Ascentis Access Validating Agency relicensing review by the Quality Assurance Agency for Higher Education May 2012
Contents About this review... 1 About the AVA... 1 Summary of outcomes... 2 Explanation of the outcomes of the review... 5 1 Governance... 5 Legal and constitutional arrangements... 5 Governance... 7 2 Strategic planning... 9 Planning and monitoring... 9 Development, promotion and enhancement... 10 3 Management... 11 Resources and financial management... 11 Staffing...11 Self-assessment and risk management... 11 Operations... 11 Data management and transfer... 12 Communications... 12 Complaints and appeals... 12 4 Course recognition... 13 Diploma development (and transfer)... 13 Validation processes... 13 Validation criteria... 13 Validation panels... 14 Diploma approval... 15 Provider/centre approval... 15 Criteria for provider/centre approval... 15 Course recognition... 16 Modifications and amendments... 16 Revalidation and confirmation of provider/centre approval... 16 5 Moderation, monitoring and certification... 18 Moderation processes... 18 Moderation responsibilities... 18 Moderator recruitment, selection and appointments... 19 Moderator induction and training... 20 Moderation reports... 20 Course monitoring and review... 20 Standardisation... 21 Award of Access to HE Diplomas... 23 Issue and dispatch of Access to HE Diplomas... 23 Conclusions... 23 Appendix 1: Risk judgement guidance... 25 Glossary... 27
About this review This is a report of an Access Validating Agency (AVA) relicensing review conducted by the Quality Assurance Agency for Higher Education (QAA) 1 at Ascentis (the AVA). The AVA relicensing review process is described in the AVA relicensing: Operational description. 2 Other parts of the QAA Recognition Scheme for Access to Higher Education can be found on the Access to HE website. 3 The main purposes of the review were to assess the AVA's compliance with QAA's AVA licensing criteria 4 and, on the basis of this assessment, make a judgement about its risk level and a decision about whether its AVA licence should be renewed. These judgements were based on evidence derived from a number of sources, principally: documentary evidence provided by Ascentis discussions with the AVA's staff and members of its Board of Trustees and AVA Committee, which took place at the review visit on 21-22 May 2012 the views of AVA stakeholders - gathered through a survey conducted by QAA - which informed the review team's analysis of documentary evidence and its agendas for face-to-face meetings. This report: identifies features of good practice identifies required actions, where the AVA is not fully compliant with the licensing criteria identifies recommended actions, where the AVA can enhance its practice states QAA's judgement of the AVA's risk level: low, medium, high or very high (see appendix for descriptions of each category of risk) states QAA's AVA licensing renewal decision and any follow-up activity. A summary of the outcomes is given in the section starting on page 2. Explanations of the outcomes are given in the section starting on page 5. About the AVA Background information about Ascentis is given in the AVA's profile on the Access to HE website: www.accesstohe.ac.uk. 1 www.qaa.ac.uk/aboutus/pages/default.aspx 2 www.accesstohe.ac.uk/home/publications/licensing/avarelicensingod.pdf 3 www.accesstohe.ac.uk 4 www.accesstohe.ac.uk/home/publications/licensing/criteria.pdf 1
Summary of outcomes Required actions Ascentis' compliance with each of the five AVA licensing precepts at the time of the review visit is summarised below, followed by the actions QAA required Ascentis to take to achieve full compliance. Governance Ascentis met most of the AVA licensing criteria. Two criteria were not fully met. To meet licensing criterion 1.7b: Increase the quorums of the Board of Trustees to a minimum of five and of the AVA Committee to a minimum of four. To meet licensing criterion 1.10c: Revise the terms of reference of the AVA Committee to specify that at least one trustee member of the Committee is from a higher education member institution and at least one trustee member is from a further education member organisation. Strategic planning Ascentis met all of the AVA licensing criteria. Management Ascentis met nearly all of the AVA licensing criteria. One criterion was not fully met. To meet licensing criterion 3.9: Provide a plan showing how the accuracy of the AVA's student data tracking system will be improved and maintained on a continuing basis. Course recognition Ascentis met many of the AVA licensing criteria. Four criteria were not fully met. To meet licensing criterion 4.6: Include an explicit statement, in its guidance for those involved in the development (and transfer) of Access to HE Diplomas, that Access to HE Diplomas are intended to provide a preparation for study in UK higher education, but the award of a Diploma does not provide guaranteed entry to UK higher education programmes. To meet licensing criterion 4.8 (and 4.10b): Ensure that its validation process and panels assess all Diploma proposals against a set of clear, standard criteria, including those in licensing criterion 4.10, checking for consistency with The Access to Higher Education Diploma and credit specifications and other regulatory information about the qualification published by QAA. To meet licensing criterion 4.29: Provide evidence to QAA of its revised approach to the withdrawal of centre recognition. Moderation, monitoring and certification Ascentis met many of the AVA licensing criteria. Six criteria were not fully met. To meet licensing criterion 5.5i: Revise its moderation procedures so that it can assure itself 2
