OfS Regional Access Partnerships Call for Evidence – FACE Response
(July 2025)
The Office for Students were seeking views on how best to create new regional access partnerships that bring together all higher education providers in a region with access and participation plans, to assess the local risks to equality of opportunity and coordinate efforts to address them.
FACE provided two responses:
- a general response that represents all HE providers in the membership.
- a second response that focuses on providers with multiple sites.
This response is to the Office for Students (OfS) call for evidence on Regional Access Partnerships.
First response on behalf of all members
Q1: What do effective regions for collaboration on equality of opportunity look like?
The Forum for Access and Continuing Education (FACE) members express that whatever the name chosen is, it should be as clear/non-confusing as possible to those who will need to understand it, for example careers advisers, schools, colleges and also learners (if they are supposed to engage directly). The name should reflect the purpose of the partnerships for example only include ‘uni’ if the outcomes are focused on progression to HE. Consider terms like equity in education which is broader and understandable by multiple audiences.
Members expressed concerns about lots of different previous names for similar partnerships (AimHigher, NNCO, NCOP, UniConnect). This is already confusing to stakeholders, and ideally future naming should have a staying power (to also reduce spend on rebranding).
Members also expressed that some existing regions are very proud of the brand (and engagement) they have built using the existing name and have concerns about this being removed e.g. Kent and Medway Progression Federation. A potential middle way would garner support, help with a national brand and provide clarity e.g. having a common name with a specific regional name in brackets e.g. Regional Access Partnership (Kent and Medway Progression Federation).
Clarity over whether these partnerships are delivery bodies or coordinators or convenors or a mix of all would be beneficial. Previous iterations of these programmes have varied in the amount of delivery expected but always seem to naturally evolve to be delivery focused.
Q2: What are your thoughts on the proposed regions, as set out in Annex A and B of this document?
Concerns relating to regions
Size of regions: FACE Members had concerns relating to the large size of the regions. Some regions span extremely wide geographical areas (e.g. South East), creating challenges where institutions on regional borders may have stronger natural partnerships with providers in adjacent regions rather than those within their designated region. In addition, some regions are so large that within them they are too varied to have defined regional needs: the needs of localised areas within the larger regions may be very different. Some members expressed a sense that these large ‘regions’ will organically devolve into smaller areas and partnerships.
Size disparities of regions: FACE members expressed concerns relating to the significant differences in region sizes (comparing Greater Manchester and Merseyside, for example) which raises questions about coordination capacity and where coordinators would be based.
Number of institutions in a region: FACE members expressed concerns that in some regions there are too many institutions. 30 institutions is far too many for effective and meaningful collaboration, 15 was recommend as probably the maximum, but that arguably is too many. Members expressed concerns that any sort of consensus and agreement would not be possible or take too long for bigger partnerships, especially in relation to local nuances within the larger regions – see concerns relating to size of regions. This may have a knock-on effect on relationships with schools and colleges which may become far more faceless and transactional which would be a problem for trust, effectiveness and connection. In addition, some providers in these large regions do not naturally cluster with each other and this may add additional challenges with collaboration.
Transport and accessibility: Geographical proximity may mean schools find it easier to work with institutions in neighbouring regions rather than those within their designated region. In addition, some regions proposed are so large it could take several hours to travel across them, and this would incur significant travel costs e.g. South West. One suggestion would be to base regional groups more on travel time, taking into account local transport infrastructure and transport links, rather than historic regions, for instance, reflecting and catering for the increasing number of students from disadvantaged backgrounds who are commuting to university (50%+ of IMD Q1 students in the last UCAS cycle).
Multi-site universities and online only providers: The proposals don’t clearly address how universities with campuses across multiple regions would fit into the regional structure. FACE will be submitting a separate response to the call for evidence on behalf of providers with a non-regional access focus. Freedom for providers to opt to be part of regions where they have campus bases and established relationships would be welcome.
Risk of disrupting existing collaboration: FACE members expressed concern that the proposed approach may ignore good practice and collaboration that already exists. Many universities are already engaged in effective collaborative working, and the transition needs to build on rather than replace these established partnerships. It may also interfere with existing good relationships that schools and colleges have with certain institutions.
