CMA Compliance
The University is responsible for maintaining compliance with CMA guidance to HEIs on consumer protection legislation, to ensure that the OfS 'C' conditions of registration are satisfied. Please see below for information on how to ensure CMA compliance in relation to curriculum development.
See below the AY2023-24 Database and CMA Handbook. This Handbook includes the following information:
- A step-by-step instruction guide for making changes in the database
- Guidance around how to remain CMA compliant when approving course and module changes, and when adding these changes to the database
- Guidance around assessing if a change is ‘material’ or not
- A list of key contacts, outlining responsibility for decision-making and for maintaining information in the database
- A summary of timelines and processes associated with making changes to courses and modules
- A set of Frequently Asked Questions for making changes to courses and modules, whilst remaining CMA compliant
AY2023-24 Database and CMA Handbook
For any questions about CMA compliance, please contact an AQP Curriculum Manager for further guidance.
The below document provides information on CMA compliant course change and material/definitive course definitions:
CMA Compliant Course Change 2023/24 [DOCX 65.42KB]
See below the recording of the Database and CMA Training session for Professional Services staff, held on 1st July 2022:
- Transcript
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Oliver Craig:
Okay, I think if we get started and then we are recording so obviously if anyone joins and wants to catch up on the first couple of minutes they can do. So, let me start by sharing my screen. Which is that one I believe. Okay, can someone just give me a verbal: Yes, that they can see that?
Lucy May:
Yes.
Oliver Craig:
Great. Good. So, morning everyone. Thank you very much for joining today. We, as you will have seen, we circulated a new handbook last week the, CMA and the database in CMA handbook, and we thought it would be helpful to set up a short briefing session really to walk, in this case Professional Services colleagues, through some of the main areas of information in that handbook. We will be doing another session at the beginning of the academic year, around September, just before school education committees as a refresher. We'll also be holding sessions at that point for academic colleagues as well DTLs and DORA's and so on, prior to those SECs. So, obviously we're recording the session today and I'll make sure that we circulate that out to colleagues for viewing if they find that interesting, but there will be another opportunity to go through this in September. So, thank you very much for coming today. And I think most of you are aware that this is a project that's been ongoing for a while the development of this handbook. So, I'm here today. Lucy May also here from General Council, who I'm sure we'll introduce herself very shortly, and I'm pretty sure I've met everyone here, but for those I haven't, I'm Oliver Craig, the head of academic quality and Partnerships. And we've been developing this handbook over the last year or so in response to a number of recommendations as a result of the CMA project that took place last summer and one of those recommendations was to make sure that we hold focused CMA training sessions, which is obviously why we're here today, but another with the recommendations was to produce some kind of essential point of reference, a manual, a handbook that colleagues across the institution could make the most of, which is obviously what I shared with you last week. Rather than share my screen of this specific pages of the handbook, if it's helpful, I think it might be better if everyone has access to the handbook, to open it yourself and that might be slightly more interactive. I'm just going to copy the link if I can find the chat bar then I can find that I can send it over to you all and make sure that you have a copy of it. And I can't find the chat bar now because I've got so many links open.
Lucy May:
It was in your email invite to this session as well Oliver.
Oliver Craig:
Of course.
Lucy May:
So, it's in that as well if anyone wants to look at that.
Oliver Craig:
Yeah, and what we'll do throughout the meeting is we'll make a number of references to specific pages and things like that so you can flick through with us, but I think if it's okay, I'll pass over to Lucy May who's going to take the first part of the training and then I'll re-join for the second part. So, Lucy May.
Lucy May:
Yeah fine. So yeah, we're here today, thank you so much for joining us, I'm Lucy May. I'm legal counsel in the office of General Council, I've been working closely with Oliver on this and although if you could just move through the slide, that'd be great. So, what we want to talk to you about today is obviously about the CMA Hamburg, but I will talk a bit about what CMA compliance is and why it matters and that's why we have developed this handbook because it's really important that we are compliant with the CMA and also that you guys then feel that you are sufficiently informed and empowered to make sure that you can help us all in that compliance. So, first of all, really moving on from that, it's important to be aware that students themselves are very informed and have a huge awareness about their rights. So, Oliver, if you could just bring up the next slide.
(Slide reads: What is CMA Compliance?
*The Competitions and Markets Authority (CMA) Guidance published for HEI providers and students in March 2015
*“CMA Compliance” refers to this guidance and to consumer law obligations)
Oh, sorry stay on that rather than moving on it. CMA compliance - I skipped aside and my one - CMA compliance itself. We have the competition of markets Authority guidance. This was issued to all HCI's in March 2015 and if anyone ever fancies some bedtime reading, it's about 70-80 pages long. And when we talk about CMA compliance, that's an umbrella term for complying with this guidance, which has been tailored to universities and generic consumer law obligations. The main laws that we focus on are the consumer contracts regulations from 2013. These are regulations which particularly focus on information that's given to you, well consumers, but in our case to students as consumers and the accuracy of that information, so in your engine to contract replacement Reliance on that, so therefore it has to be accurate. And the other main piece of legislation we're concerned with is the consumer protection from unfair trading regulations from 2008 and they particularly put an emphasis on fairness. So, we have to make sure that we're being fair in our presentation of information, that we're not missing out anything important, that we're not giving information out in a misleading way and exaggerating and that sort of thing as well and also that any terms we have are fair. So, if we move on to the next slide, please.
(Slide reads: Why is compliance so important?
*Student experience and satisfaction – Student Retention of the Year award *Integrity: delivering what has been promised *Registration with the Office for Students
*Students complaints escalating to OIA *Claims by students for breach of contract (and damages) *Risks of investigation by CMA *Internal workload resolving failures to comply *Ultimate sanction – a breach of consumer law, leading to fines, damages, requirement to changes practices and reputational damage…)
Why compliance is so important? First of all, I'd say the top section of this slide, this is about the carrot. So, getting compliance right, it's fundamentally giving students what they're expecting to receive when they turn up at university. So, if they've seen the advertisement for the course in the prospectus and then they turn up and they get, and are delivered, what they're expecting to see is most likely to give them a satisfactory student experience and that filters into things like good NSS schools, and also we recently got the student retention of the Year award. I think that's all correlated as well. It's in line with our value of integrity. We're delivering what's promised and it also helps us with our registration with the office for students, every year we have to report to them on our compliance. We then have the stick of if we get it wrong. There are a number of things that are difficult for us. We have student complaints. They can escalate up all the way to the OIA if it's not so satisfactory. We can have claims which contract. The CMA can open up an investigation into university, and in fact, they have done that to a number of universities and then you find yourself in a position of having to create excruciating and publicized undertakings and find yourself in the media around that and it's a huge workload for everybody involved when there are breaches. And obviously the ultimate sanction is that you know, we get fined, there are damages, we get required to change practices. We just don't want to go down that route. Moving on to the next slide. I want to show you here, how where students of all this. So this is not just about the university being aware, students now join and they're forking out a huge amount of money to come in tuition fees and living allowances. And so they are, you know, expecting that they're going to get the service that they want and if they're unhappy they can Google: I'm unhappy about of course change, and this is actually the fourth thing that comes down in Google Search and it's the which guide, to students, on how to make a complaint. So it's really visible and really prominent to them. They know their rights. And they can find easy step by step guys about how to enforce them. So, this is why the handbook is so important to try and make sure we are avoiding, as much as we possibly can, pitfalls with the CMA compliance. Now, I just want to talk a little bit next about material information.
(Slide reads: Material Information
Under consumer law, students must be given accurate material course information to make an informed choice:
*Course title *Entry requirements *Length & location (s) (including work placements/study years) *Core modules and an indication of likely optional modules *The composition and delivery *Assessment methodology *Award and awarding body; any accreditations ®ulations
Material Costs information
*tuition fees *additional costs)
So, material information is all information that students have to be given about the course and I've set that out here in this slide. Now this is a brief summary of it. And as you can see, we present it at course, sorry the CMA requirements to give material information about courses, but for our prospectus and our purposes, we actually give information about modules. For which students then build up their overall picture of the course and that's quite an important distinction to be aware of because it does influence how we can make changes and why changes to modules can be more problematic from a material information point of view and I'll cover that in a bit. So, in the handbook you can find more information about this. I've set it out a bit in pages six seven and eight of the handbook, and there's also a table in there as well, where I've broken down into more detail about what that material information is. This is just a bit of a truncated summary here. So, the students get this material information from the prospectus. So, all the information that's inputted into the database about modules, about courses, that then filters through to the database and that's why we have to get that source of information right. So that has to be accurate at source in the database, so it filters through the prospectus and we're automatically meeting that requirement under the CCR's, but actually the information. Now we know in a perfect world that would never happen. But obviously errors do occur, and changes are made, and we have to address those and that's what the CMA handbook is about, it's about if you notice an error, if you notice something wrong, don't just go and change it in the database because you could be changing some material information. And as I've said here at the start, they have to have that to make their informed choice and most importantly that information is then expected to stay the same for the duration of the course. If it does not students should be giving consent to any changes to material information. So, if you go and change something in the database that could mean that students are then not given the opportunity to consent to that change if it's a material change, so that's why we've set out now in this CMA handbook a flow chart which you can find, I believe it is appendix e, flow chart e?
Oliver Craig:
Which one? The risk assessment?
Lucy May:
The one about taking notice of the breach?
Oliver Craig:
Oh, yeah, it's ‘e’, yeah.
