AOR major review and Student record expansion for England and Wales - summary of responses

HE providers that are or may be required to submit data to meet the proposed requirements were invited to submit burden assessments as part of their responses to the consultation. These scores are grouped into bands with the following definitions:

Setup:

0: No impact

1-3: Almost no change to processes or systems. Can be fitted into business as usual against a known release window. Limited training or guidance required.

4-7:  Minor to medium changes to systems and processes. Difficult to resource. Date for go-live sub-optimal. Requires bespoke training.

8-10: Significant change to systems and/or processes. Detrimental impact on ability to do other activities. Cannot be serviced from existing capacity. Release date very challenging. Requires training / re-skilling.

Run:

0: No impact

1-3: Business as usual (BAU). Operated through processes and systems. No discernible impact on current operating model.

4-7: Increased resources. Sustained opportunity cost. Complexity in planning. Requires specialist support.

8-10: Sustained increased resources required. Conflict with other business priorities. Cannot be systemised – lots of manual checking. Requires subject matter expert (SME).

To meet the requirements of the OfS and HEFCW in relation to partnership students, as set out in the background section of the consultation, this proposal set out an expansion to the coverage of the Student record. This included all students studying in the UK who are taught by the reporting provider or studying for an award of the reporting provider, where this provision was not already returned by another provider to HESA or to the Education Skills Funding Agency in the Individualised Learner Record (ILR). The aim was to ensure that the quality and standards of all provision at providers can be monitored, whether the students are registered with, taught by, or studying for an award of a registered (OfS) or regulated (HEFCW) provider.

Some of the responses in this section were made in relation to transnational education partnerships rather than UK-based partnership arrangements, but these have been included in the below summary for completeness.

53% of respondents agreed with the proposal to collect data on partnership students in the Student record. 7% disagreed, and 40% neither agreed nor disagreed. Three providers stated that they did not have any partnership arrangements at present. Most providers scored the burden in the “4-7” category for setting up this data, with the majority scoring the burden in the “1-3” or “4-7” category to run the data collection to include partnerships students.

Of the respondents who disagreed with the proposals, comments made were:

• Considerable extra burden on providers and their partners for limited benefits, which included having to review contractual arrangements and establishing new data collection and monitoring arrangements which would require system development.
• Concerns raised about whether this can be ready for a 2025/26 change.
• Prefer to amend the current aggregate return or consider other approaches – such as a reduced return, a two phase implementation, or a review of only essential data requirements that are needed.
• Concerns raised about the relationships with their partners, with additional requirements for data exchange and added bureaucracy this could endanger the sustainability of such arrangements.

Of the respondents who agreed with the proposals, comments made were:

• Many were supportive of the principle of including this data in the Student record, stating it was necessary for appropriate regulatory oversight (one provider stating explicitly that this data would be needed within the scope of the revised B conditions of registration for providers in England, namely on ensuring quality, reliable standards and positive outcomes for all students).
• Some reported that the information was already collected, so little or no effort would be involved to include partnership students in the return. Others reported that changes would be needed (and for some that would be significant). The reliance on software suppliers was noted.
• Respondents supported the view that the same data model principles should be used in preference to inventing a new return.
• There was support for treating all students the same way, particularly distance learning students (as offshore and UK-based distance learning students are on the same programmes)
• Concerns were raised about the legalities of collecting this data – respondents expressed the view that contracts and data sharing agreements would need to be changed and any support in this area would be welcomed.
• The impacts on partner organisations was raised – such as additional data requirements, contractual agreements, systems and processes developed to capture, validate and store data which may not be held in the format required for the HESA Student record. This additional burden will be sustained beyond implementation, with resources and associated costs required to support the process on an ongoing basis. Some concerns were raised about the impact this could have on the partnerships they have.
• Adequate notice of the requirements was requested, and for these to remain unchanged throughout the implementation period.
• Some respondents asked for a delay in the implementation, as it will take a few years to bed in the Data Futures changes, and as the first year has shown there has been capacity issues about meeting targets for new platforms and rule definition confirmations during the implementation.

Of the respondents who neither agreed or disagreed with the proposals, comments made were:

• A third of respondents said there was little impact or this proposal wasn’t applicable to them. Some reported that their partnerships are already all reported in the Student record or ILR.
• Some queries about what the term partnerships would be covering and definitions or examples were requested.
• Many respondents were concerned about the burden of setting up record and the process changes involved (including contract negotiation), and reliance on software suppliers making the change in time was mentioned. The amount of data currently held for these students, would need to be increased in order to submit a full return. Validating this data will add extra additional burden.
• One provider noted that this work might simplify their process for new partnerships.
• Some data protection concerns were raised for students that have not been registered at the provider, additional burden to ensure that those students are presented with the relevant privacy notices.
• Suggestions were raised about the changes being identified in a timely manner and that introducing these changes for 2025/26 would be too soon, given the data futures development this year.

There was strong support among the sector body respondents for expanding the coverage of the Student record. This would minimise data burden on providers and fill current reporting gaps in the data, giving us greater insight into the shape and size of the sector. Some caution was raised about the burden this could place on smaller providers or those not currently regulated and support and training was requested from Jisc, even to those organisations without a direct reporting relationship. It should be clear how this data will be used and when it will be collected.

To meet the requirements of the OfS and HEFCW in relation to TNE students, as set out in the background section of the consultation, this proposal was to expand the coverage of the Student record to include all students studying through TNE arrangements, and to cease collection of the Aggregate Offshore record. The proposal was for the submission of a reduced data set in relation to TNE students.

