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Dame Shirley Pearce’s Independent Review of the Teaching Excellence and Student Outcomes Framework (TEF) and the Government response to the independent review

Governance News Alert

Dame Shirley Pearce’s two-year review of the TEF has been published, along with the government’s response to it. (Page numbers refer to the government response unless otherwise indicated).

The full independent review report can be found at:

The full government response can be found at:


  • A move to subject-level TEF ratings has been rejected by the government as too much of a financial and bureaucratic burden on providers (p7)
  • For the same reasons, the TEF will move from an annual exercise to one that takes place every four or five years. For each exercise the costs, for both providers or the Office for Students (OfS), should, at an absolute maximum, not exceed the costs per provider of the TEF exercise that has taken place to date (p7)
  • Gold, Silver and Bronze TEF awards will be replaced with new ratings including a fourth new bottom category. The latter will capture those providers failing to show sufficient evidence of excellence, and it will be made clear that these providers will need to improve the quality of their provision. The names of the new ratings will be announced in due course (p8 response, p13 review )
  • The Government considers it essential that student outcomes should act as “Limiting Factors”, such that a provider should not achieve a high TEF rating if it has poor student outcomes. The OfS will determine how the Limiting Factors should work (p8)
  • In line with the recommendations of the independent review, the OfS will ensure TEF ratings are based on an assessment of high quality, nationally gathered metrics and data (e.g. Graduate Outcomes, Longitudinal Education Outcomes and student non-continuation data) and contextual qualitative information. It should use more than just graduate earnings in the metrics and take account of regional variations. OfS will also need to consider if and how educational gain can be reliably measured and this should be explored in developmental work and consultation exercises (p8)
  • The OfS metrics group should take into account and address the concerns raised by the Office for National Statistics (ONS) when reviewing the robustness of its metrics and data. It should also be mindful of how metrics could measure the quality of learning delivered in a more flexible way over the course of a student’s lifelong learning (p8)
  • The review recommends a structure to measure the quality of teaching based on: Teaching and Learning Environment; Student Satisfaction; Educational Gains; and Graduate Outcomes. But the Government’s response says it does not consider ‘Student Satisfaction’ to be an appropriate measure of excellence (because, for instance, satisfaction might potentially be obtained via a reduction in quality or academic rigour). It therefore proposes to substitute this with ‘Student Academic Experience’. The OfS will consult and develop proposals on each of the aspects (p7 response, p13 review)
  • The OfS is carrying out a root and branch review of the National Student Survey (NSS), with a focus on resolving aspects of the NSS that may act as a disincentive towards quality. The outcomes of the NSS Review will inform what role the survey plays in the TEF assessment. The OfS will look at how student feedback on quality can be included in the TEF (p8)
  • OfS will consult on the new TEF Framework. This consultation will align with those on the OfS approach to quality, and with the OfS Review of the NSS.  A new Framework should be in place, assessments completed and results published by September 2022 (p8)
  • The review’s recommendation that the name of the TEF should be changed to the Educational Excellence Framework (EdEF) was rejected (p2 response, p11 review)

Implications for governance

The review of the TEF feeds into the government’s focus on measuring and improving quality, which also includes the OfS consultation on the regulation of quality and standards and the review of the NSS.

The reworked TEF and its new ratings present the prospect of either reputational risk or reward for institutions, and so will be of concern to governing bodies. Institutions currently rated Gold potentially have the most to lose from the overhaul, with present awards due to expire in the summer. The addition of a new “failure” rating may also be seen as worrying development, even if, based on the current framework at least, it is highly unlikely that traditional HEIs would fall into this category. No detailed information was provided in the government’s response about the criteria for the new ratings and the category names are yet to be disclosed. The independent review also recommended changes to the ratings to four categories: meets UK quality requirements, commended, highly commended and outstanding. However, its language was decidedly less pejorative than the DfE’s definition of the bottom category as “failing to show sufficient evidence of excellence”.

Governing bodies may also be concerned with the use of student outcomes as a “limiting factor” on HEIs ability to be awarded a high TEF rating, although some may take comfort from the reassurance that the focus will not be entirely on graduate earnings, and that regional factors will be taken into account.

Responses to this and other related consultations will be an important focus for governors in the coming months. OfS’s “root and branch” review of the NSS will feed into the design of the TEF framework. The regulator is seeking providers’ views using a survey and a series of roundtables. It will also consult on what the “student academic experience” element of the TEF should include, and will also need to consider how (or whether it is possible) to measure “educational gain” – questions that will give HE leaders plenty of food for thought and debate.

For many providers the government’s decision not to proceed with subject-level ratings will be a relief, given the potential cost and time implications and various unintended consequences, even if might have presented an opportunity to highlight very high performing subject areas. The independent review recommended that subject-level exercises could be usefully incorporated into the provider-level assessment, but the government is clear that the OfS should “not proceed with any form of subject-level assessments as part of TEF at this time”. However, the OfS has said that evidence from the 2018-19 subject-level TEF pilot exercise will be taken into account. Also, both the government and the OfS have made clear their determination to address “pockets of poor provision”. Governors with their academic assurance hats on will therefore need to remain alert to variations in quality across different subjects.

Many in the sector will also welcome the decision to move to a four to five year cycle, given the bureaucratic burden of the TEF exercise. The OfS says it is considering and will consult on options for an interim period from the present to the new system.

Read the review

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