Medr regulatory system: consultation response

We welcome Medr’s commitment to the proposed regulatory approach to minimise burden on higher education providers. The flexibility to allow providers to choose their self-evaluation approach and the mapping of regulatory requirements onto existing toolkits and frameworks support efficiency and reduce duplication of effort. The measures will support providers to reduce the administrative burden for staff to meet the necessary regulatory requirements.

We recommend that Medr explicitly outlines which elements of the condition are mandatory and which are considered good practice. For example, providers are currently mandated to use the UUK Stepchange and Suicide Safer frameworks to inform their approach to student welfare. Yet, in the proposed regulatory approach, the frameworks are listed as potential methods for providers to use for self-evaluation and self-assessment. The language suggests that using the frameworks isn’t mandatory and is instead at the discretion of the provider. If it isn’t Medr’s intention, the wording should be clarified to ensure providers are appropriately informed of the requirements placed upon them.

In response to the first consultation of their regulatory framework, Medr has committed to holding realistic expectations of providers. It said it’ll do so by monitoring their approach to make sure it operates within clear timelines in a predictable, fair, and transparent manner. This commitment should be exemplified in Medr’s communication and publication of their funding allocations for mental health and wellbeing.

Currently, the UK higher education sector is facing significant financial pressures, and our members welcome a commitment to increasing the funding for mental health and wellbeing provision at Welsh institutions. However, for the 2025/26 academic year, the funding allocations were only formally announced to providers on 18 November 2025. The announcement didn’t provide sufficient time for institutions to submit their implementation plans to the regulator, as the turnaround was eight working days. The timeframe wasn’t properly communicated to our members, which placed undue pressure to implement plans before the deadline. Compounded by the funding allocations being released towards the end of the academic term, Student Services leaders experience an increase in their workload because of high demand for their services. We strongly urge Medr to review its approach to funding allocations to align with its commitment to being a fair and transparent regulator, as well as reflect on the timing in which it announces changes, so it considers peak times in higher education.

AMOSSHE acknowledges Medr’s commitment to collaborate with the sector. Our ongoing interactions with Medr enable us to support our members in understanding and implementing regulation and best practice in Student Services. We’re happy to facilitate opportunities for Student Services leaders to inform Medr’s regulatory approach, which is grounded in realistic expectations of the sector. We recognise that the regulatory approach is an evolving process and appreciate Medr’s willingness to learn and adapt over time.

The monitoring arrangements require Welsh providers to approach the staff and student welfare condition with the other conditions in mind. This approach presumes providers operate holistically in delivering higher education. The reality of large organisations is that they often operate in siloes. Moreover, the monitoring arrangements rely on the reader holding operational oversight across multiple areas. For example, the staff responsible for ensuring a provider meets the condition of registration about staff and learner welfare won’t necessarily be the same individuals with operational responsibility for the learner engagement code, the quality framework, and so on. As a result, the new arrangements may require providers to change their processes to accommodate a more holistic approach to governance and staff operations.

As the new monitoring processes are implemented, we request that Medr exercises leniency to accommodate providers undergoing more substantial changes to their governance and staff operations. It’d be useful for Medr to share examples of good practice where providers have taken a holistic approach to responding to the new conditions of registration. It’d strengthen our members’ understanding of how to conduct monitoring arrangements, and it’d highlight the relationship between conditions.

Higher education providers may need to review and adapt their internal governance structures to align with the new regulatory approach. It’s essential to ensure governance arrangements continue to serve the best interests of students. However, such structural changes are often complex and take time to implement, with implications that cascade down to operational areas like Student Services.

Given the scale of the adjustments, it’d be helpful for Medr to acknowledge the challenges by guaranteeing that their regulatory approach will remain stable once established. Providers would feel more confident about the significant investment required to make the changes, and it’d demonstrate that their efforts won’t be undermined in the future with new regulatory expectations.

Wales benefits from a diverse tertiary sector, meaning that every institution operates with a governance management model that suits its specific needs and mission. Consequently, some governing bodies are more risk-averse than others. We’d like to reiterate that the funding allocation process should be reviewed to align with Medr’s commitment to being a fair and transparent regulator. If it commits to providing the circular funding information by summer, it’d allow institutions to plan staffing ahead of the academic year and seek approval from their governance boards for their service delivery. By reducing administrative pressure, it’d also accommodate governance boards that are more risk-averse and, therefore, unwilling to put spend against an anticipated budget from the regulator.  

The staff and learner welfare condition of registration sets out requirements for providers to have effective arrangements in place to support and promote learner and staff welfare. We welcome and support the continued emphasis on improving the welfare of both groups. Our comments below offer constructive feedback on what we think would improve the implementation within Medr’s regulatory portfolio. 

Currently, we don’t believe the condition can be applied consistently across all tertiary providers due to the scale and diversity of the operations.  The language and approach of this condition echo previous practices of the Higher Education Funding Council of Wales. This means the proposed condition doesn’t fully reflect the wider tertiary sector’s varied starting points in supporting staff and learner welfare. Any attempts to apply a single condition of registration across the tertiary sector must operate within flexible timeframes to accommodate these differing starting points.  

We’ve also noticed that the condition is disproportionately focused on student welfare. For example, the list of guidance and frameworks which are used as examples for providers to consider in addressing this condition only relate to student welfare. As a result, we’re concerned that there’d be greater emphasis and burden placed on Student Services leaders to meet said condition. We recommend that Medr provide additional examples of guidance and frameworks that clearly relate to the staff element of the welfare condition. To ensure staff welfare receives equal attention to student welfare, the condition should also be more explicit in how Human Resources teams should collaborate with Student Services. It’d result in a consistent approach to improving both staff and learner welfare in higher education.

Our members find the current annual assurance return a useful exercise for assessing and improving their approach to student welfare. We appreciate Medr’s attempt to replace or complement existing data returns to minimise administrative burden on providers. Nevertheless, our Welsh members still need time to understand and inform their staff of the new requirements which introduces additional administrative burden on Student Services staff, especially for providers with smaller teams. 

Medr should also consider providing feedback on submitted data returns. Providers don’t currently receive feedback on their submitted data returns unless they’re approached for more information or are undergoing investigation by the regulator. Receiving feedback on institutional returns would improve institutional clarity, and it’d map out Medr’s expectations around the conditions, which would in turn strengthen future submissions from providers.

The supplementary detail for the staff and learner welfare condition states that Medr will issue a welfare action plan template for providers. It’s in development, and we’d like to advocate for it to be co-created with sector representatives. Particularly Student Services leaders who’ll ensure its compliance. A collaborative approach would align with Medr’s aim to reduce administrative burden for providers whilst ensuring an inclusive and timely regulatory approach.