Lucy May:
So, there's a flow chart now, which you can go straight to, so if a course convenor comes to you and says: I've realised that this is wrong, you now can know exactly where to go to in this CMA handbook and you can follow that process at flowchart ‘e’, to make sure that at that point this material information is being kept accurate. Now, if I can move on to talk a little bit about material change, which I just touched on earlier. So, as I said, that's the material information that has to be provided to students under the CCR's. And if you want to make a change to that material information, you have to get express consent from students. So, I've put here a sort of Red, Amber, Green, which is a bit of a rough guide to; Red is when you're always going to be having to get consent from students. So, if you're changing the degree title, that's consent. If you're moving core modules, that's a need to get consent. If you're changing core module into an optional module, that's consent. Then there are other ones where there's a bit more ambiguity and this is where Oliver and I have worked really hard with others as well, to try and introduce a process to help you assess whether or not a change is material and is on where students are going to have to give their consent to it. So, for example things like, module content, with drawing optional modules, making changes to assessment or weightings, changing some of the teaching that's being delivered. They are ones where there's potentially the changes can be made without having to get the express consent of students and so we've got in the handbook now, at appendix F, we have flow charts to help you work out whether or not those changes are going to need express consent. And you can follow those three step by step, we've also got an FAQ section at appendix G which sets out various different scenarios and gives you a good indication and an answer about whether or not this is a change that can go ahead and be made or whether you're going to have to get into contact with students and getting consent to it. So, we really hope that these sections in the handbook will be particularly helpful for you when you're thinking: is this material, and if so, do we have to go and get consent to this? And as I said earlier when we do present our course information, which is the information students have to get about a course, at Sussex we present it by module, core module information. So, students can click on a module, and they will find out: 'on this module, I will be having say, 13 hours of teaching contact time and then the rest will be self-study. I will be having a hundred percent exam or 50-50 exam coursework.' And of course, then that amalgamated builds up to that picture of the course, which is why if you're changing core module information you're effectively beginning to alter the overall course information, which is why change is to core modules can be material. But we are not absolutely saying 'no, you cannot make any changes,' there are parameters within that. So, say if you're adjusting, our rough rule of thumb is around 20%, if the changes are around 20% or less, they're likely to be ones where we will consider you don't need to get express consent. Say, for example, you're shifting teaching around from seminar to lecture and adjusting those percentages within an assessment... is it an assessment mode? As that the terminology for it? Oliver? Within an assessment mode?
Oliver Craig:
Yeah.
Lucy May:
If you're adjusting the weightings within that mode and shifting it around, around 20%, so say they've been moving from like 9 to 10 exam coursework to 70-30 exam coursework, that sort of thing is likely, we don't consider it to be a material risk for CMA and have to go and get consent. If on the other hand you have a core module and you're saying, I'm going to strip away entirely on examinations and make this a hundred percent coursework, students who wanted to do the course, which is heavily reliant on exam because they hate coursework, because they find it difficult structure their time or whatever, might be unhappy with that kind of change and that's where you have a high level of risk and that's when you will start going to Oliver and the APQ team, saying, what are we going to do in this scenario? So, I hope that's really helpful and will be really helpful to you and Oliver's going to run through a couple of scenarios bit later on and to get you working around that. And the last one I just wanted to talk about is barriers to effective compliance.
(Slide reads: Barriers to effective compliance?
Key issues:
*The current content management system does not support effective compliance The database feeds into the prospectus; information can be changed on the database without alerts being raised so material changes can “slip through” Database errors (manual/failure to update information etc.) feed into the prospectus.
*There is a lack of clear process and policy for schools to follow for changes
*Lack of CMA awareness and understanding
*The timeline permits changes to material information to December prior to the academic year in which the course is taught
CMA Handbook & training aims to address many of these points: timeline & database outside remit!)
So, what are the key issues and what goes wrong? And this is largely drawn out of, as Oliver said earlier, last summer, there was a larger exercise done which was in looking at CMA compliance and its effectiveness at the University and what the barriers are and the issues that came up were things like, you know, the current content management system doesn't support Compliance, as I said, near the database the prospectus information can get slipped through, then you have inadvertent changes, we can have errors as well in that, you know, just simply a manual failure to update information. Another thing that came up was the lack of clear process and policy. Then there was, it came up, a lack of CMA awareness and understanding and then also the timeline which does allow changes to be made to material information, of course up into December until prior to the academic year in which the course is called. So that means students can be applying in the September/October for a course to be taught in the following year, but those changes can be made after their point of application and potentially even after point of offer. Although we do obviously work around that to try and make sure that we're holding off on letters from going out when we know there are core changes being made. We can't address all of those issues; the system is outside of our re-mit. So, what we have tried to do with this is to say, you know, and again the timeline is out of our remit, but we can hopefully help you with CMA awareness and training and that's what today is about and with a clearer process and clearer policies, which is what the CMA handbook is around. So, on that note, I'm going to hand over to Oliver now to talk to you more about what the handbook actually does.
Oliver Craig:
That's interesting. When I click on to that page doesn't actually give the text of what the handbook does. So, what I'll do is I'll copy and paste it into the chat for everyone. Those are the bullet points that you should be able to see. So, in terms of what the handbook actually is there to do, there are a number of points to this and obviously we've talked about the CMA side, but we've also talked, and I know I've talked with a number of colleagues over the past year, that they're probably isn't any Central Database training and quite often knowledge is passed from one person to another and it might help to have some central point of reference. And so first and foremost and we've got kind of 40 pages within this handbook that is almost a step-by-step instruction guide for how to make changes in the database and you know, I've got massive thanks to my colleague Claire who's done a lot of the work in this section in terms of setting up a new module and making changes to assessment and so on and I'm not gonna walk you through every single part of that 'how to' guide today because that would probably be incredibly boring. But what I'm going to do is kind of draw attention to some of the some of the areas that might be of particular interest. There's also a lot of guidance around how to remain CMA compliant when approving course and module changes and obviously some of this is going to be more applicable to some of the academic colleagues than yourselves perhaps, but I think it's helpful to you know, raise awareness and if you're ever asked a question, you might be able to refer to some of the information found in the handbook. Obviously as Lucy May's already touched on, there's guidance around assessing if a change is material or not. There's also at one point a list of key contacts in terms of the different information that you would find within a module or a course on the database and who's kind of responsible for maintaining each area of that, which will help if you're, you know, want to direct a question to someone and don't know who to go to. And then we've got obviously the FAQs and some timelines and processes with making changes. As Lucy May's touched on, this is all designed to work within our current system. And as we all know, and you know more than anyone, working within our current system is clunky and it's slow and it's not particularly flexible. And what we've tried to do is work with what we have at the moment, the new student record system, when that comes in, hopefully, will be slightly more flexible, but for now this is focused purely on helping us to work with what we have. So, I can move off of that blank screen now and move on to the next section about updating module records.
(Slide reads: Updating Module Records:
*Trial things out with the testing database and the staging prospectus
*Good practice to ensure that modules changes from Autumn SEC pull through to the staging prospectus
*Quick checks for module checking: Is the module CONFIRMED in the database? Has the ‘Inc. in Prospectus’ box been ticked? Has the module been added to the correct courses?)
And the first point that I would point out and there may be some people in this call that are aware of the testing database and the stage and prospectus. There are some that may not be. I certainly wasn't until I'd engaged in conversation with the prospectus team. So, not only do we have a live database per se, but we do also have this testing database, which you can make changes to that doesn't impact on what we have showing on the live prospectus. And I think it's a really, really helpful tool to be able to test changes and make sure that they're pulling through correctly onto the prospectus without inadvertently, you know, having any knock-on effects. So, page 11 of the handbook is where you'll find some information about that, and you can access the training database in exactly the same way as you would with the live database. It should use the same login details that you would for the live database as well. If you do have any trouble logging in for whatever reason, I'd recommend you just speaking to ITS. They might need to set you up with something else, but it should hopefully work and as I say, it enables you to kind of test changes without impacting the live prospectus and whenever you're making significant changes to records in the database, it's often advisable to test those changes first before making the change formerly. So, you can test it in the training database and assuming it works as hoped, you can then log out, log back into the live database, and then make the change again and then that should pull through to the to the live prospectus. It can sometimes take 24 hours for any change you make in the live database to pull through to the live prospectus. So, whenever you're making changes, please just, you know, give it 24 hours and be patient to check that it has pulled through correctly. So, in terms of process obviously, as you all know the Autumn school education committee is typically the busiest when it comes to curriculum changes. And when changes are approved by that school education Committee, of course, you'll make amends to the respective records in the database. We recommend that if possible after all of those changes have been inputted into the database, you undertake a more kind of wider spot check audit to check that the kind of modular information you have in the database is correct on the prospectus, and the reason I say that is because we trialled this last year and I know I worked with a lot of you on doing this, in terms of making sure that what is in the Database is what is showing on the prospectus. And that means that when the modules for the following year are push live in January by the prospectus team, and we can be more confident than maybe we have been in the past that the information showing is correct. And we trialled that last year and I know it's certainly made a big difference in terms of the number of errors that might have been spotted in the kind of intervening period between January and now has been much smaller this year than it has in previous years. So I think some of the changes that we're starting to make are hopefully helping. But, you know closer to the time obviously I'm very happy to talk that through with colleagues. When you are updating database as well, I just wanted to highlight a few of the quick checks that you can make and most of you will be aware of these but it's amazing how many, if you feel like you've spotted an error on the prospectus, something's not showing, there are kind of three quick checks that seem to cut out so many of those. The first is just to check that the module is confirmed in the database and the including prospectus box has been ticked in the module record and that the module has been correctly added to the right courses. So, the right occurrences of the courses as well. If obviously you go through those quick checks and you still can't find what the problem was then absolutely, I would recommend that you and get in touch with us and we can we can work with you to try and find out what the problem might be. Appendix D is the one that has the kind of responsibility for who maintains which areas of the database. So, some areas, it might be my team in AQP that would be able to help you with that, for some times, in terms of I think it's module descriptions, and it's the DCM team the Digital and Created Media team that actually make that change, so it might be sometimes better to contact them. But I've highlighted that in Appendix D. So, I mean Lucy May has already touched on this but, one of the takeaways that we realized in the past couple of years, is that we as an institution have been really, really risk-averse when it comes to potential see CMA impact of the curriculum change. We don't want to be the kind of arbiters of saying, you cannot do this and you cannot do that, but actually we want to be able to base this on a risk assessment and say, okay there are some changes that you can make and that's why we've got quite a detailed flowchart, which you might have seen, that takes into account so many different variables when it comes to assessing a CMA change. And I'll get on to some of those more specifically later on but I think, I want to take this opportunity to say that what we have now with this handbook should be your point of reference for assessing CMA impact. What you might have considered in the past, I would from now on use what we have in this handbook, because we've kind of worked together to make sure that this is up to date and that we can all refer to this and be consistent across the institution. So... In fact, actually, I'll stay here for now.
(Slide reads: Workflow for tackling a CMA breach:
*If you spot an error in the database or on the prospectus…
Firstly, contact AQP to ecplore how the error has come about or whether it’s part of ta wider problem AQP will liase with other colleagues to identify if any mitigation is required, and then the change can be made
*Schools should inform current students of the error and, if material, obtain consent.)
