Bedfordshire Access Consortium
November 1999

Contents

• Foreword
• The review process
• The AVA context
• Governance and committee structures
• Management, organisational structures and administrative arrangements
• The development, validation and evaluation of Access programmes
• Assessment, moderation and the award of certicates
• Learner experience and progression
• Student outcomes and progression
• Conclusion and Recommendation to the ARLC
• Conditions
• Recommendations
• Appendix 1

---

Foreword

1 The Quality Assurance Agency for Higher Education (QAA) is responsible to the Department for Education and Employment (DfEE) for the recognition of Access to Higher Education courses. QAA exercises this responsibility through a national network of authorised validating agencies (AVAs), which are responsible for the processes of individual course recognition and the award of 'kitemarked' Access to HE certificates to students on QAA's behalf. QAA has developed a scheme for the licensing and review of the AVAs, the principles and processes of which are described in the QAA Recognition Scheme for Access to Higher Education in England, Wales and Northern Ireland. The Recognition Scheme is regulated and administered by the Access Recognition and Licensing Committee (ARLC), a sub-committee of the QAA Board of Directors.

2 This is a report of a major review of the Bedfordshire Access Consortium (BAC), undertaken by QAA. QAA is grateful to BAC and to those who participated in the review for the willing co-operation provided to the review team.

Aims and objectives

3 The aims of the system of AVA review are:

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

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

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

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

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

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

4 The objectives of each AVA review are:

i to examine, assess and report on:

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

ii to identify and report on:

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

Outcomes

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

i unconditional confirmation of renewal of licence for a specified period;

ii conditional confirmation of licence with conditions to be met by specified date;

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

iv suspension of licence until specified conditions are met;

v withdrawal of licence for operation as an AVA;

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

The review process

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

7 The review visit took place on 24 and 25 June 1999. The visit to BAC by the review team consisted principally of meetings with representatives of the AVA including: administrative officers; members of the Executive Committee; FE member managers; Access to HE moderators; Access to HE programme leaders; former students from Access to HE programmes; and representatives of the University of Luton.

8 The review team consisted of Dr Pete Johnston, Head of Access and Associate Director of Overseas Relations, University of Essex, and Ms Carole Stott, Director, London Open College Network. The review was co-ordinated for QAA by Ms Kath Dentith, Assistant Director (Access), Institutional Review Directorate.

The AVA context

Membership

9 The Bedfordshire Access Consortium (BAC), accorded AVA status in 1990 and reviewed in 1992, is an unusually small AVA. Currently the membership consists of four Bedfordshire institutions: Barnfield College, Bedford College, Dunstable College and the University of Luton.

10 Although not a current member, Luton Sixth Form College has intermittently engaged in membership when delivering Access to HE provision. Additionally, Bedfordshire and Luton Chamber of Commerce and CfBT Bedfordshire Careers who appear listed as 'members' in the updated 1999 BAC Handbook, have participated as non-voting members of the BAC Executive but they are not members (ie subscribing and voting) as specified in the BAC constitution.

Premises, staffing and finance

11 The University of Luton provides a base and an Administrative Officer for BAC within its Centre for Quality Assurance (previously the Academic Registry). This Administrative Officer shares these BAC responsibilities, which are specified in her University of Luton job description, with linked University of Luton validation responsibilities. This provision is made without charge and in accordance with the BAC constitution which specifies that 'The consortium will be convened and serviced by a member of the Academic Registry from the University of Luton'. There is, however, no formal memorandum of agreement between BAC and the University of Luton which defines the scope and precise terms of the service to be provided.

12 The above arrangement covers core BAC business relating to its validation events and committee meetings. As a complementary arrangement, BAC itself meets incidental costs, such as costs of printing of BAC literature, and funds its staff development events. These funds are generated from payment by members of a modest annual subscription (£250 per voting member) and a student per capita registration fee. This provides the AVA with an annual income of over £3,000 and net current assets of £8,707. BAC introduced its system of financial contributions in 1995-96, in response to a recommendation from the 1992 HEQC Review Panel which, in recommending the removal of the 'cashless society', stated that 'the AVA should progress the issue of introducing a system of financial contribution from each member institution'.