55% of respondents agreed with the proposal to collect data on TNE students in the Student record. 22% disagreed, and 23% neither agreed nor disagreed. 42% of respondents scored the set-up burden of returning data on TNE students in the Student record in the “4-7” category and 50% of respondents scored the run burden in the “4-7” category. Broadly speaking, it was accepted that the proposals were less burdensome in relation to students on UK-based partnerships than they were for transnational education students.

Some points were made in support of the proposal, with respondents noting that extending the individualised data return to include TNE students would address some of the issues around the permeability of the return, providing a clearer and more complete picture of student activity. In particular, this would have a positive impact on the understanding of student progression and outcomes and the monitoring of TNE provision quality. Others highlighted the fact that they already collect the data, or could collect it with only a small change to processes, often because it is held in the wrong format or system. There was also consensus among respondents that collecting a reduced set of data for TNE students (compared to the full data requirements for non-TNE students) represented a welcome mitigation of the burden entailed by the requirement for individualised data.

The concerns raised by respondents were broadly similar regardless of whether they supported or opposed the proposal, or expressed no preference:

• Systems and processes:
  
  • Significant changes that would be required to student record systems and processes in order to meet the data requirements
  • Providers are dependent on software suppliers provisioning the necessary systems in good time to enable to data to be returned
• Collecting and quality assuring data:
  
  • The proposed collection of individualised data on TNE students would present a substantial burden to set up and run in general, particularly compared to the AOR
  • There would be significant burden incurred by organisations overseas in order for them to be able to return individualised student data to their partners in the UK. Particular concerns raised in this vein included complications around fitting data from other regulatory regimes and academic cultures into a UK framework, as well as difficulties around data sharing – including information security, data privacy, and the need to strike new or amended data sharing agreements
  • The burden of ensuring that data from overseas was compliant with the requirements of the data returns, including the risk that the task of quality assuring data from overseas could imperil their ability to quality assure data relating to domestic higher education provision. It was noted that the data shared by partner organisations overseas is likely to be patchy and the UK provider will have to address issues in the data without direct access to the original records
• The volume and complexity of change:
  
  • The substantial level of change around higher education data in general, including the Data Futures changes to the Student record, and that introducing more change shortly after the introduction of new reporting requirements would have a negative impact on data quality and staff welfare
  • The significant burden and challenges associated with the introduction of new requirements from the perspective of Jisc and Statutory Customers, and particularly in relation to their ability to have specifications, systems, and validation in place in good time
• The data and its uses:
  
  • The level of data required for TNE students might breach overseas regulations around data privacy, and some of the data captured may be illegal or incriminating for data subjects
  • The commercial sensitivity of data received from partner organisations overseas and the extent to which data on TNE students is published
  • How and the extent to which data on TNE student outcomes will be used for regulatory purposes

• The burden and associated costs of regulating TNE partnerships in this way may make the UK less attractive as an international partner than other countries

Various requests and suggestions were made by respondents as well:

• A delay in the introduction of the data requirements until 2026/27 in order to provide time for the Data Futures changes to bed in and lessons to be learned
• An initial pilot collection year in order to better understand the burden and adapt the requirements
• A delay in the use of the data for regulatory purposes so that its meaning and limitations are well understood
• Clarity from Jisc and Statutory Customers on the requirements well in advance of submission timelines
• The inclusion of software suppliers in discussions as early as possible in order to ensure that their products can be ready in good time
• Further consideration to whether any further fields or entities could be omitted for TNE students to reduce burden on the sector
• Support from Jisc and Statutory Customers on communicating data requirements to partners overseas in order to ensure that these are well understood by stakeholders
• Allowances around TNE data quality where there were issues obtaining data from partner organisations overseas
• Additional detail on the justifications for individual data items required so that the onward use of the data is clear
• For the data to continue to be collected in an expanded aggregate record in order to minimise burden
• For the data to be collected in a separate individualised record
• For Statutory Customers to consider linking up with regulatory frameworks in the countries where TNE takes place in order to avoid potential duplication of data returns
• Collecting data on fees and funding and personal characteristics data beyond the immediate requirements of Statutory Customers in order to aid sector understanding of TNE and its impact

One organisation that uses the data and disagreed with the proposal expressed the preference that an expanded aggregate record be developed for England and Wales, noting that the current structure and principles was known and tested overseas, and that doing so would retain greater data comparability across the UK.

Other sector bodies who agreed with the proposal noted that the individualised record would enable better understanding of TNE provision and the nature of students’ relationships with providers, and allow for more comprehensive analysis and use of the data. This in turn will better enable the sector to champion the quality of TNE provision overseas, and remove divides in perception between provision delivered domestically and overseas. Attention was also drawn to the fact that the burden of collecting and quality assuring the data may place significant burden on providers with certain types and volumes of TNE provision, while noting that much of the required data was either already held or proportionate.

This section invited feedback from respondents on the different types of transnational education activity in the sector, and in relation to the definitions and scenarios published alongside the consultation in particular.

