Policy paper

Reducing bureaucratic burden in research, innovation and higher education

Published 10 September 2020

Applies to England

1. Ministerial foreword: Ministers Donelan and Solloway, and Lord Bethell

Coronavirus (COVID-19) has had a significant impact on the research, innovation and higher education sectors and its effect will be felt in a myriad of unpredictable ways for some time to come. However, we can draw inspiration from how the research, innovation and university teaching communities have responded to the pandemic – quickly finding new ways of working, driving collaboration and partnerships.

High level skills, research and innovation are an integral part of the government strategy^{[footnote 1]} to overcome and recover from the current pandemic. The research response to coronavirus (COVID-19) has provided positive lessons across the research pathway and highlighted areas which need improvement. This learning will support the future health resilience of the nation and the ambition to make the UK the leading global hub for life sciences.

The government has taken urgent action to support the research, innovation and higher education sectors through this challenging and uncertain time.

We announced on 4 May 2020 a higher education package that included reprofiling of public funding. Recognising that there remains a high level of uncertainty around the financial challenges higher education providers will face in 2020 to 2021, we also recently announced the higher education restructuring regime to support providers who are at risk of market exit because of coronavirus (COVID-19)

Government support for university research has focused on the announcement in June in the form of our research stabilisation package. This means a new funding scheme will open in the autumn to cover up to 80% of a university’s income losses from a decline in international students, up to the value of its research activity from non-public sources. In addition, £200m of new government investment has been made immediately to support researchers’ salaries across the UK, bolstered by a further £80m redistributed from existing UK Research and Innovation funds. This builds on the announcement in May of £100m of university research funding for universities in England brought forward by a year to provide initial support.

Pressures on the health and care system led to a necessary pause in some research activity and we have worked closely with funding and delivery partners to support prioritisation of resources, develop guiding principles for the restart of research in health and care settings, and enable the delivery of coronavirus (COVID-19) vaccine trials.

As the nation recovers from this pandemic, the government is determined to help refocus resources on the core essential activities of research and teaching.

We have been concerned by a major growth in bureaucracy over recent decades, which became particularly apparent for the R&D system during the pandemic, much of which has added limited value or in some cases led to negative behaviours or consequences. Too often administrative activities are a distraction from the core purpose of research and education providers.

We recognise that government has to take its share of responsibility for the growth of that bureaucracy. That is why DfE and BEIS, working with the Office for Students (OfS) and UK Research and Innovation (UKRI), and DHSC’s National Institute for Health Research (NIHR) are announcing a substantial reduction in bureaucracy to help focus on what really matters. We have identified significant sources of unnecessary bureaucracy that will be removed immediately, as well as a commitment to a wider reduction of bureaucracy in universities and a system-wide review of the causes of unnecessary research bureaucracy over the coming months. In doing this we want to free up providers to concentrate on delivering the high-quality teaching and research that our economy and society need.

Our approach outlined in our announcement is twofold.

1. Outlining where we intend to remove or reduce reporting requirements and address unnecessary bureaucratic processes immediately; and

2. Setting out areas that OfS, UKRI and NIHR plan to review over the next few months with a view to reducing reporting requirements and administrative burdens as much as possible.

Furthermore, we can achieve these significant reductions in bureaucracy whilst maintaining our world-leading scientific standards and our focus on important issues such as the equality, diversity and inclusion agenda and the importance of "levelling-up" across the country.

We recognise that this package builds on reforms that regulators, funding bodies and institutions are already making. To have lasting impact, this must be a continuing, collective effort to reform and simplify processes and providers must play their part by reducing their own internal bureaucracy. Our focus throughout must be to support the delivery of high-quality teaching and ground-breaking research.

2. The Office for Students and DfE

DfE is working closely with the OfS on our shared agenda to reduce unnecessary bureaucracy, and to ensure the higher education regulatory system is truly proportionate, risk based, transparent and accountable. The measures outlined below are a combination of decisions taken by the OfS to help achieve those aims, and changes that DfE would like the OfS to implement. DfE will be following up this policy document with strategic guidance to the OfS, to ensure both the regulator and the sector are clear about our vision, and with legally binding directions where appropriate.

