University of Birmingham Putting Business At The Heart Of Higher Education: On Neoliberal Interventionism And Audit Culture In UK Universities

is a form of interventionism that seeks to pursue elite – corporate – interests. This means constructing a market rationality and constructing markets to better meet what the state takes to be elite interests. In the first phase of neoliberal interventionism in English higher education maintenance grants were replaced with loans, the National Student Survey was introduced to measure ‘satisfaction’, and the inadvertent creation of a £9000 fee-norm all helped to construct a market rationality in students. The second phase, which concerns the proposed reconstruction of the higher education market, started in November 2015 with the publication of the ‘Fulfilling our Potential’ Green Paper. This proposes to make it less bureaucratically cumbersome for ‘for-profits’ to enter the market. In terms of audit culture, a Teaching Excellence Framework is proposed, which would include representatives from employers and professional groups, along with academic experts on teaching, and students, on the assessment panels. Further, universities need to be ‘open to involving employers and learned societies representing professions in curriculum design [and developing] a positive work ethic, so [graduates] can contribute more effectively to our efforts to boost the productivity of UK economy’ (BIS, 2015(a): The Paper also that least 20% of graduates are not working in high skilled employment three and a half years after graduation and most employers of STEM graduates are concerned about shortages of high quality applicants’ (BIS 2015(a): This to prior messages from the Conservatives that non-STEM subjects are less useful for employment.

Neoliberalism is a form of interventionism that seeks to pursue elitecorporate -interests. This means constructing a market rationality and constructing markets to better meet what the state takes to be elite interests. In the first phase of neoliberal interventionism in English higher education maintenance grants were replaced with loans, the National Student Survey was introduced to measure 'satisfaction', and the inadvertent creation of a £9000 fee-norm all helped to construct a market rationality in students. The second phase, which concerns the proposed reconstruction of the higher education market, started in November 2015 with the publication of the 'Fulfilling our Potential' Green Paper. This proposes to make it less bureaucratically cumbersome for 'for-profits' to enter the market. In terms of audit culture, a Teaching Excellence Framework is proposed, which would include representatives from employers and professional groups, along with academic experts on teaching, and students, on the assessment panels. Further, universities need to be 'open to involving employers and learned societies representing professions in curriculum design [and developing] a positive work ethic, so [graduates] can contribute more effectively to our efforts to boost the productivity of UK economy' (BIS, 2015(a): 11). The Green Paper also holds that 'at least 20% of graduates are not working in high skilled employment three and a half years after graduation and most employers of STEM graduates are concerned about shortages of high quality applicants' (BIS 2015(a): 10-11). This contributes to prior messages from the Conservatives that non-STEM subjects are less useful for employment.