that consistent standards are applied in assessment and that equivalent student achievement and performance is reflected in consistent recommendations for credits and grades across all provision. To meet licensing criterion 5.10: Put in place a mechanism to ensure that none of its moderators holds a position whose nature could create a conflict of interest or limit students' progression opportunities. To meet licensing criterion 5.15: Revise its ongoing training for moderators to enable them to compare standards and judgements across all of the AVA's provision, including the 'main scheme' provision, the Higher Education Foundation Certificate (HEFC) provision and the Southern Area provision, rather than as separate subsets. To meet licensing criteria 5.22 and 5.23: Revise its course review documentation and guidance to ensure that centres report on and differentiate between outcomes and distinctive features of different Diplomas that they deliver, and include quantitative student data for each Diploma and comment on this data in the course review. To meet licensing criterion 5.27: Revise its standardisation procedures so that specific standards of required achievement for the award of credits and grades across all units and Diplomas are compared on all of the AVA's provision - including the main scheme, the HEFC provision and the Southern Area provision - rather than as separate subsets, and that its moderation systems take account of the outcome of this process. Recommended actions QAA recommended to Ascentis the following actions to enhance practice. Governance Specify the total continuous term of office permitted for non-executive trustees (licensing criterion 1.7b). Revise the Articles of Association and the Board of Trustees' terms of reference to decrease the number of trustees from 20 to a maximum number that more closely reflects the size of Board that Ascentis expects to maintain, and is sufficient to support good governance (licensing criterion 1.10a). Revise the terms of reference of the Board of Trustees to include those areas of the AVA licence that the Board is directly responsible for and cannot delegate (licensing criterion 1.12). Strategic planning Revise its strategic planning process to take greater account of specific outcomes of Ascentis' processes for monitoring and reviewing its recognised Access to HE provision, its self-assessment processes and statistical information (licensing criterion 2.1). Revise the format of its strategic plan to specify discrete actions, together with resources and deadlines for their completion (licensing criterion 2.2). Management Revise its AVA monitoring procedures, in order to improve its effectiveness in identifying the AVA's continuing compliance with the AVA licensing criteria (licensing criterion 3.5c). 3
Revise its style of committee minutes to provide a more useful summary of key points discussed, a clearer record of the decisions taken, and any resulting actions (licensing criterion 3.6). Course recognition Reassess its plans for the approval and introduction of its new Access to HE framework and make revisions, as necessary, to ensure that it takes full account of the required actions in this report, and of the current national review by QAA of The Access to Higher Education Diploma and credit specifications (licensing criterion 4.43). Features of good practice A 'feature of good practice' is defined for the purposes of AVA relicensing as 'a positive aspect of the way an AVA meets the licensing criteria, which may be seen as exemplary to others' (see the glossary on page 27). No features of good practice were identified at Ascentis. Risk judgement Ascentis' level of risk: high Follow-up QAA required Ascentis to: AVA licence decision Ascentis' AVA licence: temporarily extended report the actions taken in response to the recommended actions in its next annual self-evaluation report submit an action plan in response to the required actions by 4 January 2013 submit a progress report with documentary evidence to demonstrate the completion of required actions by 1 May 2013 undergo a revisit 5 by a QAA review team in June 2013. Please note: QAA publishes changes to Ascentis' risk level, the current status of its licence and any required or recommended actions in the AVA profile. 5 See the AVA revisit: Operational description at www.accesstohe.ac.uk/home/publications/recognition/avarevisitoperationaldescriptiondec11.pdf. 4
Explanation of the outcomes of the review This section explains the outcomes of the relicensing review in five main sections, corresponding to the five licensing precepts. Paragraph numbers and numbered references correspond to the AVA licensing criteria. A glossary of terms is provided on page 27. 1 Governance Legal and constitutional arrangements 1.1 Ascentis' constitutional basis is set out in its Memorandum and Articles of Association. These specify its legal identity, function, aims and principal governance structures. 1.2 Ascentis' company objects are congruent with the aims of the QAA recognition scheme for Access to Higher Education (Recognition Scheme). 1.3 Ascentis' constitutional structure requires the involvement of member organisations. 1.4 Ascentis is not itself a provider of Access to HE courses or a receiver of Access to HE students. 1.5 Ascentis has two categories of company membership - 'full' and 'associate' - and three categories of organisations which are eligible for membership: higher education institutions (which may be full or associate members); further and adult education institutions; and 'franchise and delegated scheme partners, as well as any Local, Regional and National Authorities and Agencies' (which are only eligible for associate membership). Member organisations include organisations providing Access to HE courses and higher education institutions which receive Access to HE students and are subscribers to QAA. 1.6 The current company members are those organisations which accepted the invitation to become members of the company at incorporation in 2009; other organisations may apply for company membership by completing of a brief application form that is considered by the Board of Trustees. The review team was informed that, to date, no such applications had been received by Ascentis. The team queried how transparent the Board's decision-making would be in respect of the application process, given that there are no written criteria for the Board to consider applications against. Instead, an application would be presented by the Executive and considered by the Board on its own merits, because membership is open to a wide variety of potential applicants. On balance, the review team concluded that the AVA met this licensing criterion. 1.7 Ascentis' legal identity and constitutional and governance arrangements provide formal accountability to member organisations, independent decision-making and operation as an AVA, and an identified basis on which it is able to enter into legally binding agreements. The review team explored in detail whether the AVA's constitutional and governance arrangements could also ensure protection from undue influence of any one of, or a minority of, its member or partner organisations, or their representatives (criterion 1.7b). Although the question of undue influence by individuals (including individual members of the Board) is covered in some detail in Ascentis' Conflict of Interest - Policy and Procedures, the team had concerns about the potential for undue influence which may arise because of certain structural aspects of the AVA's governance arrangements. In this regard, the team noted the coincidence of several factors which, taken together, present some risks, as follows. 5
