QAA 047 06/2004
The following definitions and explanations are offered for terms which are commonly used in this report.
Access As a proper noun, used generically to indicate the totality of Access to Higher Education activities in England, Wales and Northern Ireland.
Access programme Used generically to describe a programme of study which has been recognised by an AVA as an appropriate preparation for higher education for mature students and meeting the minimum requirements for the award of an Access to Higher Education certificate. Access programmes are targeted, in particular, at adults who may not have undertaken formal education for a number of years or at groups who are under-represented in higher education. Some Access programmes are broadly based; others offer specific discipline preparation; nearly all include study and/or other core skills. Most programmes can be completed in one year on a full-time basis; many are also available in part-time modes. The majority of Access programmes are offered in further education colleges, but some are provided in other locations, for example, adult education centres, community centres and higher education institutions.
ARLC Access Recognition and Licensing Committee: the body appointed by the QAA Board with responsibility for the overall operation of the Recognition Scheme. The Committee monitors AVAs through the receipt and scrutiny of annual reports, and standard data about recognised programmes and students. The ARLC also oversees the process of periodic review of AVAs.
AVA Authorised Validating Agency: a body licensed by QAA to undertake the development and recognition of individual Access programmes, the monitoring of recognised programmes, and the award of Access to Higher Education certificates to successful students. AVAs comprise both institutions that develop and deliver Access programmes, principally further education colleges, and those that receive students who successfully complete Access programmes, principally higher education institutions.
AVA review The process of periodic review of AVAs which ensures that they continue to be fit bodies to hold an AVA licence, and that they continue to conform with the principles, criteria, and operational guidance set out in the Recognition Scheme.
Licensing criteria Principles and Criteria for the Licensing of Authorised Validating Agencies: that section of the Recognition Scheme which sets out the principles and criteria established by QAA to which it refers when considering the fitness of a body to hold an AVA licence. The principles and criteria have been developed to provide assurance of the quality of the structures, operations and procedures of AVAs, in order to ensure that they are able to secure the quality of Access provision, its continuing fitness for purpose and the sufficiency and consistency of its standards. The licensing criteria are used both for the consideration of applications for new licences, and for the periodic review of existing AVAs. The licensing criteria are available at www.qaa.ac.uk/crntwork/access/recog_principles.htm
NOCN The National Open College Network: the central organisation for the Open College Networks (OCNs) based across the UK. NOCN licenses and audits the OCNs' activities. Most AVAs are also OCNs and are engaged in other types of education and training in addition to Access provision. In this report, these are sometimes referred to as OCN/AVAs.
QAA The Quality Assurance Agency for Higher Education: the regulatory body for the national recognition of Access programmes. QAA is responsible for undertaking reviews and audits of the standards and quality of higher education. In licensing AVAs, QAA is responsible for assuring the quality of recognised Access programmes, and the adequacy of standards of student achievement as a preparation for higher education.
Recogntion Scheme The QAA Recognition Scheme for Access to Higher Education in England, Wales and Northern Ireland: the scheme established by QAA through which it meets its responsiblilities as the regulatory body. The Recognition Scheme document is available at www.qaa.ac.uk/crntwork/access/recog_intro.htm
1 The basis of this report is a consideration of the full cycle of periodic licence reviews of Authorised Validating Agencies (AVAs) undertaken between 1999 and 2004 by the Quality Assurance Agency for Higher Education (QAA) in its role as the national regulatory body for Access provision. The major purposes of the report are:
2 Since their beginnings, the primary purpose of Access programmes has been the provision for mature students of an alternative, and more appropriate, preparation for higher education. Although definitions of 'mature' may have changed, and continue to change, this primary purpose remains as a fundamental principle for Access programmes. They are designed to respond to the need to broaden participation in higher education and, to cite the current Recognition Scheme documentation, they 'assume the need for, and desirability of, increased participation by those groups which are currently under-represented in higher education' and are 'built on the principle of extending opportunities for progression to higher education for those adults who have benefited least from their past educational experience'.
3 The systematic organisation of Access provision on a national basis can be traced to the 1987 White Paper, Higher Education: Meeting the Challenge, which called for the development of 'a framework within which the availability of well devised Access courses can be increased'. Subsequently, in 1989, the Council for National Academic Awards (CNAA), in cooperation with the Committee of Vice-Chancellors and Principals, established a national framework which was managed by CNAA's Access Courses Recognition Group (ACRG). The ACRG began to issue initial licences to AVAs in 1990. Under these licences, AVAs were permitted to approve Access courses offered by a range of providers including both higher education institutions (HEIs) and further education colleges.
4 With the closure of CNAA in 1992, responsibility for Access was passed to the Higher Education Quality Council (HEQC) and managed by HEQC's Credit and Access Advisory Group. The process of transfer was facilitated by the preparation and publication of A consolidated bulletin on the framework of national arrangements for the recognition of Access Courses in England, Wales and Northern Ireland. In 1995, HEQC reviewed its arrangements for Access and created a new managing committee, the Access Courses Recognition Subgroup.
5 A further process of transfer occurred in 1997 with the establishment of QAA which inherited the responsibility for Access recognition from HEQC. In December of that year, QAA created the Access Recognition and Licensing Committee (ARLC) to undertake the detailed work of the licensing and review of AVAs. In 1998, it also established the Access Recognition Advisory Committee as a consultative body, comprising Access practitioners and representatives from other interested bodies.
6 An initial version of the Recognition Scheme documentation was approved in 1998 and then expanded and revised for publication in early 1999. All licence reviews were conducted under the regulations of this scheme until 2001, when detailed criteria for the licensing of AVAs were developed and introduced.
7 In January 2003, the White Paper, The Future of Higher Education, invited QAA to 'come forward with proposals to modernise the criteria for Access Courses so that they are sufficiently flexible and attractive to meet the needs of today's adult learners'. The report of a QAA research project designed to meet this request was published in May 2004.
8 With the first AVA licences issued in 1990, an initial pilot review process was introduced by CNAA in 1991. A complete cycle of reviews was then conducted in the five-year period to 1996. Initially, these reviews were conducted through a single meeting with the AVA. In 1994, the process was revised to focus on self-appraisal by the AVA with the assistance of 'mentors' appointed by HEQC, followed by an engagement with an HEQC panel. In all, a full cycle of 38 AVA reviews was conducted in this period. In preparation for a second cycle of reviews, initial work on a Learning from AVA review report was undertaken in 1996-97 but was not completed before the transfer of responsibilities for Access to QAA. HEQC also commissioned a more general review of Access, however, and the associated report (Access Course Recognition and the Higher Education Quality Council: a review), published in 1995, made a number of recommendations about the process of periodic review, which were taken forward by QAA in the development of the AVA review process.