Respondents discussed a number of models of TNE provision that fell outside of the example scenarios in their responses, including the following:

• Franchise arrangements where the overseas partner registers the student, and validation arrangements where the UK provider registers the student
• Partially rather than fully franchised arrangements
• Distinctions between programmes that lead to multiple or combined awards
• Arrangements where multiple partner organisations or venues were involved, including multiple UK providers
• Different models of primarily distance learning provision with a local organisation, including where attendance is optional or the local organisation is not an official partner of the UK provider
• Different models of primarily distance learning provision with a small but non-zero amount of UK study
• Blended learning
• Flying faculty arrangements where provision is delivered overseas by UK provider staff
• Articulation and progression arrangements
• Twinning arrangements

Respondents also made a number of general comments about the proposed definitions for different types of TNE provision. Statements made in support included:

• Sector interest in having access to data from across the UK higher education sector in line with the proposed classification framework
• The terms would be helpful for driving the coherence of reporting on TNE arrangements within a provider
• The definitions are consistent with those used internally by respondents
• The definitions cover known examples of TNE provision
• The inclusion of the concepts of programme and provider mobility
• The distinction between different types of venues being crucial to sector and regulator understanding of how TNE provision is being delivered and awarded
• The framework represents an improvement over the TYPE definitions in the legacy AOR

The concerns raised by respondents were as follows:

• Categories of provision that were missing from the proposals
• Insufficient clarity around the thresholds at which provision could be considered in-person, blended, or distance learning
• The need for more detail on the question of when a student is considered TNE, and when not
• The terms used in the proposals not being those that providers used internally, or not as detailed as those used internally
• The terms being open to interpretation
• More clarity needed around teaching delivery
• The burden of returning the Engagement and Student course session data necessary to derive the programme type definitions
• That the partnership programme category is at risk of becoming a catch-all “other” category
• The concept of programme ownership being too broad to be meaningful
• The fact that programme ownership is not captured explicitly by the proposed data items and this is an important piece of data about TNE provision
• The proposed derivation for franchised and validated programmes ignoring the question of curriculum design
• The proposals do not include an explicit weighting of input by individual partners, limiting analysis of outcomes by the degree of involvement of the UK provider

Respondents also made additional requests in relation to the proposed definitions of TNE activity types, including:

• An indicative mapping of the type proposals to the legacy TYPE categories in the AOR
• A decision tree to assist providers in categorising their provision according to these definitions
• An additional data item to record the nature of the contractual relationship between the provider and the student
• A free text field for providers to contextualise models of provision that are difficult to categorise by these definitions
• More information on how the new definitions might affect the work of other areas of Jisc, such as access to library resources that may be available to those studying with overseas partners of UK providers

Sector bodies who responded to the consultation agreed that the proposed framework of programme and venue types were broadly representative of TNE arrangements in the sector and an improvement over the definitions in the legacy AOR. They also echoed calls from other respondents for greater clarity around definitions and curriculum design, and highlighted some of the same omissions from the illustrative scenarios provided, particularly in relation to models of blended learning, different awarding structures, and articulation arrangements.

This proposal discussed the draft individualised data model proposed for implementation from 2025/26 with respect to the expanded coverage of the Student record. The 2022/23 Student (Data Futures) data model was used as the starting point for this proposal. Unless otherwise stated, the proposals applied in respect of both partnership and TNE students. Other than the specific changes detailed in this section of the consultation, the proposal was for the specification and coding frame for each of the data items contained within the data model to remain unchanged from those currently published.

A significant number of respondents made overarching points in relation to individual areas of the proposed data model. These included calls for requirements to be finalised and announced in good time of their coming into force, often in relation to the need to prepare systems (whether internal or provided by third parties) and processes (whether in-house or concerning partner organisations overseas) in order to collect, quality assure, and submit the data. There was also demand for additional clarity and detail on the rationale for data requirements to enable them to be communicated more clearly and readily to internal and external stakeholders. Many respondents supported a suspension of major changes to the Student record until the current data model has been embedded across the sector as well.

Registration

72% of respondents agreed with the proposal to add the Registration entity to the Engagement entity and 12% disagreed. 16% neither agreed nor disagreed. 46% scored the set-up burden of meeting the data requirement in the “4-7” category, and 42% scored the run burden in the “1-3” category.

Of the respondents who agreed with the proposal, some noted that although they did not hold the data, it would be manageable to collect and return. Others agreed with the rationale for including the data within the Engagement entity. Several respondents raised concerns about the lead time for the changes, particularly where data would be required from partner organisations, stressing the burden of quality assuring the data. A number of respondents noted the burden of the system changes required, with others highlighting their dependence on software suppliers to provide the necessary functionality. A couple of respondents requested additional clarity around the definition of “registration”.

Of the respondents who disagreed, a number raised concerns about the impact of additional data requirements on smaller providers. Several other respondents highlighted their reliance on software suppliers to implement the changes.

Of the respondents who neither agreed nor disagreed, several raised concerns about the changes to systems and procedures required, noting the burden of consulting with existing partner organisations and the need for consistency of data collection at admission.

Awarding body

69% of respondents agreed with the proposal to amend the Awarding body role entity to collect the name of the awarding body and 8% disagreed. 23% neither agreed nor disagreed. 39% of respondents scored the set-up burden of meeting the data requirement in the “4-7” category and 36% scored this in the “1-3” category. 57% of respondents scored the run burden in the “1-3” category.

Of the respondents who agreed with the proposal, a reasonable number raised no concerns or noted that the data would be manageable to collect and submit. Some respondents raised concerns about the changes needed to systems and processes, requesting additional guidance on how to return dual awards. A couple of sector bodies stressed the need for consistent guidance on the collection of data on awarding body names.

Several respondents who neither agreed nor disagreed with the proposal raised concerns about their reliance on software suppliers making the changes and providers having adequate time to load their data and test the changes.

Course delivery – Course role and Venue

73% of respondents agreed with the proposal to amend the Course role and Venue entities to collect course delivery data and country data and 9% disagreed. 18% neither agreed nor disagreed. 47% of respondents scored the set-up burden of meeting the data requirement in the “4-7” category and 50% of respondents scored the run burden in the “1-3” category.