Although one third of the trustees must retire at each annual general meeting, there is no limit to the number of times a trustee may be re-elected. Half of the elected trustees have served as Board members for Ascentis and its predecessor organisation for seven years. (The Chair has been in office for six years.) The trustees acknowledged that there were potential issues with the current position, which allows individuals to remain on the Board indefinitely, and that they may need to review this situation. The total number of Board members is specified as a maximum (see 1.10), with no minimum set other than the two members needed to meet QAA requirements for higher education and further education representation, and the Chief Executive. At the time of the review, there were seven trustees (including the Chief Executive). The quorum for meetings of the Board of Trustees is currently set as one third of the trustees. Meetings of the Board can, therefore, be quorate with only three trustees present, one of whom may be the Chief Executive. Attendance at meetings of the Board for the last two years has averaged at five trustees per meeting, although two meetings have taken place with only three trustees. It is therefore currently possible for the Board's business to be conducted on a continuing basis by a very small number of individuals, who may be on the Board indefinitely. Although membership of the Board requires there to be at least one member from the higher education sector and one member from the further education sector, no such requirement applies to the quorum for Board meetings. It is currently possible for the Board's business to be conducted by a very small number of individuals who are on the Board indefinitely, with minimal (if any) representation from the higher education or further education sectors, or with representation only of one sector. In addition, the AVA Committee's terms of reference specify a minimum membership of three members (who must be trustees) and its quorum is set at two. It is therefore possible for meetings of the Committee to be quorate and for decisions to be made with only two trustees present, one of whom may be the Chief Executive. This has in fact happened. Attendance during the last two years has not exceeded three per meeting, with two meetings taking place with two trustees and one with just the Chair. Apart from one meeting in 2010, between one and three invited representatives from provider organisations (see 1.10) have also been in attendance at the AVA Committee meetings. (Typically, four or five members of Ascentis staff are also present at meetings.) Trustees who met the review team explained that the current arrangements were put in place following legal advice obtained in 2009 when Ascentis was incorporated. Trustees acknowledged a theoretical possibility of undue influence being exercised but asserted that in practice they would not allow this to happen. While trustees' actions and decision-making may be constrained by their legal duty to act only in the best interests of the charity, and the individuals currently involved may be entirely genuine and honest in their intentions, the team remained concerned that the AVA's constitutional and governance arrangements did not jointly ensure protection from the potential for undue influence of any one of, or a minority of, its member or partner organisations, or their representatives. Ascentis is therefore required to increase the quorums of the Board of Trustees to a minimum of five and the AVA Committee to a minimum of four. The review team also concurred with the trustees' view that there is a potential risk in the absence of a specified term of office for trustees, and recommends that Ascentis specify the total continuous term of office permitted for non-executive trustees. 1.8 Ascentis has appropriate agreements in place with the suppliers of goods or services that are integral to the operation of the AVA. 6
Governance 1.9 Ascentis has clear descriptions of its governance and deliberative structures set out in its formal documentation. 1.10 Ascentis' governance structures include relevant experience and expertise in relation to governance matters. The review team found that the governance structures have not fully ensured informed and considered decision-making in relation to AVA matters. Required actions set out in this report will enable the AVA to meet this aspect of the licensing criterion. The Board of Trustees' terms of reference specify the number of trustees, categories of representation (including always one trustee from further education and one from higher education) and quoracy requirements. The terms of reference and the Articles of Association specify a maximum of 20 elected trustees, including the Chief Executive, and a further five people can be co-opted to the Board. The review team asked why Ascentis was operating with the current number of trustees given the option for a larger capacity. Trustees told the review team that at the time Ascentis was incorporated, it was considered important to offer all members of the previous unincorporated organisation (Open College of the North West) the opportunity to join the new Board, but that it had never been intended to operate with a Board of that size. Since then, the trustees themselves have reached the view that operating with a smaller number of trustees was more manageable and effective, although the team was told that the Board was giving some