9 The second cycle of reviews - which is the subject of this current report - began in April 1999 following the approval by the QAA Board of Directors of the QAA Recognition Scheme for Access to Higher Education in England, Wales and Northern Ireland. In the period from 1999 to 2004, a full programme of 28 licence reviews was conducted and three applications for new AVA licences were received, of which two were approved. This process of periodic licence review has been complemented by the submission to QAA of an annual review by each AVA. Piloted in 1999, the current format for the preparation, receipt and consideration of these annual reviews was established in 2000.
10 In broad outline, this report is structured into two main sections:
11 An internal structure for the first of these two sections, Learning about AVAs, has been created by using the seven principles for licensing and re-licensing of AVAs as an organising device. The principles provide a context for the more detailed criteria which define the requirements for the award and renewal of AVA licences. After a period of consultation in 2001, the principles were introduced in January 2002 and were used specifically for the purpose of licence review for the first time in March 2002. Since that date, the 10 licence reviews which have been undertaken have used the principles as a structure for the subsequent reports. In this context, the principles thus provide a logical structure for the section, Learning about AVAs. It is acknowledged that this section also covers 14 reviews which preceded the introduction of the principles in 2002. However, in essence, the principles simply extracted and formalised the key elements of the initial Recognition Scheme approved in 1999. While the reports of the pre-2002 reviews could not have been formally structured using the principles, it is clear that the criteria by which they were conducted were broadly similar, and that the contents of the reports thus lend themselves readily to a structure which uses the current principles.
12 The seven licensing principles, and the abbreviations used for each of them in this report, are listed below.
The organisation has a structure which is based on a partnership of members, including institutions which provide Access to HE programmes and institutions of higher education. (Structure and membership)
The organisation has governance structures which allow it to discharge its AVA responsibilities securely. ( Governance)
The organisation is aware of, and in a position to meet, its legal and public obligations. (Legal identity)
The organisation is able to manage effectively its AVA responsibilities and the structure which supports them. ( Management and administration)
The organisation is able to assure the quality and fitness for purpose of Access to HE programmes at the point at which they are granted formal recognition. (Development and approval of programmes)
The organisation is able to safeguard the continuing quality of Access to HE programmes, and to secure the standards of achievement of students awarded the Access to HE certificate. (Standards of achievement)
The organisation is underpinned by structures and processes which enable it to review, evaluate and develop the Access to HE provision for which it has responsibility. (Review and evaluation)
13 In Learning about AVAs, each principle will be set out again with:
14 The second of the two sections, Learning about AVA review, has a simpler structure which considers the logistics and mechanics of the review process, some qualitative analysis of it by all participants, and some discussion of future options.
15 Appendix B to this report records the 31 separate 'engagements' between QAA and AVAs in the period since April 1999. The three engagements which relate to applications for a new licence to operate as an AVA have been excluded from Learning about AVAs, since the nature of these exercises differs from the standard review of an existing licence. However, as the basic methodology used to consider a new licence application is broadly similar to that for licence review, account has been taken of the reports in Learning about AVA review. A similar decision has been reached in respect of the four AVAs which underwent review in the period covered by this report but which are no longer operating as AVAs. It did not appear appropriate to include discussion of AVA practice which is now inaccessible, although the relevant reports and other related documentation have informed the discussions contained in Learning about AVA review. Hence, the documentary basis for Learning about AVAs comprises the remaining 24 review reports listed as part of Appendix B.
16 This report is based on a qualitative consideration of the published reports described in paragraph 15 above. For Learning about AVA review, some additional material has been taken into account mostly comprising written feedback, where it has been received, from AVAs following review, and the feedback reports which are compiled by members of review teams. These documentary sources have been analysed for recurring or common themes which, where identified, have become the focus of the report. There has been no process of selection in terms of the documentary evidence: all review reports and all submitted feedback has been taken into consideration.
17 From the beginning of the cycle, all reports of AVA reviews have contained summary lists of points of commendation, conditions related to the renewal of the licence, and recommendations to the AVA on a range of other issues. There has been no attempt to use such summaries for any quantitative analysis although the preponderance of particular issues arising through the commendations, conditions and recommendations has in some instances been useful in determining which areas may be of most value for analysis and discussion.
18 Direct quotations from review reports are included at appropriate points in the text but are not referenced to individual AVAs: this document is not an attempt to undertake individual reviews again but is more interested in what can be learned in general from the overall process of AVA review. In one case, however - the listing of points of commendation in Learning about AVAs - individual AVAs have been named. The reason for this exception is to meet one of the purposes of this report which is to identify and publicise good practice. Although it is understood that some of the commendations may now relate to practice which has been developed further or superseded, QAA would be grateful if AVAs were willing to respond to requests they may receive for details of particular aspects of their good practice which might be made as a result of this report. A process of selection has been used in the choice of points of commendation. Those very occasional points which made direct reference to individual post-holders (who may no longer be in post) have been excluded, together with any points which were particularly fixed at the point in time of the review.
19 The organisation has a structure which is based on a partnership of members, including institutions which provide Access to HE programmes and institutions of higher education.
20 The organisation will be able to demonstrate that:
21 To an extent, the principle of a structure which is based on a partnership of members reflects the traditions and origins of Access programmes which grew from productive cooperation and partnerships between higher and further education. In respect of the security and proper operation of the AVA licence, it is considered important that this structure of partnership should continue to be supported. The insistence on at least two HEIs being in membership is to prevent any sense in which an AVA might be seen merely as a 'feeder' organisation providing applicants to a single college or university. A major purpose of the Recognition Scheme is to promote the Access to HE certificate as a national award and it is thus focused on the licensing of an AVA as a disinterested body with a broad membership rather than one which has exclusive local links. The criteria attached to this principle also anticipate the establishment of formal agreements for the supply of services (especially where a supplier may be a member of the AVA) in order to provide the basis for the AVA's independence. This issue is taken up in more detail under Principles 2 and 3.
22 Given the roots of many AVAs and of Access as a whole, it is unsurprising that the issue of membership attracted much praise and comparatively little criticism during the cycle of reviews. The value of the 'partnership of members', enshrined in the Recognition Scheme's principles, was a frequent feature of the Analytical Accounts (see Learning about AVA review, paragraphs 151-152) prepared by AVAs for the purposes of review. This did not appear to be affected by the legal identity chosen by the AVA, that is, it was as likely to occur in an AVA with limited company status as in one which was an unincorporated association of members. Although it was not often a feature selected by review teams for formal commendation, it is not unusual to read of the high value placed by institutional members on the direct and indirect benefits which they gained from membership of the AVA.