2.1 Enhanced Monitoring

The OfS undertakes enhanced monitoring where they feel a provider is at risk of breaching a condition of registration. This has been an important and valuable tool during the initial registration period, enabling the OfS to better understand and address areas of concern. However, as it enters a new phase of regulatory activity, we agree with the OfS that the need for enhanced monitoring is significantly reduced. We therefore welcome the fact that the OfS has committed, in its recent letter to providers, to a large scale reduction in enhanced monitoring across most of its conditions, to the extent that it will be used minimally for all conditions of registration other than those related to financial sustainability, which is of course particularly important at this time. The OfS has also committed to acting with transparency and accountability, making clearer what reporting requirements are required by which providers and why.

We think that the need to monitor compliance more closely should be confined to a small number of cases and consider that this should be done wherever possible through the imposition of specific conditions. We would expect that this would only be a very small fraction of the cases that are currently subject to enhanced monitoring, where it is justified by the risks posed.

We are pleased that the OfS intends to report to DfE within 3 months on the reductions it is making to its use of enhanced monitoring. We also welcome that the OfS will also be looking across all of its regulatory requirements to ensure that guidance and, where appropriate, templates are in place and suitably clear. This will ensure providers are confident about the level of information required of them, so that they can respond proportionately.

2.2 Data Futures

Data Futures is a UK-wide project funded by the OfS and other funding bodies to reform the way student level data is collected and used in HE. It involves consolidating data collection so the same data is collected from all registered providers, and improved data collection infrastructure. We fully support these elements, which will lead to better data with fewer data items, and a more streamlined process – so they will actively reduce burden.

It was also intended that data collection would move from annual to termly, to enable more responsive regulation. However, DfE and the OfS have listened to the concerns expressed by university leaders, that termly data collections will impose a significant burden on providers. We welcome the fact that the OfS has therefore decided to review the proposed termly collection, with a view to ensuring data collection is proportionate. The review will also look at how data can be collected more quickly as the systems are improved.

2.3 Random Sampling

Currently 5% of all OfS registered providers are subject to random sampling each year as part of OfS regulation. For selected providers this is equivalent to a full registration and review process.

The OfS has announced an intention to suspend random sampling as they believe other processes are robust and proportionate enough. We welcome this change which represents a significant reduction in both real and potential burden on providers.

2.4 The National Student Survey

The National Student Survey is a UK-wide survey jointly funded by the four UK administrations. We have asked the OfS to undertake a radical, root and branch review of the National Student Survey (NSS), to ensure it supports the maintenance of high standards while providing reliable data on the student perspective.

Since its inception in 2005, the NSS has exerted a downwards pressure on standards within our higher education system, andthere have been consistent calls for it to be reformed. There is valid concern from some in the sector that good scores can more easily be achieved through dumbing down and spoon-feeding students, rather than pursuing high standards and embedding the subject knowledge and intellectual skills needed to succeed in the modern workplace. These concerns have been driven by both the survey’s current structure and its usage in developing sector league tables and rankings. While government acknowledges that the NSS can be a helpful tool for providers and regulators, we believe its benefits are currently outweighed by these concerns. Further, its results do not correlate well with other, more robust, measures of quality, with some of the worst courses in the country, in terms of drop-out rates and progression to highly skilled employment, receiving high NSS scores. Accordingly, the extensive use of the NSS in league tables may cause some students to choose courses that are easy and entertaining, rather than robust and rigorous.

The government shares concernsraised by some in the sector that, in its current form, the NSS is open to gaming, with reports of some institutions deliberately encouraging their final year students to answer positively with incentives or messaging about their future career prospects. Academics have also criticised the cost and bureaucracy the NSS creates, arguing that the level of activity it generates can be a distraction from more important teaching and research activities. There is a sense that the level of activity it drives in universities and colleges has become excessive and inefficient. For example, we are aware that some providers employ analysts to drill down into NSS performance, in some cases at module level, and investigate any sub-par performance.

Student perspectives do play a valuable role in boosting quality and value across the sector, but there is concern that the benefits of this survey are currently outweighed by the negative behaviours and inefficiencies it drives. Universities must be empowered to have the confidence to educate their students to high standards rather than simply to seek ‘satisfaction’.

We are therefore asking the Office for Students to undertake a radical, root and branch review of the NSS, which:

• reduces the bureaucratic burden it places on providers
• ensures it does not drive the lowering of standards or grade inflation
• provides reliable data on the student perspective at an appropriate level, without depending on a universal annual sample
• examines the extent to which data from the NSS should be made public
• ensures the OfS has the data it needs to regulate quality effectively
• will stand the test of time and can be adapted and refined periodically to prevent gaming

It will be for the OfS to take forward this radical review. We would like the OfS to conclude their review by the end of this year.

