The end of TEF as we know it (and why that might actually be good news)

Karen Heard-Lauréote (she/her) – AHEP Lead Consultant

So, the Office for Students (OfS) has finally made the announcement. No more big-bang Teaching Excellence Framework (TEF) exercises where everyone holds their breath, scrambles for evidence and then relaxes for another few years, it seems.

Instead, we’re moving to something that sounds rather more constructive, to me, at least: continuous quality assessment on a rolling cycle.

If you missed Graeme Rosenberg’s blog post, here’s what caught my attention. The OfS wants to ditch what might be described as the current boom-bust approach to quality assessment. They’re replacing it with an integrated system that covers all providers, includes taught postgraduate provision, and operates on a four – to five-year rolling cycle.

It’s being labelled “improvement-focused” rather than compliance-driven, which, to me, frankly, makes it one of the more interesting regulatory announcements in recent times.

The mistake now would be for the sector to respond by asking when this will happen and what it will look like as if the key challenge is working out the exam format before the studying begins.

That’s missing the point entirely, I fear.

The paradigm shift

It seems to me that we’re not just getting TEF 2.0 with different timings. This is a fundamental philosophical shift about what quality assessment should actually achieve – and how institutions should think about improvement.

I’ve been in enough TEF preparation meetings to know how the current system works. Institutions operate in these distinct phases: business-as-usual, then frantic preparation mode, then submission and assessment, then back to business-as-usual until the next cycle. It’s like watching my daughter cram for A-levels – intense bursts of activity followed by periods of inactivity – or in the case of the TEF, periods where quality improvement gets shoved to the bottom of the to-do list.

The new approach assumes something completely different. It assumes institutions are continuously improving and can demonstrate that improvement whenever someone asks. No more cramming. No more of those desperate evidence-gathering exercises where you’re trying to remember what you did three years ago.

Just ongoing, embedded enhancement that’s visible when assessors turn up.

Now, this terrifies some people because it means you can’t wait until you know the rules before you start playing. However, it could actually be liberating for institutions that are genuinely committed to improvement, rather than just ticking compliance boxes.

Why ‘wait and see’ has probably just become the riskiest strategy

Just last week, I was in a conversation with a quality team lead who asked whether they should pause their improvement planning. “Should we wait until the OfS consultation concludes in autumn?” The thinking was: why invest in systems that might not align with whatever requirements eventually emerge?

I get the logic, of course. If we were talking about a new form to fill in or tweaking submission requirements, then yes, wait and see makes sense. But in this instance, we’re talking about building institutional capability for continuous improvement.

That capability will be valuable regardless of what the final assessment framework looks like. More than that – it’s what the sector should be doing anyway to ensure student experience and outcomes isn’t it?

The providers that start building these capabilities now will, I think, be in a much stronger position come consultation time. When the OfS asks for feedback on their proposals, would you rather respond from a position of “we haven’t started thinking about this yet”? Or “we’ve been testing approaches for six months and here’s what we’ve learned”?

The sector groups that have been engaging with the OfS conversations are already shaping what emerges. The ones sitting on the sidelines could possibly find themselves responding to a framework they had no hand in creating – and that rarely ends well.

What actually needs to change (and what doesn’t)

Despite all the noise about transformation, much of what institutions need to do remains remarkably consistent. The B conditions aren’t changing. The focus on student outcomes and experience isn’t shifting. Even equality of opportunity maintains its central position (thank goodness).

What’s changing is the expectation that institutions can demonstrate their approach to these areas continuously rather than episodically. This means shifting from evidence collection to evidence generation. Building systems that capture improvement activities as they happen rather than trying to reconstruct them retrospectively when someone asks to see them.

Consider this: the best institutions are continually improving. The challenge isn’t doing different work. It’s getting better at capturing and communicating the work they’re already doing.

Yes, this requires different infrastructure. Probably different governance arrangements too. It definitely needs different cultural expectations about how quality improvement gets documented and shared.

But it doesn’t require institutions to become fundamentally different places. Which is reassuring, because wholesale transformation in the middle of everything else happening in the sector would be… challenging.

The hidden opportunity in regulatory uncertainty

There’s also something else I find quite interesting about this moment. While some may be fixated on the uncertainty, a significant opportunity is actually hiding in plain sight.