23 In respect of the routine organisation of the receipt and approval of applications from prospective members, a standard pattern emerged of which the following example might serve as an illustration of the good practice to be encountered:
Applications for membership are made on a pro forma which is contained within a larger Membership Application/Renewal document. This comprises a comprehensive statement on membership including details of eligibility and criteria, fees and charges, method of application, and a statement of rights and responsibilities. Applications are considered by the Quality Assurance Group (QAG) which makes a recommendation to the [OCN's] Council. The minutes of the QAG demonstrated that appropriate attention was paid to applications and that QAG also monitored and amended the membership application documents when necessary.
24 This particular example demonstrates an AVA where applications from prospective members are considered through the governance structure as a 'peer' process. In other cases, such applications were received and processed by officers of the AVA very much as an administrative task. Review teams did not overtly criticise this latter procedure although it might be argued that it is not wholly appropriate as a practice for those AVAs which place value in the notion of the 'partnership of members'. In the cases of best practice, prospective members are commonly required to demonstrate that they are willing and able to support the mission and aims of the AVA. Those who are intending to become providers of Access courses are also assessed rigorously to ensure that they have the capacity to meet criteria related to quality standards, finance and resources, and general infrastructure. Assessing prospective members in these contexts would appear ideally to be a responsibility shared appropriately between the management staff of an AVA and its deliberative structures.
25 In considering the range of organisations in membership, most AVAs operated some system of layered categories, although there was much variety in the ways in which the layers were established and how they were defined. However, although no standard pattern exists, it was frequent to find three basic categories:
26 In general, the review cycle demonstrates the adroitness of AVAs in the design of such membership categories and their ability to accommodate within them the size, position and interests of their member organisations. Occasionally, membership categories appeared to be over-elaborate and a source of unnecessary administrative effort for an AVA. In such cases, it may be useful to recommend the practice of AVAs where no distinction is drawn between members although differential subscriptions may be charged according to some indicator of volume (for example, institutional size or number of learners).
27 There were a very limited number of examples of AVAs which had no formal process and associated documentation for admitting new members in place. There was no evidence that this was the result of any deliberate policy - in many cases, the AVA appeared simply to operate a more informal process for admitting new members which was no longer appropriate in the light of the licensing criteria. There were occasional examples, however, of AVAs where some difficulties may have been experienced in making the transition from earlier notions of the limited membership of an AVA whose only interest was the straightforward validation of Access programmes, to the much broader concept of membership which needs to be considered if the requirements of the AVA licence, as described in the 2001 Recognition Scheme, are to be met.
28 In such cases, it was usual to find membership restricted to higher education receivers of Access students and further education providers of Access programmes with little or no representation from the voluntary, community or private sectors. The principles which drive the Recognition Scheme are informed by the wish to allow 'for responsiveness to the specific needs of adults and targeted groups, and to local needs and circumstances in the organisation of provision and in curriculum design. The resulting provision will inevitably be diverse, and the Recognition Scheme acknowledges both the diversity of programmes, as well as the diversity of providers engaged in this activity'. In some cases, then, AVAs with rather limited membership will find it increasingly difficult to respond to this diversity without expanding to include a broader range of organisations.
29 There was very little evidence in the review reports of AVAs which had deliberately sought to expand their membership by pro-active means. With very well established AVAs, it may be the case that virtually all organisations in their region with Access interests are already in membership. However, to the exception already described in the paragraph above, might be added the case of some HEIs which do not appear to be members of the AVAs which are located in their region. Some review reports comment on these absences and encourage AVAs actively to seek the membership of more HEIs. In some senses, this issue is related to the requirement of the licensing criteria that an AVA must have at least two HEIs in membership (and is also related to the discussion of the legal identity of AVAs in paragraphs 52-56 below and the notion of the 'host' institution). There is some evidence that HEIs can be sensitive to situations in which an AVA might appear to have a special relationship with a particular HEI, or where some residual, but now unused, preferential treatment might still be visible from a past exclusive relationship. The Recognition Scheme promulgates the consortium model of AVAs as an acknowledgement that it is the cooperation between further and higher education which is at the centre of the success of Access. In this context, the recruitment of HEIs to AVAs constitutes a priority.
30 At various points in this report, the notion of the 'critical mass' of an AVA will be raised. Briefly, this relates to the evidence arising from the review cycle which suggests that the operation of an AVA under the Recognition Scheme demands a certain level of resource if the licensing criteria are to be met satisfactorily or with any comfort. The first appearance of this theme is related to membership and the ultimate overall size of an AVA. Typically, an AVA may well call upon staff of its member organisations to assist in a number of its activities and operations, for example, committee membership, chairing of recognition and review panels, and appointment as moderators. It is an obvious point that the larger AVAs will have at their disposal a larger pool of people with sufficient and varied enough experience to take on these roles and duties. In many cases, the issue of 'externality' will also be less acute for them than for those AVAs with a very limited membership who may have to make particular arrangements to ensure that a measure of externality is built into their processes. There is no sense from the reports that review teams have supported a simple, and simplistic, argument that size is of paramount importance; they have pointed out, however, the continuing difficulties which may be faced by AVAs with a comparatively limited membership.
31 At the time of the relevant AVA review, the following examples of commended practice were noted:
32 Some of the areas which might be developed further by AVAs in respect of this aspect of the Recognition Scheme are:
a ensuring that the notion of membership responds to the requirements of the Recognition Scheme, and that AVAs have in membership a diversity of providers and other organisations in order to take a lead in the development of diverse opportunities for Access;
b where opportunities are known to exist, pro-active efforts to expand the number of HEIs in AVA membership;
c a consideration of the issue of 'critical mass' in respect of membership and its impact on the ability of an AVA to meet, and continue to meet, the licensing criteria and other demands of the Recognition Scheme.
33 The organisation has governance structures which allow it to discharge its AVA responsibilities securely.
34 The organisation will be able to demonstrate that:
35 In the most basic sense, this principle is designed to ensure the current and probable future security of the licence within an AVA as an organisation. It requires the AVA to be properly constituted, to ensure that there is an appropriate balance between its management and governance structures, to specify clearly responsibilities for its major operations and to protect itself from inappropriate or undue influence. The criteria also ensure that an AVA cannot devolve its major responsibilities under the licence to other bodies or individuals. In the Recognition Scheme, these aspects of governance are seen as forming the secure foundation for an AVA's activities as a validating body.