consideration to adding a further member to the Board's membership. Given that there is no intention to use the current capacity for 20 elected trustees, the team recommends that Ascentis revise the Articles of Association and the Board of Trustees' terms of reference to decrease the number of trustees from 20 to a maximum number that more closely reflects the size of Board that Ascentis expects to maintain, and that is sufficient to support good governance (including, for example, protection from undue influence). A reasonable degree of flexibility may be maintained by retaining the current provision for up to five co-options on the Board. The AVA Committee's terms of reference do not specify the categories or balance of representation for the trustee members, although the terms of reference do state that 'at least two representatives from provider organisations will be invited to be in attendance at all meetings, one from further education and one from higher education'. Trustee members are responsible for making the decisions, informed by the discussion of those in attendance. The review team was told that the invited representatives are fully involved in the Committee's discussions but do not have voting rights. The team concluded that the AVA Committee's terms of reference do not currently ensure representation from the AVA's further and higher education member organisations. Ascentis is therefore required to revise the terms of reference of the AVA Committee to specify that at least one trustee member of the Committee is from a higher education member institution and at least one trustee member is from a further education member organisation. Ascentis monitors attendance at its formal committees, takes action to address nonattendance, and has a Search and Governance Committee to ensure vacant places on committees are filled. 1.11 The Board of Trustees and its committees operate according to terms of reference which detail their remit, responsibilities and reporting relationships, through which their accountability to the organisation is defined. 1.12 The Board of Trustees is the ultimate authority for the AVA licence and is responsible for ensuring that Ascentis meets its responsibilities as an AVA. The Board agreed in November 2011 that trustees should delegate all functions in relation to the terms 7
of reference of the AVA Committee, with the exception of the four areas listed in licensing criterion 1.12 (approval of the annual self-evaluation report and other formal reporting to QAA in relation to AVA licensing requirements). In the review team's meeting with trustees, it was clear that the Board was aware of these responsibilities. However, these responsibilities are not explicitly stated and new members joining the Board in the future would not be aware of them. The AVA's governance arrangements for Access to HE (see criteria 1.7d and 1.10) can create difficulties for managing delegated responsibilities. For example, in 2010, the AVA's annual self-evaluation report to QAA was considered at a meeting of the AVA Committee which was attended by two trustees (including the Chief Executive, who was in the chair on this occasion). It was noted that Section 5 of the report was yet to be written but that 'the full report would be submitted to the Board meeting'. Two weeks later it was presented to a Board meeting that was attended by five trustees (including the two trustees who had been present at the AVA Committee meeting), and approved on the basis that 'it had already been considered by the AVA Committee'. The team therefore recommends that Ascentis revise the Board of Trustees' terms of reference to include those areas of the AVA licence that the Board is directly responsible for and cannot delegate. 1.13 The Board has ultimate responsibility for the company's legal and financial affairs, policy development and strategic direction; as well as for the approval, quality assurance and enhancement of the AVA's recognised Access to HE courses; monitoring and approval of academic standards; and the process for the award of Access to HE Diplomas to students. 1.14 Responsibilities are specified and appropriately located within the governance structure. 1.15 Monitoring and reporting procedures are in place through which the Board can ensure that delegated activities are undertaken. 1.16 The extent and limits of authority of bodies or individuals holding delegated responsibilities are defined. 1.17 The review team explored whether the separation and links between Ascentis' governance and management structures are clear and demonstrated in the AVA's operation. The team noted that the Chief Executive, as a trustee, could make up one third of a quorate meeting of the Board and half of a quorate meeting of the AVA Committee (see 1.7). The team further noted that important formal approval processes, such as Diploma validation and revalidation, involve recommendations from the Executive for approval by the AVA Committee. Given the quoracy issues already noted, this position presents a risk that undue influence may be exercised over the Committee's final decisions. The team recognised the importance of the advice given at meetings of the Board and AVA Committee by the Chief Executive, as well as other Ascentis staff who are in attendance at meetings. Trustees described their expectations of the Executive and how accountability is secured, and gave examples demonstrating how they maintain the separation between governance and management. Overall, the team concluded that the AVA is currently managing the risk of a blurring of boundaries between management and governance. The risk will be mitigated once the AVA takes the actions required and recommended elsewhere in this report. 1.18 Generally, full and accurate records of committees' decision-making are maintained (although see 2.5 and 3.6). 1.19 Minutes of the Board are retained for the lifetime of the organisation. 8