Lack of rationale for decision: FACE members found the rationale for the regional partnerships unclear. Members suggested it would be good to align them to strategic entities, such as mayoralties or other forms of local government so that objectives can be aligned with other relevant regional priorities around social mobility. Members were unable to find evidence that has been considered. Members spoke of regions needing to align with existing regional structures and initiatives e.g. councils, careers hubs, schools networks, Chambers of Commerce (LSIPs) etc.
Alignment of recruitment and access work: Some FACE members expressed that the regions may work for institutions for whom their access and recruitment work is also regional, but it may be challenging for other institutions where this is not the case.
Subject provision: The suggested regions may not have a balanced offer in terms of subject/course choice. Providers who are specialists in a certain area eg Arts are focused on supporting national challenges and a regional approach may limit their engagement. FACE members expressed an interest in knowing how this would be ensured under the new proposal.
Target population: FACE members expressed concerns that the regions have been decided without considering the target population of the regions, for instance the regions may look different if focusing on FSM vs TUNDRA vs ABCS.
Cold spots: FACE members expressed concerns around how the partnerships address cold spots, where this is primarily the responsibility of the institutions adjacent to those cold spots, as opposed to a national imperative. This is particularly relevant in the South West where many coastal and rural communities exhibit entrenched patterns of low higher education participation, requiring highly localised, community-focused approaches that might be difficult to address through broad regional models.
Concerns relating to London
London’s complexity: Whilst geographically smaller, London contains a huge number of providers with vast diversity. There’s a risk that smaller providers could get lost in such a large grouping and that alignment of interests would be impossible.
London centres: A large number of universities (10-12) have centres in London as well as a main campus elsewhere. FACE members questioned how these would fit in with the proposed model.
Disparities amongst University of London institutions: Royal Holloway is a ‘University of London’, but not part of the London region.
Focus of London partnership: FACE members suggested that potentially the London regional partnership could have a different approach e.g. student success, focusing on cost of living for students.
Concerns relating to specific regions
Stoke-on-Trent: Stoke-on-Trent is part of the major drawing of the lines around Uni Connect but there is a brand-new region of the North Midlands mentioned in the proposal. For the past 20 years there hasn’t been a regional access partnership covering this new region and this will mean implications for merging Uni Connects for Higher Horizons and Dancop. Dancop would become a coordinating body which would be challenging considering transport links to Staffordshire. This might prevent current positive collaboration with other institutions e.g. Loughborough working closely with institutions in Derby and Nottingham because of better transport connections.
Sussex: There is an existing regional target for Sussex University, but the new OfS approach is very different to the county-level approach that they have taken where there is very specific and identified need.
Wider concerns about regional partnership approach
User-centred approach: Some FACE members expressed a concern that the regional divisions should be decided from a user centred approach, focusing on how a student would navigate the offer in their region.
Progression: There has been mention of the regional partnerships evolving to look at Progression(specifically regional graduate employment) as well as Access. There is a lack of evidence of whether this has been considered in the way that the regions have been constructed.
Focus: In some regions, the risks to equality of opportunity with respect to continuation or progression, might be more acute and widespread than access. For example, relating to London – is access an issue in London or would the partnerships be better focused on success? FACE members also expressed what this could mean for the allocation of funding, i.e. would London have a larger allocation of funding for access due to the number of partners, but access is less of an issue there than in other regions.
Alignment with UniConnect: Some regions have been aligned to UniConnect partnerships, but some institutions are not part of UniConnect partnerships.
National collaboration: FACE members expressed the lack of clarity over what this would mean for existing national collaboration. Would the regional partnerships be the only access focus for institutions, or would they still be expected to work collaboratively nationally as well, and if so in what proportion?
Data: There is some data available in the public domain for local areas, but it is not clear that institutions will have access to all the data needed to really understand the local areas within their region. OfS could support by sourcing and providing access to data sets that support the partnerships to address the local risks to equality of opportunity.
Q3: How could a region best collaborate to improve equality of opportunity in access to higher education?
Governance
Equality: FACE members expressed the importance of understanding how the providers within a partnership would be given equal representation (considering differences in size, demographics, provision etc). Members expressed that weighting needs to be considered between big and small universities, and colleges – the college APPs are much smaller and very bespoke to their own FE to HE progression. Members also expressed concerns about what provider is a lead and which providers hosts joint activity. Learners will remember a host university not a partnership and this has an impact on recruitment as well as meeting partnership targets. This is potentially where the proposed independent coordinator has a part to play or alternatively a third way that moves away from the lead institution approach, which poses a potential threat to the benefit of impartiality associated with Uni Connect.
