Your views
7. Please share your response below.
Please share your response below.
(Required)
The introduction of a cost-recovery model of fees for accredited learning providers is of significant concern in the following ways:
A. Compounding current pressures in higher education and working against ARB’s aims to broaden access to the profession.
Tuition fees for UK UG students have remained almost static at £9250 since 2012, while there has been significant inflation in salary, energy and other material costs, eroding the real terms value of income available for universities to teach and support students. The Russell Group estimates that it now costs closer to £14,000 to educate students on STEM courses such as engineering and £10,500 for classroom-based subjects such as history (an average of £12,750 over all courses — see ‘Briefing — University Business Model Explainer’, August 2023, https://russellgroup.ac.uk/media/6145/university-business-model-explainer.pdf). This is a significant threat to the quality of education and support that can be provided to students: ‘universities cannot meet the rising level of subsidy required [due to static fees] simply by reducing costs in education without impacting on the quality.’
The inaccurate C2 banding of architecture is an issue well known to ARB, and we estimate that the actual cost of educating architecture students to the standard required – once specialist studio, workshop and printing facilities, design teaching SSRs and professional expertise are factored in – is comparable to that of engineering students. As a result, education in architecture will be running at a deficit in many institutions, and the introduction of ARB’s fee worsens this already very challenging financial outlook for the subject and provision for students. This is likely to contribute to a number of negative impacts, ranging from the more immediate to long term:
1. Less money available to teach and support students.
Accreditation fees are typically a subject-level responsibly, paid from the devolved budget allocated for supporting teaching and learning (fee income less charges for central services, facilities and salaries etc). ARB’s £9200 fee is equivalent to approximately 40 days of teaching (at our institution’s rate for professional tutors), the amount we would spend on practitioner-led studio teaching for 24 students for the entire year. Alternatively, it is roughly the total amount we spend each year to support field trips for students across our ARB-accredited programmes, or double the amount we spend subsidising material costs for key model making tasks. Subject budget holders already face tough decisions about what to prioritise within constrained budgets. As teaching is likely to be prioritised to maintain accreditation standards – particularly at a time when additional ARB guidance and new outcomes place more emphasis on professional skills – the risk is that cuts have to be made to funding for trips, material costs and equipment, disproportionately impacting students who have difficulty funding these themselves, and increasing barriers to their qualification.
2. Unequal impacts on students at different institutions.
ARB describes the new fee as a charge to providers, but it is in effect a fee applied indirectly to all students of architecture, because it must be taken from the income that universities receive via student tuition fees. This is an important point of clarification when ARB compares the charging of providers with the alternative that qualified architects bear the cost of architectural education. Without getting into the broader question of whether current students or graduates are best placed to pay for the cost of education — and the ethics of ARB’s flat registration fee structure – it is important to recognise that the cost always reaches individuals, whether directly via registration or indirectly via a component of tuition fees; the question is when and how. Understood in this way, the transfer of costs to students falls unequally. At a larger institution, the effective fee per student per year resulting from ARB’s fee may be as low as £20, but at a smaller school it could be over £150. The students likely to be paying a higher proportion of their fees to ARB — and therefore to be most impacted by a reduction in resources available to support their teaching — are those at institutions outside major regional centres and those that have more recently launched architecture programmes, often through innovative offers designed to appeal to under represented groups.
3. Reduced places for UK students to study architecture.
In the current HE funding model, international students pay considerably higher fees than UK students, bringing in a much higher income per student that cross-subsidises the education of home students (Russell Group, 2023). Where budgets are tight, this creates an incentive for institutions to focus on expanding recruitment of international students, thereby reducing the proportion of places available to UK students. ARB’s introduction of a fee compounds this situation, and frustrates the ambition to broaden access to the profession in the UK.
4. Less innovation in response to ARB’s new education framework.
Tight budgets limit funding for external tutors, meaning that internal staff need to take on a greater proportion of teaching. Innovation in education structures and teaching formats takes considerable time and institutions are already scaling back plans for more significant programme revisions in order to ensure they have sufficient resourcing to complete the most essential changes effectively. The fee will further this focus on core activities over innovation, working against the intention of ARB’s reforms to open up alternative routes to qualification that support a more diverse profession.