So, in terms of tackling a CMA breach Appendix E of the handbook will kind of highlight the various actions that might need to take place if there's a this potential CMA issue, and they usually come around as one of two reasons: the first one being if someone spots an error in the prospectus, which is probably the most common; and the second might be a late kind of choice change of content. So, you know, approval of a change to material information outside of the recommended timeline. Now, the latter part will cover with details and so on another time, so we'll focus on spotting an error in the database, and as you can see in Appendix E, that gives you a timeline of how to work through that, who to contact at what point. Lucy May's already said: 'as a first port of call, if you do spot an error, don't just change it, because it might be, we don't know, it might be part of a wider more systemic problem.' It might not, and it might be okay. But don't just change it because it may be that an applicant has been looking at the website and then you've changed something and that can lead to knock on impact. So as a first port of call, it's probably best to contact myself and my team in AQP, just to try and work together to try and find out whether it is part of a wider problem or just an isolated incident. Lucy May were you wanting to come in there.
Lucy May:
I was actually because I think that's a really good point you just made there Oliver. So, I was looking at quite a lot through the compliance lens and it's not making material change inadvertently, but I think two or so years ago, I think some of you here might have the joy of remembering the contact hours that came up and that initially came to our attention that someone said, I've noticed the contact hours on my course are wrong, and actually what it turned out to be was across the university that when we sort of adjusted our semesters, I think we're trying from a 12 week to an 11 week, and that haven't been reflected in updated contact hours, so across the University, across all the courses we were out and sometimes we were out by a significant margin, it led to a huge amount of work. So actually, it is worth flagging those errors up to AQP because it might unearth something more significant across the institution. So that's a really good point then Oliver.
Oliver Craig:
Thank you. And so, obviously as you will have all been aware, I'm sure most of you have been involved in an error occurring at some point, some impact just applicants, others obviously may impact existing students, current students as well, and one of the important points that we've noted in the handbook, which may be new for some of you, is that, where express consent is is required to make a change for current students, we are asking schools to determine what that level is going to be in terms of asking for consent. So ideally, obviously, a hundred percent of students would agree to a change, we understand that it may not always be possible to get in touch with 100% of students. They may not always be responsive, particularly if that takes place over the summer or the school holidays or something like that. So, we would ask schools to determine their own level of what they consider on the balance of risk is to be you know, if at least 50 or at least 70% of students affected have agreed to this change and we've made sure that we have contacted the rest of them and given them every opportunity to respond, then we feel like we have done everything we can and therefore we are going to make that change. And so that's an important point and that's on page 45 at the handbook. Just if you want to read a little bit more about that. Obviously, it's very rare that students do dissent to a change, but it can happen. So obviously, as I'm sure you're all aware, if you don't get that required level of consent from the student body, you may need to still run what they were expecting to run and obviously what we were originally advertising. So, it's just making sure that everyone is aware of that. So, I move on now to Appendix F, which is obviously a huge flow chart and probably a little bit intimidating on first look.
(Slide reads: Appendix F: Flowchart
*The flowchart assesses what the change is e.g. to core modules, option modules or definitive elements of modules, and provides a tailored response *Single changes to core modules are permitted in circumstances where the change is to under 20% of the module * Change to a course’s module structure are permitted where the change is to under 20% of the option modules on the course *Wherever there is uncertainty or ambiguity, please contact the AQP team for advice.)
Some of you may be aware of the old risk assessment tool, which was around probably produced five or six years ago, we realized quite quickly that it wasn't necessarily fit for purpose because there are so many variables that may determine whether something is a CMA issue or not. So, we've kind of removed the binary scoring element of what was in that and tried to guide colleagues through the thought process that you should be taking, and you know, your academic colleagues as well should be taking, when considering making a curriculum change and what potential impact that might have on students. So, there are a number of obviously factors that would need to be taken into consideration. The first one I want to draw your attention to is whether the change is to core modules are not. Core modules obviously are their own thing entirely and in some circumstances a change involving a core module can be made without it being a material change. So, we've taken the core module section out of the main flow chart and it's like Appendix FB essentially. So, if you're making a change to an individual, like Lucy May said earlier, if you're changing the weighting from like 90/10 to 80/20 or something of the existing assessments on a core module, it's very minor change. And even though it is a core module we feel that the risk of that is very low and that therefore school should be enabled to make that change and shouldn't be restricted. If that change is wider, obviously, that's when we might run a risk of CMA non-compliance and the flow charts kind of designed to try and guide you through that process. We've identified that 20% figure, that you'll see quite a lot throughout that risk assessment tool, as being that point that kind of pushes something into relatively minimal concern to something that might be of concern. So, if you're changing, you know, 20% of the teaching methods on a core module, for example, that might be when your advised to contact AQP for advice, but if it's lower than that maybe less so. Things are a bit more nuanced when it comes to option modules, because if you're just adding option modules to a course, this is pretty low risk and therefore can be approved. But if you're withdrawing modules, if you're replacing option modules, then, you know, there are so many other factors to take into consideration such as what percentage of those modules are changing? Is the general content remaining the same? Or is it changing? If the course is at PGT level, are you removing any of those specialisms that might have been important, you know, that some students might have really wanted to take the course for? As you can see there are so many things to take into consideration. It's not an exact science. But what we tried to do is guide you through that process to give you the opportunity to come to that decision yourself. But where it is slightly more nuanced, that's where you might require support and discussion with a colleague in ATP for example. But we want to be able to encourage course innovation and changes without purely saying flat out, 'No, you cannot do this. No, you cannot do that.' Actually, there are some circumstances where change is possible and, in many cases, encouraged. So, you know, there are a number of things within that flow chart, and we'll come on to those in a little bit, but I think generally, I just want to check is TAP considered an exam? I will double check that. I haven't got the specific page up right now. Where is it?
“The current slide outlines the decision-making process that colleagues should use when assessing the potential CMA impact of a curriculum change. The flowchart asks colleagues to consider the type and extent of the curriculum change, in order to identify the most appropriate course of action.”
So, TAP is not in there and that's a very good point, thank you Kelly, I'll make sure that's added but yes, that should be an exam. So, that will take you through a probably a Whistle Stop tour of the...why's it done that again? How strange? Okay, so those FAQs, that's not helpful. So, I'm going to use the chat bar again. So, I'm just going to refer to that so it's not a blank screen. So, Appendix G, you'll have loads of FAQs in there and Lucy May's already explained that these are essentially to provide a bit of context and a bit of real-life example to a lot of the information that you'll find in the flow chart. There are plenty of examples in there. It's going to be a live document really that we can keep adding to and based on some of the experiences that we have over the next year, because you know, there are a number of examples in there, but I can guarantee it's not exhaustive at this stage and we want to just give colleagues in schools the opportunity to you know, in terms of consistency across the board, what have... what conclusion has been taken in result of, in response to a similar issue in the past, for example. So, I don't know why I can't show those questions up on the board, which is the same. So, in that case, I'm actually going to stop sharing the screen for now, so I can see everyone again because that's much easier for me. Now in the event invitation obviously I sent to you before, I just gave a few examples of indicative questions of things that might come up in your school. And if you've had the opportunity to reflect on what the answer, what the response to those might be, obviously that's great. What I'll do is just give everyone a minute or so just to reflect on those. I'll put them in the chat bar. I realize I've talked quite extensively for 20 minutes. So, I'll just give everyone a break for a couple of seconds. And the questions that I put, that you can use the flowchart to try and work out the answer to, the first one is there, the second one is there, and then the third one is there. So, I'll be quiet just for a minute or two. I'll let you have a little think and a glass of water or whatever and then we can come back together and discuss those three questions there and then we'll have plenty of time for any questions that you might have as well. Okay. So, it's the first question which actually was a two-part question that I popped in the chat, was about removing and adding option modules. So, the first part of that question, what would be the correct course of action if a convener wanted to remove three option modules from a course that has a total of six option modules. Does anyone want to hazard a guess at what the correct course of action would be in that case?
Kelly Wing:
Um, yes. Um, for the first part they'd have to approach AQP. Do you want me to answer the second one as well or do you want someone else to do it?
Oliver Craig:
Why not.
Kelly Wing:
Okay, for the second one, it'd be fine to do it because it's a smaller number.
Oliver Craig:
Exactly, yes. So, three of twenty is 15%, so that's under that kind of nominal figure of 20%. In which case on the balance of risk, we assess that that is likely to be okay and therefore that we would be happy for that change to go ahead. So that's exactly right. Thanks Kelly. Lucy May?
Lucy May:
Yeah, I was just hoping that everyone had found flow chart FA for looking through that because that's exactly the answer you would have got to, you can literally follow it down, you know, what's the change? Is it to core modules? No. Is it an optional model? Are you adding? Are you taking away? All of that would have taken you to that answer as you follow it on a step-by-step basis. I just really want to highlight that flow chart FA would have got you to exactly that result.
Oliver Craig:
Thanks, Lucy May. So, this second question, it's like a really fun quiz this, what is the correct course of action, if a convener wants to change an assessment on a core module from an MCQ to an essay? Anyone like to suggest what the flowchart would give you in response to that one?
Micah Hookham-Simms:
To contact AQP because, because they're in two separate sections of the table.
Oliver Craig:
Exactly right, yeah. Thanks Micah. And yeah, so that's the kind of point I wanted to highlight is actually, obviously aside from the TAP point that we covered earlier, if that change is within mode, if it was changing from an essay to report for example, we'd consider that the risk of that change would be very marginal and that even though it is to a core module, in most cases that change could go ahead, however because this is a change from two different modes, from one mode to another, the risk is higher and that's where we would advise that you contact us for advice and we'd need to learn the context about why that was coming about. Usually, with changes like this, it's never a case of we are against the change in principle, but it might be, can it be delayed for a year perhaps? To make sure that future applicants can see on the prospectus and have that as part of their application cycle and things like that. Now, obviously course conveners might have a number of reasons for why they want to make that change, but this is just to give you a point of reference that you can refer to and can evidence if they just want to ask you a question for example, but you know my team in AQP, and for reference AQP, if you haven't seen actually, is the new acronym of what was ADQE. It comes into effect officially from the first of August, but that's why you'll see that everywhere in the handbook, but I'll be sending out for kind of communication about that when that comes into effect. So yes, that's the second point. And then the first the third question: if a convener is proposing changing the assessment on an option module from 100% essay to 50% essay and 50% report, what would be the correct course of action in that case?
Micah Hookham-Simms:
Thought I'd give someone else a chance, but I haven't found in the table, but I'm assuming because that's within the table, that would be okay? Is it the same for an option or...?
Oliver Craig:
Yes, you're following the right line. So, if you have the flow chart FA up, you're changing the definitive elements of option modules, is it a single change or no it's not because there are multiple changes? Are you making changes to multiple elements of one option module? Which is what is happening in this case because you're changing the weighting, but you're also changing the types of assessment, but as it's only to one option module, we feel that that's not changing the full look and feel of the course, it's not changing the material information of the overall course, and therefore we think it's a low-risk change. Even though it is kind of multiple changes within one.