36 As paragraph 47 below demonstrates, this was not an area that attracted frequent commendations from review teams. On the contrary, on the evidence of the review reports, it is an area which has been problematic for AVAs and the cause of persistent difficulties. This general statement is not intended to camouflage the good practice which does exist; a review team noted, for example, that the governing body of one AVA 'meets regularly, effectively conducting business that is appropriate to it and maintaining a strong commitment to strategic positioning, planning and review. Its membership is knowledgeable...and the seniority of representation contributes to the authority of the organisation with member organisations'. However, it remains the case that such commendations are rare. It is more common to read of committee structures being under strain, badly affected by poor attendance and inquoracy, and with ad hoc solutions having to be adopted in order that essential business can be conducted in a timely manner.
37 Even with the variance in the size and nature of AVAs, there are some common patterns in their deliberative and governance structures. Many have an overarching body, a council of members, which represents the whole of the membership of the AVA and, in many cases, is the source of ultimate authority (referred to here as the Council for convenience). The day-to-day management of the AVA is then placed with a smaller executive body which has more frequent contact with the management staff of the AVA (referred to here as the Executive). Typical sub-committees of the Executive are those for quality matters (known, for convenience, as the Quality Committee in the text of this report) and for resource issues including finance and staffing.
38 An analysis of the difficulties which AVAs have experienced in the operation of their governance structures would be lengthy in its own right. A synopsis of the major and most frequent issues raised in review reports would include:
a the basic articulation of the deliberative structure including clear statements on areas such as membership, remits, and terms of reference. It is not unusual to encounter conditions set at review which require an AVA, for example, to 'review[s] its committee structures and membership, and make[s] revisions as necessary in order to address and clarify, in particular, matters of quoracy and members' voting rights; accountability through reporting lines; and the optimum numbers and representation required for effective and accountable governance', or to 'review[s] the Constitution, and committee terms of reference, names, functions and relationships and current practice; and revise[s] documentation or practice as necessary to ensure consistency between constitutional obligations and operational practice';
b the representation or positioning of Access within the governance structure of the AVA. The role of specific committees with responsibilities for Access matters is discussed in paragraphs 38c and 39 below. In this context, the more general issue is the overall representation of Access in OCNs where Access programmes may constitute only a proportion of their work (referred to as OCN/AVAs in this report). From the evidence of the review reports, there appears to be a tension between a position adopted by some OCNs - that Access matters are simply embedded in their mainstream work and therefore require no particular representation - and the requirement set by the licensing criteria for review teams to seek and identify the single locus of authority and responsibility for Access within an AVA's governance structure. The same issue arises in respect of strategic planning within an OCN/AVA and is discussed in paragraphs 69-70, below. In some senses, this is an artificial tension. The 'single locus' does not necessarily imply a special 'Access committee' or even special representation for Access on other committees: there are examples of OCN/AVAs where the responsibility for the AVA licence is clearly located in the governance structure, unambiguously stated in the appropriate remit or terms of reference, and where minutes and papers demonstrate the attention which is given to Access matters. There are some cases, however, where a senior committee has stated responsibility for the operation of the AVA licence but has little prospect of fulfilling that responsibility simply because a process of devolvement to sub-committees has left it with little or no direct involvement. In general, review teams have looked for genuine rather than theoretical responsibility for Access;
c the use of a separate committee for Access in the governance structure of OCN/AVAs. In most cases, such committees have chiefly quality assurance responsibilities although they may also be the focus for discussions of policy and strategy. Typically, then, they might deal with such business as the recognition of new Access programmes, the consideration of annual programme reviews and moderators' reports, and the appointment of moderators. It is unavoidable that, in an OCN/AVA, there will be another committee in the structure undertaking exactly the same tasks for the non-Access provision of the OCN. Although there are isolated examples where this co-existence appears to work (albeit often through rather uneasy compromise), there are more cases where the existence of two committees dealing with similar quality issues creates tension and confusion. It could be argued that, in many cases, there has been insufficient thought given to the remits of separate committees for Access: the differences between Access and non-Access provision are not essentially related to fundamental quality assurance processes, but are often in the context of the nature, development and enhancement of specific Access provision;
d the proper delineation of responsibility between executive officers of the AVA and its committees. Some issues in this area are straightforward, for example, the occasions where review teams have reminded AVAs of basic good practice in governance which prevents officers of the organisation from being members of committees rather than being in attendance. Other issues are more complex and are related to the general operation of the AVA. In many AVAs, officers play an absolutely key role in providing committees with the information and advice which they require in order to fulfil their remits. This is an area of work which requires a thorough appreciation of the line which separates the responsibilities of the executive and deliberative structures, a line which had perhaps been blurred in the case of an AVA required to ensure that 'its committees discharge fully their responsibilities as set out in their terms of reference in the Constitution and that its officers do not exercise the responsibilities of committees or their chairs'. However, it must be said that, in the light of the problems encountered by AVAs in securing adequate attendance for key committees, it is difficult not to feel some sympathy for AVA officers who are responsible for ensuring that the business of the AVA is conducted in a timely and efficient manner. On the other hand, it is possible for influential and decisive officers unwittingly to make, for example, a Quality Committee redundant or marginal and thus contribute to a decline in the commitment of its members. Nevertheless, the evidence of the review cycle indicates not only the importance of the proper delineation of responsibilities between the executive and the committee structure, but also why that delineation is important for the health and security of the AVA;
e the basic operation of committees. At a very detailed level, but seen by some review teams as demonstrative of a particular misunderstanding of the importance of the governance structure, is the occasional weak level of committee servicing usually evidenced by poor minuting standards. As examples, one report notes 'the reporting of the AVA's activities, discussions and decisions was not to a uniform standard, and the quality of minuting and reporting had varied across committees and time, sometimes to the detriment of clarity'; another report comments that minutes 'were not sufficiently substantive to provide adequate records of the Committees' work for the purposes of external audit or scrutiny'. Given that review teams rely on minutes as a key written evidence source, this might be interpreted as irascibility on their part. However, in this and other cases, teams have reminded AVAs that their minutes function not only as an internal record of outcomes to be addressed, but also as evidence of business for external information. In terms of public accountability, all formal records of an AVA should be produced to a standard expected of a validating body.