5. Closure of architecture programmes.
The timing of the fee introduction is very unfortunate, as schools initiate conversations with their institutions about the future of programmes. Discussions about how to cover the new annual fee will coincide with requests to fund the expansion of teaching provision to deliver new technical and practice competences, and for the academic and administrative support necessary to propose, develop and secure approval for major changes to programmes. As The Russell Group (2023) concludes, if funding arrangements are not changed ‘universities may be forced to make a range of difficult and potentially unpalatable choices, such as reducing the number and types of courses available across all disciplines’. ARB’s new fees weaken architecture’s position, and in extreme cases, this may prompt universities to reconsider whether architecture is a subject that they can afford to offer. With the removal of accreditation from UG programmes, the position of small MArch and Part III programmes (those outside of London and the most high profile institutions) may be particularly imperiled. Considering the fees now applied for accreditation, alongside the less visible — but considerable — resources involved in preparing accreditation documents and annual data returns, and assuring coverage of criteria through time-intensive teaching and assessment processes, institutions may conclude that only UG architecture programmes are viable. This could lead to reduced choice of level 7 accredited programmes and a more uneven geographical distribution, exacerbating the existing concentration of architectural knowledge and practice in certain parts of the country.
6. Curriculum narrowing.
The new Competency Outcomes shift the emphasis of architectural education decisively towards technical and professional skills, and away from a broader understanding of architecture’s historical, theoretical, urban and artistic contexts (compare the 9 subsections of GC 2-4 with CK1 and D2-4, which is a generous interpretation as D2-4 also overlap aspects of GC1 and GC7, a reduction from 27% of criteria to 2-9% of outcomes). Required to demonstrate efficiency while covering required competencies within tighter budgets, institutions are likely to have to prioritise recruitment of staff with technical and practical expertise rather than those with expertise in the architectural humanities. Over time this could result in a significant narrowing of architectural education (and research) with unintended consequences for the theoretical, historical, urban and artistic literacy of future architects and architecture. ARB missed the chance to avoid this in its limited response to academic concerns raised about the new framework and competency outcomes, but the fee further compounds this situation.
B. Undermining confidence in ARB’s processes, the policy and its application.
Other concerns relate to the way the fees have been devised and introduced, and to lack of clarity in the policy, which gives the impression that it has not been well thought through. This raises broader concerns about ARB’s capacity to devise effective policy and frameworks to achieve its (important) stated aims:
1. Communication and Consultation.
ARB acknowledges errors in communication, however there are more fundamental issues with the way fees have been introduced. A meaningful consultation on the options under consideration and investigation of potential impacts — on institutions and indirectly on students — should have been undertaken prior to the introduction of fees, rather than subsequently, once it has been made clear that changes to the already agreed approach cannot or will not be made. Following on from the introduction of a new education framework and competencies, with little attention seemingly given to the significant concerns raised by academics during consultations, the impression is that ARB does not well understand the pressures currently affecting UK HEIs and how these impact students, or value the views of academics.
2. Transparency of decision making.
It is unclear how ARB has arrived at the £9200 cost, other than that it is conveniently just short of a single tuition fee. This figure is far higher than those levied by other accrediting bodies. The extra cost is in part justified by the need to carry about additional visits and review processes, however, the case for their necessity is unclear. It is equally unclear what process of modeling or evaluation ARB undertook to decide that this was the most appropriate mechanism of cost recovery, what other options were considered, why they were disregarded, and what criteria were followed in this decision making.
3. Uncertainty of charges.
Arrangements for periodic review appear unclear. There is little indication of how regularly this might be anticipated, what would trigger it, or how much notice would be given. That makes it very difficult to budget for the considerable additional charges involved. Depending on the criteria used for conducting reviews, it may be that some institutions are more likely to be reviewed more frequently than others, exacerbating the unequal impact of fees on students described above. If the cause of that review is linked to resourcing, the charge for review would only compound those difficulties. In such circumstances, the triggering of a review, and the associated cost, might also lead to a loss of institutional support.