Micah Hookham-Simms:
Sure. Thank you for talking the flowchart through, it helps to sort of look at it and talk about it, in one.
Oliver Craig:
That's fine. Great. So, look, that was just a few examples to try and help you kind of understand how we're looking at them. Oh, there's someone in the waiting room looking at them. So, I'm fully aware that myself and Lucy May have kind of talked to you for 45 minutes and it's probably slightly overwhelming, but I'm now happy to kind of open the floor to you guys. If you have any questions about anything that either we've said today, any of the content in the handbook or generally that you want to ask, very happy to answer any of those questions. So, if you just want to raise your virtual hand? Then that way I can keep track. Thank you. Does that mean that everything's absolutely perfect? Look so, I think what will...oh Tony, go ahead.
Tony:
Sorry. As there's no questions, I just wanted to say the flowchart particularly, but the whole handbook is fantastic. It's really, it's a really useful tool. I think we're all gonna really appreciate and what I'm really looking forward to being able to use this for is, we have a particular issue in our school where regardless of the guidance we give in the boards of study, the individual schools or departments will approve changes that should only really be approved in November. Often because they just don't really understand the reason why, or the issue with compliance even you know, based on what we're trying to explain. So I think those flow charts they really do lay it out so very clearly that I think we can take those with us to the boards of study as a really helpful visual prompt as to why we may be saying: 'no, you shouldn't be approving this change,' and you mentioned giving training to academics, I think that's gonna be really useful for our side as well because we just end up having quite protracted conversations that eventually end with not being able to approve the changes anyway, and then there's frustration on the academic side because they feel like we're, as she said at the beginning we're just kind of you know, they sometimes feel our job is here to say no to them...
Oliver Craig:
I know.
Tony:
...to make changes when that's absolutely not the case, but.
Oliver Craig:
Absolutely, I mean that's really helpful feedback. Thank you, Tony. I appreciate that. I think that's one of the things that I'm incredibly conscious of is for you guys in schools. You can, as the Professional Services in schools, you can often be seen by academics as 'The Gatekeepers' to letting them, do anything. Well actually, if you've got some kind of formal written down evidence to be able to support whatever advice you can give, then obviously we want to be able to provide that. If you feel like they're you know, you need to kind of contact any of my team for further advice or for further support, then we're absolutely there to support you in doing that. But if you've got something as your first point of call to refer to then, you know, we want you to be able to use this. So that's positive to hear. I can see Lucy May unmuted as well. So, I don't know.
Lucy May:
Yeah, I mean, it's nice to hear Tony and I think a really key objective behind this, it's been two-fold, it's been helping have a process in place to support compliers and help make sure that there's clear guidance on how to use the system, the database as best we can within the limitations that we've got there. And the other one is really to help empower, it’s a cheesy word, but it really is true, academics and you guys to help make those decisions. It's not like, as we were saying, the risk assessment tool that we have before was very blunt or not fit for purpose, it's like we're starting from scratch with this. This is now effectively as it were, our source of truth on CMA compliances. The go-to is the handbook and particularly in it, the go to are those flow charts. And you'll also see, I don't if you had much for chance to look at it, but we have at points put the decision making on to a DTL. So, for example, you're looking at multiple option changes, we are kind of saying: right, in your judgment are you feeling that this is going to materially alter it or not. So, we are giving them some discretion here as well within the overall arching requirement to be compliant. So, I just wanted to make that point as well.
Oliver Craig:
Anyone else?
Shaun:
Actually, could I break in? Um, I mean the handbook looks fantastic, I had a quick skim through it. There are things which I don't do because I had no idea I was supposed to do them, because as you said, there's no real explanation on how these things works, you know, you just pick things up. That's completely, that's very very useful. Um what I, I know Oliver in our school, everything happens so, you know so late and it's almost that the changes are unavoidable, you know, because of staff absences or staff leaving and the ability to deliver a course, you know, it's actually impossible for us to do it because the staff have left and now the expertise has gone and this happens so late in the day that, and then you know, you try to explain this kind of stuff. But, oh, no, no, it all goes up to the head of school and things. And it's, it is quite frustrating, you know. It's like, look, there's the CMA stuff and then there's actually the real world, actually what happens in the scores and...you know...
Oliver Craig: Yeah, sorry, I understand that Shaun. I think, what we will have here will cover 90% of the kind of issues and things that occur, there are also things that are completely unavoidable such as you know, when we've had number of Staff leave from voluntary Severance or things like that and we've had to like to make last-minute changes. They are exceptional situations that sometimes require different approaches, but obviously, what we have and with the flowchart and so on, is designed to encourage, because ultimately the majority of changes for the following Academic Year should be made by in that kind of October SEC and if anything is kind of trying to be forced through later on well in that case, I'd recommend, as you have done absolutely fine in the past, is come to me and my team. And if we have to have a discussion about whether that is something that can or cannot go ahead for whatever reason then we'll have that discussion. But what this will do is cover off those kind of general curriculum developments that are, you know, constantly happening from year to year. Lucy May?
Lucy May:
Yeah, Shaun, I completely hear you, and yeah we recognize that this is something that does crop up a lot. One thing that we have brought out in the handbook, and it's in the general preamble around CMA compliance is, and we will be stressing this again at the training to the academics and the heads of schools and DTLs in September, is trying to plan courses as much as possible so that you don't box yourself into corners. Particularly around staff. So, you know making sure that core modules are ones that can be delivered by multiple staff members, so you're not then suddenly finding yourself running around going: Oh my goodness so and so's left and we've got a hundred students on this undergraduate core in year one, and we've got no one to teach it. So, it's trying to give yourself that freedom and flexibility to cope with changes. It's also doing some things like keeping core module titles broad. So that you're not then, if you do have to have an academic change, that the content has been kept as broad as you can in the prospectus description. That the title is broad. So, it's not too narrow, and I've used some examples in there. So, if you take like a really silly example, but you know, you're not having a core module which is like 'The Life Studies of Irawadi Dolphins in the Mekong Delta' as a core, you know, not being so narrow about having it in like, I dunno, like 'Marine Mammals' as a core module would be far broader so that you've got different people that can pick that up. And that's a message we will be giving again, it's been given before, but we will be repeating it and you know, you guys can help repeat on that as well if you're asked for guidance on course structure.
Shaun:
Okay, thank you.
Oliver Craig:
Laura, did you want to ask a question?
Laura Owen:
I did. Yes. Sorry. My camera can't, well my laptop, can't handle doing one or many people on the screen...
Oliver Craig:
That's fine.
Laura Owen:
...sorry. Um, I just, it might be included, but I did a quick search and I wasn't sure but, if we have periods of industrial action, I'm guessing if we're making big changes to, if we're zero weighting an assessment or something like that, do we have to go through the same process, if it's for the current year of study or is that something else? Is it covered under different regs for industrial action?
Lucy May:
We haven't covered it in the CMA handbook. Because this is really looking around sort of new structural changes or database areas, that kind of thing. Industrial action is covered under, I mean the colloquially known as the 'force majeure regulations.'
Laura:
Yeah.
Lucy May:
So, it would be covered under that. And it's also, our Ts and Cs with students do also have terms in there to students basically saying, it's out of our control, unless it's a local action, which we don't need to delve into that, but fundamentally, you know, if we're having to react to situations out of our control, we might need to make changes to courses and that could include like your assessments for example.
Laura:
Okay, so we wouldn't need to do the whole 'express consent' thing? It would come under the force majeure, right?
Lucy May:
Yeah, but you would be communicating to students around all of these.
Laura:
Yeah, of course. Thank you.
Oliver Craig:
Anyone else? Okay, in that case, if everyone's happy, I'm gonna draw this to a close. Like I say, we will kind of go over this again in September. We'll make sure we go over in great detail with the DTLs and DORAs in particular as well from their perspective. I saw that Haley asked if we could share these slides, which I'm very happy to do so, so once we've drawn this to a close obviously, and the recording has saved to the cloud, I'll make sure I send that around to everyone that wasn't able to be here and send the slides around. But in the meantime, you know, if you have any feedback or suggestions or anything like that, obviously my virtual door is always open. So I'm very, very happy to take any of those. In the meantime, have a lovely afternoon, weekend. It's almost Friday. Yes, Friday afternoon, and I'm sure I'll bump into you all again very soon. So, thank you very much and see you soon.
Shaun, Laura, Micah, Lucy collectively:
Thank you. Cheers. Bye.
See below the recording of the Database and CMA Training session for academic staff, held on 14th September 2022:
- Transcript
-
Oliver Craig:
Morning, everyone. So, there are a couple of people still joining, but I think what we'll do is we'll get started because the first couple of minutes will just be introductions anyway, and so first of all, I just want to thank all of you for your time today, for joining us. My name is Oliver Craig, I'm the head of academic quality and Partnerships. I'm joined by Lucy May Tarafder after of the legal team, we're here today to talk to you about CMA compliance, which is a thrilling topic that I'm sure everyone's really excited to be here to listen to. The main reason why this training has come around is, as many of you will be aware, CMA has become more and more important in our day-to-day work at the University recently and making sure that we CMA compliant has been incredibly important as well. As a response to some of the changing regulation over the past year a number of people, some of whom are on this call actually and who I'm very grateful to, have helped produce a CMA and database handbook, which is kind of designed to produce plenty of information to help both Professional Services staff understand the database from a CMA perspective, but also, and what this session specifically is aimed at, kind of Staff with decision making responsibilities and academic staff, and primarily this session is aimed at DTLs and DOSEs and DORAs. I know we have some marketing colleagues as well to talk about CMA from a decision-making point of view. So, I think what I'll do is start by sharing my screen so that everyone can see the wonderful presentation that we've prepared. Which is that one. If someone could just say: yes, that they can see that, that would be great. Yep. I can see a thumbs up, lovely. So, there we go. So, first of all just to start with why CMA compliance matters, obviously, we have a requirement to provide course and content information that we advertise to students. If we're not CMA compliant, and for reference the CMA is the competition and Market Authority, and if we're not CMA compliant that can obviously have many wide-ranging ramifications, anything from student complaints, fines, reputational damage, which are obviously things that we all as an institution, and as course leaders, and people that work very closely with students, we all want to avoid clearly. So, what we want to use with this training session is to give you an opportunity to refer to the handbook and to see some of the content that we've included in that. It's meant to be, essentially, an essential point of reference, that any number of colleagues can use, that should be able to kind of empower you to make some decisions. One of the things that I think can be maybe a misconception of CMA compliance is the assumption that there are so many things that we cannot do. Well actually, there are some things that maybe have not been possible in the past, that we think actually, could be possible whist remaining CMA compliant and we want to kind of identify some of those today and to give you the opportunity to understand how you can refer to those as well. Um, so I think if without further ado, I'm going to pass over to Lucy May, who can talk about the kind of legal side of CMA in a bit more detail first.