2 Strategic planning Planning and monitoring 2.1 Ascentis operates a regular process for strategic planning relating to its Access to HE activity. The review team found the overall approach to be structured and reflective. The team explored in some detail whether the process took sufficient account of the outcomes of Ascentis' processes for monitoring and reviewing its recognised Access to HE provision (criterion 2.1c), Ascentis' self-assessment processes (criterion 2.1e) and statistical information (criterion 2.1f). The team noted several weaknesses in these three areas, which impacted on their usefulness as the basis for the AVA's strategic planning process, including: weaknesses in the identification of key issues through course monitoring (see 5.19) limitations to the AVA's own self-assessment processes (see 3.5) problems relating to the completeness and accuracy of statistical information, and a lack of use of statistical data in course reports. Ascentis has identified that student non-completion rates are unacceptably high and has actions relating to this in its strategic plan. Further analysis has been hampered because of data inaccuracies. These inaccuracies are attributable, to some extent, to problems with reports on providers' data received from the Data Service, and this difficulty was noted by the review team. Nonetheless, the review team observed that the annual reports which Ascentis receives directly from providers (see 5.19) were significantly lacking in student data and critical analysis of data at course level. It was therefore difficult for the review team to see how these reports could meaningfully inform Ascentis' self-assessment or strategic planning processes. The review team recommends that Ascentis revise its strategic planning process to take greater account of specific outcomes of Ascentis' processes for monitoring and reviewing its recognised Access to HE provision, its self-assessment processes and statistical information. 2.2 The AVA's strategic plan for Access to HE has a single strategic aim: 'to make Ascentis the first choice for centres seeking to provide QAA-recognised Access to HE provision'. This aim is supported by strategic objectives, with linked operational actions. Resources and deadlines for completing the actions are not specified in the plan, although responsibilities at Executive level are indicated, together with a commitment to review progress 'at least termly through the Access Working Group, Executive and the AVA Committee'. (The review team was informed that, as a working group of Ascentis staff, the Access Working Group no longer met regularly but that it could be reconvened at any time, if needed.) The review team noted that the operational actions supporting the strategic objectives were mainly worded as ongoing aims rather than as discrete actions that could be completed. While the team accepted that some issues warrant ongoing action, it formed the view that some aspects of the AVA's strategic plan could be improved. The team recommends that Ascentis revise the format of its strategic plan to specify discrete actions, together with resources and deadlines for their completion. 2.3 The strategic plan includes objectives relating to the development, promotion and enhancement of Access to HE in the geographical areas in which the AVA operates. These objectives take on an increased significance with the expansion into areas more distant from the AVA's main office. 9
2.4 The strategic plan is formally approved within Ascentis' governance structures. 2.5 Within the governance structure, the AVA Committee is responsible for regularly monitoring the strategic plan. The Access Strategy has been a standing agenda item since May 2011; in February 2012, a progress update on the plan was presented to the AVA Committee. However, it was not clear to the review team, from the minutes and other evidence provided, whether the Committee assesses the achievement of the objectives nor whether it requests action to be taken in light of the outcomes of its monitoring. The recommended action in 3.6 should enable the AVA to evidence these points more fully in the future. 2.6 The strategic planning process is considered through Ascentis' self-assessment processes. Development, promotion and enhancement 2.7 Ascentis provides a focus for the development, promotion and enhancement of Access to HE provision within its areas of operation. Ascentis has three main areas of operation for Access to HE provision: the North West, the North East and Hampshire (although Ascentis also has recognised provision outside of these areas). In broad terms, these three main areas of operation are reflected in three distinct subsets of provision: 'main scheme' courses (in the North West and elsewhere); Higher Education Foundation Certificate (HEFC) courses 6 (in the North East); and (since 2011-12) Southern Area courses. 2.8 Ascentis gathers and analyses information relevant to the development, promotion and enhancement of Access to HE, and communicates its analyses to its providers and other stakeholders on a regular basis. 2.9 Ascentis provides advice on the delivery of the Access to HE Diploma to ensure that providers meet the AVA's expectations and the requirements of The Access to Higher Education Diploma and credit specifications (although see also 4.10). Ascentis also arranges events or opportunities for practitioners to support and develop good practice, including training events, conferences and meetings of the Access Coordinators' Advisory Committee. For providers who are delivering courses for the award of the HEFC as well as the Access to HE Diploma, there is a separate equivalent group: the HEFC Course Committee. This committee, and the monitoring of attendance of provider representatives at meetings, is managed independently by the HEFC Consortium. The HEFC Course Committee receives the minutes of Ascentis' Access Coordinators' Advisory Committee, and there is an arrangement in place for a member of the HEFC Course Committee to attend the Access Coordinators' Advisory Committee and report back to the HEFC Course Committee. The minutes of the Access Coordinators' Advisory Committee indicate that a HEFC representative has attended only once (out of three meetings) in 2009-10 and once (out of three meetings) in 2011-12. 2.10 Ascentis promotes Access to HE through its activities and publications. 6 The Higher Education Foundation Certificate Consortium (HEFC Consortium) is a consortium of colleges and Northumbria University (the University), which is responsible for running and governing the HEFC programme that is validated by the University. A formal agreement between the HEFC Consortium and Ascentis has been in place since 2001. On successful completion of the course, students are awarded the HEFC by the University and the Access to HE Diploma by Ascentis. The HEFC Consortium has its own Board to govern and manage the HEFC provision, and this is carried out separately from Ascentis' management of the standards of the Access to HE Diploma provision. Ascentis is represented on, and receives for information the minutes of, the HEFC Consortium Board. 10
