15 Sep 2020
MillionPlus's primary concern is a lack of real clarity in how the OfS will actually use this condition, how it will define ‘material risk’ and how it will make that judgement. We are particularly concerned that the OfS will hasten market exit through this condition, rather than support providers in their recovery plans, with students facing instability if the OfS announces that their provider is going to exit the market.
It is not clear that OfS considers any of the current SPPs in place as sufficient to cover market exit. There is also the risk of “leakage” from C4 to C3 as the OfS gains greater understanding of what needs to be in a market exit plan. Should this happen, then it will make the process of producing SPPs even harder than now, particularly if the OfS starts to require market sensitive information to be included.
Providers need to be clear with students on what to expect should a provider be at risk of market exit, but the publication of a plan has the risk of potentially hastening that exit by creating confusion and anxiety. This could detract from a provider’s efforts to recover and avoid market exit. It is potentially the case that it will be the OfS identification of the risk that could exacerbate the risks of market exit, which would not be in the best interests of students.