Lucy May:
Thanks Oliver, I just also wanted to stress what Oliver has said, we really want people to come away from today feeling that you have got more information and also more power to make decisions. We do know that there have been people feeling that they have been hamstrung and so, whilst compliance is obviously really important, what we're trying to do is to enable people to make decisions in a way that is compliance. So, coming back to CMA compliance and hope I'm not teaching to stuck eggs, but I know some people might not be as familiar with it. So, we use it as an abbreviation for compliance with the Competition Markets Authority, it's an umbrella term, and also in particular as well, consumer law. So, it's a kind of compliance with the CMA, the Competition Markets Authority Guidance, to all higher education in providers, which they published and March 2015, if anyone ever wants any bedtime reading, it's about 80 pages long and goes into considerable depth about how universities can comply with all the consumer law obligations that we have on us. And on that, I just really want to touch as well - just trying to move to the next slide…
(The current slide reads as follows: Title: Why is compliance so important?
*Student experience and satisfaction – Student Retention of the Year award *Integrity: delivering what has been promised *Registration with the Office for students * Student complaints escalating to OIA *Claims by students for breach of contract (damages) *Risk of investigation by CMA *Internal workload reolving failures to comply *Ultimate sanction – a breach of consumer law, leading to fines, damages, requirement to change practices and reputational damage….’)
…why compliance with all these laws is so important. Oliver touched on it earlier, and obviously negatives, but I just want to first of all focus on some of the positives. If we get compliance right, we're fundamentally delivering what students are expecting to receive when they turn up. So, they've looked at the prospectus, they come to open days, they've chatted to colleagues and staff and got an impression and feel for the university and the course they'll be studying and what content is going to be on that course. So if they are then getting what they're receiving, they're likely to be happier and more satisfied, and last year the university won the time student retention of the Year award and there's going to be a myriad of factors that will have gone into that, but I would argue that CMA compliance would be one of them, because the students are turning up here not finding that actually they're getting something totally different than what was originally described to them. So, delivering for our students and making them happy as one thing, that's also in line with our value of integrity, delivering what was being promised. And obviously it's a tick box for our office for students, but it's more than that. We have to demonstrate every year that we are meeting all the sea of conditions of registration around consumer law and compliance. And then obviously we've got various bits that can go wrong, if we don't get it right. We can have student complaints, which can escalate up to the obviously independent judicator. We have had planes for breach of contract which we've had to deal with in the courts, if they're ever upheld then we can have damages against us. We've had some occasions when we've had to settle and reach a settlement agreement with a student and then we've had to make a pay-out. We have risk investigation by the CMA and that's really something we don't want because that carries with it a big reputational damage. Universities have been wrapped over their Knuckles by the CMA and then they're usually forced, if they're found by the CMA to have breached their consumer law obligations, to write an undertaking, which is then published by the CMA and made available to various news and media Outlets, who will pick up on it. So, UEA a few years ago, was found by the CMA to have reached its consumer law obligations when it made a number of optional models on a course core modules. And the CMA agreed with the complaining students that this was a breach. And they made UEA undertake not to make any optional modules core modules without obtaining express consent of students. So, this is real, it is live, it does happen to universities, and we don't want Sussex to be in the times as a result of it. I've flagged here as well internal workload, it's really important. A lot of people on this call, I'm sure, have been involved in some of the workload around CMA compliance and that can be just from simply, you know: Oh no, we've noticed an error that hasn't fed through to prospectus and rectifying that, to dealing with student complaints, all sorts of ways we can have workload on us. And so, I've put here, the ultimate sanction is, you know, if we get found to have breached consumer law, we could get fined, we could get damages from students, requirements to change practice. It's just not a route we want to go down. So that's why compliance really is important. I'm just touching here, just to reiterate a principle. I'm sure you're all aware, but students are consumers. I put there the definition and the trade that we provide to the individual of the student is our trade of higher education.
(The current slide reads: Title: Students as consumers
Students are consumers: “an individual acting for purposes wholly or mainly outside that persons trade, craft or profession.”
The University provides the “trade” of higher education: *Consumer Rights Act 2015 *Consumer Contracts (Information, Cancellation & Additional Charges) Regulations 2013 (CCRs) *Consumer Protection from Unfair Trading Regulations 2008 (CPRs).)
And these are the laws that we are adhering to. So, we've got; the consumer rights act, which is the umbrella piece of legislation, and then we've got regulations as well, and these ones that we refer to a lot and the CMA refer to in their guidance. So, we've got the consumer contracts, regulations, the CCRs, and the consumer protection from unfair trading regulations, the CPRs. If you look at the handbook, you will on occasion see reference to CCRs and CPRs, and that's what that's talking about, it is that legislation, it's compliance with that legislation that we have to do. Students are also highly aware that they are consumers and they're aware of their rights. They know that they can make complaints and I've got here on this slide: the Which Handy Guide to students on how to complain if they're not happy. So, I think when I did this Google Search, I pretended I was a student. I literally typed into my Google search bar, course change unhappy complaint, or something around that, with the term and up this flashed. I think it was about the third or fourth thing down on my search results. So, and it does literally provide a step-by-step guide about how to complain and you'll see there it even talks about complaints University, complaining up to the OIA, and you'll see one of the first things there is check your terms and conditions and obviously we do have terms and conditions with our students. So, students are very aware of the fact that they're consumers and they're very aware of the fact that they have rights and they're very easily able to obtain information on how to enforce those rights, if they feel that things are going wrong. A key thing under consumer law compliance is around material information. Now, there's all sorts of angles that could take today, but this is one I'm going to particularly focus on.
(Current slide reads: Material Information
Under consumer law, students must be given accurate material course information to make an informed choice:
*Course title *Entry requirements *Length & location (s) (including work placements/study years) *Core modules and an indication of likely optional modules *The composition and delivery *Assessment methodology *Award and awarding body; any accreditations & regulations
Material Costs Information
*Tuition fees *Additional costs)
Under consumer law students have to be given accurate transparent material course information about the courses they're thinking of studying to enable them to make an informed choice. And it's really important to highlight that the information that they're given, the material course information they're given, has to remain accurate from the point of them looking at the courses and applying through to completion of that course. So, the course information they've got here, I've listed it here, you can see it's course title: entry requirements, where they'll be studying core modules and I've highlighted in italics here: an indication of likely optional modules. And the difference between core modules and optional modules and the changes that you can make around it, we'll talk about a little bit later on. The composition and delivery of the course. So, that will be; how's it going to be taught? Is it gonna be seminars? Is it gunna be lectures? What sort of teaching staff are there gonna be? What's their likely level of experience? Assessment methodology. So how is the course going to be assessed and the awarding body? Now, I want to pick out and particularly highlight a way in which Sussex presents its course information. So, you go onto some University websites, and you look at a course, so you're looking at a BA in history for example, they might have a summary that would say: on this course 30% will be coursework and 70% will be exam. We don't present information about our assessment methodology in that way. The way we present information to students is by the module information. So, we will give them information about the modules on a course and within that they will be able to see that on that module they are going to, for example, have an assessment of 50/50. And effectively what we're saying to students is, look at our core modules and from the information you're looking at, that will enable you to build up a bigger picture about composition and delivery of the course and assessment methodology. So, that's how we present the information. And that's important for you all to know that, because I think one thing that has happened in this past is that we have had feedback from academics in particular saying: 'I can't change any element of my module because it's given to students in the prospectus, so even if I want to make a very slight adjustment, say from a 75% course examination to 80% examination, I feel unable to do that because I know that information has been published in the prospectus,' and in feeling, you know, very as I said earlier, I used that word hamstrung. One thing we very much tried to do with the handbook and also in this training today, is sort of say there is leeway, because we present course information at a module level, to make slight changes to modules, provided that overall that course information isn't being materially deviated from. So, we'll touch a bit more about that later on and in this training. When we do make changes to this material information, we have to get express consent from students. So, if we've got students already studying here and we're making material changes, we will be getting consent from in-call students. When we have applicants, we should be getting their consent if a material change is made after they have had an offer which they've accepted. And that's why sometimes we will put freezes on offer letters going out, so if we know of course change has been made and it's going to differ from what's currently in the prospectus, we will put a freeze on sending out offer letters until we can send out, with those offer letters, information about what those course changes will be, so that when an applicant accepts and offer and place at Sussex, they're doing it on an informed basis, that they know that if they've been told that they're going to be studying a core module, in 19th century literature for example, and actually we change that core module, and it's now going to be 20th century feminist literature, that they know that that's what they'll be receiving on their first year at turning up at Sussex to study an English literature BA, for example. So that's that, on material consent and when we have to gain express consent to changes to material information. A little sting in the tail is that you might be thinking: well, what if we miss something out or we're not allowed to do that either? If there is information which students will expect to receive and it's important and we don't give it to them, it's what's called a misleading omission and that's a no-no as well under the CPRs. So, for example, if a student has to complete certain modules in order to get exemption from further examinations or further study, that's the sort of thing we have to make very clear to students, if we fail to do that that can be a misleading omission. And you might also think well, why don't we just simply have in our terms and conditions a clause that says, we reserve the right to make changes to the course, well again, that's not permitted either, that would be considered as being a breach of the unfair terms regulations, so we can't just put that in there as a big organization to make changes to the courses that our students are studying. So, that's on that. I'm gonna pass over to Oliver, because he's going to talk to you, we know that although this is the military information and it has to be true and accurate for the length of the course, we know that this is the real world that you're operating in, you're dealing with constraints and there can be changes.
(Current slide reads: Course Changes
“it is important that students receive what they expected, rather than something different..any need for variation must be balanced against the overarching requirement that students should receive the educational service they expect”
But in the real world…. *Staff change *Demand alters *Timetables are troublesome *External bodies require changes *Need for pedagogic innovation
Changes are therefore sometimes necessary and must be carefully managed, depending on the stage of the student’s journey.’)