Mission in relation to Access to HE

13 The defining purpose of BAC is to further Access to HE; the BAC Handbook states that 'BAC...exists to validate Access Courses in the Bedford, Dunstable and Luton area' and the formal BAC mission statement also expresses this purpose.

Provision and target groups

14 A notable feature of the AVA is that the University of Luton contributes a major component of the BAC validated provision. Of the 22 BAC programmes currently offered, eight are individually designed pathways within level 0 of the University of Luton's modular credit provision. In terms of student numbers, these level 0 programmes contribute substantially; in 1997-98, 304 of the 511 BAC registered learners were studying on University of Luton level 0 programmes.

15 The validation and review of the level 0 provision is the joint responsibility of BAC and the University of Luton. Judgements relating to the approval of level 0 programmes are therefore made against the same criteria as for the approval of Access courses.

16 In relation to targeting, the level 0 provision lays the same emphasis on the recruitment of mature students from under-represented groups. An indication of the application of this policy can be found in the particular case of the University of Luton level 0 programmes, where 43 per cent of the students registered in 1997-98 are recorded as 'ethnic learners' (Annual Report of 1997-98, section 6).

Developments since the last review

17 The Critical Report notes that there has been little change in the structure and composition of the Consortium since the HEQC periodic review in 1992. With regard to provision, the major development has been the conversion (in terms of formal status) of the University of Luton's provision from Access Courses to programmes within level 0 of the University's modular credit scheme.

18 Actions taken in response to recommendations made in the 1992 report include the initiation of some relating to ensuring consistency of standards; the maintenance of close links with neighbouring AVAs, in particular Cambridgeshire Authorised Validating Agency and Hertfordshire Access Consortium, focusing on staff development events; some steps taken to move away from 'cashless society' status; and the recent introduction of a standard pro forma for annual course reports.

19 A major strategic issue to be addressed by BAC concerns its position in relation to credit frameworks, and to Open College Networks (OCNs) in particular. The Critical Report records that over the last five years BAC has 'constantly reviewed' its position on this matter and this is reflected in the minutes of the Executive Committee over this period.

20 All further education members of the Consortium are also members of Chiltern Region Open College Network (CROCN) and accredit non-Schedule 2(c) provision through CROCN. Members therefore have substantial experience of the OCN framework and 'have seriously considered the option that BAC become an OCN through a ''merger'' or ''affiliation'''. Indeed this option was reconsidered during the academic year 1997-98 and was again discussed with the Chair of CROCN in February 1999.

21 In reaching a decision about the development of a common credit framework for all BAC courses, which is specified as an aim in its Future Strategy and Action Plan (Critical Report Part 6), BAC further specifies that 'particular care will be taken to develop a credit model that spans further and higher education and which can contribute to the establishment of seamless progression routes into HE'. An important factor which will have to be considered by BAC is that a major component of BAC's existing provision is already offered in such a format in that the University of Luton's provision of BAC programmes is made as level 0 of its undergraduate modular credit scheme.

22 It was clear to the review team that there was as yet no emerging consensus within BAC on the choice of credit framework.

23 The other linked major strategic matter to be addressed by BAC is that of broadening its membership. BAC itself acknowledges that it is an 'unusually small' AVA. It also acknowledges in the Critical Report 'a growing recognition within the consortium that there is considerable scope to extend the membership to include other agencies that are clearly new stakeholders in ''Access'''. Reference is made to the possibility of BAC forming 'the nucleus of a new approach' with 'firm commitment to obtaining representation from the voluntary sector, adult education, employers, widening participation and lifelong learning initiatives, guidance providers' in time for the academic year 1999-2000.

24 The review team noted BAC's commitment in its Critical Report to progress these strategic matters. The team also noted with interest the indication by the Chair of BAC that BAC recognised that it had now reached a point where major change was required, and the corresponding need for a detailed action plan in order to secure that change.

Governance and committee structures

Legal status

25 BAC is a partnership of its four member institutions within Bedfordshire. BAC is not incorporated either as a company or as a charitable trust. It does not employ staff nor does it hold significant assets. BAC members are signatories to a formal constitution. BAC regards itself as owned and led by Access practitioners.

