New rules that will force English universities to keep students’ assessed work for five years after graduation could cost the sector more than £100 million a year, say experts who have urged the Office for Students (OfS) to rethink its approach to tackling grade inflation.

At present, many universities destroy examination scripts or other assignments one year after they are marked, with some junking assessed work just .

Under its , however, England’s higher education regulator now requires universities to “retain appropriate records of students’ assessed work...for a period of five years after the end date of a course”. The OfS, which took over from the Quality Assurance Agency as England’s designated quality body last month, is “likely to need access to students’ assessed work, including for students who are no longer registered”, it adds.

With the OfS launching its first three investigations into alleged grade inflation, the revised rules are causing alarm among universities, which, having disposed of years of old student work, fear they are in breach of the regulator’s tougher conditions.

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“The vast majority of institutions are not able to comply, which is worrying as these investigations begin,” said Nicola Owen, chair of the Association of Heads of University Administration (AHUA), who added that the new retention rules “do not reflect how institutions operate at all” given the widespread use of written exams and practical assessment on campus.

“The OfS is assuming that most institutions are holding most assessed work in some form, a lot of it electronically,” she explained, adding that demand for “access to students’ assessed work” raised questions about the “very considerable amount of assessment” that might need to be held.

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“Are they saying that any piece of assessed work by any candidate should be accessible, even five years after graduation, if an investigator wants to see the link between that piece of work and its classification?” said Ms Owen, who added that a request that universities retain a sample of assessed work for inspection had already been dismissed by the OfS.

The cost of retaining student work for five years after graduation was likely to run into tens of millions of pounds a year, possibly more than £100 million, AHUA estimated, said Ms Owen. The regulator’s preference for anonymisation of assessed work, combined with the ability to identify the student if required, added “extra complexity and cost”.

“Universities have been asked to create this huge machine, but how many inspections will it conduct annually? It could be a relatively small number,” said Ms Owen.

In order to comply with the rules, some larger universities faced set-up costs of £5 million and annual running bills of up to £1 million, said Jamie Roberts, policy manager at the Russell Group, who called for the “OfS to adopt a more proportionate and risk-based approach to regulation”.

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Addressing the House of Lords inquiry into the OfS, its chief executive Susan Lapworth claimed the guidance was “broadly consistent with previous guidance from a sector body” – a reference to Jisc’s non-binding advice to institutions – and would be “relatively straightforward where students submit their work electronically”. Universities would not need to keep large pieces of art from degree shows, she added.

Even storing digital copies of practical work would, however, entail considerable costs, said Gordon McKenzie, chief executive of GuildHE, which represents smaller specialist institutions focused on the arts and vocational subjects. 

Universities might also need to retain filmed clinical assessments, architectural models, degree show fashion items, design portfolios and large assessed work for agricultural science, he added.

Previously, the QAA did not prescribe a fixed period for keeping assessed work, which was only held in case of an academic appeal. An AHUA spokeswoman said the timescales for making appeals were “typically within months, not years” and the Office of the Independent Adjudicator puts a one-year limitation on appeals after an institution completes its procedures.

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Jean Arnold, director of quality at the OfS, told ����Vlog that the “sustained and significant growth in higher-degree classifications over the past decade not only undermines students’ hard work but also public confidence in higher education”, pointing out that “the proportion of first-class degrees awarded in England has more than doubled, from 15.7 per cent in 2010-11 to 37.9 per cent in 2020-21”.

The OfS’ investigations sought to understand and identify the factors that might have contributed to such an increase, said Ms Arnold. “To better inform our work on tackling grade inflation, we expect universities and colleges to retain appropriate assessed student work to examine that assessment is effective and consistent between students and over time,” she added.

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A working group with representatives from the sector had been created to identify “the types of assessed work and what it is appropriate to retain, which will take into account the various assessment formats at different universities and colleges”, said Ms Arnold, who added that this would inform “supplementary guidance on which work we expect to be retained”.

jack.grove@timeshighereducation.com