39 A striking feature of the review reports is the common existence in OCN/AVAs of an advisory group on Access. The formal title of this body varies from AVA to AVA (it is often known as an Access Tutors' Group or Forum), but the comments made in review reports on such groups are remarkably similar. Mainly comprising Access practitioners, they are often described in Analytical Accounts as being a key feature of the AVA's approach to Access. Their role includes offering advice on Access policy and strategy, and generally providing a forum for the discussion of key issues for Access as they emerge. However, they are rarely part of the formal deliberative structure of the AVA and review teams have commented on the tendency for their work to be marginalized, or for there to be confusion about their role and powers. More often than not, such groups have the greatest experience and expertise in Access and, in some cases, they appear to attract better levels of attendance from higher education members who may see their major interests in Access rather than the broader work of the OCN. On the evidence of the review reports, these groups are a lost opportunity in many AVAs. In terms of the discussion contained in paragraph 38c above, AVAs may wish to consider whether there is greater value in the formal inclusion of such groups in their committee structures rather than the current emphasis on separate quality-based committees for Access.
40 Given the terms of the Recognition Scheme and the nature of the licence awarded by QAA, a focus on the particular function and effectiveness of quality committees in governance structures is to be expected in review reports. In general, such committees do not escape the criticisms which are levelled in reports at committee structures overall. It is not uncommon to read of weaknesses in the basic statements of remit, terms of reference, quoracy regulations and membership. There have been cases when such committees have been criticised for not operating effectively either because of such weaknesses or, on a small number of occasions - but of more fundamental concern - because they do not appear to have the expertise and experience required to undertake the work involved. This may appear to be a somewhat gloomy picture. It is ameliorated by aspects of good practice which are noted by review teams (some of which are considered below) and, to an extent, by the uncertainties caused by the transitions taking place in the working methods of quality committees.
41 This transition in working methods appears to have two main catalysts: the advent of self-assessment and internal audit as features of the internal quality assurance practice of AVAs, and the weight of work which faces a quality committee in most AVAs. It would now be unusual, except perhaps in the smallest of the AVAs, for a quality committee to have direct contact with all aspects of Access provision, that is, to receive and consider in full detail, all annual programme reviews or moderator reports. From the evidence of the review cycle, many have adopted a method in which synoptic reports are prepared by AVA officers for the consideration of the committee. Review teams have not criticised this practice per se but they have commented on those cases where such synoptic reports appear to be the only source of evidence or information for the committee. Teams have noted the potential fragility of a method in which the committee is wholly reliant on the quality of synoptic reports, and the extent and accuracy of their coverage. It has not been thought good practice to reach a position in which the quality of the officer support to the committee becomes the most crucial element for the committee's effective operation.
42 In terms of learning from AVA review, some of the reported developments in self-assessment and internal auditing may well recommend themselves for wider consideration. The practice of a quality committee undertaking some direct sampling is commonplace (for example, committee members considering a sample of moderators' reports following the receipt of an officer-prepared summary of all moderators' reports), although review teams have commented on the small size of the sample sometimes chosen. Other methods of 'direct contact' between members of quality committees and the quality functions of the AVA may occur as part of normal practice, for example, the common use of such members to chair, or be members of, recognition panels. In some cases, the contacts are less common, for example, members of a quality committee attending a sample of assessment boards. There are also cases where a quality committee selects a number of programmes from the AVA's provision on an annual basis and audits them separately as a means of verifying the general accuracy of the synoptic reports it may receive.
43 Examples of fully developed internal audit systems were not common in the review cycle, although it is clear that all OCN/AVAs are adopting such systems in response to the requirements of NOCN Quality Audit. Good practice in the consideration of such systems and in their development was noted by review teams. As an example:
Since the last formal AVA review, the working methods of the Quality Assurance Committee have been subject to evaluation and consequent change. The volume of provision...initially led the Committee to request summary reports from officers rather than to scrutinise, for example, all annual reviews or moderator reports on an individual basis. The Committee did not, however, consider that this method provided a sufficient level of evidence for it to fulfil its remit...
[The AVA has] thus developed a more distinctive audit approach...[which]...involves individual members of the Quality Assurance Committee taking a lead responsibility for auditing a particular aspect of the OCN's operation. Currently there are five such aspects: programme recognition, certification, moderation, organisation, and the general AVA function. In most cases, another member, or members, of the Committee assists the lead auditor.
In discussion with members of the Quality Assurance Committee, the review team heard that, typically, the equivalent of two days a year might be spent by auditors in reviewing their assigned area of the OCN's operation. This could include sampling of the work of officers, seeing appropriate reports and reviews, and a more general review of the process in question. At the end of each cycle, a report is made to the full Quality Assurance Committee.
44 Such audit systems clearly have the potential to provide a quality committee with ample reinforcement for the normal synoptic reports, although there are evident training issues for members of the committee to ensure that they have the expertise to undertake the audit function. The adoption of internal audit highlights the issue of the expertise of committee members in a broader sense. The format of review reports does not allow any robust quantitative analysis, but it does not appear that AVAs make any significant use of external members on their quality committees, although there are some instances where a member of a neighbouring AVA has been invited to join a committee. It might be helpful for AVAs to consider a more substantial use of external members, especially where they feel that internal experience may not be sufficient, or simply as an expression of good practice in demonstrating the transparency of their quality assurance processes. This injection of externality may be particularly pertinent in respect of smaller AVAs where review teams have commented on the tendency for the same members to occupy multiple committee places.
45 In summary, and drawing general messages from the review reports, it is difficult to escape the conclusion that the most fundamental issue related to governance in AVAs is caused by the gap between ideal theoretical structures and the realities of practical governance. A frequent cause for criticism is the inability of committees to carry out fully their specified remits. Very often, such remits are unrealistic for reasons which may involve the ability of the AVA to guarantee sufficient attendance, or because the committee could not possibly undertake the prescribed duties in the manner and timescales described. Two examples related to the position and role of the Council illustrate this problem and the solutions which were implemented:
The Governing Council as a large inclusive body was judged to be inappropriate as a vehicle of executive management within the AVA since it was never quorate and all decisions had to be ratified by postal ballots. In practice, much day-to-day executive responsibility fell upon officers or the Management Group and there was thus a mismatch between the AVA's constitution and the reality of the way in which authority was exercised. The new arrangements which have now been adopted by the AVA were intended to remedy these deficiencies. The Governing Council was abolished and replaced by a Council of Members which holds an annual general meeting. The Management Group was recast as the Executive Committee, and a Quality Committee was established as the locus of...quality assurance arrangements. Members of both committees are elected by the Council of Members at its AGM.
And continuing the theme of 'realistic' governance:
...changes had been made to the constitution which devolved substantial powers from the Council to the Management Committee. These changes appeared to the team to be a recognition on the part of [the AVA] that its governance structure, particularly in respect of the Council, was increasingly unable to respond effectively to the needs of the organisation. In the papers scrutinised by the team, for example, it was clear that the Council had not had a quorate meeting for some years (including the meeting at which the constitution was changed), and that the pattern of its meetings was somewhat irregular...