Oliver Craig:
Yeah, that's exactly right and I think obviously Lucy May has gone through the kind of very high level overview so far and we will get on to a bit more practically what that means for you in your kind of day to day and in terms of making changes at school education committee, for example, but I think it's really important to point out the text that's on this slide that, sometimes things occur that mean that we do have to make changes either to material information or changes at last minute, and they can be a result of, for example, staff change, voluntary Severance, issues with the time table, for those who have courses that are accredited by and by external bodies, obviously, they can impose changes as well that we might have to adhere to, and where that happens and we have to react one of the things that we've tried to include in the in the handbook is some instruction as to how to appropriately respond to those kind of changes and what actions need to be taken and what consent needs to be sought from existing students or applicants. One of the most important things to State, and as Lucy may have said already, is about that transparency with students and whenever we are making changes to material information, we need to make sure that we are being clear and open with those applicants or those students so that they fully understand and, where necessary, consent to those changes. So, I'm going to move on to the....
Lucy May:
…Just before you do Oliver, I'm just gonna flag to the text in green at the top, where it says: its important students receive what they expect rather than something different any need for variation must be balanced against the overarching requirements students receive the educational services they expect, that comes directly from that CMA handbook. Sorry, CMA guidance to all universities that I talked about earlier at the very outset, that is lifted from there. But I suppose it's also, that is what we're trying to achieve here in this, so, balancing those real-world scenarios against giving students what they're expecting.Oliver Craig:
So, in terms of what actually constitutes a material change, obviously, there are a whole number of different things that can, that Lucy knows already touched on, and you'll see there that we've kind of highlighted a few of the most common ones.
(The Current Slide reads what is a material change?
In red: *Nature of the award *Introduction of new compulsory modules *Removal of core modules *Changes to modules required for accreditation/recognition *Changing a core module to an option
In yellow: *Changes to assessment methodology/weightings *Changes to module content *Withdrawal of an optional module
In green: Additional new optional module)
There is a kind of standard colour code system there that broadly works, such as, for example: any changes to core modules, can often be considered as a material change. That doesn't mean that any change involving a core module is not allowed and we'll get on to that in the flowchart later. And those are the kind of bits of information that we really want to make clear in this meeting today. But you'll also notice at the bottom in green, for example, adding a new Option and module, it is a material change, but, actually, it doesn't have any impact on the choice available to students in that they will still be able to do the same course that was originally available to them, for example, just with an additional option. So, as I say, we'll move on to what that means in a more practical sense later on but that's to give you an idea of the kind of material changes that kind of occur and most of them involve changes to the kind of course structure and which modules are available, particularly those that are core modules.
(New Slide: Current slide reads: What does the Handbook do?
*A step-by-step instruction guide for making changes in the database *Guidance around how to remain CMA compliant when approving course and module changes, and when adding these changes to the database, *Guidance around assessing if a change is ‘material’ or not *A list of key contacts, outlining responsibility for decision-making and for maintaining information in the database (A summary of timelines and processes associated with making changes to course and modules *A set of Frequently Asked Questions for making changes to courses and modules, whilst remaining CMA compliant.)
So, as a result of all of this very heavy information about what we can and cannot do, we, as an institution, are trying to respond and make the decision making as simple and as straightforward as possible, particularly for you as DTLs in school education committees, but also making sure that information is available to other staff members, as I've mentioned Professional Services colleagues and DORAs and marketing managers, for example. So, the handbook is very extensive and it's about 80 pages long and you can find it on the Academic Quality and Partnerships website and there is a link in the event invitation for today if you wish to open that up and refer to it as we're speaking, but there's a full CMA compliance tab within that website. It includes a video recording of the webinar that we did for Professional Services staff. It will include the recording of this session today as well for those who are unable to attend. The handbook specifically, as you can see, encounters a number of different areas, the first one, which is probably less relevant to those in attendance today, is a step-by-step instruction guide for making changes in the database and that was something that came up as a result of the ongoing project that we had, that actually there isn't a central database user guide. So, we've developed that and kind of incorporated it into the overall CMA compliance piece of work. There is guidance about how to remain CLA compliant when both approving changes to courses and modules, but also when using the database as well and in more detail, there's guidance around assessing if it changes material or not. Obviously, the previous slide gave a general idea of that, but there's more in-depth information in the handbook. One of the things that we wanted to help colleagues with is by providing a list of key contacts, and by key contacts, that's more of the job role of the department rather than the person, but that should hopefully outline responsibility for decision making if there ever is a question that you have and you don't know who to go to, or it just gives you the opportunity to find the right person to answer a question or to make a change wherever necessary. From the CMA side of things, we've included a summary of timelines and processes associated with making changes because, depending on the nature of the change, some of those might have a longer lead time than others and by incorporating that into handbook that hopefully enables you to plan ahead. And then at the bottom, and I'll come on to this in a bit and more detail at the at the end of this session, there's an extensive frequently asked questions section, which I'm very happy to keep developing as we go on, but that frequently asked questions and section gives you plenty of real world scenarios such as, I want to get rid of this option module from a course and add a replacement option module, what is the process for doing that? And is that permitted under CMA guidelines? And as I say, we'll continue to add to that FAQs as we progress, and more scenarios occur.
(Current Slide Reads: Appendix F: Flowchart
*The flowchart assesses what the change is e.g. to core modules, option modules or definitive elements of modules, and provides a tailored response *Single changes to core modules are permitted in circumstances where the change is to under 20% of the module *Change to a course’s module structure are permitted where the change is to under 20% of the option modules on the course *Wherever there is uncertainty or ambiguity, please contact the AQP team for advise)
Lucy May:
Thanks Oliver. That last point is one that's worth stressing. The handbook is still something that is a work in progress. So, we would really welcome feedback on it. If there are scenarios that you are dealing with, that you don't feel we've covered, please do filter them back to us because it can be updated, and it will be updated. It's not going to be static on that. I did also want to pick up, before I move onto a bit more detail on appendix F, just a touch on the database and the systems and just explaining what the handbook does is it takes what we have at the moment. We are aware, as Oliver said, this has been a large project, to look into CMA compliance and what will barriers of compliance are and we are aware that the database has got some barriers to compliance, but we are not in a position to fix that. But, what we have tried to do is to give really clear guidance on how to manage the database as best as possible so that I know that the people on this call today, you're not directly involved with that, but it's just something I wanted to stress, that there is now really, really excellent guidance on how to work with the database as best as we can, with what we have there is awareness that it's less than perfect. There is awareness that it's something that does need fixing and I think there are plans to improve it and fix it, so this but this is what we've got at the moment. Where I want to focus on next to the next few minutes of this presentation is really looking at two, or one but they're actually two of them, two important appendixes, and these are appendix F and appendix B, and you might find it helpful to actually bring up the flow charts yourself and handbook if you've got it, but we will have slides in it. So, these flow charts are ones that we have put together, and you can use them in conjunction with the FAQs, to help assess the CMA impact of changes to courses and modules. And we actually have worked with people on this calling, Jessica horses worked with us on this as well, so we want to thank our colleagues who have very much given an input to these. And this is because we know, as we're talking about earlier, we know that changes can want to be made, and some of these changes may seem relatively minor and insignificant, but actually could be CMA tracks. Others, you might feel that actually that's great, I can go away and do this, and this is the process to help do that. We also set out, within these flow charts, what definitive elements to modules are as well and effectively if there's definitive elemental module changes to that are usually likely to be potentially material changes for CMA purposes as well. We have introduced a sort of rule of thumb which is allowing changes to be made to core modules, if the changes are under 20%. So if I take, as an example, assessment, if we have a core module where the assessment is currently 90% examination and 10% written coursework assessment, and the person doing that module has had feedback from students that the examination element is too high and they think: you know what next year I'd like to try introducing a larger element, I'd like up it to 20% and see how that works, that is less than that 20%. And so, we are saying, go ahead and make that, because as I explained a few slides ago, we present our course information at module level. So, if one core module is making a small change, then it's not going to affect the overall course methods of assessment. If we've got multiple modules making changes, then that can be different, but single changes to a single module, with that 20% figure, I think I want people to be going away with that in their heads, it's kind of like a rough rule of thumb and we're saying that again, as well, that if you've got optional modules and you're wanting to make changes to optional modules, which is less high risk under CMA. So, it's always core modules we look at, they're always the kind of red flags for us. But, as I said at the outset, under the material information that we have to provide students for that informed choice, we have to give an indication of likely optional modules. So again, we're sort of saying, if you're making changes to 20% of the options, then it's unlikely to really be affecting that overall indication of course of optional modules. And so, that's something to be looking to do. So, if you've got, say, 10 optional modules and you're looking to move to, but introduce or replace it with another couple, that's in your 20%, so you can feel, yeah, I can be confident in going ahead and doing that. When there is uncertainty, ambiguity, or if you just got any questions, you can just come straight to AQP. So, question from Jessica, if an assessment weighs more than 20% then it is not green in the flow chart mood change. I feel like it's still green... I'm not quite sure I'm following that, Jessica?Jessica:
I can just verbally explain right? So, if you go to, if you go to flow chart FB, and you go to: I want to make a change to core module. What's the change assessment mode? Is it still within that same table on the right? So, for example, changing a written assessment to a different written assessment? The flowchart says: yes, if it's still within like written to written and you're not doing like written to exam then yes, its low risk, but is there a weight limit? Does that 20% come into effect there as well? Because the 20% isn't in that part of the flowchart.
Lucy May:
That's a good comment Jessica. As I said, the handbook is a reading feast, we will on board your feedback and we will change that flow chart actually to make it clear actually that you could do that within that 20%, but I'm gunna actually go through in a bit more detail now. Flow chart FA and FB. But actually Jessica, that's an example where, we have developed this, as we said it's quite a few pages, and that is an error there that we will correct on that. Hopefully there won't be too many more. I've brought up here flow chart FA…
(“The current slide outlines the decision-making process that colleagues should use when assessing the potential CMA impact of a curriculum change. The flowchart asks colleagues to consider the type and extent of the curriculum change, in order to identify the most appropriate course of action.”)