Executive Council

26 BAC is governed by an Executive Council which is the decision-making centre, with responsibilities including Access policy development, validation, revalidation, moderation and review of Access programmes, and some financial matters. It is constituted on the basis of two nominated representatives from each of the subscribing member institutions. The Chair is held by each subscribing member institution on a rotating basis (normally for a period of two years). The Critical Report states that the Chair is held by a senior member of staff of the member institution, but this is not specified in the current constitution. Additionally, representatives from Bedfordshire Guidance Services and Bedfordshire TEC have attended Executive meetings as non-voting participants.

27 The current constitution requires two meetings per term. In practice, as recorded in the Annual Report of 1997-98, at least one meeting is held in each term.

28 To assist it in discharging its wide range of responsibilities, and utilising clause 5 of the current constitution which specifies that 'Committees will be convened as and when required by the Executive Council', BAC has delegated specific tasks to sub-groups of its members. The following are standing sub-groups of the Council: Quality Assurance group, Staff Development group and Marketing group. These groups have no formal remit and meet on an irregular basis to undertake specific tasks and report back to the Executive Council (either in written or oral form). In particular, during the past calendar year the Quality Assurance group has developed standard forms for external moderators' reports and for Examination Board Chair reports. Responsibility for quality assurance remains, however, with the Executive Council; it is not devolved to the Quality Assurance group.

29 As indicated above, the Executive Council, whose membership consists largely of Access programme leaders, is charged with a heavy load of responsibilities covering strategy, policy development and all quality assurance matters. It endeavours to discharge these responsibilities without the aid of a formal sub-committee structure.

30 With particular reference to central quality assurance, there was clear evidence that serious slippage had occurred in BAC's systems in recent years. In particular, with regard to the important matter of annual monitoring, although 'thematic evaluation' of course reports had been undertaken and reports produced for each of the years 1992-93, 1993-94 and 1994-95, no such reports existed for years 1995-96 and 1996-97. Although an Analysis of External Moderators' Reports for 1997-98 now existed, this had only recently appeared. In addition, in relation to BAC's reporting lines to its members, only two annual reports have been produced, for the years 1994-95 and 1997-98 (the latter a recent production bearing the new QAA Access logo). Further indicators of slippages in procedures are indicated in paragraphs 44, 45 and 53 of this report.

31 The review team therefore identified an urgent need for BAC to reorganise and revitalise its structures and systems so as to enable it to discharge its Access quality assurance responsibilities effectively, reliably and consistently.

Management, organisational structures and administrative arrangements

Summary of structures and processes

32 The part-time Administrative Officer employed by and shared with the University of Luton provides all administrative support for the Executive Council and the quality assurance processes of BAC. The Centre for Quality Assurance appears to be flexible and supportive in ensuring sufficient administrative support for BAC during times of peak demand. Formally, however, there is no management of administration by BAC.

33 The Critical Report states that 'it is likely that the Consortium will appoint an Executive Officer' and acknowledges the further resources needed. At the time of the review visit, no decision had been taken on this. The review team is mindful of the need for BAC to take any decision in the context of the overall strategic direction of the Consortium, its development of a credit framework model, and the relationships that the Consortium chooses to establish with neighbouring AVAs and/or OCNs.

Quality assurance functions

34 As BAC does not have an Executive or Development Officer, all quality assurance functions are carried out by members of the Executive Council supported by the Administrative Officer. This places considerable operational responsibility on this officer who operates and develops all administrative systems for validation, moderation reporting, certification and data collection.

35 In the absence of a designated post, or of any specific requirements for quality assurance expertise within BAC's committee structure, much of the essential expertise in administering quality assurance processes is provided through the Administrative Officer's experience of the University of Luton's systems and the management support available within the University. The review team noted that the current Administrative Officer was initiating a number of planned improvements in processes as a direct result of this experience.

36 The review team noted BAC's recognition of the difficulty in realising its tactical and strategic objectives without the support of an Executive Officer, and the consequent resourcing implications.

37 The review team also noted that BAC had employed a consultant 'to look at the development within BAC, and assist with co-ordinating preparations and documentation for the Review'.

Data management, collection and analysis

38 BAC does not hold a centralised database of learners registered on validated Access programmes. Learners register with the providing centre and data is held in each centre's records. BAC is notified of numbers of students registered on Access programmes by providers, for the purpose of calculating the provider's financial contribution to the AVA. Learners are registered with BAC at the point of claiming Access certification.