Role of OfS: FACE members expressed the need for balance between OfS defined collaboration and institution-led collaboration. Existing positive current practice examples of regional collaboration include Kent and Medway Uni Connect with shared APP targets and intervention strategies for care leavers and the Sussex partnership has a shared FSM target. However, this approach is successful through being institution-led rather than being overly defined by the OfS. Members expressed that the role of the OfS should be more about an informational steer about what local area needs are, rather than what the HEIs must do.
Civic university engagement: Members suggested that since APPs already cover so much, could another area of a university contribute to the regional partnerships, for instance aligning the regional approach to the Civic University Agreements.
Importance of shared priorities: FACE members expressed that effective regional collaboration needs to be based on shared priorities, grounded in place and built on trusted relationships between partners. Members considered that not all providers in the proposed regions may have shared priorities. Members expressed a need to maintain institutional autonomy over the regional partnerships that are entered into, with whom the partnerships are made, and the extent of collaboration to ensure alignment with institutional strategic direction and priorities. Members commented that institutions who enter into partnerships voluntarily and based on shared values and mutual trust are more likely to be effective than anything that is imposed.
Funding
Input: If HEIs are expected to fund collaborative activities, they must have meaningful input into how regional partnerships are structured and operated.
Split of funding: FACE members requested more clarity on how the funding be split: what would the proportion for each institution be and how would that be decided? Concerns were raised in relation to what this may mean for institutions that are financially unstable at present. Some institutions are reducing their staff and it is unclear how this work would then be delivered.
Budget: FACE members expressed that there is not yet an understanding of budgets, who is paying for the work, where the funding would come from, whether there would be money to continue the work that is currently being undertaken and what work would have to discontinue. Members requested clarity on the focus of the funding, e.g. would it focus on broad-brush access work or still enable focus on smaller projects that work with smaller numbers e.g. care leavers work.
Targets: Members expressed concern about how all institutions in such vast regions could coordinate their APPs with regional access targets. Members requested clarity on how the targets would be decided on and who would be responsible to ensure they are met – the region or the lead institution or each individual institution? Members mentioned that even getting an agreement between three organisations for a shared target is challenging, this would be even more difficult for a large region with significantly more partners. Furthermore, a lot of institutions don’t have access targets: in a climate of financial instability, how would the partnerships enforce those institutions to devote resource to the access partnerships?In addition, members questioned whether it would be fair to students at that institution where there aren’t as many access challenges that their institution will have to divert resources from student success to access. Members also expressed that targets must align with school language/targets to aid school engagement and learner/parent/carer understanding of the aims of the partnerships.
Alignment with current APP targets: individual current APP targets might not align with the regions that have been proposed (e.g. IMD is a very useful London tool, but other regions may not find this as useful.) There is also a lack of clarity around what a provider should do if they already have a target that is decided for their region. Concerns were expressed that the approach may result in targets that don’t work for all the providers in their own context. Members expressed how well the current APP approach works which enables institutions to decide access targets that work in their context and are grounded in research.
Competition: Members expressed concerns that institutions are recruiting from the same streams and how the competition versus collaboration balance may look. Given the current financial requirement, it would be a hard sell for university leadership to take this approach if it’s more focused on widening participation than linked to recruitment. However, partnerships in which high-, medium- and low tariff providers are represented could help to address the challenge of undermatch, whereby disadvantaged learners are more likely to progress to universities with entry requirements that do not reflect their academic achievements, an area for improvement identified in the recent Public First review of Uni Connect.
Age groups: Members were concerned about a lack of clarity on age groups for the work of the regional access partners. In general, pre-16 access work tends to be more collaborative whereas post-16 more recruitment focused. This is particularly important in the current financial climate as many institutions are having to give up their pre-16 work. A new partnership model could be an opportunity to review research and follow recommendations such as working at primary school level.
Timelines: Members expressed concerns around timelines being unrealistic as time would be needed for institutions to agree on collaboration, including targets. Members expressed frustrations that many haven’t even started their new APPs yet and the evaluations will take time to enable institutions to figure out what works. Concerns were also expressed in relation to the sector being already under significant financial pressure and dealing with uncertainty.