…and I just wanted to say, the first one is, your kind of thinking, what change has been proposed? And as you look along it, you can see that the changes are, one of them is degree title, it's done accreditation status, course structure, for example involved in a placement, all of those are really high risk from a CMA point of view and they're the sort of thing that should never really be changed without getting students' express consent. So, it's not a maze we're referring back to Oliver and his team for advice and guidance on how to be doing that. Then we've got 'is the change involving core modules?' for which we have an entirely separate Flow Chart, which is Flow Chart FB, which we will come to next, after looking at this. And then we've got one which is the additional removal of optional modules. So, if you're kind of flowing that through it, if you're sitting there and you're thinking actually, the optional module offering we've got on this course doesn't feel quite right, actually what we want to do, we want to make some changes, or you've had staff changes. So actually, some of the optional modules that were done by a member of staff, that member of staff has now left, and so you need to make changes to introduce new modules or potentially not even replace them at all, depending on scenario, so you follow that through. First of all, just to be clear, you can add more modules. If you've got additional options you want to run, that's fine, go ahead. The next one is looking at, are you only removing options as I just said, sometimes you might find yourself in a position where you've had members of staff leave and you can no longer offer the options, and we're saying yes, you can remove them. And our rule of thumb is 20%, or less, can be removed. So, if you've got a menu option, as I said earlier, of 10 and you want to drop out maybe one of those optional modules, that's low risk, you can go ahead and make the change. If on the other hand, say you're only got five optional modules and you're wanting to withdraw two of them, that's a 40% change and that's really where you would be coming to AQP for advice. And then they will be looking, with you, at detail. It's not good when it says here 'contact AQP,' I want to stress that that does not mean there will be a 'no' response to your question, what AQP will be doing, and Oliver's team, is they will be then looking at the course in the round, thinking about, what have we told students about this course? How does it look? And do we think, based on that material course information, that we are making a change away from this where we should be getting student consent for it or not?
Oliver Craig:
And I would say, obviously, 'courses' as well. There are some options that can apply, or sit on multiple courses, and it may be one of five on one course, but one of 10 on the other and that's where we would perhaps need to assess the situation holistically to understand what the next steps might be.
Lucy May:
Yeah. Really good point, thanks for that Oliver. And then similarly you can see, sometimes you might want to swap in change modules again, we're sorting if you're swapping in and changing around 20% of those options, that feels to us like a low risk, but then if you are say, taking your own tasks of modules or the vast majority of them, and wanting to make changes, that does then start to potentially affect that indication of optional modules that students have been given and again that's coming back to Oliver and his team, who will be looking at that, holistically in the round for your course, and as Oliver made that very valid point for other courses as well. And so, I hope that helps on that element of things. And then you'll see the last one there, again, we're talking about optional modules, not core models here. Are you making a change to those definitive elements of it? And is it a single change to just one module? And we're saying that if it is a single change for just one module then, that feels to us, a low risk from a CMA point of view. If it's multiple changes to elements of an optional module, then again what we're saying is, we think that that's probably low risk, because if it doesn't affect the overall look of the course, then those changes be made. But, when it's affecting multiple options, then we're saying to the DTL we would like you to be looking at this, have a look, what are the changes that have been proposed? You know now that students are meant to be given information, that material course information and an indication of likely optional modules and how that course will be structured, for example with assessment weightings, teaching. So, you'll be looking in and round and you should be thinking, do these do these changes, are they going to definitively alter material to what I think the optional offering the students have been told about on this course. And if you think, actually no I don't think they do, I think fundamentally, yes, there are changes but there's not a definitive change in the material that alters it and students are unlikely to pick this apart and go, well actually, I feel that you really changed it, then I think, we feel that that will be no risk. But if you use a DTL are looking at this, I'm not sure if I feel comfortable, this feels to me that maybe a student is going to be receiving something significantly different in their optional module presentation and offering then they expect to receive again, that's when you're contacting AQP and checking in with Oliver and his team. So, I think what we're doing here is we're trying to, when we talk about earlier in the presentation, to make you feel empowered to make these decisions. This is it very much live in action. We're expecting people to be coming up to DTLs with queries, I want to make these changes to the options, if you're getting a single staff member come to you then you approach about a single module then you can approach, but if you're getting multiple staff members of multiple optional modules, that's when you'll be thinking, right I need to be looking at this very holistically across the optional module offering on this course.Oliver Craig:
I just noticed that Linda had her hand raised a little while ago. So, I just wanted to give her the opportunity to ask a question. Linda? Okay, we'll come back.Linda:
I have a question.Oliver Craig:
Oh, hi Linda.Linda:
Hi, sorry. I was muted so I was talking to you, but you weren't answering. Thanks so much. And it's something that worries me about all of this, and I completely get that we're bombed by CMA, and I completely get that we can't change big picture things such as proper core module or change the title on a core module and I get all of that, but I am I am worried about the: you can't change... the changing modular within things like assessments. I mean, and the reason I'm worried about it is because every year we change our assessments based on student feedback, on external examiners, we might change something from 20% to 30%, we might change from a print group presentation to a report or project and this is all the time and it's always in response to the teaching and the module and what's come through the module and the suggestion that we can't change that for me is worrying or that we have to look at it across the whole degree and then go will this affects only 20%. I mean, I don't know how other people in the room feel but for me, I find that quite disturbing that notion that suddenly it's no longer the lecturers' ability to adapt and adjust a module based on what they've experienced in the classroom, what the externals are saying, what the feedback from the students has been, and that there has to be a much longer leading. And I really don't want to appear difficult or obstructive or anything like that. But to me, that's a fundamental contradiction of the ideology of teaching in a classroom and also of the exam board process and the MAB and PAB process.Oliver Craig:
Jessica, I see you have your hand raised as well.Jessica:
Yeah. I just thought I'd chime in so then Oliver and Lucy May can see if this is helpful or not. I have the same reaction to Linda except we've had this/that issue for years. Now where technically we weren't allowed to change things until like super, super, super late. Like we'd be stuck teaching something we knew wasn't the best thing because well for CMA you have to wait till the November SEC and then it's not until the next year. So, my understanding is that this new thing does help with some of the things that we used to not be able to do right? So, it used to be that pretty much any change, it was 'like oh but it's in the prospectus, you can't change it until you get a whole new cohort of students,' and I remember trying to change electives and having details and other schools tell me, 'Oh, but surely that's only for students who are still applicants like years and years from now,' that you know, like putting things off for years. So, my understanding is that this is better because yeah, there might still be a few cases where yeah, you do have to wait over a year, but for a lot of things if we know it's better like, 'oh that essays too long or that essay should be a, I don't know, early submission, or whatever, we can do it. It's just yeah, so I think it's not quite so bad as it was, but I don't know. I don't know if that's helpful.
Linda:
I have a feeling maybe they haven't been waiting for SECs. I have a feeling we might have been doing it wrong now.Lucy May:
I think there are always going to have been different approaches within different schools and even within different departments within schools, and I think what we're trying to do is we're trying to give you the information that you need to then help you make those decisions as much as possible at school level which will be CMA compliant decisions. We can't take away that CMA's there and there is a quirk in the fact that we present material information at a module level. Now, if you had a course which is just presented, as I said, using that very simplistic example from earlier on, you can go on some websites and you'll see universities that will say on this course, you can expect on BA History to have 30% coursework and 70% exam. Then they might break it down a little bit more by a year, they sometimes might break it down a little bit more by subject, but they're given that big overall picture. We don't do that and because of that we have had some people say 'I cannot change anything for five years, I feel hamstrung and stuck, I don't feel like I can even alter a slight weighting,' and I think possibly other schools haven't even had any awareness about changing those assessment weightings, because a certain methodology is a key material information under those CMA guidelines, but if you then move too far away from it, then you are changing the information you have given students, you are fundamentally changing what you've advertised to them now. Now I'm going to draw on an example of a case that's recently happened. Now, I think some of you may well have heard of Natasha Abrahart. She was a student at Bristol University and very sadly she committed suicide. Now, I'm not gonna go into the reasons firstly, as it's complex, but her parents have sued Bristol University, at first instance the judge has actually found in their favour and one of the things that has been highlighted in the Judgment was that Natasha Eberhart has had to do, as part of her Physics degree, presentations, oral presentations, and this caused her acute distress and anxiety. And if you're a student and you're looking at a course, and maybe you know that you already really struggle, say with exams, and so for you choosing a course where there is a high level of course work or a low level of examinations, or maybe like Natasha Abrahart you have a fear of presentations and so you actively want to avoid doing courses where you might be exposed that situation. You will then be basing your decisions on that. And this is why when we are looking at talking about course information and assessment information that we don't want to be straying effectively too far away from what students have been told. So, Linda, I absolutely hear you, it's absolutely right that you can respond to students. If you're getting student feedback, which is saying, you know what, and I illustrated it earlier on, we have got you know, we feel the assessment load is too heavy, the assessment coursework is too much, you need to go and respond to that. Now we are trying to say to you, you have parameters where you can respond to that in a way which we think is CMA compliant, without going to get consent. However, if we're thinking and we're looking at it and going you know what, actually what you're saying to us, we are wanting to significantly shift it. So, if you look at the course holistically as a whole and you are saying, you know, actually looking at your different construction of different modules, we feel that overall, you're going to shift it, from say a 50/50 overall exam assessment, which is a very simple example, to 70/30. That's the significant shift in weighting. We're not going to say, you cannot do it. But we will, say you need to go out to your students, and you'll need to get their consent for that. And then, if they're happy with it, you can go ahead and make those changes, now that is a bit more of a consultative process, but it's not an absolute no. Or you might say, actually bring the changes in but let's just wait a while, like Jessica was saying that that's been done before, and then your new cohort of students they can be taught in that way.Attendee speaking:
Okay, so when we're dealing with Master students almost every year is a new cohort. So, actually we don't have quite the same constraints in some ways?Lucy May:
Yeah, with master’s students effectively, you're teaching what was advertised to them in the prospectus. And if you're making, as I said, those material changes, that's when you'd be saying to them; Hi, well, you can probably do it as an Introduction, you know, welcome to the course, we've had a review over the summer, we've listened to some student feedback we had at the end of the course last year and actually we would like to make some changes. Say you wanted to, again take that assessment as an example, on one of your modules you might have had feedback, which is like this would be a really excellent one to do purely by coursework and strip out the examination element of it, if that was a piece of feedback, and if that was something the school wanted to do, you would then effectively present a case to them and say this is what we would like to do and this is how we're going to do it. That's if it's a material change. If on the other hand, it's an adjustment and weighting within that 20%, on a single module, then you don't need to say anything at all. You just go ahead and do it. It's when we're looking at something that would materially differ from what they've been told. Oliver, have you got anything you want to add?Oliver Craig:
Not to what you've just said, I think that was a really clear explanation. I was just noticing that yeah and noted a question in the chat: can you define student consent a bit better? I'm gonna ask, with your legal hat on, that maybe you take that one?Lucy May:
Oh, student consent a bit better. Right, so there's different ways to look at it.Attendee Speaking:
Can I maybe very quickly make more specific this case so that we don't discuss in vain?
Oliver Craig:
Please, yeah.