A number of those respondents who agreed with the proposal took the view that the changes would be straightforward to implement, with others noting that their limited TNE and partnership provision would keep the burden of doing so small. Some respondents acknowledged the need to collect data about the organisation delivering the provision, while others raised concerns about the burden of changes to systems and their reliance on software suppliers to make the changes. A couple of respondents asked that the data model be published well in advance of any requirements coming into effect.

Of the respondents who disagreed, several were concerned that the proposals would be significantly burdensome to implement and operate with no benefit to providers.

Some of the respondents who neither agreed nor disagreed with the proposal opined that although burdensome to set up, this requirement would be straightforward to meet on an ongoing basis.

Distance learning

69% of respondents agreed with the proposal to return location data for distance learning students outside the UK and 12% disagreed. 19% neither agreed nor disagreed. 50% of respondents scored the set-up burden of meeting the data requirement in the “4-7” category, while 43% of respondents scored the run burden in the “1-3” category and 39% scored it in the “4-7” category.

Of the respondents who agreed with the proposal, a reasonable number stated that the information was already being collected or that only a small change would be needed to meet the requirement. Other respondents raised concerns about the burden of changes to systems and processes, including the need for a long lead time to accommodate testing.

A few of the respondents who neither agreed nor disagreed noted that they already held the required data and that it would therefore be straightforward to meet the requirement.

Primarily outside the UK

82% of respondents agreed with the proposal to remove the Primarily outside the UK field (Engagement.ENGPRINONUK) and 3% disagreed. 15% neither agreed nor disagreed.

Some of the respondents who agreed with the proposal agreed with the rationale of removing the Primarily outside the UK field and general principle of removing fields that are not used, and other respondents noted that they do not return this data or have a use for it internally.

Several of the respondents who neither agreed nor disagreed highlighted the low impact of removing the data item.

No respondent made the case for retaining the Primarily outside the UK field.

Identifying TNE students

86% of respondents agreed with the proposal to add a TNE flag to the Engagement entity to identify TNE students and 9% disagreed. 4% neither agreed nor disagreed. 43% of respondents scored the set-up burden of meeting the data requirement in the “4-7” category and 39% scored this in the “1-3” category. 58% of respondents scored the run burden in the “1-3” category.

A significant number of the respondents who supported the proposal agreed that a flag to identify TNE students in the data would be a sensible approach, and many of these noted that this would help with internal reporting and validation as well. Some respondents stated that these students are easy to identify and that this solution would be straightforward to set up and run. A reasonable number of respondents raised concerns about their dependence on software suppliers to make the changes, and several about the need for system changes and a long lead-in time to allow for testing.

Student identifiers data

77% of respondents agreed with the proposal to collect student identifiers data and 5% disagreed. 16% neither agreed nor disagreed. 45% of respondents scored the set-up burden of meeting the data requirement in the “1-3” category and 43% of respondents scored the run burden in the “1-3” category.

Regarding the comments made in support of the proposal, many respondents noted that they already held the necessary data internally, while others respondents agreed that they could meet the requirement with relative ease. Several respondents suggested that the proposal would not be burdensome, provided that their software supplier could deliver a solution. Several respondents gave the view that the proposals represent a sensible approach in general.

Several respondents who raised concerns about the proposal highlighted the burden of ongoing quality assurance of the data, and others noted that the necessary changes to systems and procedures would carry significant burden. Some respondents were concerned that additional links would need to be established with partner organisations overseas in order to share the data.

A small number of respondents asked for additional clarity around the requirements for new versus continuing students, while others stressed that the requirement could be met provided a reasonable lead-in time was provided.

Several sector bodies noted that new data sharing agreements, or updates to existing ones, would be needed in some cases to accommodate the proposals.

Personal characteristics data

65% of respondents agreed with the proposal to collect personal characteristics data and 11% disagreed. 23% neither agreed nor disagreed. 34% of respondents scored the set-up burden of meeting the data requirement in the “4-7” category and 34% scored it in the “1-3” category. 46% of respondents scored the run burden in the “1-3” category.

Of the comments made in support of the proposal, a number of respondents stated that they held the data already and could meet the requirements, with other respondents agreeing that it could be met with relative ease. Some of the respondents gave the view that the subset of personal data requested for TNE students was reasonable and proportionate, noting the burden of collecting and sharing the data and the potential risks to students of collecting certain types of sensitive personal data.

A reasonable number of respondents raised concerns about the cost of changes to systems and processes, while others noted the burden of ongoing quality assurance of the data, their concerns around the data sharing arrangements with partner organisations overseas that would have to be in place, and the difficulty of transforming data received from overseas in order to meet the requirement. Several respondents suggested that only returning a subset of personal characteristics data for TNE students would present its own challenges.

Several respondents agreed that the requirement could be met provided it was finalised with a reasonable lead-in time in order for providers to prepare their systems and processes.

Most sector bodies who responded to the consultation acknowledged that although a more limited subset of personal characteristics data would limit the analysis that could take place, this was a reasonable when balanced against the burden that a wider set of data requirements would place on submitting providers.

Course and qualification data

72% of respondents agreed with the proposal to collect course and qualification data and 11% disagreed. 15% neither agreed nor disagreed. 39% of respondents scored the set-up burden of meeting the data requirement in the “4-7” category and 49% of respondents scored the run burden in the “1-3” category.

A large number of respondents made supportive comments to the effect that they were already in possession of the data and could meet the requirement, or could do so with only small changes to systems or processes, and several respondents noted that the burden score they had provided was based on the additional records that would need to be processed. Other respondents agreed that the data would be an important component of an individualised record on TNE students.

