“And these children that you spit on as they try to change their worlds are immune to your consultations…”

Consultations are strange beasts. In most cases, they are used where government wants to enact a policy but doesn’t have the body of evidence to just go ahead and do it. The myth is that you run a consultation to gauge the response of interested parties to a change in policy, the reality is that you use a consultation to gather evidence that supports what you were going to do anyway.


And White Papers are a curious form of consultation. In policy implementation circles, they very quickly assume the status of sacred texts, even though (technically) the policy within is still subject to consultation. “How white is this paper?” is a frequent question in such circles – meaning “is anyone actually going to pay any attention to consultation responses here?”.


But this government generally likes to go one better. In HE, they’ve gone ahead and implemented most of the policy, then run a consultation.


They could do this based on the evidence of an “expert” report, the Browne Review. So interested parties had no chance to comment directly on plans to shift to a model where government funding for tuition follows student choices, just to pluck one example out of the air. And even stuff announced in the White Paper has already been enacted (MarginCore, AAB… indeed from next year ABB based on the massive success – ahem – of AAB this year).


Consultation responses are funny things too – organisational responses (and the vast majority do tend to be organisational) are written by a tame in-house wonk who’s job it is to draft consultation responses. These responses are seldom the genuine, unfiltered, opinions of experts – the pattern tends to be “how can this proposed policy be tweaked in such a way as it benefits my organisation”. They tend to be qualified approval, even if the policy itself is shockingly awful, because the possibility of the organisation maybe getting some more money outweighs the overall effect on the entire sector.


So the summary or responses is, at best, a summary of what we’d mostly guessed would happen anyway. The questions were largely concerned with the tinkering-around-the-edges aspects of HE policy – the responses (especially to the technical consultation) were largely along the lines of “stop playing with it, you’ll go blind”.


The big news items for me are as follows:


  • Explicit confirmation that there would be no primary legislation on HE, despite the need to give HEFCE new statutory powers and to protect the loan conditions of students within the new funding system.
  • Confirmation of the eventual reduction of HEFCE grant to strand A and B subjects. This makes it explicit that BIS wants to move away from direct institutional funding entirely (para 2.1.20)
  • Moves towards the idea of releasing data on institutional use of fee income. This is actually one of the more insidious themes as many organisations depend on institutional subscriptions, and many institutional projects are multi-year long term benefit invesments, both of which will be difficult to justify for students conditioned to expect £9k of direct value-added to their experience for £9k of fees.
  • The HEFCE exemptions from the margin policy (largely for arts/music institutions that admit by portfolio/audition) now look a lot less temporary than we initially expected.
  • Expansion of OFFA. This is actually a rather lovely example of the confused nature of HE policy, as a small-state focused government attempts to further regulate a market via an expansion of civil service numbers!
  • Confirmation that PQA won’t happen, as predicted on Wonkhe.com. 🙂 It never happens, but always turns up in White Papers. Like compulsory teaching qualifications for academics.
  • A whole range of further consultations. Great news for wonks everywhere.



personal opinions only. Available under a CC-BY license.

One thought on ““And these children that you spit on as they try to change their worlds are immune to your consultations…””

  1. David; I have only just happened across your website. It’s brilliant, I love it. I found ‘followers of the apocalypse’ in the course of consultancy work I am doing when searching for good stuff on AAB+/ABB+ recruitment, but got so interested started looking at more and have to say I agree 100% with your thoughts above. Might have something to do with me having worked for nearly 20 years in what is now BIS, I guess but just wanted you to know you really made my day. Keep it up, you’re a good chap…

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