Office for Students 2025 to 2030 strategy: consultation response

We welcome the opportunity to respond to this consultation on the Office for Students’ (OfS) key strategic priorities for 2025 to 2030.

To respond to this consultation, AMOSSHE consulted with its Executive Committee who are elected representatives of our membership and current Student Services professionals.

AMOSSHE welcomes the focus in the strategy on partnership working, although we state that effective partnership working must involve clear, timely and transparent communication with established channels for feedback and reporting.

Whilst we support emphasis in the strategy on other areas that form part of the wider student interest (accommodation, mental health, harassment, sexual misconduct), we seek further clarity as to how this will be enacted including if there are future plans for regulation in those areas.

AMOSSHE recommends that the OfS 2025 to 2030 strategic plan considers how the strategic priorities will impact the workload, resourcing and wellbeing of Student Services staff.

AMOSSHE welcomes any future collaborative opportunities to support the OfS in the next stage of their strategic plan.

AMOSSHE welcomes the commitment to working in partnership with the sector. A united sector will foster a favourable student experience and improve diversity, inclusion and innovation. AMOSSHE celebrates and supports all types of collaborative approaches, including collaborating with the higher education regulator for England.

AMOSSHE has previously collaborated with the OfS to foster clarity for its members on the E6 condition to tackle harassment and sexual misconduct. The partnership provided our members with an opportunity to seek clarity on specific areas of the condition to aid in the planning of their approach. Similarly, it has provided opportunity for the OfS to gather feedback on how the condition is being approached by providers.  

AMOSSHE believes effective partnership requires clear and timely communication with established channels for feedback and reporting. Whilst we agree, in principle, with the commitment in the proposed strategy to partnership working, we suggest this needs further strengthening to improve transparency with the sector. For example, any introduction of new regulation and / or practice that impacts the sector should be made publicly accessible at one distinct time on the OfS website. Such an approach will improve the efficiency of policies and reduce workload for Student Services staff who are responsible for these at provider level.

AMOSSHE welcomes the acknowledgement that providers are expected to deliver a positive student experience whilst simultaneously facing increasing demand to provide specialist health support, particularly around supporting students’ mental health. Delivering a positive student experience for students requires adequate resourcing for the maintenance and expansion of services. This is informed by the local, regional and national contexts of providers. AMOSSHE members have told us that resourcing hasn’t aligned with the increase in demand for student mental health support, disability services and reporting of harassment and sexual misconduct. This has meant providers need to accommodate students whilst facing decreased funding of services per student.

We recognise the financial pressures the sector is currently facing with limited financial resources available for providers from the government and / or regulatory bodies. AMOSSHE appreciates the acknowledgement within the proposed strategy of how these financial pressures intersect with wider pressure on public services and where institutions feel they are being asked to fill gaps in the delivery of public services. Any new asks to providers as part of the OfS 2025 to 2030 strategic approach needs to be mindful of how these pressures manifest in the workload of Student Services staff.

Increased financial burden placed on Student Services without adequate financial and staff resourcing means reduced capacity for innovative and bold work. We’d like the strategic priorities to offer further clarification and exemplars as to what kinds of approaches the OfS considers to be innovative and bold in delivering positive student experiences.

AMOSSHE would welcome collaboration opportunities with the OfS to provide a greater understanding of the impact of the current landscape on Student Services staff.

AMOSSHE welcomes the acknowledgement that the higher education sector is diverse. Consequently, we welcome the request to understand further any unintended consequences for different types of providers from the proposed OfS 2025 to 2030 strategy.

On page 15, the proposed strategy states that “institutions should be innovative and bold in their work to deliver positive student experiences, but we acknowledge that the sector’s response to these issues needs to be considered in the context of constrained finances and wider pressures on public services”.

Financial pressures are particularly likely to impact, although not exclusively, small and specialist providers who have a smaller pool of staff and financial resource. To be innovative and bold in improving the student experience requires greater financial resourcing. This is so that providers can pilot innovative services and / or projects whilst also maintaining current provision.