Some respondents highlighted the significant development work required to ensure that the data was properly held, processed, tested, and reported on, and that the software was in place to facilitate this. Several highlighted the general burden of provisioning the necessary data, and others noted that the burden of meeting the requirement would divert resources from other projects, including the main Student return for non-TNE students.

The sector body respondents broadly welcomed the proposals on the grounds that they would enable the sector to undertake analysis based on the subject of study of TNE students.

Engagement and Student course session data

45% of respondents agreed with the proposal to collect engagement and student course session data and 39% disagreed. 14% neither agreed nor disagreed. 45% of respondents scored the set-up burden of meeting the data requirement in the “8-10” category and 42% of respondents scored the run burden in the “4-7” category.

A reasonable number of respondents noted that they already held the data and could meet the requirement, or could do so with only small changes to systems or processes, and a few agreed that the Engagement entity would be manageable to return. Several respondents agreed that Engagement and Student course session data was important and necessary for TNE students.

A large number of respondents reflected on the challenges involved in returning Student course session data for non-TNE students in the Student record, and that doing so for TNE students would be more complex. Some respondents expressed concerns that the concepts in these entities were more difficult to apply to TNE students, and would entail additional burden in data collection and quality assurance. Others highlighted concerns that cultural differences across the globe, including in academic cycles, would result in inconsistencies in the data. A reasonable number noted in their responses that significant work would be required to develop systems and processes to meet the requirement, while some respondents were concerned that despite the significant burden of meeting the requirements, the work required would not benefit submitting providers’ own activities. Several respondents warned that they were likely to face significant issues quality assuring the data, limiting its potential for onward use, including for regulatory purposes.

A reasonable number of respondents raised concerns in relation to specific data items covered measures of FTE, dates of status changes, and the concept of session years. These were primarily flagged due to the potential for delays in receiving information from partner organisations overseas and the differences in how these aspects of student data are understood and captured across different academic cultures.

Several respondents requested additional detail on the regulatory purpose and legislative basis for the proposed data requirements, noting that they did not understand the rationale for collecting Session year data where TNE students were concerned. A couple of respondents asked that the data requirements be confirmed and communicated to the sector with as much notice as possible.

One sector body noted that Engagement and Student course session data was likely to represent the area of highest data burden for providers because the differences in overseas provision were likely to necessitate a significant amount of quality assurance of the data and consequent clarification with partner organisations overseas. Another highlighted the need for clarity around the communication of the UK regulatory requirements for the data and impact on data sharing agreements with partner organisations overseas.

Leaving data

72% of respondents agreed with the proposal to collect leaving data and 12% disagreed. 15% neither agreed nor disagreed. 36% of respondents scored the set-up burden of meeting the data requirement in the “1-3” category and 34% scored it in the “4-7” category. 41% of respondents scored the run burden in the “1-3” category and 38% scored it in the “4-7” category.

Of the comments made in support of the proposal, a significant number of respondents noted that they already held the data and could meet the requirement, or could do so with only small changes to systems or processes. Several stated that collecting awards made was a reasonable and relatively straightforward requirement to meet, and others agreed that leaving data was important to collect in principle.

Several respondents expressed concerns that partner organisations overseas may be slow to share this data with the UK provider due to their need to follow processes within their own national environment first. Others highlighted concerns that identifying reasons for engagements ending may be burdensome as some partners do not collect this information routinely, and several respondents noted that they anticipate quality assurance around these data items – and particularly dates – to be burdensome. Several respondents noted that a significant amount of development work and corresponding resource would be required to deliver the systems and processes necessary to meet the requirement, while others had more general concerns about the burden of including this data in their returns.

A handful of respondents asked that the data requirements be confirmed and communicated to the sector with as much notice as possible.

The sector body respondents welcomed the introduction of additional data to help analyse the outcomes of TNE provision, but echoed concerns raised by other respondents around the ability of providers to return this data in a timely fashion.

Additional personal characteristics data required for offshore GMC regulated students

In order to meet its regulatory requirements, the GMC proposed a requirement for additional personal characteristics data items to be collected for offshore primary medical qualifications.

One respondent agreed with the proposal to collect personal characteristics data for TNE students on primary medical qualifications overseas and one respondent disagreed. Both respondents scored the set-up burden of meeting the data requirement in the “8-10” category. One respondent scored the run burden in the “8-10” category and one respondent scored it in the “4-7” category.

No specific comments in support of the proposal or concerns were submitted by the two providers whom the proposal would directly impact.

Several sector bodies noted their concerns that certain categories of personal data may be inappropriate or impossible to collect in certain territories.

Replacing the TYPE field – proposed derivation

A number of respondents made supportive comments to the effect that the derivations covered the TNE provision they offer or that the derivations were correct in general.

Several respondents highlighted types of TNE provision that they believe are missing from the proposed derivation, including distance learning with a local teaching centre, hybrid learning arrangements, and distinctions between joint and multiple awards. Questions were also asked in relation to the definitions of franchised and validated provision, and several respondents indicated that they would prefer to return combinations of programme and venue type manually without a derivation.

One sector body noted that definitions of franchised and validation provision differ across the sector and proposed the inclusion of an additional data item to capture responsibility for the design of the academic programme or curriculum.

