Us ‘Quality’ folk are always asking “Why?”. Because we know it’s important to understand why something fails, so you can put improvements in place to prevent it happening again, or at least reduce the likelihood of it happening again. Simple. Obvious. Right?
So before the OfS portals re-open at the end of August, we thought we would take another look at the OfS Refused Reasons page to see exactly why previous providers have had their registration applications thrown out so we can learn and improve.
In true Top of The Pops style, lets start from the bottom (are you hearing the ToTP countdown music, sorry about that 😉)
- In 7th place was A2: Access and Participation Statement. Just the one case of this but I was surprised, as it is a relatively simple task in comparison to the volume of work required for an application – but shows that it is absolutely mandatory and not to be overlooked.
- In 6th place C1: Consumer Protection Law. Obviously we are going to see much more focus on this shortly but in essence, nothing surprising here – contract terms and conditions unclear, not easily accessible, website included misleading or missing information, lack of evidence-based details for how the provider follows consumer protection guidance.
- So now to 5th place and we have B3: Student Outcomes. Issue here is continuation rates failing to meet successful outcomes including gaps among different demographic groups and for two of the six providers in this category, this was the only reason for refusal.
- 4th place, E1: Public Interest Governance. In total, eight providers were found not be demonstrating public interest principles with B1, B2, B4 and B5 not being considered.
So onto the Top 3 (still got the tune in your head?)…
- In at number 3 we have C3: Student Protection Plan. In double figures for this one, eleven providers planned inadequately, lacked clear and credible assessment of risks, failed to identify financial risks or did not address specific or differentiated risks. Concerns around premises’ stability were cited with some risk being identified as irrelevant, undermining the credibility of the plan.
- So, on to number 2, just missing out on the top spot by one instance, we have D: Financial viability and sustainability. I guess unsurprisingly, finances were always going to be towards the top of this list with reasons such as high risk of insolvency, unrealistic forecasts, inaccurate or inconsistent financial commentary. Weak liquidity, projected deficits and reliance on uncertain future investment were included compounded by the lack of risk management (as seen in No.3). A total of thirteen providers were in this category.
- And at number 1… have you guessed yet? It is E2: Management and Governance. A total of fourteen providers fell into this category. Lack of evidence and clarity were key here with errors, inconsistencies and weak documentation included as reasons. Lack of self-regulation and understanding of OfS requirements were another key indicator and where planned structures were not implemented e.g. planned new governance structure lacked evidence and was not yet operational, where providers were refused they had not considered B1, B2, B4 and B5 in their assessments.
In summary, unsurprisingly, the top three are still a priority for the sector and regulator today: Governance, Finance and Student Protection and with the imminent publication of the new registration rules, C5 and E7, these key areas for any provider, registered or not, will continue to be a laser-focus for OfS.
If you want to read the detail of OfS refused registrations you can find it here.
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