39 The review team was provided with statistical data on completion details and award of Access Certificates for 1997-98. There was also data from the University of Luton on Access students. In addition, BAC's Annual Report of 1997-98 included a statistical analysis compiled from annual course reports and information supplied by member institutions.

40 There have clearly been recent enhancements in the collection and collation of data and the review team noted the development of common data collection pro formas for 1998-99 which should provide the AVA with the necessary data at the end of each academic year. However, the system has not yet operated, and in the absence of a central BAC database of registered learners, the team is not able to comment on the AVA's ability to operate efficient and effective data collection and analysis.

The development, validation and evaluation of Access programmes

Development and design of new provision

41 Support for programme development is provided mainly through sharing of practice between Consortium members, with members of the Executive Council able to offer advice to tutors preparing for validation. The AVA publishes a handbook for practitioners, summarising validation, moderation and review requirements. Curriculum development is also seen as a central aim of staff development and BAC both organises staff development events, normally one or two per year, and funds attendance at other events and conferences for members through its budget.

42 Evidence provided for the review team indicated that, outside the University of Luton level 0 provision, Access to HE within the county was in decline. A workshop for BAC members held in May 1998 agreed on the need to 'strengthen BAC's ability to engage in development work', but to date there appears to be no clear strategy or action plan for the development of Access to HE across the county.

Validation of new and revised provision

43 The validation process is widely regarded as a key strength of the AVA and the main mechanism for quality assurance. Given the very small size of the AVA, it is a requirement for all validation panels to have external representation. The review team saw clear evidence of appropriately constituted panels providing detailed comments on programme submissions.

44 Each panel is chaired by a member of the Executive Council who reports on the panel at the following meeting of the Council. The Executive Council ratifies panel decisions. Because of the AVA's small size and 'practitioner model', Council members appear to have a detailed knowledge of local provision. They are able to follow up issues in member institutions and to provide a link between members and the operations of the AVA. However, the review team noted evidence of slippage in the formal reporting and operation of the quality assurance system for validation. For example, the team noted that discussion or confirmation of validation was not always reported in Council minutes, and substantive items on validation were sometimes reported under 'any other business'.

Monitoring, evaluation and review of programmes

45 BAC requires each Access programme to submit an annual report to the Executive Council. The AVA's Annual Report of 1997-98 notes that 'our previous reliance on individual colleges' reporting mechanisms for quality assurance provides an insufficient basis for clear comparability between institutions and common forms of reporting will need to be enhanced henceforth'. A common form for course reporting has been adopted for use in 1998-99. The review team noted that the preparation of thematic evaluations of course reports, provided for Council from 1992-93 to 1994-95, had not occurred in recent years.

Assessment, moderation and the award of certicates

Assessment

46 Assessment arrangements are confirmed through the validation process. The review team was told that BAC operated a 40 per cent pass mark for all its validated Access programmes. The team was also advised that all students were required to 'pass all modules'. However, the BAC Handbook does not include clear and specific information and guidance on these regulations and the team suggests that all AVA regulations, requirements and key policy statements are published and available in an accessible format.

47 A workshop for Consortium members in May 1998 agreed the need to 'adopt more consistent statements of learning outcomes across the Consortium' and the Annual Report for 1997-98 noted 'the need to explore the extent to which standardisation of such course features as learning outcome statements might assist it to ensure the equivalence of standards across the Consortium'. The review team considers that such a development would make a worthwhile contribution to consistency of assessment.

Selection, appointment and training of moderators/examiners

48 Moderators, who must be external to the county, are appointed by the providing institutions. Institutions are required to notify BAC of the appointment and to forward a copy of the moderator's CV to the AVA. Remuneration is the responsibility of the provider although BAC provides guidance on this. The moderator is required to submit an annual report to the centre which is forwarded to BAC as an appendix to the annual course report.

49 The moderators whom the review team met appeared to have little direct contact or communication with the AVA, and clearly identified their responsibilities as being to the college and the Access programmes and learners for which they were responsible. No training or support for moderators is provided directly by BAC. There is no provision for moderators across the Consortium to meet to review standards. The Critical Report noted that 'There is some work to be done in the ''training'' of moderators and in providing them with the opportunity to meet each other and compare notes'.

