions. Moderator and annual reports comment on student feedback. Evidence presented during the review indicated that providers offer a number of opportunities within their institutional quality systems to systematically receive student feedback on provision. In discussions with Access students it was clear that all felt they had had opportunities to discuss the course with tutors and that this dialogue was valuable to both tutors and students.

Progression and monitoring

73 SEOCN has collected information systematically on learner achievement and progression since 1992. Detailed analysis of the cohort of learners enrolling on Access to HE provision and, more recently, the impact of enrolment in relation to widening participation indicates the importance placed on this aspect of its work by the AVA.

74 Achievement and retention data indicates that the percentage of registered learners awarded the Access to HE certificate compares favourably with national averages, and that this percentage improved between 1998-99 and 1999-2000. The review team noted that the number of learners receiving credit for partial achievement had also increased. The development of 'new Access' will need to be closely monitored in order to assess the impact of this in relation to retention and achievement.

75 In 1999-2000, 48 per cent of registered Access students progressed to HE. A further 5 per cent progressed to FE and 9 per cent to employment. Fifty per cent of centres achieve a progression rate to higher education of 91-95 per cent of learners awarded the Access to HE certificate, with 90 per cent of centres achieving a 61-65 per cent of learners awarded the Access to HE certificate progressing to higher education. The OCN produces a range of statistical and analytical reports on outcomes and progression and uses this information to inform the AVA and practitioners in further and higher education. The review team concluded that use of statistical information for analysis is a strength of SEOCN despite some difficulties with data collection in 1999-2000. Officers commented on the need to strengthen the reporting requirements of the providers to further enhance opportunities for analysis and the introduction of the compliance model (see paragraph 44, above) is an attempt to ensure this.

76 In addition to statistical analysis, SEOCN has since 1992 undertaken a series of research activities linked to Access provision. The review team found considerable evidence to suggest that this AVA continues to investigate and interrogate both quantitative and qualitative information in a systematic manner to ensure a sound and thorough understanding of Access to HE provision and student achievement.

Conclusions

77 SEOCN provides an efficient and valued service in relation to Access to HE, through which it maintains a reputation as an effective organisation that is able to make a distinctive contribution in assisting providers to meet their widening participation objectives. It has been able to adapt and respond positively to external changes affecting the organisation and its work, and it is pro-active in addressing new challenges. As an AVA, it has a visible presence and influence which contributes to a high profile for Access to HE provision in the region.

78 Its effectiveness is in part a result of its internal organisation, with very capable management and coordination of its activities, supported by thorough and consistently applied operational procedures. Strong leadership gives a clear sense of direction to the AVA's activities, and 'co-ordinator' may be something of a misnomer for the range of activities undertaken by, and level of executive responsibility delegated to, its senior officer. In addition, there is an evaluative and self-critical ethos to the AVA's work which is underscored by the emphasis on the collection and analysis of statistical data. It has developed this area of its work successfully, and the outcomes are beginning to provide a secure evidential base for the further development of its work, particularly in relation to targeting. Its effectiveness might also be attributed to the attention given to external liaison. As well as providing feedback from data collection and well-presented guidance documentation and other publications, it is able to act as a source of information and advice about wider developments to members and other organisations, thereby also promoting the AVA more widely.

79 The OCN's decision to adopt an integrated model for its Access and non-Access work appears to work well at most operational levels, from administrative procedures to programme development. At this operational level, there are clearly specified separate or additional procedures relating to Access to HE where necessary, which reflect the distinctiveness of the provision and its regulatory framework. Such a distinction is not made, however, within the governance structures or strategic planning procedures of the AVA. While a present commitment to Access is evident among both practitioners and the AVA's officers, that commitment is not secured by the AVA's governance structures or procedures. Some within the AVA hold the view that a 'mature' organisation does not need special structures or measures, and that Access to HE does not have to be specifically marked where there is a clear commitment to widening participation and well-developed procedures. The evidence from elsewhere, however, does not suggest that this can be taken for granted, and without special attention, and with a change of key personnel, this area of activity can be neglected and decline over time. While such a decline has not yet occurred at SEOCN, the AVA is not sufficiently well protected against such an eventuality, and Access to HE is therefore potentially vulnerable.

80 Quality assurance procedures are generally well-developed and effectively operated, although some attention is required in relation to the distinction between officer and committee responsibilities at some key points. However, the main processes of quality assurance are generally secure, and recommendations made here are largely about further development and refinement of procedures, rather than first stage assurance of quality. The new model for Access, potentially a valuable addition to the Access to HE provision accredited by SEOCN, may, however, require the AVA to undertake some substantial re-thinking in relation to appropriate procedures for quality assurance, and the AVA would be well-advised to consider at an early stage how it can adapt its present procedures to assure a continuing high standard of quality assurance.

81 The review team commends SEOCN for:

the standard of its administration in support of its operation as an AVA;
the provision of data services, and the use of data to analyse the AVA's activities;
the standard of its publications and the clarity of its guidance documentation;
the introduction of activities to monitor consistency of assessment.

Recommendation to the ARLC

82 The review team recommends that SEOCN be granted a conditional renewal of its AVA licence.

Conditions

83 Subject to the approval of the ARLC, SEOCN's licence is renewed on condition that it:

locates ultimate responsibility for the recognition of an Access to HE programme with the AVA itself, in order to meet the need for monitoring of decisions made by validation panels;
secures representation of Access to HE within its Executive Committee;
ensures that consideration of its strategic direction and specific objectives for Access to HE is incorporated into SEOCN's formal planning process, and that the outcomes are made explicit within the organisation's strategic plan.

(Conditions to be met by 31 December 2001.)

Recommendations

84 The review team recommends that SEOCN:

develops a clear statement of the medium-term financial strategy of the AVA in relation to plans for the surplus, contingency fund and special reserve account, to include reference to financial planning for the possibility of expenditure being incurred in relation to accommodation for the AVA;
considers the draft terms of reference for the Executive Committee to define more carefully the relationship between the relative executive and strategic responsibilities of the Co-ordinator and the Committee;
considers the introduction of requirements specifically relating to expereince of operating quality assurance systems for members of the Quality Committee to ensure that they are able to exercise their responsibilities fully;
provides a formal relationship between the Access Practitioners' Group and the AVA's decision-making structures;
reviews the practice of scrutiny of moderators' CVs at validation panels;
considers its requirements for moderator training and the declaration of sufficient experience by moderators in relation to the purpose of training and consistency of process and outcomes;
develops a more systematic approach to following up issues raised by moderators, and considers more regular and active involvement by the Quality Committee in monitoring reports.

South of England Open College Network July 2001

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