Despite the trend towards consolidation, very little is being so far done towards this. The only way to gain credibility and trust is to create an effective regulatory system and fully submit to it. The regulatory system that Independent colleges submitted to so far was ineffective, and the proposed system of dual control through UK Border Agency Highly Trusted Sponsor Status, which focuses on how the colleges manage their international students, and review by Quality Assurance Agency, which involves how the colleges service the students, fail to go beyond the surface. Besides, the starting point of both these regulatory regimes is compliance to the system, mainly from an immigration control point of view, and it will leave out critical issues like the continuity and stability of the institution, relevance and currency of its curriculum and deliverable, and employability and progression of the students it taught. In a way, the requirements set by the current regulatory regime is based on a mistaken assumption that the independent sector will only ever service the international students, and is triggered by the presumption that every independent college is a 'visa college' indeed.
I am not suggesting that these requirements are meaningless - surely a college needs to recruit the right students and manage them adequately - but this kind of regulation is unlikely to generate any student confidence in the sector. In fact, once the dust settles - as it will at the end of 2012 - having an UKBA Highly Trusted Sponsor status and 'Confidence' in the limited review that QAA will carry out, will be like having access to electricity. It will be necessary, but no longer sufficient for survival. Further, these are not any excellence benchmarks anyway and will fall short of the expectations of the students, who are information savvy and demanding anyway.
This effectively means that the sector must set independent benchmarks and create a system of self-regulation, which must, given the severity of the problem, go beyond the cosmetic and offer substantial guarantees and safeguards to the students, local or international. This may mean creating some sort of guarantee for the students in case of an institutional failure, a reality in independent sector, which could be done through collaborative arrangements and collective insurance. This should also lead to the establishment of a code of practise, covering areas like how the agents are rewarded, a body to arbitrate student complaints, an ethical standard for public information and also how the academic staff is employed and rewarded. Indeed, one may go beyond and create awards and benchmarks for quality systems and performance standards, but this will surely follow.
Being at the sharp end, I feel the necessity of doing this immediately and effectively. However, the sector is fragmented and the practises are still quite immature. Besides, there are very few independent colleges who may end up on the other side of the tunnel, and hence, this may all become a question of timing. However, one thing is certain - the independent college sector must now aspire to go beyond the minimum and set standards of expectation for itself.