Open letter to the vice-chancellor: devalued degrees at the University of Bristol

Dear Professor Evelyn Welch

cc Pro Vice-Chancellor (Education and Students) and Chair of the University Education Committee; Associate Pro Vice-Chancellor (Quality and Standards) and Chair of the University Academic and Standards Committee

We are writing in response to the recently published temporary amendments to academic regulation for 2022/23, approved by yourself, the Pro Vice-Chancellor (Education and Students), and the Associate Pro Vice-Chancellor (Quality and Standards) on 11 May.

We do not believe that it is possible to meet the stated aims of maintaining academic standards while proposing to award degrees (classified or otherwise) under the temporary changes to academic regulations and would ask that you immediately rescind these temporary regulations. These changed academic regulations devalue degrees awarded at the University: students are getting degraded degrees at the University in 2023 under these temporary regulations.

In short:

• The changes to the regulations are deeply unfair in that they will lead to lower classifications for some students and higher classifications for others in the absence of a full run of marks. (Principles 5 and 9, 3.12, 2.1.1)
• The lack of internal oversight of exam boards means decision-making will not be robust. (Principle 6, Principle 7.4)
• The lack of oversight by external examiners is a failure to meet quality assurance expectations, namely, that students’ achievements are reliably assessed taking account of external expertise. (Principle 6, Principle 7.4, 3.6, 3.11)
• There is no clear basis for the excessive discretion given to chairs of exam boards to waive large parts of units. (Principle 3, 2.1.1)
• Waiving large (and later) assessments in units is pedagogically unsound (2.1.1)
• The incompatibility of these amended regulations with professional accreditation requirements implies that they undermine the credibility of any degrees awarded using them. (Principles 1 and 3, 2.1.1iii)

These amended regulations propose to disregard unknown quantities (work which has not yet been marked). This means that, for instance, the integrity of degrees conferred this academic year will differ: some students will be issued with classifications based on much fuller evidence than others. This inconsistency will necessarily devalue University of Bristol degrees, because (for e.g.) employers will have no way of determining the basis on which a given 2023 2.1 degree was awarded. Such degrees will not be comparable to those conferred in other years.

In implementing these amended regulations, the University of Bristol is in breach of OfS guidance that ‘awards granted to students are credible at the point of being granted and when compared to those granted previously’ (condition B4).

Very few academic staff with responsibilities for maintaining University academic standards have been consulted on these amendments. It is notable that in institutions such as the University of Cambridge, where a wider constituency of academic and academic-related staff have oversight of such matters, this sort of regulatory amendment has not been possible. In the communication sent to students on the subject of these amendments, it is stated that the institution is ‘balancing the need for you to graduate with our responsibility to ensure the quality of our degrees and we are confident that these temporary regulations achieve this’. Rather, it appears to us that the institution is prioritising its need to graduate students—or ‘produce’ degree certifications—over its responsibility to assure the quality of the degrees it confers.

We outline in more detail below a number of our concerns relating to these regulatory changes, some of which are likely to leave the institution vulnerable to student appeals, and many of which contravene QAA’s UK Quality code (namely, that ‘The provider uses external expertise, assessment and classification processes that are reliable, fair and transparent,’ p. 3).

The changes to the regulations are unfair in that they will lead to lower classifications for some students and higher classifications for others because of the absence of a full run of marks. Despite the stated principle that mitigations should only be applied where they would improve a student’s outcome, these changes to regulations could lead to lower classifications for some students, especially if the dispute is not resolved quickly.

Even where decisions as to students’ degree outcomes are made at School or Faculty Exam Boards, they are likely to be, in the majority of cases, based on a severely limited range of evidence. In addition, in relation to the ‘third stage’ of mitigation, there is a significant risk that students may graduate with worse degree outcomes than their submitted work merits. It does not appear to be possible to mitigate against this risk, because it necessarily excludes from consideration unknown (but knowable!) quantities: students frequently excel, for instance, in their 40-credit dissertations, which given the high weighting of the final year of degree programmes can have a significant impact on outcomes (in programmes where Y3 is weighted 75%, 40 credits represents 25% of the marks contributing to a classification). This risk is not mitigated by the assurances in Principle 9 (that classifications can subsequently be amended if marks become available). It is not clear, after all, that marks will become available; in any case even a temporary falsely low classification is a significant detriment for students.

From a different perspective, the principle that mitigations should only be applied where it is to the students’ overall benefit might produce unfair outcomes. Take two students who achieve 1sts in all of their 3rd year TB1 units, but 2:2s in TB2. One student has a full run of marks; the other has had all of their TB2 units affected by industrial action. The student with a full run of marks would be awarded a 2:1; under these amended regulations, the other student could be awarded a first. If and when that second student’s TB2 work was marked, they would be allowed to retain their 1st class degree. That would be manifestly unjust. We have modelled situations where the difference in outcome having excluded 40 credits is as wide as two classifications.