Where greater financial resourcing is not possible, financial resources may need to be redirected from other projects. This should be considered by the OfS particularly where regulation is enforced to acknowledge that providers’ financial resources are finite and may need to be redistributed which could consequently impact other key areas of work.

Two specific examples of unintended consequences of the proposed strategy relate to the introduction of E6 condition, and the overall impact on staff wellbeing.

AMOSSHE members in England are already demonstrating innovation in their approach to tackling harassment and sexual misconduct in response to the incoming E6 condition of registration. Examples of innovation include ensuring a whole-institution approach and collaboration with other providers and sector organisations in order to effectively meet the condition.

AMOSSHE members have told us that meeting the incoming regulation requires financial resources which can be challenging for those already struggling financially. This particularly affects small and specialist institutions who may already be operating at financial capacity.

AMOSSHE previously supported, in principle, the introduction of a condition of registration to tackle harassment and sexual misconduct but we maintain that any regulation needs to be impactful and intuitive to ensure that it is workable for the sector.

The proposed strategy states that measuring the impact of the E6 regulation will involve collecting and publishing data on the prevalence of sexual misconduct. AMOSSHE suggests this intention should have been made clearer in the condition itself, as it’s implied in written communication of the condition that this would only be used if a provider was at risk of a breach. Similarly, in the Ipsos sexual misconduct survey guidance for providers it remains unclear as to how the data will be used for regulatory means. AMOSSHE has previously raised concerns with colleagues at the OfS regarding the lack of clarity in how the condition links to the newly introduced sexual misconduct survey. This is likely to have unintended consequences on Student Services staff who will need to find the additional resourcing required to accommodate the sexual misconduct survey and the impact this might have on their provider’s response to the condition.

An additional unintended consequence following the strategy is staff wellbeing. Asking Student Services staff to enact additional regulation and / or respond to policy recommendations in addition to an ever-expanding workload is highly likely to negatively impact staff wellbeing. This has been recently evident in the recent independent review of the Data Futures programme. The review found additional staff resources were required to enact the necessary changes for the programme. The programme also increased staff working hours and left staff unable to take holidays due to increased workload. In some cases, it contributed to staff long-term sickness absence and / or staff vacating roles.

AMOSSHE welcomes further opportunity to work with the OfS to support their understanding of how the enactment of the proposed strategic priorities can impact staff wellbeing.

AMOSSHE welcomes the commitment in the strategy proposals to working in partnership with the sector to ensure effective collaboration. We value the current opportunities we have to work with the OfS in offering our expertise and insight from our membership. Our members benefit from the further insights OfS are able to provide in key areas including, but not limited to, disability and sexual misconduct.

We’d like further clarification as to how partnership working with the sector will be practically enacted by the OfS. This includes further transparency in the channels in which the OfS will share insights and expertise whilst learning from the experiences of others in the sector.  

We’d also like further clarification and exemplars as to what work might constitute as innovative and bold in delivering positive student experiences. This would ensure that what is being asked of providers is clear and does not take institutions by surprise, as is currently articulated through one of the proposed I statements.

AMOSSHE supports the focus on areas that are not currently regulated but undoubtedly form part of the wider student interest. We welcome the areas of mental health, harassment, sexual misconduct and accommodation as topics of interest as all can have a profound impact on student outcomes and the wider student experience. We recommend that disability is also introduced into this list as a topic of interest. One in five students have a disability which highlights the potential for disability to have a profound impact on student outcomes and the wider student experience.  

The listed areas largely fall within the remit of our AMOSSHE membership. As a result, it is likely that the budgets of Student Services staff will be disproportionately affected if asked to do more in these areas without additional funding. Similarly, asking Student Services staff to enact additional regulation and / or respond to policy recommendations in addition to an ever-expanding workload is highly likely to negatively impact staff wellbeing.

