University of Leeds UCU agree with the stated objectives of the Green Paper: to provide the highest quality of education for our students, empowering them in the process, and ensure that a university education can be enjoyed by everyone who is able to benefit from it. We do not agree however that the TEF is a means of achieving these objectives. Nowhere in the documentation is ‘excellence’ defined, and this plainly undermines the arguments made about achieving it. The TEF will add another layer of bureaucracy onto an already over‐burdened profession, making excellent teaching harder to achieve. We do not believe that the metrics being proposed represent adequate proxies for teaching excellence. It is also self-evident that the attempt to define sector‐wide metrics could not adequately recognise the differences between disciplines in pedagogic, delivery or assessment terms.

The Green Paper argues that information about key elements of the educational experience either does not exist or is not widely available to applicants, and therefore cannot assist students in making informed decisions about their choice of university. We do not recognise this as based in fact. There will be an increased administrative burden while universities accommodate the new requirements and change their procedures. Experience of the REF suggests that where there is reputational and financial advantage to be gained, universities will expend considerable effort to ensure that they obtain the ‘best’ results, and this will inevitably have a direct negative impact on academics, who will be at the front‐line in delivering them. One fear, consequently, is that TEF might have the paradoxical effect of making excellent teaching harder to achieve because of the increased bureaucratic burden it will place on teachers.

We support the ambition to increase the participation of all disadvantaged groups in HE. We are not convinced this can be achieved by a TEF as described. The Green Paper contains few concrete proposals about how to improve access to HE for students currently marginalised by the system. The Green Paper notes, correctly, that matters of ‘prior educational attainment’ cannot explain disparities in achievement between some BME groups and white students, although no alternative explanations are offered. This presents an inadequate frame for consultation.

There is a body of expertise and good practice and a network of relationships in some of the existing bodies that should not be jettisoned lightly. Also, as the Green Paper argues (para 13), some bodies have wider roles. With this is mind, we would argue that the QAA, along with the HEA and HESA, should be maintained in something like their existing form and with their current responsibilities.