50 The May 1998 workshop identified the need for BAC to produce clear moderator guidelines but no action on this has yet been taken beyond the new reporting requirements. The AVA's Staff Development group has initiated training for Chairs of Examination Boards.

51 The review team considers that the provision of training, support and activities to assure comparability across centres is necessary for moderators as an integral part of BAC's quality assurance system. The team also considers that the moderators should be accountable directly to the AVA for the moderation of its validated provision.

Receipt of and response to moderators' reports

52 On receipt in the BAC office, moderators' reports are copied to members of the Executive Council. The Critical Report states that 'The annual reports will form the main agenda item at an October meeting of the validating committee and that meeting will be required to agree an action plan to overcome or investigate any apparent problems indicated by the reports'. The review team noted, however, that the 'validating committee' no longer existed, its duties being undertaken now by the Executive Council. Although Council members received moderator reports, they were not always available for an October meeting and there was no record of a meeting to consider these reports or of an action plan resulting from any meeting in recent years.

53 For 1997-98 a member of the Executive Council has produced an Analysis of External Moderators Reports. Although the team was advised that this had been circulated to Council members, it had not been formally considered by the Council at the time of the review visit.

54 The moderators' reports seen by the review team varied considerably in format and in the standard of detail and information provided. In its Annual Report for 1997-98, BAC identified the need for a common reporting format to be introduced for 1998-99. There is no indication, however, of how BAC may deal with inadequate moderator reports.

55 Whilst the review team recognises strengths of the practitioner-based model of BAC, and acknowledges the detailed knowledge and commitment that the practitioners bring to the work of the AVA, the team nevertheless believes that there is an urgent need for the AVA to establish more rigorous and systematic monitoring and review across validated provision as part of a clear and comprehensive quality assurance system.

Procedures for the award of the 'kitemarked' certificate

56 The Critical Report states that 'member institutions notify the BAC office of student success by providing lists of names of students who have successfully completed'. BAC issues numbered certificates to centres, keeping a central record of student names and certificate numbers. The certificates are signed by the college principal and distributed to students by the college.

57 Currently, certificates are issued on the basis of a written request from the programme tutor. There is no requirement for an authorised signature of, for example, the external moderator, to verify the names of students who have successfully completed. The Administrative Officer has plans to improve this system and the review team suggests that more rigorous quality checks, including the requirement for authorised signatures, are introduced into the process.

58 Students whom the review team met, while highly complimentary about the value of the Access certificate, were critical about the quality of the certificate they had received, some of which had been provided only after a considerable lapse of time. The Administrative Officer stated her wish to redesign the current certificate which may provide the AVA with an opportunity to address these criticisms.

Learner experience and progression

Student experience, feedback and representation

59 The review team heard from current and former BAC students that they were well prepared for higher education courses. Students also commented very favourably on the support they received during their Access programmes.

60 As a commendable feature of its revalidation procedure, BAC provides an opportunity for feedback to panel members from current or previous students. Annual opportunities for student feedback are provided through participation by student representation on programme committees, and through meetings with programme moderators.

Outcome standards

61 BAC has adopted a number of policies and practices in seeking to assure itself that there is consistency of standards achieved by students successfully completing its approved programmes.

62 All approved programmes cover core elements of Language and Communication Skills, Information Technology, Numeracy and a Project. In 1996, BAC commissioned an external review of the standard of marking for the Language and Communication Skills element across all BAC providers, which showed that those elements were 'well aligned' and that the programmes 'were providing a rigorous assessment of language skills'.

63 BAC took this initiative in recognition of the fact that while the use of moderators external to the Consortium is central to the aim of achieving 'comparability of Access programmes within BAC and between BAC and other AVAs', 'it cannot guarantee that standards within a subject area are similar between programmes'.

64 BAC has held a training event for Examination Board Chairs, although this addressed process rather than matters related to standards.

65 Although these steps have been taken, BAC itself acknowledges a 'clear recognition within BAC that there is scope for further development of common features to elaborate a stronger curriculum model which would create better opportunities for students as well as enabling BAC better to ensure the equivalence of its programme and of their outputs standards'. This is then linked to the development of a common credit framework itself dependent on 'common forms of expression of learning outcomes'. The review team concurs with this analysis and would propose that BAC addresses these matters with urgency.

