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Transforming opportunity in higher education

The Office for Students (OfS) has released an analysis of the 2020-21 to 2024-25 access and participation plans (APPs) submitted up to 31 October 2019 by providers. In its review, Transforming opportunity in higher education, OfS details its approach to access and participation, the expectations it has with regard to the implementation and achievement of provider plans and nationally the collective impact if all APPs are delivered.

Comments from the Chair of OfS

Released alongside its review, OfS has issued a press release titled “Universities pledge to reduce equality gaps dramatically within five years”. In the press release, Sir Michael Barber, Chair of the OfS, comments that the chance of going to university is something of a “postcode lottery”; but that equally the simple binary division between North-South is misleading.

A condition of registration

A condition of registration with OfS covers access and participation (condition A1). An approved (fee cap) provider – those wishing to charge the maximum permitted tuition fee rate - must:

  • operate an APP approved by OfS
  • take reasonable steps to deliver the plan.

Commentary by the Director of Fair Access and Participation

Transforming opportunity in higher education’ opens with a commentary written by Chris Millward, Director for Fair Access and Participation. The commentary summaries the background to, and the approach adopted by, the OfS. Some of the points discussed include:

  • Given the persistence of stark gaps in relation to access to higher education and student success the need for a radically different approach
  • A move to a five-year cycle for the submission of APPs
  • The expectation that APPs should cover the “whole student lifecycle” – access, progression and success
  • A focus on outcomes
  • The view that the large amount of money invested in access work in previous years has led to only incremental progress in return. As a result, OfS no longer views investment alone as a measure of success
  • In addition to providers setting their own targets, OfS has set national targets (known as Key Performance Measures – KPMs)
  • Compared to previous periods and reflecting the desire to achieve transformational change, a change in OfS’s approach to APPs
  • A recognition that the new approach is “undoubtedly challenging”
  • A need for providers to deliver their APP
  • The recognition that even if providers meet their targets some gaps will remain
  • Generally, a failure of plans to give sufficient attention to, for example, mature students, or specific groups, such as care leavers
  • The statement that OfS “will not hesitate to use our powers to improve progress where gaps are widest or slowest to close”

Plan approvals

To date, OfS has not refused to approve any provider’s APP; although some 96% of plans had some mitigation placed against them. 90 providers have received enhanced monitoring requirements and 79 formal communications.

Of the 171 plans approved, 157 (92%) were approved for the maximum five-year period, 5 (3%) plans for up to three years, 6 plans (3%) for up to two years, and 3 (2%) plans were approved for one year.

Next steps

OfS expects to monitor delivery of APPs through the annual impact report. The first annual impact reports are expected to be submitted in 2022. In addition, providers subject to enhanced monitoring may be expected to submit additional information alongside or in advance of the annual impact report (ie. 2020 or 2021).

Reflecting OfS’s risk-based approach, providers at higher risk of breaching condition A1 will be subject to closer monitoring.

OfS will also support the development and sharing of effective practice in relation to access and participation. This is a statutory requirement placed upon OfS by the Higher Education and Research Act 2017.


The publication of Transforming opportunity in higher education details the expectations that OfS has of providers with regard to access and participation. The focus is on outcomes, with providers expected to deliver to their agreed targets. If this is achieved, collectively the sector will over the next five years make faster progress to closing the gaps in relation to access and participation.

The risk of a provider not delivering the outcomes agreed in their APP and the threat of action by the OfS, suggests governing bodies will need to be aware of the provider’s progress in meeting it's targets, and be alert to the need encourage early and appropriate action should significant adverse variances emerge between the agreed targets and actual outcomes.

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