A meander into institutional designation

[For those jumping up and down and shouting “The HE&R bill!” at me – patience. It’s not law yet, and I’ll get to it at the end.]

So just what is a “higher education institution” in the UK? Section 71 of the 1992 F&HE act currently defines a HEI as one (or more) of these three things:

• a university¹
• a higher education corporation
• a designated body, designated by the Secretary of State where a full-time equivalent institutional enrolment number for courses of higher education exceeds 55 per cent. of its total full-time equivalent enrolment number.

Point three gives us the clue that an institution will not be a HEI just because it delivers higher education. Indeed, even if it delivers only HE, it will not become a HEI unless designated as such by the Secretary of State.

At this point, it may also apply for teaching and/or research degree awarding powers, currently via the QAA. And also for university status (currently via the QAA and Privy Council). And also for institutional designation for HEFCE funding and student fee loans. And it may submit an access agreement to OFFA so it can charge fees up to the maximum amount. Or, in any of those cases, it may decide not to. But it needs to be a HEI in order to even think about doing these things (unless it happens to be the Archbishop of Canterbury).

Prior to achieving HEI status, an institution will have one or more designated courses (eligible for student fee loans and, if applicable for the subject of study in question, HEFCE funding). The degree courses it delivers will be validated by a HEI partner, sub-degree courses may instead be validated by Pearson.

If you want to know the status of a particular institution as regards these various attributes, all of this is reflected on the HEFCE register of HE Providers. As long time readers of “Followers…” may recall.

The HE&R Bill takes some steps to clear some of this mess up, notably combining HEI status, HEFCE funding designation, T/RDAP and University title into a single process and makes the access agreement a mandatory component.

It took a while to for this to occur to me as well – but all of these lists, designations and attributes have one thing in common. They refer to the “teaching” end of Higher Education. So what’s the deal for research?

Of course, there is nothing stopping anyone from conducting research into any thing they like in any way they choose. Indeed, this may be paid for by any number of bodies for no other reason than they think that that institution/organisation in question might be quite good at it.

The two jewels in the research funding crown, however, are QR funding and research council funding. How does an institution get access to both edges of “dual support”?

QR funding is the stuff that is linked to the REF – you have to be in the REF and get the required score in order to get the money. It’s up to each institution to decide whether to enter the REF and to work out whether the return via QR plus the reputational benefit is equal to the effort put in.

You have to be an institution designated to be eligible for HEFCE funding in order to reap the rewards of QR. Obviously if you want the support for research degrees that HEFCE may provide alongside this, you need to be eligible to award them.

The entry requirements for the REF itself are surprisingly hard to find. The long and terrifying list of FAQs don’t shed any light, and my best guess from the language in the guidance is that only “Higher Education Institution” status is required, as per the F&HE Act 1992 Section 71 definition at the top of this post (and as far as I am aware, the Archbishop of Canterbury didn’t submit to REF2014). No private providers submitted to REF2014 (not even the University of Buckingham), but I can’t find anything in the documentation to say that they couldn’t.

There is one main anomoly. The Institute of Cancer Research has designated courses at postgraduate level via the University of London but is not a HEI, but it DOES submit to the REF. I’m also unsure of the status of the Institute of Zoology (claims to be HEFCE funded, submitted to the REF, but isn’t on the HEFCE register – I think it hides under UCL somewhere).

And Writtle College (shortly to become Writtle University College – many congratulations!) wouldn’t have had TDAPs (or University College status) at the start of the REF 2014 period. However they were designated as an HEI in 1994 so were eligible to submit to the REF from that point.

So you’d think that HEI status (or being the institute of Cancer Research) may also be your path to research council funding, and you’d be wrong.

There are three groups of institutions eligible for research council funding:

• institutions in receipt of grant funding from a UK HE funding council (like HEFCE) can apply to any research council. Though the wording is unclear, this means designation at an institutional level (thus eligibility for HEFCE QR in England)
• Long-term established research institutes can apply to any research council. These are places where the research councils have made a long-term investment, and where they are a primary funder.
• Independent Research Organisations (IROs) can apply to one or more research councils as agreed in either a “responsive” (whenever they decide to) or “managed” (with permission on each occasion) mode.

To become the latter, there are some fairly detailed eligibility criteria . An IRO needs to be a charity or similar, a legal entity not owned by business or for primarily research purposes by any part of the public sector, and it needs to have the internal capacity to conduct research. Even beyond this, the bar for IRO designation is high and an assessment is made for a five year period (automatically renewed if funding is awarded) by the Grants Governance Committee accross all research councils, even where designation is sought for a single research council.

Though IRO status is a high bar, it is not as high as the designations currently offered by HEFCE – certainly organisations as diverse as the Tate, RAND Europe and the Institute for Fiscal Studies currently hold IRO status but would absolutely not be eligible to become a HEI.

But so what? you may ask.

Remember that the QR funding “Research England” side of HEFCE becomes a part of UKRI (the research councils umbrella body) as a part of the HE&R Bill. Why would one sub-committee of an organisation run a completely different set of eligibility criteria to all of the others. Why would an institution need to have OfS designation to get QR funding, but not to get a research council project? Why would one part of UKRI run a competition only for a subset of the institutions funded by all the others?

The thrust of modern HEI policy has been on simplification of regulatory structures – what would make Research England the exception?

If you are that rare breed, a research manager in an FE college strongly committed to research (that probably delivers some HE on the side), I think you should be having a careful read of that IRO document…

 

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^{1. [What’s the difference between a University and a University College? Size. A University has to, since 2012, have more than 1,000 FTE students. Before 2005 you needed 4,000FTE and RDAPs, with the latter requirement lost at that point.]↩}