Student outcomes and progression

66 Summary statistics provided in the Annual Report of 1997-98 showed a total of 511 students registered on BAC courses in 1997-98. The Report records that 'overall 74 per cent of registered students completed and 76 per cent of these [288] were certificated or progressed successfully to Level 1 at the University of Luton'. However, not all of those received an Access certificate. 'University of Luton students who successfully complete Level 0 progress to Level 1 of an appropriate HE award within the University's Modular Credit degree scheme. They are only issued with an Access Certificate if they transfer their studies to another institution or discontinue their studies on completion of the ''access'' stage'.

67 In discussing the reduction from 511 to 288, particular reference is made to the role of the University of Luton modular provision in permitting transfer to part-time study or interrupted study.

68 In attempting to track students' progression into HE, BAC had experienced difficulty in obtaining data, including data from the University of Luton. The (unconfirmed) report of the meeting of 26 May 1999 to consider the University of Luton and Bedfordshire Access Consortium review and revalidation of level 0 provision at the University of Luton refers to 'difficulties experienced by the team in obtaining relevant, accurate statistics' with 'concern that the pass rate appeared to be only 50 per cent' but recognition that 'it was possible that the centrally provided figures were inaccurate'. BAC recognises the need for regular collection of relevant statistics and has introduced new forms to be used for the annual course reports of 1998-99.

Conclusion

69 BAC is a small AVA, with just three FE members and one HE member. Its HE partner, the University of Luton, is a major Access provider, with over half of BAC's student numbers being accounted for by the University's own provision, made through its level 0 programmes. The University is a supportive member of the Consortium, contributing substantially to BAC by acting as the host institution for the AVA and providing staff time and resources for BAC's administration.

70 In spite of the introduction of a required financial contribution by all members following the last review, BAC still operates essentially as a cashless economy, with finances being used to meet incidental expenses rather than to fund core activities. BAC is not responsible for managing the staff currently working on its behalf and, although there is some measure of agreement that the organisation would benefit from appointing an officer, it has yet to reach agreement on the type of appointment which would best help it achieve its aims or how it would meet the financial commitment of making such an appointment. In its current form, with current structures, it is unlikely that the AVA would be able to exist as a viable or sustainable independent entity.

71 Discussions which have taken place over several years indicate that BAC itself has been uncertain about the best course for its future as an organisation, and this has contributed to an instability and lack of direction in its operation and planning which has yet to be resolved.

72 BAC is characterised by a practitioner-led ethos and operation. Because of its small number of members, it is able to operate largely without formally recorded policies or detailed procedures, relying on informal networking, members' close knowledge of the AVA's programmes, commonly understood practices and mutual awareness and acceptance of common objectives.

73 The body responsible for oversight of all the AVA's operations and quality assurance matters, the Executive Committee, works with commitment to the Consortium and its ideals, and with evident concern for students and their progress. However, in spite of the dedication of practitioner members on the Committee, it operates without the support or structures needed to make it an effective quality assurance body, and with an apparent lack of expertise in these matters. As a result, there is a lack of systematic and rigorous quality assurance and monitoring procedures in a number of the areas for which the AVA holds responsibility.

74 In the two or three years following the last review there was some development of quality assurance procedures, but there has been a subsequent decline both in continued development of procedures and in the implementation of those systems which had been developed. Although the AVA represented this as a temporary 'dip' in its management of quality assurance, at the time of the review, and in spite of some evidence of recently introduced measures, the review team was unable to have confidence that adequate and effective quality assurance systems were securely in place for the future.

75 The review team commends BAC for:

i well-established and well-understood processes for validation panels, including the use made of student views at re-validation;

ii the commitment of practitioners on the Executive Committee, where attendance by voting members is generally good;

iii its current administrative support which has brought assistance and some experience to the development of some quality assurance processes.

Recommendation to the ARLC

76 The review team recommends that BAC be granted a provisional confirmation of licence with conditions to be met by the dates specified below and a further review visit in autumn 2000.