A. Compounding current pressures in higher education and working against ARB’s aims to broaden access to the profession.
Tuition fees for UK UG students have remained almost static at £9250 since 2012, while there has been significant inflation in salary, energy and other material costs, eroding the real terms value of income available for universities to teach and support students. The Russell Group estimates that it now costs closer to £14,000 to educate students on STEM courses such as engineering and £10,500 for classroom-based subjects such as history (an average of £12,750 over all courses — see ‘Briefing — University Business Model Explainer’, August 2023, https://russellgroup.ac.uk/media/6145/university-business-model-explainer.pdf). This is a significant threat to the quality of education and support that can be provided to students: ‘universities cannot meet the rising level of subsidy required [due to static fees] simply by reducing costs in education without impacting on the quality.’
The inaccurate C2 banding of architecture is an issue well known to ARB, and we estimate that the actual cost of educating architecture students to the standard required – once specialist studio, workshop and printing facilities, design teaching SSRs and professional expertise are factored in – is comparable to that of engineering students. As a result, education in architecture will be running at a deficit in many institutions, and the introduction of ARB’s fee worsens this already very challenging financial outlook for the subject and provision for students. This is likely to contribute to a number of negative impacts, ranging from the more immediate to long term:
1. Less money available to teach and support students.
Accreditation fees are typically a subject-level responsibly, paid from the devolved budget allocated for supporting teaching and learning (fee income less charges for central services, facilities and salaries etc). ARB’s £9200 fee is equivalent to approximately 40 days of teaching (at our institution’s rate for professional tutors), the amount we would spend on practitioner-led studio teaching for 24 students for the entire year. Alternatively, it is roughly the total amount we spend each year to support field trips for students across our ARB-accredited programmes, or double the amount we spend subsidising material costs for key model making tasks. Subject budget holders already face tough decisions about what to prioritise within constrained budgets. As teaching is likely to be prioritised to maintain accreditation standards – particularly at a time when additional ARB guidance and new outcomes place more emphasis on professional skills – the risk is that cuts have to be made to funding for trips, material costs and equipment, disproportionately impacting students who have difficulty funding these themselves, and increasing barriers to their qualification.
2. Unequal impacts on students at different institutions.
ARB describes the new fee as a charge to providers, but it is in effect a fee applied indirectly to all students of architecture, because it must be taken from the income that universities receive via student tuition fees. This is an important point of clarification when ARB compares the charging of providers with the alternative that qualified architects bear the cost of architectural education. Without getting into the broader question of whether current students or graduates are best placed to pay for the cost of education — and the ethics of ARB’s flat registration fee structure – it is important to recognise that the cost always reaches individuals, whether directly via registration or indirectly via a component of tuition fees; the question is when and how. Understood in this way, the transfer of costs to students falls unequally. At a larger institution, the effective fee per student per year resulting from ARB’s fee may be as low as £20, but at a smaller school it could be over £150. The students likely to be paying a higher proportion of their fees to ARB — and therefore to be most impacted by a reduction in resources available to support their teaching — are those at institutions outside major regional centres and those that have more recently launched architecture programmes, often through innovative offers designed to appeal to under represented groups.
3. Reduced places for UK students to study architecture.
In the current HE funding model, international students pay considerably higher fees than UK students, bringing in a much higher income per student that cross-subsidises the education of home students (Russell Group, 2023). Where budgets are tight, this creates an incentive for institutions to focus on expanding recruitment of international students, thereby reducing the proportion of places available to UK students. ARB’s introduction of a fee compounds this situation, and frustrates the ambition to broaden access to the profession in the UK.
4. Less innovation in response to ARB’s new education framework.
Tight budgets limit funding for external tutors, meaning that internal staff need to take on a greater proportion of teaching. Innovation in education structures and teaching formats takes considerable time and institutions are already scaling back plans for more significant programme revisions in order to ensure they have sufficient resourcing to complete the most essential changes effectively. The fee will further this focus on core activities over innovation, working against the intention of ARB’s reforms to open up alternative routes to qualification that support a more diverse profession.
