An article highlighting some of the key issues in complaints we have seen to date when a course, campus, or provider has closed.
Last week we published a new briefing note which shares some learning from complaints we have seen when a course, campus, or provider has closed. Even in less turbulent times, providers often make changes to what, how and where courses are delivered. Sometimes significant changes are made in response to unavoidable external factors, such as changes to the requirements for students entering regulated professions. In other cases, changes are driven by a provider’s own plans for the future, for example, a move to newer facilities in a different location. We have been reviewing complaints from individuals and from groups of students about course, campus and provider closure, since we began work in 2005.
The impact of the coronavirus pandemic means that providers are looking at their provision in a different light. For some, it will be financial pressures that drive a re-evaluation of what they offer. But there are also opportunities to build on some of the many positive innovations of the last nine months, for example, developments in blended learning or changing assessment practices. These too might lead to changes in the courses a provider offers, and where it offers them.
So it seemed timely for us to highlight some of the key issues in complaints we have seen to date when courses, campuses and providers have closed. Many of the principles we draw out from these cases have wider application and apply to any changes in provision.
Tell students what’s going on as early as possible
Providers need to tell students about the potential for changes as soon as possible. This won’t always be easy, especially where a provider knows that a significant change is likely to be needed, but must try to maintain confidence in its provision in the meantime. But it is important to give students as much time as possible to understand what the changes will mean for them, and to decide what they want to do.
It’s also important to think about who needs the information. Current students might be expected to have finished their studies before the changes are made, but inevitably there will be some students who do not complete within the standard timeframe. We have reviewed complaints from students who might have made different decisions about taking time away from their studies if they had known about changes down the line. Of course for some students taking time out is not a choice, and it is important to consider how to support these students through the changes.
Communication needs to be two way
Communication isn’t just about telling students what is happening – or might happen. Clear, early and frequent two-way communication is essential. Students need to understand what the impact of the change will be, what options may be available to them, and what actions they may need to take.
It is equally important to listen to students’ views. Students may be affected by the changes in ways that haven’t been anticipated. They may also be able to suggest solutions that reduce any negative impact upon them.
The complaints we have seen have often come from students who have felt that a change has been imposed upon them. They feel a lack of control, and a lack of agency. Some students who have complained to us did not understand that they had a choice whether or not to accept what the provider was putting forward as the “default change”.
It is important to explain all of the options available to students, even those which are more administratively difficult, are more expensive for the provider, or which might mean the student does not complete their studies within their originally planned timeframe. In our experience, students do not always know how to go about transferring to another provider – or even where to start. Transferring is a decision not taken lightly and may involve financial and personal costs. Even so, for some students, taking time away from study to consider their options, or completing their studies elsewhere, are the best options. In some cases the provider may need to meet additional costs reasonably incurred by a student in completing their studies.
In our experience, where a course or campus closure has been planned, providers are often able to make arrangements that broadly work for the majority of students affected. For some, the new arrangements may be better than the old. But some students will be more seriously affected by a change in their place or method of study than others. Some will have chosen to study at a location for specific reasons, for example because they have caring responsibilities, financial constraints, or they are disabled or have a health condition that affects travel. These students may need extra support and it’s important to identify them, discuss their concerns, and agree with them how their individual needs can be met.
Help is at hand?
We have seen that students can be very mindful of the impact that major changes can have on staff. Although many students will reach out to the academic staff they already know, it can be helpful to signpost students to independent sources of advice and support. Students may benefit from the perspective of someone they believe has no vested interest in their decision. Students’ unions or other student representative bodies can be a valuable source of advice in these circumstances. Students may also need expert advice to understand the impact of making particular choices on their financial or visa arrangements, or on their future career path.
Students need to know about any deadlines which may be important, such as deadlines for withdrawal without incurring fee liability, or deadlines for selecting alternative modules. They also need to know what the default position will be, if they don’t make an active choice by that date.
Being told that a course, campus or provider is closing is stressful. Students are likely to need additional welfare and wellbeing support. It may be helpful to liaise with local services if large numbers of students are likely to be affected, particularly if a provider closure means that students will lose access to in-house counselling or other support services.
Closing the doors
The complete closure of a provider has historically been very infrequent, and carefully managed. We hope that continues to be the case. We have not to date had complaints relating to a sudden unplanned provider closure, but we have recently finished reviewing complaints that arose from the planned closure of GSM London which went into administration in 2019. We have published reflections on what we saw in Closure of GSM London: the OIA’s perspective.
The complaints we received showed that students were shocked that it was possible for a provider to close at relatively short notice. But we also saw that the way a closure is managed can make a real difference to students. There are clear benefits from continuing to run advice and support services for as long as possible to help with this process.
Most students should be able to continue with their studies if their provider closes. In the GSM closure, it was possible to find similar courses at other providers for students to transfer to and this was made easier because there were a number of other providers in the local area that offered comparable courses. Students whose interests lie in specialised fields that are not offered by many providers are likely to need additional support to complete their studies if their provider closes.
Mind the gap
Closing a course or campus is always likely to be difficult but it doesn’t have to be too painful if it’s managed and communicated well. Students who feel properly supported and listened to are more likely to accept the change and even see some benefits. But the closure of a whole provider is likely to be shocking and upsetting for all involved. Even in these circumstances with careful planning the majority of students should be able to transfer to other providers successfully and continue with their studies. Since the closure of GSM, developments such as the Department for Education’s restructuring regime and the Office for Students’ proposed student protection directions go some way towards reducing the likelihood of provider failure and reducing the potential impact.
But there remain some gaps in provision for students in this position. Some students might be seriously disadvantaged by a closure and be left without a meaningful remedy. We have argued for several years that there is a need for some kind of insurance scheme that could help protect students, give them confidence in the system and pay out in the worst-case scenario. This is a subject that deserves more discussion and policy thought: who should provide this protection and how should it be paid for?
Felicity Mitchell
Independent Adjudicator
November 2020