Conditions

77 Subject to the approval of the ARLC, BAC's licence is provisionally confirmed on condition that it:

i undertakes a thorough review of its current situation and the context for its work, and formulates an action plan which will ensure its future viability, and which will allow it to discharge its quality assurance responsibilities as an AVA (by 1 June 2000);

ii clarifies its relationship with the University of Luton in order to confirm its essential independence (by 1 June 2000);

iii reviews the governance structures within the AVA in order to establish a clear locus of responsibility for the management and operation of a clearly understood, comprehensive quality assurance system to include (by 1 April 2000):

• the development of a common AVA statement which clearly defines the required learning achievement for the award of the 'kitemarked' Access certificate on any of the AVA's Access to HE programmes, in accordance with QAA specifications as set out in Appendix 1 to this Report
• systematic monitoring to verify validation
• issue of moderator contracts to ensure that moderators are appointed by, and with responsibility to, the AVA, rather than to a providing or receiving institution
• the development of a programme of moderator training, covering all aspects of moderators' duties, to be delivered on a regular basis for all new moderators
• the development and implementation of a clear system to ensure verification of student achievement by the external moderator before the award of the 'kitemarked' Access certificates to students
• systematic reporting and monitoring of course evaluation, moderation outcomes and subsequent action plans.

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

Recommendations

78 The review team recommends that BAC:

i develops its systems for record-keeping, to include the introduction of the recording of student registrations;

ii takes measures to revive the interest of other local bodies working in the broad area of access and widening participation, and encourages their involvement in the activities and quality assurance processes of the AVA;

iii proceeds with the development of a learning outcomes approach to assessment;

iv develops a programme of moderator support to address matters of standardisation at a cross-institutional level.

Appendix 1

Criteria for the granting of the Access to HE award

The criteria for the granting of the 'kitemarked' Access to HE award under the QAA Recognition Scheme allows for the clear articulation and specification of the type and standard of learners' achievements, and the demonstration of the fitness for purpose of the award.

Programme recognition

Within the recognition process, providers and AVAs are expected to establish clearly the fitness for purpose of the award, ensuring that the following criteria are addressed:

• specification of the title of the award which may be generic or may indicate the main subject area(s) studied;
• clear specification of the overall learning achievement required for the granting of the award;
• demonstration of the academic breadth and depth of learning achievement at the appropriate level;
• specification of the subject content within the achievement portfolio, indicating whether optional or compulsory, its level and the proportion of the subject represented overall;
• separate identification and formal assessment of key skills together with specification of their level;
• identification of other requisite achievement in optional or compulsory areas;
• specification of any learning achievement transferred from other programmes;
• identification of any exemption from learning achievement granted on the basis of prior learning or alternative qualifications;
• identification of any learning achievement recognised on the basis of prior learning experience;
• where relevant, identification of any specific forms of assessment attached to particular learning achievement.

Student achievement

The achievement required by learners in order to be granted the Access to HE award is intended to reflect the requisite nature, volume and level of learning to prepare learners to enter into and thrive within a higher education environment.

The nature of learning required for the Access to HE award should be determined by the aim to prepare students for a course in higher education, whether this is specified in general terms or with reference to a named progression route. It should encompass the acquisition of knowledge and skills necessary for successful study at HE level and should provide familiarity with subject content and methods appropriate as a preparation for further study in higher education.

The volume of learning required for the Access to HE award is identified through the specification of learning achievements which can, on average, be expected of a learner undertaking an Access to HE programme of a minimum of 500 hours total study time, including contact hours and private study.

The level of learning required for the Access to HE award is specified through reference to the cognitive and academic skills required for successful study in higher education. This specification should be at a level that can be demonstrated as being equivalent to that of other awards accepted as entry qualifications for higher education. Although some valuable learning will take place at a lower level, evidence of the achievement of sufficient learning at a higher education entrance level must be clearly demonstrated. In this context, sufficiency is judged by the proportion of achievement at the higher level (normally 75 per cent of the benchmarked minimum) required to be certain of a student's readiness to embark on and be sustained in a course of higher education.

In responding to the diverse needs of learners, many providers will, within their Access to HE programmes, offer learners the opportunity to achieve more than this minimum. The particular criteria for the successful completion of any Access to HE programme will be clearly stated and will include the broader minimum requirements for the achievement of the Access to HE award.