3 Management Resources and financial management 3.1 Ascentis has sufficient financial resources to exercise its AVA responsibilities in full. 3.2 Its facilities, administrative systems and allocation of funds are sufficient to manage its AVA responsibilities including, in particular, responsibilities relating to assuring the quality and standards of its recognised Access to HE provision. 3.3 Ascentis operates a responsible, systematic and rigorous approach to the management of its financial affairs. Staffing 3.4 Ascentis' level and structure of staffing can deliver the requirements involved in the holding of an AVA licence. The AVA has reorganised its staffing recently and has re-evaluated its staffing needs following the transfer of some provision offered by providers which had been validated previously by Southern Area AVA. A part-time manager and an office has been established in the South, with communications from providers in the South being channelled first through the main Ascentis office. Recent decisions to invest in new senior staff will further enhance the AVA's staffing capacity. Self-assessment and risk management 3.5 Ascentis has procedures for regularly monitoring and assessing the quality, effectiveness and security of its management and operations. It makes use of a range of information to review its performance, though some weaknesses have been identified by the AVA (such as incomplete forms from some centres or moderators, and inaccuracies in statistical data received from the Data Service), which makes the AVA's assessment of risk less robust. Compliance monitoring is the responsibility of the Directorate of Regulation and Quality Assurance, and the self-evaluation grid prepared for the relicensing review is used as a master document for ongoing monitoring. In spite of its explicit self-assessment against the AVA licensing criteria, prepared for the review, the AVA did not itself identify any unmet licensing criteria, although the review team identified a large number of areas in which the AVA does not currently meet the criteria. The team therefore concluded that Ascentis' procedures for monitoring its continuing compliance with the AVA licensing criteria were not fully effective. The team recommends that Ascentis revise its AVA monitoring procedures, in order to improve its effectiveness in identifying the AVA's continuing compliance with the AVA licensing criteria. Operations 3.6 Minutes of Ascentis committees' proceedings and other formal records are produced, are retrievable, and are held for an agreed period. The review team formed the view, however, that the standard of some committee minutes could be improved so that they provide a consistently useful summary of the key points discussed at the meeting, as well as a clear, auditable record of the decisions made, and any subsequent actions to be taken. The team recommends that Ascentis revise its style of committee minutes to provide a more useful summary of key points discussed, a clearer record of the decisions taken, and any resulting actions. 3.7 Ascentis develops, maintains and documents procedures, including indications of specific actions for AVA staff, in relation to key aspects of AVA operations for Access to HE, 11
to ensure that the work of the AVA is not unduly reliant on the knowledge, practices or efforts of individual staff. 3.8 Its documented operational procedures for Access to HE are clear and readily available, and include the processes expected by this licensing criterion. Data management and transfer 3.9 Ascentis has structures and systems for collecting, recording and holding data about Access to HE providers, courses, students and awards. Systems and processes enable the AVA to award Access to HE Diplomas to students who complete requirements. Ascentis also provides statistical reports to QAA when required. The review team was concerned about the adequacy and effectiveness of some aspects of the system, given the inaccuracies in Ascentis' data identified by the AVA itself. The team noted that Ascentis had experienced difficulty in reconciling discrepancies between data received in Data Service reports and data which it collected directly from providers (which is not always complete) or data generated by Ascentis itself. In spite of efforts made by the AVA (for example, through discussions at its Access Coordinators' Advisory Committee), significant discrepancies remain. The team therefore formed the view that this licensing criterion was not fully met and that, at the time of the review, the AVA had not put plans in place which would resolve these problems. Since the review, Ascentis has informed QAA that, as a result of its investigations, some centres have identified inaccuracies in the data returns made to the Data Service (which form the basis of the Data Service reports received by Ascentis), while other discrepancies remain unaccounted for. Further work will be required by Ascentis to ensure that centres provide complete and accurate data on their Access to HE provision to both the Data Service and to Ascentis. Ascentis is therefore required to provide a plan showing how the accuracy of the AVA's student data tracking system will be improved and maintained on a continuing basis. Communications 3.10 Ascentis has a range of appropriate and effective mechanisms through which it communicates to, and gathers feedback from, member organisations and other stakeholders about matters relating to Access to HE. 3.11 Ascentis monitors providers' published information about Access to HE to verify its accuracy and currency, and consistency with QAA requirements. 3.12 Ascentis makes appropriate use of the Access to HE logo in its own publications and ensures that its use of the logo is consistent with QAA's published guidance. Complaints and appeals 3.13 Ascentis has transparent and accessible procedures to enable complaints and appeals to be received, considered and resolved fairly, including procedures for complaints and appeals made to the AVA by students and providers which relate to its role as an awarding body. 12