The OfS is signaling that they want to move away from one-size-fits-all assessment. They’re talking about approaches that reflect “the full diversity of providers.” Proportionate effort. Context-sensitive evaluation.

They’re even exploring how different types of institutions might take different approaches.

This suggests much more space for institutional distinctiveness than the current TEF allows. Instead of trying to squeeze diverse missions into standardised metrics, the future system might actually celebrate what makes institutions different. While maintaining common standards for student experience and outcomes, obviously.

So what’s the catch? Well, providers will only really be able to take advantage of this flexibility if they’ve done the work to articulate what makes their institution distinctive. And crucially, how that distinctiveness serves their students.

That articulation work needs to start now, not when the consultation closes. Because if providers wait, they’ll likely be scrambling to define their distinctiveness under time pressure – and in my experience that never produces the most thoughtful results.

Building foundations while others wait

The institutions that will thrive in this new environment are I think the ones using the current uncertainty as a competitive advantage. While others wait for clarity, they’re building foundations that will serve them regardless of what emerges from the consultation.

What does this look like in practice? Developing systems that can capture improvement trajectories rather than point-in-time snapshots. Building stakeholder engagement approaches that generate ongoing insight rather than periodic consultation exercises. Establishing governance arrangements that support continuous enhancement rather than cyclical compliance.

Most importantly, it means shifting institutional culture toward viewing quality improvement as core business practice, rather than something that gets wheeled out when external assessment looms.

That cultural shift takes time, much longer than learning new submission requirements or adapting to different metrics. I’ve seen institutions try to change culture under pressure and the results are not usually pretty.

So for me, the institutions starting this work now will find the transition to continuous assessment relatively straightforward. They’ll already be operating in continuous improvement mode. Those waiting for the final framework may find themselves trying to transform their culture and systems under time pressure.

And as anyone who’s tried to implement meaningful change in HE knows, that’s never the ideal scenario.

What this means for your planning

So what should you actually do now while we wait to see the final shape of things from the OfS?

Start with an honest assessment of your current quality systems. Not compliance checking – genuine evaluation of how effectively your existing processes capture and demonstrate improvement. Most institutions I work with discover they’re doing excellent work but struggling to evidence it systematically.

Focus on building an evidence infrastructure that operates as business as usual, rather than conducting special exercises. This means integrating improvement documentation into existing processes. Annual monitoring becomes an evidence source. Programme review generates case studies. Student feedback cyclescapture impact stories.

Develop your institutional narrative around what makes you distinctive and how that distinctiveness serves your students. This isn’t about producing endless new marketing copy – but rather a genuine reflection on your educational philosophy and strategic priorities. The kind of deep thinking that can’t be rushed when deadlines loom.

Most importantly, start building the cultural expectation that quality improvement is everyone’s responsibility. Not just something that happens when an external assessment looms.

The beauty of this approach is that it makes you better at what you’re already trying to do while preparing you for whatever assessment framework emerges. It’s improvement with a purpose rather than compliance with a deadline.

The bottom line

It seems to me that the OfS announcement isn’t just about changing assessment methods but rather more a case of fundamentally altering the relationship between regulation and improvement.

Instead of external assessment driving occasional bursts of enhancement activity, the new approach assumes enhancement is continuous. Assessment simply captures what’s already happening.

This is actually much more aligned with how good institutions want to operate in my experience. The obvious challenge is building the infrastructure and culture to support it before it becomes a requirement rather than an aspiration.

The institutions that get this right won’t just be better prepared for whatever assessment framework emerges. They’ll be better at serving their students, supporting their staff and fundamentally, achieving their mission.

Which, when you strip away all the regulatory complexity, is what quality improvement should be about anyway, shouldn’t it?

So rather than waiting to see what the rules will be, we could all be getting at the actual game. In a sector facing multiple pressures and uncertain futures, that strikes me as the most sensible strategy available.

Want to explore how your institution can develop sustainable, high-quality systems for the new assessment environment? AHEP Consulting works with senior leadership teams to develop improvement capabilities that serve the institutional mission while meeting external requirements. Get in touch: consulting@ahep.ac.uk

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