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On Friday 15th January 2016, the Royal Society of Biology submitted its response to the BIS consultation, ‘Higher education: teaching excellence, social mobility and student choice’.

The Society supported the Government’s overarching aims to raise the status and standard of teaching, support higher education teachers and increase transparency for students, teachers and employers. However, it was felt that the Teaching Excellence Framework (TEF) in its proposed form would not achieve these objectives. Through consultation with the bioscience community, wide consensus was found for several main points.

Whilst it is important that tuition fees are allowed to rise with inflation to reduce gaps in income and cost, there was strong objection to linking increased levels of perceived ‘teaching quality’ with increased tuition fees. The sector currently operates as a ‘flat-fee market’ where the vast majority of universities charge £9,000 per year. Differential fees may result in prospective students from low income households choosing  universities with lower TEF ratings (which in theory would equate to ‘lower quality teaching’) because they are cheaper; this goes against the stated aims of the paper to widen access and improve associated social mobility.

There was concern that the administrative burden resulting from the TEF process could negatively impact on the time academics need to provide excellent teaching. The Government must be careful not to replicate the problematic bureaucracy experienced by teachers in primary and secondary education.

The proposed metrics to measure teaching quality were not viewed as strong enough, as indeed a refined definition for teaching quality does not exist. There was also potential for unintended negative consequences such as incentivising universities to ‘game’ any resulting ranking system.

The timetable for roll-out was widely seen as too short to effectively develop a fit for purpose TEF and that more time is needed to further consult with the higher education (HE) community.

If a TEF is implemented, scores must be awarded by broad discipline, not at an institutional level. Only then will it be meaningful and of any use to prospective students and employers. All data gathered in the TEF should also be transparent, publicly accessible and include a peer review element.

It is hoped that the Government will also utilise the groundwork the Society has already carried out with its Degree Accreditation, CSciTeach register and HE Bioscience Teacher of the Year Award, as well as the 2014 report, ‘Improving the status and valuation of teaching in the careers of UK academics’. These initiatives are already helping to raise the standard and value of bioscience teaching in the HE sector and may be useful for universities to include when submitting evidence.

The Royal Society of Biology looks forward to contributing to further developments of the TEF, and supporting any evaluation of future iterations.