The lack of internal oversight of exam boards means decision-making will not be robust. The changes to regulations determining the quoracy of exam boards, and the high probability of the majority of decisions being referred up to smaller ‘parent’ exam boards raise severe concerns. The efforts of Faculty Education officers and Professional Services colleagues in meeting demanding timelines and maintaining high standards are Herculean even in ordinary years, when both department and school internal and external exam boards have already done a significant amount of processing, checking, and clarifying. Despite the high levels of integrity and expertise of our colleagues, we are not confident that it is possible for either Faculty or institution-level exam boards to safely manage such a volume of work. Given the high levels of participation in the MAB by UCU members, errors would be all but inevitable in such a situation.

The lack of oversight by external examiners is a failure to meet quality assurance expectations, namely, that students’ achievements are reliably assessed taking account of external expertise.  We are also concerned about the implications for quality assurance of the diminished involvement of external examiners. In many areas of the university, external examiners attend department and / or school-level exam boards. They do that because it is usually the forum in which the majority of decisions are made, and where they can share their thoughts on the programme design, students’ work, and assessment processes with the staff who do that work. If these amended regs are put into full effect it is highly likely that external examiners will have very little oversight over the majority of the substantial decisions made regarding degree outcomes, because those decisions are likely to be referred up to boards at which they will not be present.

There is no clear basis for the excessive discretion given to chairs of exam boards to waive large parts of units. In certain places these amended regulations also invest significant discretionary powers in education officers, which will place them under undue pressure. There are other areas where there is a worrying amount of leeway or lack of guidance. Faculty Education Directors are permitted, for instance, to waive the requirement that no more than 50% of a unit’s marks can be excluded on the basis that they have been affected by the MAB, at the ‘second stage’ of mitigation. Importantly, that stage might well enable the classification of student degrees on the basis of partial evidence (and on the basis of evidence more partial than these regs at first sight would seem to permit). It is unclear what the criteria are for determining which programme intended learning outcomes have been or should be met by a student’s run of marks. Finally, under 3.7 it is stated that ‘Exceptionally, the pass mark will be awarded for the unit where a unit mark is returned that is below the pass mark and a progression decision has already been made’. This appears to contravene Principle One, and it is not clear under what conditions such an exception would be permissible.

Waiving large (and later) assessments in units is pedagogically unsound. Under these amended regulations, where units or assessments are excluded from consideration on the basis that they have been affected by industrial action, the remaining units or assessments will have their weighting ‘scaled up’ to compensate. This scaling up would interfere significantly with unit and assessment design, and the ways in which unit and programme learning outcomes are fulfilled in practice. The amount of teaching and student time directed towards particular assignments naturally varies according to weighting; it is not fair to over-inflate the outcome of a low-weighted assignment, because teachers will have designed, and students will have approached that assignment in ways which reflected its relatively low weighting.

The incompatibility of these amended regulations with professional accreditation requirements implies that they undermine the credibility of any degrees awarded using them. The amended regulations concede that certain PRSB accreditation requirements would prevent the application of certain mitigations. A question of parity of treatment arises: why should students whose degrees happen to be accredited by external bodies enjoy a more rigorous process for the determination of their degree outcomes, compared with students whose degree programmes are not ordinarily subject to such external regulation?

Students deserve to have their work marked by the expert staff who designed their assessments, delivered their teaching, supervised their dissertations and projects. They deserve for that work to be weighted in the way they were advised it would be, for that weighting will have rightly dictated the ways in which they directed their time and effort. They deserve degree outcomes which have been determined in rigorous ways which correspond with that of other cohorts, and which are based on the achievements evidenced in the full range of their submitted assignments.

As you will be aware, this is (largely) a cohort who 3 years ago had a very direct experience of the ill effects of algorithmic interference in the awarding of educational qualifications. It is not necessary to implement these regulations, as it may have been necessary to do something then: this is not a global pandemic, but an industrial dispute. It can be resolved via negotiation. We would reiterate the sensible demands made by students in this open letter: that the University should issue a public statement calling on UCEA to reopen negotiations on pay and working conditions (as our colleagues at the University of Bath have recently done). Notably, these students say that they want their work to be marked by their tutors, because they want the work that they have put into their studies to be acknowledged, and to be properly assessed. In saying so, they recognise that it is in fact the academic and professional services staff with whom they have worked closely who maintain this institution’s academic standards.

Those academic standards cannot be replicated or worked around by hastily-amended regulations.

Yours,