MillionPlus broadly welcomes the proposed reforms to the Teaching Excellence Framework (TEF) and wider quality system, particularly the move towards a more integrated and comprehensive approach covering all providers and provision types. However, there are significant concerns that the proposals risk shifting TEF from a system focused on quality enhancement to one centred on compliance, with potentially harmful financial consequences for institutions.

Key issues include the heavy reliance on data with known limitations (such as NSS, Graduate Outcomes Survey and LEO), time lags in outcomes data and a proposed ratings methodology that could oversimplify performance by assigning overall ratings based on the lowest metric. This risks unfairly penalising providers with diverse student populations and missions, potentially discouraging widening participation.

While supportive of assessing both student experience and outcomes, there are important contextual factors, such as institutional diversity and flexibility in assessment.

There is an overall need for a more balanced system that prioritises enhancement, ensures fair and contextualised assessment, and avoids unintended consequences for access, diversity and sector stability.