In discussion with senior staff of [the AVA], it was clear to the review team that the changes to the constitution had been made with an understanding of their consequences. In this sense, the organisation has acted responsively to a situation in which the Council could not realistically undertake those responsibilities which the constitution had allocated to it. The team believes, however, that the consequences of the constitutional changes now need to be followed through. The transfer of significant responsibilities to the Management Committee effectively establishes it as the senior body in the governance structure. However, the relatively small size of the Management Committee, which would appear essential for its efficiency, leaves open the question of how [the AVA] is generally held accountable as an organisation to its full membership. This might be resolved by a clear statement on the future role of the Council as a consultative body but the retention of its annual task to elect the members of the Management Committee.
46 The retention of a Council as a consultative body with powers to elect the members of the main executive committee permits the AVA to meet the requirement of the Recognition Scheme that it formally renders itself accountable to its members. It removes, however, an unrealistic situation in which considerable routine powers are invested in a body which has little possibility of ever discharging them. The same principle might profitably be applied to all parts of the governance structures of AVAs.
47 At the time of the relevant AVA review, the following examples of commended practice were noted:
48 Some of the areas which might be developed further by AVAs in respect of this aspect of the Recognition Scheme are:
a ensuring that all aspects of the deliberative structure are operated as professionally as possible. This includes establishing, and maintaining, clear statements on areas such as membership, remits, and terms of reference, and the mode of operation of committees and, in terms of public accountability, ensuring that all formal records of an AVA are produced to a standard expected of a validating body;
b the identification of the single locus of authority and responsibility for Access within the AVA's governance structure, that is, the body which holds the AVA licence; and a clear description of the role and responsibilities of any sub-committees which may be involved in the practical operation of the licence;
c further consideration of the use of separate committees for Access, not necessarily for the purposes of quality assurance, but for purposes which would not be duplicated elsewhere in the deliberative structure (for example, the discussion of Access policy and strategy, and the provision of a forum for the discussion of key issues for Access as they emerge);
d continuing to seek the most efficient and effective ways for the quality assurance of Access provision, particularly through the development of self-assessment and internal audit models;
e reviewing the overall governance structure of the AVA to ensure that it achieves the most effective balance between constitutional obligations, the requirements of external licensing bodies and pragmatic operational practice.
49 The organisation is aware of and in a position to meet its legal and public obligations.
50 The organisation will be able to demonstrate that:
51 It is a fundamental aim of the Recognition Scheme to promote the Access to Higher Education certificate as a national award which is consistent and comparable across the range of licensed AVAs. It is therefore in the interests of the Recognition Scheme, and the Access provision which it regulates, to ensure that AVAs are independent bodies, which are able to respond to the requirements of the Recognition Scheme without being restricted or controlled by any other body or organisation. It is also important, for the AVA's security, that the liability of the organisation and its members, and the basis for any formal agreements is made explicit. The adoption of a clear legal identity is thus seen as a key element, as is the ability of an AVA to control its own staffing, finances, and other resources.
52 The issue of legal identity and the concept of the restriction of the 'independent decision-making or operation of the AVA' may well constitute the most sensitive area of this cycle of AVA review. The sensitivity arises from the position which has been taken by QAA - that it would not be fulfilling its remit from the DfES as the regulatory body for Access if it were to grant licences to organisations which were not in full and independent control of their own operations - and the origins of many AVAs which are in specific links with host organisations, most usually a local HEI. As is often evidenced in review reports, AVAs have benefited significantly from their close contact with a host HEI, not the least in the provision of free services, including office accommodation, and use of professional services related to finance and personnel. There is no question that the generosity of such host organisations has been of immense benefit to the development of Access provision, but the current regulatory environment differs from that which pertained when many AVAs were first established and the notion of a clear legal identity and independence is now a priority.
53 Most AVAs have recognised the nature of this changing environment and have reacted accordingly although, during the review cycle, seven of the 24 AVAs received conditions on the renewal of their licence which related to issues of independence and the nature of their relationship with a host organisation. There is no pattern to be discerned in these AVAs which might suggest that membership of NOCN, or a particular legal identity, is more or less helpful in securing independence. Of the seven AVAs, six were also OCNs; at the time of the review, five were unincorporated associations and two had incorporated company status.
54 In some senses, these details are unimportant since the licensing criteria do not indicate a preference for any particular legal identity. As a matter of interest, however, at the time of review, there was a roughly equal balance between AVAs which were unincorporated associations and those which had company status, with a slight preponderance of the former over the latter (a situation which, at the time of writing, has probably been reversed). In seeking to apply the criteria, it is clear that review teams also did not seek any one particular status but looked for a convincing statement of the chosen legal identity and a demonstration of the independence of the AVA. The 'tests' of independence also seem clear from the texts of review reports. They included:
55 This last point raised some particular issues during the review cycle. As noted above, some AVAs benefit significantly from the provision of the free services offered by a host organisation and most were aware of the possible financial consequences of the withdrawal of those services. There were a small number of AVAs, however, where there appeared to have been inadequate risk assessment applied to a possible future where such services might have to be purchased at full cost or sought commercially. Although the relationships between AVAs and their host organisations was never less than cordial and, as also noted above, the host organisation frequently offered support because of its belief in the aims and mission of the AVA, there remains the possibility of a change in circumstances or in the prioritising of resources which might affect the AVA adversely.
56 The interpretation of the phrase 'undue influence' by different AVAs was also variable. In some cases, AVAs were convinced of their essential independence while admitting that the guarantee of that autonomy was often 'understood' rather than written down. This variability also applied to those situations where a relationship had been committed to paper. Review reports describe a range of arrangements from basic memoranda of cooperation to binding service-level agreements, the legal status of the former often being more open to debate than the latter. The range of understanding of the concept of independence, and the reaction to it, might be illustrated by one AVA which had legally binding service-level agreements in place with its host organisation and had also amended its constitution to ensure that the representative of that host organisation could not become chair of the AVA, to an AVA which had not yet achieved an appropriate degree of separation from its host organisation which still enjoyed a guaranteed seat on the Executive of the AVA.
57 It is a tribute to the majority of AVAs that they have been willing to make amendments to their structures and organisation in order to meet the requirements of the Recognition Scheme, particularly since this has often meant considerable effort, substantial change and the loss of some of the advantages which they might otherwise have enjoyed. In its wish to develop the Recognition Scheme, QAA will continue to implement the criteria regarding legal identity and independence. The report of the recent Access to HE Project leaves little doubt about QAA's wish to confirm the Access to HE certificate as an acknowledged national award, and its drive towards ensuring that successful Access students enjoy the same broad opportunities and choice of programmes and HEIs as, for example, successful A level students. One of the foundations for the achievement of these aims is the existence of strong, independent AVAs who are able to exercise their rights as validating bodies without restriction.