Replacing the TYPE field – derivation versus submission

The most popular option for replacing the TYPE field was to solely rely on the proposed derivation of programme types and omit data on venue types (41%), though a reasonable number of respondents wished to see some form of mandated venue type data (32%):

• 41% of respondents expressed a preference for data on programme types to be derived and no data on venue types to be collected
• 18% preferred to mandate the submission of data on programme and venue type without the derivation
• 14% preferred to derive data on programme type and mandate the return of data on venue type
• 11% wished to see some combination of optional data on programme and venue types alongside the derivation
• 14% of respondents expressed no preference

50% of respondents scored the set-up burden of submitting data on programme and venue types in the “4-7” category and 46% of respondents scored the run burden in the “1-3” category.

Of those respondents who opted for the derivation of programme type data and no data on venue types, many noted in general terms that this was the least burdensome option for providers. Others suggested that the derivation would meet the regulatory requirements, and a number of respondents wished to discourage a requirement for any further data items due to the burden of the other regulatory requirements in the proposals. Several respondents stated that use of the derivation alone would ensure data consistency.

A number of respondents in favour of mandating data on programme types and venue types expressed the view that this was necessary for fully comparable and transparent data across the sector, and several suggested that data on both programme and venue type was essential to provide a complete picture of TNE and understand the outcomes associated with different types of provision. Most sector bodies made the case that it is necessary to mandate data on programme and venue types in order to understand TNE provision and ensure that comparisons could be made across the UK, and one of these highlighted the value of data on different types of venue for understanding the activities of UK providers around the world. Several sector body respondents noted the limitations of optional data submissions due to the incomplete nature of the resulting data.

Some of the respondents who preferred to derive programme type data and mandate data on venue types argued that this would strike the best balance between minimising burden and ensuring that data is useful and comparable across the UK, and others suggested that this approach would provide the greatest clarity about TNE provision. Several of these respondents noted in general terms that data on venue types would be useful.

Among the respondents who preferred some combination of optional data submissions, several noted the low burden of optional data submissions, while others suggested that the optional submission of programme type could be used where submitting providers disagreed with the derivation.

A handful of respondents who did not select a preference noted that they would be able to meet the requirements provided that they were clear, or that they had a limited stake in the decision due to their limited TNE provision.

Replacing the TYPE field – further feedback on collecting programme and venue type data

Several of the comments made in support of the proposal noted that the data would have a low ongoing burden once the systems and processes to allow its submission were in place.

Some respondents highlighted their concerns regarding the general burden around provisioning new data fields, and others suggested that there would be an ongoing burden associated with submitting the data or its ongoing quality assurance. Several reiterated the lower burden associated with the data being derived from other data fields. Some respondents noted their reliance on software suppliers to make the changes.

A couple of respondents reiterated that they had limited TNE provision and that the proposals were therefore associated with limited burden, and several suggested that submitting the additional data fields would not represent an increase in quality assurance burden beyond that already required for the AOR.

One sector body reiterated their support for mandating the return of data on programme type and venue type on the grounds that it enabled the greatest insights and comparisons around TNE data.

This section of the consultation asked respondents their views on returning the following fields on student activity, which collect data on whether:

• The student course session includes a sandwich placement (not including statutory clinical placements) (StudentCourseSession.PLACEMENT)
• The student undertook a preparatory phase in the first student course session of their course, in order to gain access to the course (StudentCourseSession.PREPFLAG)
• The student is studying abroad during the student course session (StudentCourseSession.STUDYABROAD)
• Students on courses in medicine, as well as those in dentistry or veterinary sciences have taken time out during the student course session to study for a qualification or credit that does not count towards their main qualification, with the intention to return to their main programme on completion of the second one (StudentCourseSession.INTERCALATION) 

Some respondents selected data items they considered worthwhile to collect, but the majority felt that none were worthwhile. A slightly higher number of respondents said it was feasible to return these data items, the placement and preparatory flags with the highest numbers. The burden assessments were scored fairly highly, with the majority selecting either “4-7” or “8-10”.

19% of respondents stated that none of the categories would be relevant to their provider. 30% of respondents stated that it would be burdensome to collect and return this data when the value of doing so wasn’t clear, some stating that data collected should be driven by the regulatory requirements only. Extending the collection of data to include this activity data from international partners would require significant investment, administrative burden and change in working practices for both UK providers and their international partners. Some concern was voiced about applying the same definitions for UK students to non-UK students, as different understandings of the data categories could lead to confusion.

A couple of respondents were supportive of collecting placement data, but others acknowledged that collecting this data would be difficult across the globe.

Preparatory flag was the field with the most support as respondents could see a use for the data, in understanding the wider context. Sector bodies particularly supported this data item; a large proportion of TNE delivery is aimed at students who would not meet the requirements to direct entry for an onshore UK HE course and so includes preparatory courses.

The Study abroad flag was questioned about whether or not it made any sense in terms of overseas students studying abroad, and it would probably need a new definition if it were collected.

The Intercalation flag didn’t apply to most providers, but could be collected if needed.

Although no preference for either was given on the part of the regulators, this proposal set out two options for the required timing of the expanded Student record including partnership and TNE students. It was noted that it was considered necessary to align timings for each of the proposed expansions with the submission timings for either the existing Aggregate Offshore record (once per year) or the Student record (twice per year as two discrete data collections). If the data was only collected once a year, the regulators’ view was that this would represent a separate data model for the data on partnership and TNE students, given the future move of the Student return model and HESA’s data collection systems to two discrete collections. It was also noted that trying to accommodate the two different timing requirements into a single model and collection would add complexity and burden to the data reporting process.

22% of respondents could submit partnership student data once a year, compared to 35% who could submit twice a year. 38% of respondents could submit TNE student data once a year, compared to 31% who could submit twice a year.

Several respondents who supported submitting the data once per year stated that returning TNE data in line with the current timescales would be least burdensome in general, and several others suggested that the complexity of provision around the world meant that submitting more than once a year would impact on data quality.