2.5 No further regulatory action on student transfer arrangements

The OfS is required in law to monitor the availability of schemes or other arrangements for student transfers. When registered, providers are expected to publish their arrangements for transferring students internally and to other providers. The OfS has decided it will review the current requirements and consult on any changes.

2.6 Estates data and non-academic staff data:

These are both data collections that the OfS has announced will be made non-mandatory in England, because the data is not needed for the OfS to fulfil its functions. We welcome this decision, and the principle on which it is based.

2.7 A review of TRAC (T)

This is the Transparent Approach to Costing for Teaching. This data has been used by the Government to monitor efficiency and the actual cost of delivering provision. However, we have listened to sector concerns that it is disproportionately burdensome to its impact, and are therefore proposing an OfS review to consider if this could be made more effective. The OfS has also agreed that because of the review it will not require a TRAC (T) return to be submitted for 2019 to 2020. OfS will work closely with UKRI on this to ensure coherence with evidence gathering for the review of the research aspects of TRAC, while allowing the two reviews to progress in tandem.

2.8 A review of the Transparency Condition

The OfS is required in law to impose a condition of registration that requires providers to supply certain information relating to offers and acceptance of places on higher education courses, completion rates and academic outcomes (and may be requested by reference to gender ethnicity or socio-economic background). While it is important that the OfS continues to collect data necessary for it to perform its functions, and to monitor and explain trends in higher education, we are pleased that they intend to explore whether there is scope to reduce information requested under this registration condition and consider if more reliance can be placed on other sources.

2.9 Efficiency savings

The OfS has today announced that, in recognition of the shared difficulties the sector is facing at the moment, it will conduct a review of its own efficiency with a view to reducing its registration fees by 10% in real terms over two years. This will represent a direct saving to providers. Alongside this, the Government will be bringing forward the review of OfS registration fees, which are set by the Secretary of State from 21/22 to this autumn.

The OfS will also expect the Designated Data Body and the Designated Quality Body to work in line with them in seeking improvements to efficiency and value for money for providers, in order to deliver comparable reductions in statutory fees.

2.10 Timing of Reviews and Decisions

The OfS will report on its review of the NSS before the end of the calendar year.OfS and UKRI will set out a clear way forward on how they will be reviewing TRAC by October.

OfS will report on enhanced monitoring requirements in place within three months.

We expect the OfS to:

• report on its proposed approach to the Transparency Condition by end October 2020, with conclusions following its board decision in December 2020
• report on its proposed approach to termly data collection by end October 2020, with final conclusions to be announced by April 2021, as part of the OfS Data Strategy

We are aware that the other nations of the UK have a stake and interest in several elements of this statement, particularly Data Futures, TRAC and the NSS, and the OfS will engage and work with devolved governments and funding bodies fully during its reviews.

3. UK Research and Innovation and BEIS

UKRI is implementing a set of major changes to how it interacts with applicants – innovators and researchers – and its broad range of stakeholders across research, business and government. The changes build on work already underway across UKRI to streamline and simplify its processes and the lessons learnt during UKRI’s rapid response to the coronavirus pandemic.

These changes are focused on reducing the burden placed on researchers and innovators applying to UKRI whilst ensuring UKRI continues to invest in the best ideas and people. They have been designed to support the Government’s ambition to eradicate unnecessary bureaucracy in the public funding system for research and innovation.

UKRI has a clear plan on how to reduce bureaucracy further, beginning with a root and branch review programme starting now to look at UKRI’s approaches to:

• selecting the right things to fund
• assuring the funding is spent for the purpose allocated
• capturing the outcomes

This will include the following:

3.1 Selection process

1. Reviewing, with a view to simplifying, the criteria for organisations to be eligible to apply to UKRI for both research and innovation funding.

2. Streamlining the 200+ research and innovation grant schemes run by UKRI e.g. moving to single institutional "Impact Acceleration Accounts" for all future funding rounds and maximising the standardisation of Terms and Conditions.

3. Changing to a streamlined, two stage application process for standard grant rounds. Applicants will only provide the information necessary to make a funding decision up front, with information necessary to make an award only required for successful proposals.

4. Replacing multiple, varied approaches to providing CV and track record information with a single format based on the Royal Society’s Résumé for Researchers.