4 Course recognition Diploma development (and transfer) 4.1 Ascentis has a systematic and transparent approach to developing new Access to HE Diplomas (and considering requests for course transfer). 4.2 Ascentis considers key information at an early stage in the development of new Diplomas (or consideration of transfer requests), and confirms all areas expected by this licensing criterion. 4.3 During the development phase for a new Diploma, individuals currently delivering higher education provision in a subject relevant to the progression route(s) are involved in advising on the expectations and requirements for entry to the progression route(s) and the appropriateness of the Diploma proposals in meeting those expectations. 4.4 In considering a request by a provider for the transfer of responsibility for course recognition from another AVA, Ascentis formally confirms, before the transfer is agreed, all areas expected by this licensing criterion. 4.5 Ascentis publishes clear guidance for those involved in the development (and transfer) of Access to HE Diplomas. The guidance includes all information expected by this licensing criterion. 4.6 The AVA's guidance includes an explicit statement that the design of Diplomas should be appropriate to the primary purpose of Access to HE courses. The guidance does not include the other explicit statement required by this licensing criterion. Ascentis is required to include an explicit statement, in its guidance for those involved in the development (and transfer) of Access to HE Diplomas, that Access to HE Diplomas are intended to provide a preparation for study in UK higher education, but that the award of a Diploma does not provide guaranteed entry to UK higher education programmes. Validation processes 4.7 Ascentis operates a thorough, transparent and consistent approach to the validation of Access to HE Diplomas. 4.8 The AVA's validation process involves the scrutiny of Diploma proposals by an appointed panel. The panel does not, however, assess the proposals against a set of clear, standard criteria, including those in licensing criterion 4.10. Ascentis is therefore required to ensure that its validation process and panels assess all Diploma proposals against a set of clear, standard criteria, including those in licensing criterion 4.10, checking for consistency with The Access to Higher Education Diploma and credit specifications and other regulatory information about the qualification published by QAA. See also 4.10. 4.9 Both the individual units and the totality of each named Access to HE Diploma are considered as part of the Diploma validation process. Validation criteria 4.10 The AVA's validation process has ensured that, for a Diploma to be recommended for approval, it meets most of the requirements of this licensing criterion. The review team explored whether the validation process ensures that the proposals meet the detailed requirements of The Access to Higher Education Diploma and credit specifications and any other regulatory information about the qualification published by QAA (criterion 4.10b). 13
In November 2008, QAA published Access to HE Diploma: points of clarification 7 and wrote to all AVAs requiring them to take action if any Diplomas were operating with structures that were inconsistent with the specification. Among the points clarified were: 1) 'all Diplomas are structured to allow students to gain the qualification on the basis of achievement of 45 level 3 credits and 15 level 2 credits', and 2) 'achievement of more than 45 credits at level 3 cannot be required for the award of a Diploma'. Access to HE Diplomas validated by Ascentis are structured in such a way as to meet the first of these requirements (that is, the validated course allows students to gain qualifications on the basis of achievement of 45 level 3 credits and 15 level 2 credits). However, the review team noted a number of courses in which the second of these 'points of clarification' from QAA was not being observed, because providers had chosen to deliver the course entirely at level 3. Such a model was illustrated in the AVA's handbook. For students registered on these courses, achievement of more than 45 credits at level 3 was required for the award of a Diploma. Ascentis' validation process has not prevented this practice, and the review team was informed that this delivery model was regarded as a matter of provider choice. The review team concluded that Ascentis does not therefore fully meet criterion 4.10b. See required action in 4.8. 4.11 The outcomes of the validation process for each Diploma, including recommended conditions of approval and textual amendments to documentation, are recorded. Validation panels 4.12 An expert, external panel is appointed by Ascentis to scrutinise proposals for new, transferred or major modifications to Access to HE Diplomas. 4.13 The composition of panels ensures that panel members jointly provide current, relevant experience and expertise in the delivery and assessment of Access to HE courses; curriculum knowledge relevant to the Diploma(s) and all the units being considered; and the delivery of higher education programmes in areas indicated as intended progression routes for the Diploma(s) being considered. 4.14 The number of members and composition of validation panels for Access to HE Diplomas, and the criteria for selecting panel members, are clearly specified and consistently applied. 4.15 The Chair and members of the validation panel have no conflicts of interest in respect of the outcome of the validation event. 4.16 No more than one member of the validation panel is also represented on the body which has been designated as responsible for the approval of Diplomas within the AVA. 4.17 AVA officers attend validation events to ensure consistency of conduct, and advise the panel on the AVA's validation process, including requirements that relate to the application of QAA's requirements for Access to HE Diplomas (although note 4.10). 4.18 Before the panel event, panel members are informed about their roles and responsibilities, the purpose and conduct of validation panel events, the possible outcomes of the process, and the post-panel process. 4.19 The panel makes a recommendation for approval, including any recommended conditions of approval, and the panel's recommendations are referred to the AVA Committee via the Ascentis Executive for formal approval. 7 www.accesstohe.ac.uk/home/publications/access%20to%20he%20diploma%20-%20clarification.pdf 14