Various concerns were raised in relation to submitting the data once per year, with several respondents highlighting the complexity of returning records at different times of year within the same return, noting that software suppliers may find this challenging, and that having different submission timescales would undermine the case for combining the records. Some respondents suggested that work would be needed to determine the TNE and non-TNE population each time the non-TNE population was submitted anyway, and that there would therefore be limited benefit to returning the TNE students only once.

Most of the respondents who supported submitting the data twice per year agreed that it would be sensible and less burdensome to align with the timing of the Student record, and several made the point that this would allow for greater efficiency in setting up, extracting, and quality assuring the data.

Concerns were also flagged around a requirement to submit the data twice per year, as some respondents highlighted that TNE provision is administered to different timescales and may not follow the standard UK academic calendar, and that more regular data flows would require renegotiation of data sharing agreements with partner organisations overseas. Several were concerned that justification had not been provided for two submissions per year. Other respondents noted the burden of data quality checking entailed by twice-annual submissions. A reasonable number of respondents argued that submitting data on TNE students more than once a year would significantly increase burden, and some of these made the case that this would be to the extent that it would negate any benefits.

Several respondents who stated no preference as to the timing of the expanded return noted that all of their partnership data is already included in the Student return by them or their partners.

Several sector bodies expressed a preference for the data being collected twice per year in line with the non-TNE Student data, noting the utility of aligning the timescales, while others argued that in the absence of regulatory justification for twice-annual submissions, a single submission would be preferable.

A number of suggestions were made with regard to the timing of the return, including an initial transition year with one data submission, moving to two submissions the following year.

A number of respondents made comments in support of the proposals in general. The general tone of these was in support of the principle of collecting individualised data on TNE students in a combined Student record. It was also noted by some that the additional data would benefit the sector in terms of both benchmarking and regulation.

Concerns around the proposals echoed those raised elsewhere in the consultation, and fell into the following broad categories:

• Calls for additional clarity on requirements, including the data required for new versus continuing students and any allowances around respective data quality, plus clear communication of new requirements with a long lead-in time to allow providers to prepare
• The theme of a long lead-in time was echoed in a number of comments relating to ensuring that the necessary systems and validation were in place in good time for submission activity, with some respondents noting that there would be an adverse impact on burden and data quality if lessons were not learned from the Data Futures programme
• Many respondents made points relating to obtaining and transferring data from partner organisations overseas and the impact that this could have on these relationships, including the need for ample time to renegotiate agreements and the fact that those based overseas are unlikely to prioritise UK regulatory requirements over local regulatory frameworks. Several respondents noted that the burden associated with the proposals could make new partnership arrangements less attractive and imperil existing ones
• Transnational framework misalignment was another common theme, as a number of respondents highlighted that cultural and legal definitions of patterns and modes of study, including the academic year structure, would vary across different countries and be difficult to fit into a UK-centric data model
• Many respondents called for a delay to the implementation of the changes beyond 2025/26, noting that integrating TNE data as proposed would divert resources away from efforts to prepare for the first in-year Student return, and that a delay would allow for lessons to be learned from the first Student return, issues to be addressed, and submitting providers to prepare their systems and processes
• A few respondents expressed concerns about the divergence in approach between England and Wales on the one hand and Northern Ireland and Scotland on the other in principle without going into detail
• The question of burden and resourcing was raised by many respondents in this section as elsewhere in the consultation. Comments covered the challenge of managing changes to TNE data for smaller institutions, as well as for those with significant TNE provision; the challenge of an additional expansion to Student data when viewed holistically alongside other changes and the risk that diverting resources towards TNE data will place sector work to adapt to Data Futures at risk; the burden of changing processes and systems; dependence on software suppliers to make system changes; and the comparative burden of the proposals compared to the aggregate return

Many respondents made suggestions in relation to the proposals:

• Requests for more detail on the requirements and intended use of individual data items
• A general set of guidance on the data requirements that submitting providers can share with their partners overseas
• Allowances around data quality for TNE students, particularly where the timing of changes to a student’s engagement is concerned
• Additional engagement with the sector on the part of Jisc and its Statutory Customers
• A delay before individualised data on TNE students is used for regulatory purposes
• The collection of aggregate data at a more granular level
• The collection of individualised data on TNE students separate from the main Student record

Among the sector bodies, there was general support for more detailed data on transnational education and the benefits that this could bring, as well as concern that these benefits and the regulatory need for the data should be balanced against the reporting burden placed on providers. Several raised concerns about regulatory divergence across the UK and the implications that this would have, including limiting options for cross-UK analysis by the sector and the creation of an unlevel playing field in transnational education data. Sector bodies also echoed calls from other respondents for additional justification for the data requirements and context on how the data would be used for regulatory purposes, support for the sector on messaging with partner organisations overseas, and allowances around data quality where there are delays in data exchanges with partners overseas. One sector body made the case that it would be preferable for England and Wales to align with Northern Ireland and Scotland and agree an enhanced aggregate data model that could be used across the UK.

Respondents provided various pieces of feedback in relation to the consultation itself. On the positive side, a number of respondents noted that the additional guidance published, including the transnational education scenarios, had been a helpful addition to the information usually published alongside consultations. The webinars that were run alongside the consultation were also highlighted as a positive supplement to the consultation materials and process.