58 No examples of commended practice were noted in this area during the cycle of reviews.
59 An area which might be developed further by AVAs in respect of this aspect of the Recognition Scheme is where there remains any doubt, considering further action to demonstrate their legal identity and independence.
60 The organisation is able to manage effectively its AVA responsibilities and the structure which supports them.
61 The organisation will be able to demonstrate that:
62 The rationale for the use of this principle, and its associated criteria, in the award or review of an AVA licence is to ensure that the organisation has the general administrative and management capacity and ability to operate that licence appropriately and that it demonstrates every indication that its operations can be sustained into the future. Many of the requirements are statutory, or would be expected as good practice, for any organisation (for example, policies for equal opportunities and to respond satisfactorily to complaints or appeals). The focus on areas such as systematic data collection, rigorous financial management, proper record-keeping and written procedures for key operations is designed to ensure that the work of the organisation is well established, sustainable and not reliant on individual staff. The expectation that an AVA will engage in activities which promote Access more generally is part of the Recognition Scheme's aim to extend the opportunities which are provided by Access programmes regionally and nationally.
Major issues from AVA review
63 This particular principle covers many of the operational aspects of an AVA and, as can be seen in paragraph 83 below, attracted a significant number of commendations for good practice. Many reports acknowledged the quality of the basic administrative functions within AVAs and the staff who undertake them. There are also commendations for, among other things, the nature of communications between AVAs and providers of Access programmes, customer service levels and strategic planning processes. The range of activities covered by this principle has meant that a process of selection has been necessary in describing what might be learnt from the review cycle in this area. As such, the following paragraphs cover:
64 From the evidence of the review reports, AVAs excel in the range and nature of their communications with their members. Throughout the reports, there are abundant examples of written means of communications including newsletters, bulletins and annual reports (in some cases, the AVA uses the annual report submitted to QAA for the purposes of informing its members about the year's work). Many AVAs also produce a range of information packs and guides on various aspects of Access provision which are clearly welcomed by providers and students. There was increasing mention of web sites in the later stages of the review cycle, and almost all AVAs now have them (see Appendix A). Many Access coordinators or programme leaders met by review teams expressed their appreciation for the frequent and helpful contact with AVA staff, and for the range of forums or conferences designed to help them to keep up to date with developments in the AVA and in Access more generally. Those AVAs with a large enough critical mass to be able to employ staff with specific responsibilities for Access appeared to be particularly well placed to create and maintain excellent links with members and providers. In some cases, member organisations were assigned an officer as a designated personal link.
65 In one aspect of communications between AVAs and providers, however, review teams did express the need for some improvement in practice. As validating bodies, it is incumbent on AVAs to ensure the accuracy of what is presented about them and the award which they validate in providers' promotional and other literature. In a limited number of cases, review teams found that some of this information was inaccurate and potentially misleading for a prospective student. Typically, there was no acknowledgement of the AVA or QAA as validating and regulatory bodies, incorrect use of Access logos and outdated references to former regulatory bodies. It is part of their responsibility as validating agencies for AVAs to establish a process by which they can verify the accuracy of providers' promotional literature.
66 Paragraph 83 lists particular commendations made by review teams in relation to the administrative excellence of AVAs, and review reports in general are very positive in this respect. Together with common praise for the teamwork demonstrated in many AVAs, the reports confirm that key procedures and processes are usually well documented. In isolated cases, and often without challenging the quality of procedures as they were operated, review teams noted the need for more systematic statements or operational handbooks to ensure continuity in the face of staff changes. There were a number of particular commendations for customer service and for the use of service standards which describe what a provider can expect in areas such as programme development and recognition, moderation and certification.
67 In respect of the particular service offered to members for Access provision, there are links with the comments made on communications in paragraph 64 above. The individual competence of AVA staff is not in question, but it was clear from review reports that those AVAs which were able to appoint officers with special responsibilities for Access, and thus establish a pool of particular Access expertise, were able to offer a more extensive service to their members. This is simply the issue of critical mass again. One indication of the variety and range of AVAs is the volume of their staffing levels. On the evidence of the review reports, the smallest AVA has 0.5 staff and the largest has over 20. Irrespective of the size of an AVA's Access provision, these differences are striking and cannot help but affect the level of service provided to members.
68 The review cycle demonstrated that some system of strategic planning, and the production of a written strategic plan, was present in almost all AVAs. A typical pattern emerged of the periodic strategic plan (often three years) supported by annual operating statements containing more detailed targets. Although the majority of AVAs had reasonably systematic methods for establishing, implementing and reviewing strategic plans, review teams noted occasions where the information and data gathering for the planning process could be improved. The overall quality of strategic plans varied between coherent documents resulting from a 'strong strategic planning cycle' to instances where AVAs have been required to undertake a substantial review of their planning methods and ensure that strategic plans and operational statements include 'specific targets, allocated responsibilities and target dates'.
69 In examples of best practice, the strategic planning cycle was methodical, included appropriate references to Access provision, involved both executive and committee contributions, and was reflective in terms of future enhancement. For example:
[The OCN] operates a two-year strategic planning cycle which incorporates annual operational plans. The strategic plan is developed in the first instance by the staff of the AVA and is then approved by the Management Committee. The Committee is also responsible for the monitoring of the annual operating plans.
In its scrutiny of this process, the review team noted that the general strategic aims which emerge from the text of the current Strategic Plan are translated into more specific objectives; these are in turn used to produce specific targets and performance indicators in the annual operational plans. In the current planning documents, the team was able to trace this logical progression as it applied to the strategic aim for Access provision which culminated with a detailed action plan for [the OCN's] AVA activities. It was clear from its minutes that the Management Committee devoted an appropriate amount of its time to the discussion and monitoring of the Strategic Plan and the related annual plans.
In its Account, the AVA reported that an internal analysis had revealed the need for greater involvement on the part of its staff in planning processes. To this end, it has established a Strategy Group to inform the strategic direction of the AVA. Such a development can only enhance further what, in the belief of the review team, is an already effective strategic planning process.