5. Closure of architecture programmes.
The timing of the fee introduction is very unfortunate, as schools initiate conversations with their institutions about the future of programmes. Discussions about how to cover the new annual fee will coincide with requests to fund the expansion of teaching provision to deliver new technical and practice competences, and for the academic and administrative support necessary to propose, develop and secure approval for major changes to programmes. As The Russell Group (2023) concludes, if funding arrangements are not changed ‘universities may be forced to make a range of difficult and potentially unpalatable choices, such as reducing the number and types of courses available across all disciplines’. ARB’s new fees weaken architecture’s position, and in extreme cases, this may prompt universities to reconsider whether architecture is a subject that they can afford to offer. With the removal of accreditation from UG programmes, the position of small MArch and Part III programmes (those outside of London and the most high profile institutions) may be particularly imperiled. Considering the fees now applied for accreditation, alongside the less visible — but considerable — resources involved in preparing accreditation documents and annual data returns, and assuring coverage of criteria through time-intensive teaching and assessment processes, institutions may conclude that only UG architecture programmes are viable. This could lead to reduced choice of level 7 accredited programmes and a more uneven geographical distribution, exacerbating the existing concentration of architectural knowledge and practice in certain parts of the country.
6. Curriculum narrowing.
The new Competency Outcomes shift the emphasis of architectural education decisively towards technical and professional skills, and away from a broader understanding of architecture’s historical, theoretical, urban and artistic contexts (compare the 9 subsections of GC 2-4 with CK1 and D2-4, which is a generous interpretation as D2-4 also overlap aspects of GC1 and GC7, a reduction from 27% of criteria to 2-9% of outcomes). Required to demonstrate efficiency while covering required competencies within tighter budgets, institutions are likely to have to prioritise recruitment of staff with technical and practical expertise rather than those with expertise in the architectural humanities. Over time this could result in a significant narrowing of architectural education (and research) with unintended consequences for the theoretical, historical, urban and artistic literacy of future architects and architecture. ARB missed the chance to avoid this in its limited response to academic concerns raised about the new framework and competency outcomes, but the fee further compounds this situation.
B. Undermining confidence in ARB’s processes, the policy and its application.
Other concerns relate to the way the fees have been devised and introduced, and to lack of clarity in the policy, which gives the impression that it has not been well thought through. This raises broader concerns about ARB’s capacity to devise effective policy and frameworks to achieve its (important) stated aims:
1. Communication and Consultation.
ARB acknowledges errors in communication, however there are more fundamental issues with the way fees have been introduced. A meaningful consultation on the options under consideration and investigation of potential impacts — on institutions and indirectly on students — should have been undertaken prior to the introduction of fees, rather than subsequently, once it has been made clear that changes to the already agreed approach cannot or will not be made. Following on from the introduction of a new education framework and competencies, with little attention seemingly given to the significant concerns raised by academics during consultations, the impression is that ARB does not well understand the pressures currently affecting UK HEIs and how these impact students, or value the views of academics.
2. Transparency of decision making.
It is unclear how ARB has arrived at the £9200 cost, other than that it is conveniently just short of a single tuition fee. This figure is far higher than those levied by other accrediting bodies. The extra cost is in part justified by the need to carry about additional visits and review processes, however, the case for their necessity is unclear. It is equally unclear what process of modeling or evaluation ARB undertook to decide that this was the most appropriate mechanism of cost recovery, what other options were considered, why they were disregarded, and what criteria were followed in this decision making.
3. Uncertainty of charges.
Arrangements for periodic review appear unclear. There is little indication of how regularly this might be anticipated, what would trigger it, or how much notice would be given. That makes it very difficult to budget for the considerable additional charges involved. Depending on the criteria used for conducting reviews, it may be that some institutions are more likely to be reviewed more frequently than others, exacerbating the unequal impact of fees on students described above. If the cause of that review is linked to resourcing, the charge for review would only compound those difficulties. In such circumstances, the triggering of a review, and the associated cost, might also lead to a loss of institutional support.