5. Implementing a brand new, fully digital, user-designed, applicant-focused and streamlined grants application system with the first pilot launched in August.

6. Ensuring there is a single information document for a funding call rather than multiple documents to consult.

3.2 Assurance and capturing outcomes

1. Harmonising reporting requirements across UKRI and where possible with other funders.

2. Reducing the number of questions for mandatory reporting for the Researchfish 2020 Submission Period and actively reviewing our approach to outcomes monitoring with a view to ensuring it is fit for purpose and minimally demanding on our awardees e.g. via use of ORCID/integration with other datasets.

3. Identifying opportunities to enhance our risk-based funding assurance approach to align better to the organisation and project type, to reduce the burden of independent audits and where possible assure the organisation’s funding, rather than individual projects.

4. Reviewing end of award reporting, for example, the use of and process for Final Expenditure Statements.

3.3 Broader systems and activities

1. Working with external advisers to provide additional, independent challenge and to calculate the total costs of bureaucracy.

2. Stopping multiple asks for data or information that already exists elsewhere e.g. in ORCID, CrossRef, DataCite and Companies House.

3. Reviewing the approach to, and use of TRAC, with a focus on the research aspects of TRAC, to identify and implement improvements to ensure we accurately capture the true costs of research and innovation and act in a sustainable and informed manner. UKRI will work closely with the OfS and funding bodies in the devolved administrations on this to ensure coherence with evidence gathering for the review of TRAC(T), while allowing the two reviews to progress in tandem.

UKRI will work closely with key stakeholders to design, deliver and evaluate the impact of these changes to ensure that they result in true systemic reductions in bureaucracy rather than simply moving the burden to another part of the system and without compromising UKRI’s ability to invest in quality ideas, researchers and innovators.

UKRI will engage across the UK sector to develop and deliver this review, linking closely with the wider BEIS-led review of UK sector bureaucracy, to identify the opportunities available to reduce bureaucracy for both UKRI and award holders, and ensure its understanding of the costs of bureaucracy is accurate, fair and robust.

Embedding good practice in equality, diversity and inclusion in our administrative processes is critical to supporting our commitments to address inequalities, challenges and issues, and drive transparency and accountability. To help us better understand these issues we need to collect information such as data on diversity and protected characteristics, and in future we may need to collect additional data. We need to use this information to understand and address inequalities in a targeted way. Wherever possible we will use existing data sources and, should we need to collect additional data, we will do so with clear consideration of the impact these requests place on those submitting information.

In addition, in the longer term, UKRI will undertake a first principles review of UKRI Research Institutes to ensure that these institutions continue to fulfil a unique and valuable role within the research and innovation landscape as UKRI expands its ambitions. ­­­­

4. DHSC’s National institute for Health (NIHR)

The Department of Health and Social Care’s (DHSC) National Institute for Health Research (NIHR) has previously implemented a range of measures to reduce burdens on researchers, by streamlining funding application processes, mitigating duplication of reporting and improving the management of ‘excess treatment costs’ in non-commercial research.

4.1 New commitments

Building on this previous work, NIHR is now following a two-stage process to reduce bureaucracy further with some immediate changes as well as a review of systems and processes in autumn 2020 designed to deliver further significant improvements. NIHR will work with researchers, institutions and other funders to review the burden of bureaucracy and how this can be reduced further in the following areas:

• funding application and compliance processes
• peer reviewing funding applications
• NIHR research contracting
• monitoring and reporting against research contracts

4.2 Funding application and compliance processes

From 1 August 2020 the stage 1 standard NIHR application form was reduced from 17 to 6 pages. In consultation with stakeholders, NIHR will review the stage 2 standard NIHR application form with a view to significantly reducing its length by autumn 2020. A preliminary assessment indicates that the form could be reduced by up to a third.

4.3 Peer reviewing funding applications

Peer review is the evaluation of work by one or more people with similar competencies as the producers of the work (peers). It functions as a form of self-regulation by qualified members of a profession within the relevant field. It is critical to the delivery of good quality research but can become burdensome where there is a limited filed of expertise or a significant volume of research.

Over the next three months NIHR will consider ways of making peer review more proportionate, for example:

• a risk-based approach – reducing peer review for low risk studies, for example, where the methods used are well established and the scale of the research is small
• increased use of peer review by funding committee members (to complement external peer review as appropriate) so that those already involved in the selection process conduct the peer review thereby reducing stages in the process where possible
• shorter reviewer forms to reduce the burden on reviewers and others involved in the selection process

4.4 NIHR research contracting

NIHR research funding is underpinned by detailed research contracts between DHSC and organisations hosting NIHR research.