70 The most common issue to surface in review reports related to OCN/AVAs and the place of Access in their strategic plans. In a number of cases, teams noted the absence of specific reference to Access or the lack of any particular objectives or targets which responded to the needs of Access provision. On occasion, an OCN/AVA might argue that Access 'remained central to the ethos of the OCN and was intrinsically embedded within its aims and objectives' and therefore did not require any particular attention in strategic planning (an argument similar to the one forwarded in respect of governance, see paragraph 38b above). It is clear, however, that the interpretation of the licensing criteria used by review teams led them to seek - whatever the planning process adopted by the AVA - a clearer identification of the needs of Access in strategic plans and a consequent greater specificity in aims and targets in plans and operational statements. As an example:
The team recognised the legitimacy of the AVA's integrated approach to strategic planning, but had concerns that the current processes did not secure the place of Access to HE or its development as a particular area of activity, and that the responsibility for the development and monitoring of a strategic agenda explicitly for Access to HE within the AVA's structures was uncertain...While not wishing to understate the extent and value of [the AVA's] current and recent developmental activity in relation to Access to HE, the team concluded that future strategic planning should include specific consideration of the further development of [the OCN's] AVA responsibilities and Access to HE provision. The results of this process should be reflected in discrete and specific strategic objectives, in order to secure the place of Access within [the OCN's] overall strategic framework.
71 In summary, review teams were faced with three general categories of strategic plans in OCN/AVAs:
72 Of these categories, only the first was consistently criticised by review teams. There were some OCN/AVAs which attempted the separate plans described by the last category and, despite the potential for lack of coherence or articulation between two such plans, it is worth noting that at least one had successfully managed this:
73 In another example, an OCN/AVA produced a three-year strategic plan supported by:
74 In cases where they perceived weaknesses in strategic planning processes, review teams also persistently commented on the failure to ensure that all appropriate activities of the AVA were brought to bear on strategic plans. In many cases, this involved an insufficient use of the data collected by AVAs (see paragraph 78 below); teams also noted instances where the outcomes of self-assessment processes were not always clearly used to inform future strategic planning.
75 On the evidence of the review cycle, the expectations of the Recognition Scheme in respect of the identification and targeting of particular groups which might benefit from Access provision have not always been satisfactorily met by AVAs. Typical comments were that 'targeting is currently perceived as primarily the responsibility of member organisations and there is no evidence of a deliberate strategic approach to following through any identification of low or non-participant groups with targeting policies or advice' or 'the AVA could play a more active role in helping providers to target and effectively recruit members of groups under-represented in higher education'.
76 AVAs do commonly offer valuable support and advice to their providers in the development of Access programmes for particular target groups and, in some cases, insist that providers demonstrate at the point of recognition that a proposed Access programme meets a target group specified in the general strategy of the AVA. The existence of aims related to the targeting of particular groups is not unusual in AVA strategic plans but review reports have been critical of the essentially passive approach adopted by AVAs and have encouraged them to adopt 'a more proactive and purposeful approach in the context of targeting policies and strategies'.
77 In general, review reports have avoided any detailed discussions of the relative merits of different management information systems. In addition, while they have noted instances where data collection and returns have been affected by late submissions or inaccuracies - and have required these to be remedied - their major interest has been in the use of data rather than its simple collection.
78 In particular, and as noted above, there has been frequent criticism of the failure to use data for the purposes of general strategic planning and, more specifically, to assist in the targeting of Access provision. Typical requests have been for an AVA to extend 'the depth and range of statistical collection, analysis and reporting in order to improve its capacity to monitor current Access to HE provision and its ability to plan for the future' or, where such data does exist, to make use 'of its own statistics and other data to evaluate the success of Access to HE programmes in identifying and reaching their target groups within the area', or to adopt 'a more systematic method for the evaluation and use of statistical data to review, develop and promote Access provision for the benefit of learners, providers and receiving HEIs in the region'.
79 Such comments indicate an important message from AVA review: some of the key principles of the Recognition Scheme, and the ways in which AVAs fulfil them as validating bodies, are reliant on the foundation provided by accurate and focused data on learners and provision and, more importantly, its deliberate use by AVAs to develop and promote Access opportunities in the regions in which they operate.
80 This is an area which attracted broadly positive comments from review teams. All but two AVAs had satisfactory written policies in place (in one of these cases, the AVA was using the policy of its host organisation which, in the judgement of the review team, did not adequately cover all aspects of the AVA's activities). In addition, the majority of AVAs made reference to equal opportunities in general, and to equal access to learning opportunities in particular, in their organisational aims and objectives.
81 Review teams also noted and commended AVAs where it was clear that the commitment to equal opportunities was not allowed to remain simply as a passive statement:
The AVA has an appropriate policy statement on equal opportunities, the implementation of which is apparent in relation to its major activities. The promotion of equal opportunities is also embedded in its mission statement and its statement of aims. The review team noted examples of the ways in which the commitment to equal opportunities was implemented in the AVA's activities. These include the checklist contained in the document, Submitting a Programme for Recognition where, following a restatement of the policy, providers are offered comprehensive guidance under the headings of curriculum, recruitment, course structure, the learning environment, and learner support, which is designed to ensure awareness of equal opportunities in all aspects of programme design and delivery. Moderators are also asked to comment on evidence that programmes are continuing to meet the equal opportunity requirements of the original submission document. The AVA is to be commended on its commitment to equal opportunities and the ways in which this commitment is evident in its activities and procedures.
and the AVA with:
...a statement on equal opportunities, which underpins the organisation's approach to membership, promotional materials, staff selection, and curriculum. The review team noted that a statement on equal opportunities was also a requirement in submission documents, and that the principles which governed the AVA's approach to moderation required moderators to comment generally on the issue of inclusivity, and specifically to examine methods of assessment for 'fairness, equality of opportunity and clarity'.
82 These examples serve as useful illustrations of the ways in which written policies can be actively implemented to ensure that equal opportunities are maintained as an effective and functional aspect of the work of the AVA.
83 At the time of the relevant AVA review, the following examples of commended practice were noted:
84 Some of the areas which might be developed further by AVAs in respect of this aspect of the Recognition Scheme are:
a improved processes by which, as part of their responsibility as validating bodies, AVAs verify the accuracy of providers' promotional literature;
b a consideration of the staffing levels necessary to offer a full service to providers and members;
c the adoption by OCN/AVAs of strategic plans which make specific reference to Access and contain appropriate objectives and targets for Access provision, or the use of a separate action plan for Access which is articulated with the overall strategic plan for the organisation;
d the use and evaluation of data for the purposes of strategic planning and, particularly, for the targeting of Access provision;
e more proactive and purposeful approaches by AVAs in the context of targeting policies and strategies;
f the active implementation of policies for equal opportunities across the activities of the AVA.
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