Diploma approval 4.20 The Access to HE Committee considers the validation panel report and the panel's recommendations, and confirms that the AVA's validation processes and expectations have been applied. 4.21 The AVA Committee grants or withholds approval (with or without conditions) and, with regard to any conditions on the approval of a Diploma, it confirms that conditions will ensure that the Diploma meets the AVA's validation expectations, that there are clear timescales for meeting conditions, the date by which any conditions must be met, and the process for confirming that conditions have been met. 4.22 Ascentis monitors whether and when conditions have been met, ensuring that the process for confirming that conditions have been met is followed. 4.23 When Ascentis is satisfied that the conditions have been met, the approval of an Access to HE Diploma is formally recorded, and the provider(s) wishing to deliver the Diploma is/are informed that it is available for delivery. 4.24 Ascentis has a formal procedure in place for the withdrawal of approval from a Diploma before the end of its validation period, which is managed through its procedure for the withdrawal of approval for units and/or a pathway. 4.25 Ascentis holds full records of all validation and approval decisions, and it maintains definitive Diploma documentation (making amendments, as necessary, to reflect approved modifications). 4.26 The AVA Committee maintains oversight of the validation and approval process and is responsible for ensuring the robustness of processes and consistency of their operation (although note 4.10). Provider/centre approval 4.27 Ascentis operates a transparent, systematic and consistent approach to the approval of providers for the delivery of Access to HE courses, through which it confirms that the provider meets its criteria for centre recognition. 4.28 Ascentis formally confirms centre recognition for the delivery of named Access to HE Diplomas (or Access to HE provision) before a provider is permitted to deliver any part of any individual Access to HE Diploma. 4.29 Ascentis provided information to the review team about its procedure for the withdrawal of centre recognition if a provider fails to continue to meet the terms of its approval. At the time of the review, the team identified a weakness that created a circularity in the process, which was discussed with the AVA. Since the review, Ascentis has informed QAA that it has rectified this problem and that it now requires all centres to sign a centre agreement, which includes a full section on the centre recognition withdrawal process. Ascentis is required to provide evidence to QAA of its revised approach to the withdrawal of centre recognition. Criteria for provider/centre approval 4.30 Ascentis' process and criteria for centre approval ensure that a provider that is approved to deliver an Access to HE course is located in the UK and has in place all the resources, policies, procedures and systems expected by the AVA licensing criteria. 15
4.31 Ascentis' process and criteria for centre recognition ensure that a provider makes an explicit commitment that it will cooperate with the AVA's moderation, monitoring and standardisation procedures. Course recognition 4.32 Ascentis operates a standard process to confirm that Diploma and centre approval have been satisfactorily completed before course recognition is confirmed. 4.33 Providers that have applied to deliver a new Diploma and have been approved to do so are notified when Diploma approval has been confirmed, and informed of the date of course recognition and when delivery may start. 4.34 When the AVA has confirmed recognition of a new course, it uploads the required course information to the Access Courses Database; and it revises course records, as necessary, to maintain the currency of information available on the Database. Modifications and amendments 4.35 Ascentis provides mechanisms through which providers, moderators and partner higher education institutions can suggest modifications to units or Diplomas, and for those suggestions to be systematically considered. 4.36 It operates standard procedures for regulating modifications to units and Diplomas, and ensures that any feedback received from providers, moderators or receiving higher education institutions is taken into account. 4.37 It differentiates between minor and major modifications, makes clear where authority lies for making different kinds of modification or amendment, and gives an appropriate level of scrutiny to each. 4.38 When minor modifications are considered (including modifications to units included in more than one Diploma), Ascentis confirms that affected Diplomas will continue to comply with the AVA's expectations before approving the modification. 4.39 If modifications are made to a unit or Diploma which is delivered by more than one provider, all providers involved in the delivery of the unit or Diploma are informed of the amendments. 4.40 The AVA Committee maintains oversight of the approval of unit and Diploma modifications. Revalidation and confirmation of provider/centre approval 4.41 Ascentis' standard validation period for Diplomas is five years from the date of initial approval, and it maintains a forward schedule of revalidation for Diplomas. 4.42 Ascentis performs what it describes as an 'annual revalidation' as a requirement of continued course recognition. This involves gathering together a profile of information about each provider, including outcomes from quality processes and participation in events organised by the AVA. The annual revalidation is approved by the AVA Committee. 4.43 Ascentis operates a process for the periodic revalidation of Diplomas, which takes account of the areas required by this licensing criterion. 16