A number of respondents highlighted that the timing of the consultation had unhelpfully coincided with a busy period of HESA collection activity, and the Student deadlines in particular. It was also noted that the consultation subject matter would ideally have involved significant consultation with partner organisations overseas in order to provide a fully informed response, and that the timeframe allotted for responses was not sufficient to allow for this. Other respondents expressed the view that it was premature to be consulting on an expansion to the Student record before the annual return and the in-year return had been completed. Some respondents expressed concerns that combining the transnational education and partnership questions in one consultation was not sufficiently clear, and that some partner organisations might have missed the significance of the consultation and therefore their opportunity to respond.

Question 3: What is your organisation?

The Open University has responded to all 4 countries in question 3, but we will count them as an English provider for the below analysis.

The “sector group/body” responses were from: Universities UK International, The Quality Assurance Agency for Higher Education and Independent Higher Education.

The “Other organisations” responses were from: Office of the Independent Adjudicator for Higher Education, Department for Business and Trade and British Council.

UCAS sent a separate response outside of the consultation software.

Question 6: In what capacity are you responding to the survey?

Question 7: Does your organisation currently submit data to the Aggregate Offshore record?

Question 8: To what extent do you agree with the proposal to expand the coverage of the Student record to include data on partnership students? 

Question 9: Please complete your provider’s burden assessment for expanding the coverage of the Student record to include data on partnership students

Question 11: To what extent do you agree with the proposal to expand the coverage of the Student record to include data on TNE students? 

Question 12: Please complete your provider’s burden assessment for expanding the coverage of the Student record to include data on TNE students

Question 14: Do these scenarios accurately reflect TNE provision in your experience? For those completing a response on behalf of a provider, are the combinations of programme type and venue type ones that you recognise at your own provider?

Question 15: Are the registration, delivery, and awarding arrangements as expected in each case?

Question 17: To what extent would you agree that the proposed definitions provide a useful means of classifying TNE provision?  

New data items required for all students

Registration

Question 19: To what extent do you agree with the proposal to add the Registration entity to the Engagement entity?

Question 20: Please complete your provider’s burden assessment for returning data on who registers all students

Awarding body

Question 22: To what extent do you agree with the proposal to amend the AwardingBodyRole entity to collect the awarding body name?  

Question 23: Please complete your provider’s burden assessment for returning data on who awards the qualification to all students

Course delivery and venue

Question 25: To what extent do you agree with the proposal to amend the CourseRole and Venue entities to collect course delivery data and country data in particular?  

Question 26: Please complete your provider’s burden assessment for returning data for all students on who delivers the course

Distance learning

Question 28: To what extent do you agree with the proposal to amend the StudyLocation entity to collect the country of study location?  

Question 29: Please complete your provider’s burden assessment for returning location data for distance learning students outside the UK

Data items no longer required in the data model

Primarily outside the UK

Question 31: To what extent do you agree with the proposal to remove the PRINONUK field?

New data items required for TNE students

Identifying TNE students

Question 33: To what extent do you agree with the proposal to add a TNE flag to the Engagement entity to identify TNE students?

Question 34: Please complete your provider’s burden assessment for returning a TNE flag in the TNE data collection

Existing data items required for TNE students

Student identifiers data

Question 36: To what extent do you agree with the proposal to collect the proposed student identifiers data for all TNE students?

Question 37: Please complete your provider’s burden assessment for returning the proposed student identifier data items for all TNE students

Personal characteristics data

Question 39: To what extent do you agree with the proposal to collect the proposed personal characteristics data for all TNE students?

Question 40: Please complete your provider’s burden assessment for returning the proposed personal characteristics data for TNE students

Course and qualification data

Question 42: To what extent do you agree with the proposal to collect the proposed course and qualification data for all TNE students?

Question 43: Please complete your provider’s burden assessment for returning course and qualification data on TNE students

Engagement and Student course session data

Question 45: To what extent do you agree with the proposal to collect the proposed engagement and student course session data for all TNE students?

Question 46: Please complete your provider’s burden assessment for returning engagement and student course session data on TNE students

Leaving data

Question 48: To what extent do you agree with the proposal to collect the proposed leaving data for all TNE students?

Question 49: Please complete your provider’s burden assessment for returning leaving data on TNE students

Additional personal characteristics data required for offshore GMC regulated students

Question 51: To what extent do you agree with the proposal to collect the proposed personal characteristic data for TNE students on primary medical qualifications overseas?

Question 52: Please complete your provider’s burden assessment for returning personal characteristic data for TNE students on primary medical qualifications overseas

Further data items for TNE students that could be submitted on an optional basis

Replacing the TYPE field – optional

Question 55: Which of the five options details above would be your preference for identifying different types of TNE provision?  

Question 57: Please complete your provider’s burden assessment for returning data on programme and venue types for your TNE provision

Further optional data items – Activity data

Question 59: Which, if any, of these data items do you consider that it could be worthwhile to collect within the Student record for the purposes of gaining contextual information about TNE student? Please select any you would consider worthwhile to supply.

Question 60: Do you consider that it would be feasible for your provider to return data on these items for TNE provision? Please select any you would be able to supply.

Question 62: Please complete your provider’s burden assessment for returning the Placement, Preparatory, Study Abroad and Intercalation flags for TNE students

Question 64: On which frequency do you consider that it would be feasible for your provider to submit the reduced Student record return proposed for partnership students?

Question 65: On which frequency do you consider that it would be feasible for your provider to submit the full Student record return proposed for TNE students?

Question 67: Please complete your provider’s burden assessment for submitting partnership student data once a year

Question 68: Please complete your provider’s burden assessment for submitting partnership student data twice a year

Question 69: Please complete your provider’s burden assessment for submitting TNE student data once a year

Question 70: Please complete your provider’s burden assessment for submitting TNE student data twice a year