Reputational damage: Providers have made commitments to partners through their APPs. There is the risk of reputational and relational damage if these are subsequently abandoned to align with alternative (regional) priorities.
Variations: Members expressed a concern that the introduction of the new approach may require institutions to undertake variations of the APPs that they have just had approved.
Evidence: FACE members requested more clarity on the evidence behind the regional approach, specifically on what underpins the assumptions in the theory of change. Members noted a lack of clear rationale about how the changes will benefit anyone but especially learners. Members request evidence that the approach will work, who is going to benefit and how. Members questioned how the learner is considered in this approach (how they navigate the skills and education ecosystem in a region) and how they fit within the call for evidence. Members also questioned how many schools will respond directly to the call for evidence, considering their capacity.
Existing partnerships: FACE members would like more clarity on what will happen to existing partnerships, both university partnerships and with schools. Unclear on whether this would increase or decrease the volume of schools that institutions work with.
Small and specialist: A one-size-fits all approach will not work especially for small and/or specialist providers. They may (or may not) deliver outreach locally or engage with their existing Uni Connect partnership. Rather, they may work with grass roots community organisations both local and nationally. Small providers are already expected to comply with the same regulatory and reporting requirements of much larger (and well resourced) institutions. Existing APP guidance is very much around what is appropriate “in your context” but this proposal appears context blind for many different types of providers.
School perspective: Whilst schools would benefit from having one contact point to access multiple universities, this may not be achievable in practice under the proposed model. Schools don’t always fully understand the current Uni Connect model, and adding another/different layer may increase confusion rather than provide clarity. OfS could support this by engaging the school/college sector at the highest levels to ensure the message is filtered through all schools/colleges.
Q4: One option for leadership and coordination would be working with an independent regional coordinator identified by the OfS to facilitate collaboration in each region. What are your thoughts on this approach?
Members expressed that work that is independent of universities is an admirable objective, and separation of WP from profit is positive.
Independent coordinator: FACE members expressed that there is a place for ‘independent’ regional coordinator but that it shouldn’t be tied to regulation otherwise the coordinator would not be independent. Concerns were raised that the coordinator should not dictate to universities. More detail is required on what a coordinator would look like, for instance would they essentially be a branch of OfS located in respective areas with their own offices and infrastructure? Concerns were raised about how the workload of the lead of these partnerships who would have to coordinate the objectives and priorities of up to 30 universities, especially in existentially challenging times and how they would set up the kind of relationships necessary for this by September 2026.
Knowledge limitations: Members expressed that it is likely unrealistic to expect coordinators to have sufficient time and deep knowledge across such large numbers of institutions and local contexts.
Limited influence: FACE members questioned how much support and actual influence these coordinators would have to drive meaningful collaboration.
Q5: What support would be required for your organisation to work collaboratively across a defined region to improve equality of opportunity in access to higher education?
Resource: FACE members expressed that support would be appreciated in research and planning. For instance, understanding the local area, what initiatives are already in place from other organisations within the region and how new members of partnerships could get involved in existing initiatives.
Culture shift: Support would also be required to engender a culture shift within institutions to be able to collaborate with institutions where that collaboration hasn’t previously been there and where the institutions have been competitors.
Engagement beyond HE: OfS can use its presence to engage with the school/college sector to share the existence and expectation of participation with partnerships. OfS could also explain to LAs, LSIP boards, Career Hubs at the highest levels to garner engagement and participation.
Advocacy: Some of the local and regional risks to equality of opportunity will be beyond universities to ‘fix’, an example of this is the educational outcomes and HE progression of boys on free school meals which requires policy changes at a school level. OfS could collate learnings and understandings and take them to DfE and other policy makers to support the wider education sector
Q6: What are your views on addressing regional risks to equality of opportunity in your access and participation plan?
National recruitment: FACE members expressed that the regional approach doesn’t speak to the expectation of national recruitment, needed by high tariff providers. Budgets are already stretched; this is going to be impossible on top of that in current financial climate.
Wider risks: Some risks to equality of opportunity are wider than the regions suggested. In addition, the risks/issue for small specialist providers may not be the same as those of other providers within their allocated region.