NIHR will immediately delete clauses which place obligations on research institutions which add limited value to the general research endeavour and end user from the standard NIHR contract. In addition, over the next three months in consultation with key stakeholders, NIHR will review the scope for rationalising the NIHR contract further, with the aim of reducing burdens on researchers and research organisations associated with negotiating and agreeing contracts.

NIHR will review eligibility criteria for all funding streams including requirements for compliance with charters and concordats. This review will take place in the context of the NIHR commitment to equality, diversity and inclusion.

In particular, NIHR will no longer require academic partners applying for some NIHR Infrastructure awards and for Integrated Academic Training (IAT) posts to hold a Silver Award of the Athena SWAN charter for Women in Science. However, as a research funder that is committed to actively and openly supporting and promoting equality, diversity and inclusion (EDI) we plan to strengthen our approach. We will expect organisations that apply for any NIHR funding to be able to demonstrate their commitment to tackling disadvantage and discrimination in respect of the nine protected characteristics set out in the Equality Act (2010). These are: age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

Organisations will be expected to demonstrate at application how the protected characteristics have been considered and addressed in their proposal, including steps taken to ensure the work programme does not perpetuate or exacerbate inequalities. We will continue to work closely with our partners in Advance HE to ensure the NIHR continues to focus on EDI and recognises that Charters for equality continue be useful tools for organisations that demonstrate good practice, as will the Concordats that support research integrity and the career development of researchers.

4.5 Monitoring and reporting against research contracts

NIHR currently obliges researchers, through a standard contractual provision, to notify DHSC of all publications associated with their research. There are multiple publications per project taking account of press releases, journal articles and presentations of findings (for example scientific papers at conferences). This contractual clause will be deleted for almost all new contracts from 1st August 2020 and researchers holding current contracts will be notified of this change in requirement which will apply to most existing contracts.

Further changes to facilitate more proportionate monitoring and reporting, including reporting of outputs, will be made in the autumn following consultation with stakeholders.

5. Reductions in providers’ internal bureaucracy

This announcement is intended to support universities and other higher education providers to focus on their core priorities of delivering high quality teaching and research. Government is clear that providers must also play their own part in this: by reducing their own unnecessary bureaucracy, administrative tasks and requirements placed on academics that do not demonstrably add value.

We therefore expect providers to ensure reductions in government or regulator imposed regulatory activity are not replaced with internal bureaucracy. In addition, we want them to go even further to enable academics to focus on front line teaching and research: stripping out their existing unnecessary internal bureaucracy, layers of management and management processes.

There are a wide variety of organisations which offer voluntary membership awards or other forms of recognition to support or validate an organisation’s performance in particular areas. Some of these are specific to the higher education and research sector, and others are offered more broadly. Such schemes can be helpful but can also generate large volumes of bureaucracy and result in a high cumulative cost of subscriptions. Where a university believes that membership of such schemes are genuinely the best way of addressing a matter, it is of course free to do so, but in general universities should feel confident in their ability to address such matters themselves and not feel pressured to take part in such initiatives to demonstrate their support for the cause the scheme addresses. We have therefore asked the OfS, UKRI and NIHR to ensure that they place no weight upon the presence or absence of such markers or scheme memberships in any of their regulatory or funding activities.

This aligns to the OfS’s planned development of its approach to the regulation of quality which will ensure that universities are clear that voluntary codes and guidance do not constitute regulatory requirements. Institutions should consider the extent to which the use of such voluntary material creates unnecessary bureaucracy and prevents academic staff from focusing on core teaching activities.

This also aligns to the announcement of the wider planned review of Research Bureaucracy and Methods on ways to minimise bureaucracy while maintaining flexibility, diversity and necessary accountability. We will engage with the sector, and in partnership with research funding bodies across the UK, to tackle the broader issues that are often causes of unnecessary bureaucracy.

This is also an opportunity to shift the research sector to more modern methods of research, which will help cut red tape too. This means embracing modern methods of peer review and evaluation. It also means tackling the problematic uses of metrics in research and driving up the integrity and reproducibility of research. Crucially, we must embrace the potential of open research practices.

1. Research and Development Roadmap and The UK Government’s COVID-19 Recovery Strategy. ↩