We’d like further clarity as to how the OfS envisage these strategic priorities will manifest in practice for providers, particularly considering these priority areas are not currently relating to sector regulation. If these priority areas are listed in the strategy in order to enable regulation in these areas at a later date, any regulation must be impactful and intuitive to avoid any unnecessary burdens placed on university staff. This includes not replicating any existing frameworks in these areas and thus increasing Student Services staff workload.

AMOSSHE supports the proposal of a five-year strategy.

We recognise that the OfS is going through a distinct period of change including a change of government and new Chair. This is situated within the wider context of financial instability of the higher education sector. AMOSSHE believes a five-year strategy would give sufficient time for the new chair to implement a strategy of the length proposed by the OfS.

We suggest that there should be an annual review update which is published to the wider sector and considers how the strategy is meeting and responding to the demands of a constantly evolving sector landscape. Any planned regulatory change should be communicated in this annual review and demonstrate how this connects to the OfS strategic objectives, in addition to involving wider sector consultation.

AMOSSHE agrees that there should be differing ways in which the impact of delivery of strategic objectives is assessed depending on which key stakeholder is being addressed. AMOSSHE therefore believes it is appropriate that there should be differing ‘I’ statements for students, providers, taxpayers and employers.

Any ‘I’ statements targeted at students must ensure it accounts for the broad variety of different kinds of students that participate in English higher education.

A number of the I statements ask students to rank whether they feel they received what they felt was ‘promised’ to them for their studies. We argue that this phrase is inappropriate for this context as it is too broad and subjective to be used in a meaningful way. Furthermore, student responses may be more nuanced than this measure can capture. We recommend this phrase is edited accordingly to ensure clarity of meaning.

AMOSSHE agrees in principle with the I statement for students which states ‘my institution recognises my needs outside of the classroom and takes reasonable steps to ensure I benefit from higher education in the round’. We feel the phrase ‘outside of the classroom’ has the potential to alienate postgraduate researchers and / or students taking placement years who may not be studying in a classroom setting for part or all of their studies. This should be updated to be more inclusive for all student groups. Similarly, the phrase ‘benefit from higher education in the round’ is unclear in meaning and should be rephrased.

AMOSSHE agrees in principle with the I statement for institutions which states ‘I can engage constructively and transparently with the OfS and am confident I won’t be taken by surprise’. We feel this I statement is important because it identifies the need for clear and transparent communication between the regulator and providers.

Using a practical example, we’ve previously raised with the OfS our concerns around the sexual misconduct survey. AMOSSHE members have told us that the current pilot of the sexual misconduct survey was unexpected and therefore took them by surprise. AMOSSHE and other sector organisations were uninformed of plans to administer the 2025 sexual misconduct survey. Additionally, information for staff and providers was not initially publicly available. Consequently, this meant AMOSSHE was unable to support our membership in digesting the guidance until much later in the process.

Practical information regarding the dissemination of the survey has been sent to providers at different times. AMOSSHE members have told us that this information was unclear, and in some cases was only communicated to them after the survey was published to students. We’ve already welcomed opportunities to raise these issues constructively as points for learning to colleagues at the OfS to improve any future iterations of the sexual misconduct survey. To ensure that institutions are not taken by surprise, we recommend that any information that relates to activities undertaken by institutions overseen by the OfS be made publicly available, accessible and in one place. If updates need to be made to any documentation, these should be communicated to the sector and publicly updated in a timely manner.

We recommend that the new 2025 to 30 strategy first reviews current work being undertaken by the OfS. This approach will ensure strategic alignment between past and future projects and improve collaboration between the OfS and sector organisations like ourselves.

AMOSSHE broadly agrees with the strategic objectives distilled in the proposed ‘I statements’.

Currently the I statements do not recognise the involvement of mission groups, membership organisations and charities that contribute to the sector and will be impacted by the OfS 2025 to 30 strategy. Sector organisations like ours regularly collaborate with the OfS through reciprocal sharing of insight and expertise in areas that impact students. This collaboration supports our membership of Student Services staff who enact these points of learning for the benefit of their student community.

We recommend that there is an additional I statement that reflects this stakeholder group in accordance with the OfS commitment to partnership and collaboration with the wider sector.