Variation within regions: Whilst there are some similarities in regional risks, particularly within larger regions these can be very different. For example, the diversity between city and rural universities, different types of providers and varying levels of competition.
Existing practice: Some FACE members expressed that many institutions already meet regularly to discuss regional risks and challenges – these established practices should be built upon rather than replaced.
Measurement frameworks: Members expressed that clear mechanisms need to be established for how collaboration will be measured and assessed. This should focus on outcomes for learners rather than process. The framework must also recognise that universities contribute to regional collaboration in different ways based on their size, mission, and local context.
Learner-centred approach: Members expressed that the “benefit to the learner” should be the primary consideration in designing collaborative approaches and measuring their success.
Q7: What are your views on a regional coordinator identified by the OfS providing feedback to us on levels of collaboration reflected in APPs?
Openness: Members expressed that if the regional coordinator was led by the OfS that might make institutions less open to reporting issues, but also that an OfS appointed coordinator might provide more impartiality rather than weighting towards lead institution.
Reporting mechanisms: FACE members expressed a desire for more clarity on reporting mechanisms and whether they are going to be manageable for small institutions.
Levels of collaboration: Members requested clarity on what ‘levels of collaboration’ means?Is it planning, shared delivery, targets? In addition, how will this be measured and what the consequence of not meeting the ideal level of collaboration would be?
Balance: Members requested clarity on how institutions may be judged on balancing institutional and regional access targets.
Cross-regional learning: Rather than just measuring collaboration within regions, there should be built-in mechanisms to share learning and good practice across the country and across regions. HEEL could play a role in supporting this.
Second Response
Regional approach for non-regional providers
This communication to the Office for Students (OfS) supports the FACE submission to the call for evidence.
This communication comes from a group of providers from the Forum for Access and Continuing Education who have discussed how the proposed new ‘regional’ approach to Access and Participation Plans could work for providers who do not have a strong regional ‘Access’ focus, as well as providers who need a national as well as regional approach.
This includes the following types of providers:
- Fully online providers (e.g. The Open University)
- Multi-campus providers (e.g. The University of Law)
- Providers who have a national access approach due to their specialism (e.g. Guildhall School of Music and Drama)
- Providers who have a national access approach due to their high tariff requirements in addition to a strong regional Access presence (e.g. The University of Cambridge)
A traditional ‘regional’ approach would not work for these providers as either they have no region (online), they have multiple regions, or (part of or all of) their Access work must be national to engage with learners who might progress to their institutions. The group focused on identifying how the ‘regional’ approach could be adapted to ensure that these providers are able to make the most impact on reducing inequalities nationally as well as addressing their own institutional access gaps.
Here are some suggestions below:
National grouping
Establish a ‘national’ grouping or ‘region’ for all these providers to be part of. These providers could work collaboratively to ensure national outreach provision, so learners from the whole nation have access to outreach about online, high tariff and specialist courses. Multi-site providers could also engage with this as much of their outreach is by necessity online and they could link in where they have capacity with regional partnerships local to their campuses. Providers who work both nationally and regionally could be part of both this national grouping and their regional one.
This national grouping could align and support the work of the future national collaborative outreach programme by providing this specialist outreach. The national grouping could also focus on key national priorities such as:
- ‘Boys Impact’
- Care-experienced and estranged students linking with charities like NNECL
- Service children with organisations like SciP Alliance
- Justice-experienced students
- Student carers
Special groupings by provider type
Establish multiple groupings for providers who do not fit the ‘regional’ model based on their provider type so that they can work collaboratively on relevant targets that would be applicable for those groups. From initial discussions, the four groups listed above were identified but there may be more.
Special groupings by demographic
Establish multiple groupings for providers who do not fit the regional model based on their demographics or targets. For example, grouping together providers who primarily attract mature students, those who have very diverse cohorts or those who do not have diverse cohorts.
Opt-out
Allow institutions for whom a regional approach would not be suitable based on their context to opt out of the regional approach, provided they have a strong supporting rationale. Provide a requirement for these institutions to develop some appropriate collaborative targets with relevant institutions.
We would be keen to discuss this with the Office for Students to work together to ensure that non-regional providers are both supported and appropriately challenged to make a significant impact on inequalities within higher education.