Attendee Speaking:
So, what if I want to change a core module at some level, I send the mail to all the students that will take that module, tell them: this is the change I'm going to introduce, please let me know by these dates if you disagree with it. And if I don't receive any mail, I take that as consent. Is that consent?
Lucy May:
Yes. Yes, I think I'd say it is, what we would suggest is that ideally, yes you would consult your students first and then you would give them the information about what the change is going to be. Now ideally, you would say to them, can you email me back or confirm to me that you've understood this change and are happy with it, but you would always get students who simply do not respond. And so, for those students if they then, carry on with the course or re-register we would say, well, you know, you have the information and by your actions you have showed us that you accepted it. You would not be entitled to turn around at the end of the year and say well actually, you made this change, and I didn't ever agree to it because we told you about it, we gave you an opportunity to say, I don't agree with it or ideally to give your contentment, but you then turned up and registered and proceeded with the course anyway.Oliver Craig:
And to kind of add to that yakapo, in the handbook, and forgive me, I can't remember which section it is...
Lucy May:
Appendix i.
Oliver Craig:
Is it? Okay. There is a page that we have noted about responding to and seeking consent from students and asking schools to kind of identify what level of response or lack of response they would consider is consent or otherwise, so we have got that section written down in the handbook as well for you to refer to.Lucy May:
Because of course, you will get the situation when, we have crafted you an email that you may wish to use or adapt and feel free to change the tone of it to seat and it might be horribly dry and legal, I hope not but, you might get a student who does say: I'm really not happy with this, I really just cannot agree to this change, I've got my reasons. Then you will have to think about, I mean, you'll probably have some dialogue with that student, engage with them: what are your concerns? You might well be able to address it and persuade them. But if you've got them digging their heels in, then I suppose fundamentally, you've got options as to press ahead anyway? And then just give them their rights about what they could do, which could include re-drawing from the course for example, or you might say, you know what I've got really unhappy student here and I don't want to rock the boat, potentially their representative of others, I might just sit on this for a while and see. But in that scenario, Oliver and I, we're available for you to come to us.Oliver Craig:
Yeah, absolutely. Jessica has noted in the chat. Is there a good rule of thumb to give them for responding? Is one week too short? Couldn't find a rule in the handbook.Lucy May:
I think Jessica, I think it was in there actually, I can't remember where, but I think I said seven days, so yeah, a week. So yeah, okay. I think now if we just look at flowchart B. And down to it.
“The current slide outlines the decision-making process that colleagues should use when assessing the potential CMA impact of a curriculum change. The flowchart asks colleagues to consider the type and extent of the curriculum change, in order to identify the most appropriate course of action.”
So, this flow chart is the one where it does involve changes to core modules. Now, you know find that drum again, core modules are the ones that always raise red flags in terms of CMA and risks. So, what we have said is, if there are changes to multiple core modules being proposed come to AQP in the first instance. But if you have been asked if you can make changes to a single core module then we've got that flow chart you can follow through and say what are the changes that have been phased, it changes content? Are we looking at changes to the title? Change to assessment mode? And as you currently pointed out Jessica, we will amend that to bring in the 20% and the waiting and again teaching in contact hours. So, you'll be able to follow that through when looking at it and I was just going to give you an example here on one, that actually just came in relatively recently, it was on a change to a core module and the question was, we want to change the title from 'participatory journalism' to 'participatory media.' And that that came to me and what you'd be doing on this flow chart is saying right, any other module changes? No, it's just a single core module. I've been asking me this module change. What's it to? It's to the title of the module. And then it's for the DTL, based on academic judgment, would the title significantly differ from the description in the prospectus? Now I'm almost tempted to throw it out to you. What do you think? What would you say? Anyone got a view, if you would say, I'm okay with a change from ‘participatory journalism' to 'participatory media'? Maybe originally you would say no.Attendee speaking:
Course title or module title?Lucy May:
Sorry?Attendee speaking:
Course or module title?
Lucy May:
It's a core module title. So, it's not a course title. This flow chart is just looking at changes to core modules. They aren't mod for module changes. It's just one single core module, as part of a course.
Attendee speaking:
I would change a module title, but I wouldn't change a course title.Lucy May:
Wouldn't change a course title? Well done. Excellent. So, looking at this example, this is a core module title. Do you think you would approve that; do you think the change from 'participatory journalism' to 'participatory media' significantly differs from the description that's been given in the prospectus?Attendee speaking:
So, if it were me, and it was just that change, that change doesn't bother me that much, I'd be tempted to say look, does it really matter that much? Can we wait a year? To our staff? That change doesn't worry me, and it's just the title change. I would say, let's just run it this year. We'll change next year.Lucy May:
Well, that's exactly answer I gave. So, I have no issues with that changing, I said it is a slight change, but it doesn't significantly deviate from what's been given in the prospectus. It's probably a broader version of it, moving from Journalism to Media, but then maybe that was covered in the course content anyway, sorry the module content anyway, so yeah. And that's the sort of thing that you could do, if that came to me and we're saying, I don't think there is a need for that to come into legal, that feels like a kind of common-sense decision that you can all look at and take on a single core module. Now if the change had been from 'participatory journalism' to 'methodology and film production', that's not just a title change, that's clearly content change and its content change of a core module. So, at that point you're going, no, no, no, no, no. Because look, you know, this doesn't stack up. Of course, you can also look at what the content is. So, is the title actually potentially a more accurate mirror, even if the title does look actually maybe a bit different but does it actually maybe more mirror the content descriptions given in the prospectus. You might go, well, maybe it does differ quite significantly, but actually I think it's more accurate and maybe I feel comfortable making that change as well. That's what we're trying to do here with this flow chart. I was going back, I just want to finish finally by just mention, I want to refer back to that Natasha Abrahart case earlier and you can see that at the top there we have got those different modes of assessments. So, for example, there with Natasha Abrahart, if you and her fear and anxiety of presentations and it's been picked up in that judgment about making sure that students are aware of what they may be doing in the course, which does include things like assessment, and I think here there has been criticism of the University of Bristol for not giving this student alternative forms of assessment. And I'm not going to go into the 'whys' and 'wherefores' of what Bristol may or may not have done on that, but I think for us we just kind of really thinking of looking through that student lens of those modes of assessment, things that they've been informed that they'll be doing and being very sensitive about that. For some students, they might have really particular reasons why a mode of assessment might be particularly appealing all particularly off-putting, and that's why we are saying that with those we have to have elements of caution with them.Oliver Craig:
I'm conscious that we don't have much time left. So, I wonder whether it's actually best if we just open the floor, if there are any other questions that have occurred to any of you over last hour or so, that you wanted to raise now, then please do raise your hand. Gordon, please.Gordon speaking:
Thank you very much for the talk. I've got a particular problem, I think within the post-graduate’s medical store, and that is that courses run over five, often students register over five years. So not an MS in one year. So, what that means is that changes that occur over that five-year period may need to be, I guess from what you've said, identified and flagged up to students, even if they're not going to be taking them for a while, and I don't know quite...it's quite difficult to communicate with our students actually, many of them are clinicians who just take a break of two or three years between one module and the next. And so, getting consent from them for changes that are going to be impacting on them two or three years later is actually quite difficult.
Lucy May:
Yeah.Oliver Craig:
Yeah, I mean that's a really good point and I suppose I would refer back to one of the comments you made earlier Lucy May, in that if kind of on an annual basis, you're able to communicate what the modules are expected to be and if the student turns up and starts studying on those, that is, to a certain extent, a level of consent in that they have been given and provided the information and have agreed and are continuing to study.Gordon:
Well, yeah, I sort of understand that, I mean, so what you do your best there, but I think actually, you know, there may be a substantial change in terms of introducing optional modules over that five-year period, and they might not have known about them. What I'm saying is that then, you know, it's quite difficult to achieve all that you've said without and make substantial changes we want to introduce. For example, we want to introduce 'sustainable health' modules as part of the programs that we run, and it might not be the case that they know about them until quite late in the program and then they could argue, look you didn't give us a choice to do this, previously. And you know, and we now want to do this and yet you didn't inform us of that possibility. So, it becomes complex I think for programs that extend over such long periods of time.Lucy May:
Yeah, it does and I'm really sympathetic to that and I think I would say that I feel that you need to be able to innovate and make changes to your programs. And what we need to do is to help you do it in a way which is compliant and doesn't put the institution at risk. So, if you've got queries, do come to us. I mean, I wonder if there could just be something like, you’re doing kind of keep warms with students, kind of saying, like a kind of newsletter, students may be aware.Gordon:
Yeah. I wish we could I mean we've tried all this sort of stuff in terms of communication in between times. It is actually very difficult. Anyway, we can only try our best, I think.Lucy May:
But I think that's it. I think, there is an element of try your best. We cannot, fully, 100% mitigate risks here. The CMA say it's express consent. Now if I take that at it's very literal interpretation, that would mean for every material change, we would have to say we had written consent from every student now, we've made a decision as an institution the we are going to effectively send out a piece of comms and if a student chooses not to accept it, for whatever reason, they might be back packing and you know out of Mongolia and not see the communications, but we kind of have to take it, on risk that that student could potentially turn up and say I had no idea, but there's only so far we can go with things. And I think this is what it is. It's gonna be a balance. So, my general feeling is that, as long as students are kept informed of changes, of material changes, so it's not just kind presenting them as a fate accompli which they knew nothing about, which is when you're more likely to get upset anyway and a reaction, as long as you can say, we have kept you informed, it can be kind of things like dropping into lectures, for example, you might end up find yourself studying this, we're looking at program, there can be different ways of feeding in information as well, and then doing those pieces when there are significant changes. It might be like, 'we're looking forward to welcoming you back next year. We have reviewed the curricular and here are the changes you will be studying. It's really exciting. Of course, the way you present it is so important as well. If it's too dry, kind of like, please can you confirm you consent to these changes etc. But, if you're saying, we have feedback, it's really innovative, it's really exciting, we can’t wait to present it to you, we think it's better. And the way it's done, you're far less likely to get any kind of reactional student feedback to it. Anyway.Oliver Craig:
I'm conscious of time, I know people have other meetings to get to and things like that. So, I'm just gonna stop sharing the screen and just say to everyone, obviously this is a massive subject that people have plenty of questions on and things like that as well. And so, if anyone does have any more specific questions or things that they want to and to ask then, please do approach either myself or Lucy May via email and after this, but yeah, just to summarize, thank you very much for coming along and we will put this online so that other people who weren't able to attend can see it as well. And so yeah. Anyway, thank you very much for the time and see you all soon.Lucy May:
Thank you.Oliver Craig:
Bye.