Introduction
A large critical literature has developed on the increased marketization of higher education. Three themes can be identified in this literature. 1 First, marketization is held significantly to devalue education by presenting it solely as a means to gain economic advantage (Collini, 2012;Giroux, 2013;Holmwood, 2011(a);2011(b); 2015(a); 2015(b); Molesworth, Scullion and Nixon, 2011;Readings, 1996;Tuchman, 2009).
Second, the rise of audit culture in education is criticized. Audit culture is meant to ensure that professionals ' deliver' ' excellence' in terms of teaching and research ' outputs', with management having more ability to increase the 'performance' of professionals, in a 'market' environment. The general criticism levelled against this is that it further instrumentalizes education, and increases stress in a workplace culture dominated by targets (Barcan, 2013;Collini, 2012;Donoghue, 2008;Ginsberg, 2011;Hall, 2015;Readings, 1996;Holmwood, 2014;Tuchman, 2009). Third, casualization of the workforce increases to reduce costs in a market environment (AAUP, no date; Donoghue, 2008;Ginsberg, 2011). For some authors the changes occurring in universities cannot be separated from capitalism and the commodification of all domains of society (Bailey and Freeman, 2011;Blacker, 2013;Hall, 2014;Hall and Stahl, 2012).
The marketization of higher education is linked to neoliberal capitalism (Barcan, 2013;Collini, 2012;Giroux, 2013;Hall, 2014;Hall and Stahl, 2012;Holmwood, 2011(b); McGettigan, 2013). For neoliberals, the stated problem to solve is the stifling of freedom and innovation that they claim is caused by state intervention, professional-vested interests, and producer-vested interests such as 'sluggish' corporations dominating a market while providing poor quality services and products. These stated 'barriers' are taken to be a disincentive for entrepreneurs to take risks, with their successful risk taking stimulating economic growth. They are also taken, in such rhetoric, to be a suboptimal situation for consumers, who face markets distorted by vested interests. Against this, the stated neoliberal solution is to 'roll back' state interventionism, and displace vested interests, so as to create free markets, where 1 I would like to thank the anonymous referees for their very useful feedback. Any errors that remain are entirely my own.
consumers can be 'sovereign', with their ' demands' ensuring that the best quality products and services are supplied at the best price (Collini, 2012;Giroux, 2014;Harvey, 2005;Hay, 2007).
However, despite individualist rhetoric about freeing individuals from stifling regulation and vested interests, neoliberalism is actually a form of state interventionism in pursuit of elite -that is, corporate -interests (Davies, 2014;Van Horn and Mirowski, 2009). This interventionism seeks to construct a market rationality in all actors; and to reconstruct markets to better fit elite interests (Brown, 2015;Davies, 2014;Van Horn and Mirowski, 2009). Thus as Van Horn and Mirowski put it, the Chicago School, which established neoliberalism, in promoting 'freedom', was primarily interested in 'guaranteeing the freedom of corporations to conduct their affairs as they wished. Thus the Volker Fund [which financially supported the Chicago School] was not interested in bankrolling a classical economic liberal position ' (2009: 157). This is not to say corporations are expected to be 'sluggish'. Large actors are seen to be large because they are successful, but any inefficient actor is expected to go bankrupt.
Audit culture, it is argued, in the form of the UK's National Student Survey (NSS), the Research Excellence Framework (REF), and the now-proposed Teaching Excellence Framework (TEF), plays an important role in neoliberal interventionism in English higher education. In the first phase of neoliberal interventionism in English higher education, students were repositioned as customers. There are three elements to this phase. First, the maintenance grant was replaced by loans in 1998 and students' welfare rights were slowly abolished during the 1980s and 1990s. Second, the NSS, introduced in 2005, was designed to provide: [i]nformation on student satisfaction with their HE experience, covering the views of students on: arrangements for academic and tutorial guidance, support and supervision; library services and IT support; suitability of accommodation, equipment and facilities for teaching and learning; perceptions of the quality of teaching and the range of teaching and learning methods; assessment arrangements; quality of pastoral support (HEFCE, 2002).
The language of 'satisfaction' positions the student as a customer purchasing a product (Collini, 2012: 185). Third, the Conservative -Liberal Democrat coalition Government partially implemented the Browne Report (2010), which inadvertently created a fee-norm of £9000. 2 The second phase starts with the publication in November 2015 of the most recent Green Paper (consultation document) on English higher education (BIS, 2015(a)). This sets out to reconstruct the market of higher education in England to better fit what the Conservative government takes to be elite interests. Liberalisation is proposed to allow more 'for-profit' institutions to enter the market. Further, there are proposals to establish a Teaching Excellence Framework (TEF), which would have employer and professional group representatives on the TEF assessment panels, along with academic experts in teaching and learning and student representatives, albeit with subject specialists only being brought in at a later date (BIS, 2015(a): 28).
The Green Paper also states that universities need to be ' open to involving employers and learned societies representing professions in curriculum design [. . . and developing] a positive work ethic, so [graduates] can contribute more effectively to our efforts to boost the productivity of UK economy' (BIS, 2015(a): 11).
When it comes to the supply of graduates into the labour market, the Green Paper contains messages about the value of STEM (science, technology, engineering and maths) subjects that, as will be argued below, contribute to previous Government messages about STEM subjects being more useful for the economy than their arts and humanities counterparts. After noting that many non-STEM graduates are underemployed and that companies seeking STEM graduates face a shortage of graduates, the Green Paper states that: 3 Employers want highly skilled graduates who are ready to enter the workforce.
And the country needs people with the knowledge and expertise to help us compete at a global level. Increasing productivity is one of the country's main economic challenges, and universities have a vital role to play (BIS, 2015(a): 10).
Elsewhere, changes are also proposed for the REF entailing a greater use of metrics for efficiency savings, and more focus on 'impact', defined as ' an effect on, change or benefit to the economy, society, culture, public policy or services, health, the environment or quality of life, beyond academia' (HEFCE, 2015(a)), even while the Green Paper derides the financial cost of impact case studies. The Browne Report (2010) sought to put the student, as customer, at the heart of higher education. Now the place of business interests at the heart of higher education is being affirmed.
While some literature tends to present neoliberalism as monolithic (see for instance Giroux, [2013]), it is the case that contingencies play an important role.
There are two types of contingency to note here. First, there are political contingencies concerning the outcomes of elections, such as the Conservatives moving out of coalition with the Liberal Democrats. Second, there are unintended consequences stemming from the implementation of policies and audit regimes. The partial implementation of the Browne Report (2010), by the then coalition Government, inadvertently leading to a fee-norm of £9000, is an example of both types of contingency.

Neoliberal Interventionism
Before turning to recent developments in UK higher education policy, it is necessary to set out the broader political context of neoliberalism within which these transformations must be situated. Neoliberalism may be presented as a reaction to the problems encountered by Keynesian demand-management welfarist / reformist interventionism in the 1970s. This was exemplified in the rise of public choice theory. Keynesian 'welfare economics' saw itself as the 'science of market failure' and public choice theory set itself up in opposition to this, as the 'science of political failure' (Hay, 2007). For public choice theory, economic problems are caused by the ' overburdened state' seeking to regulate the market and a neoliberal focus on markets is needed to overcome this problem (Hay, 2007).
In contrast to such a view, Brown (2005;, Davies (2014), Foucault (2008) and Van Horn and Mirowski (2009) all present a history of neoliberalism that traces its origins to the period following the Second World War. They also show how neoliberalism is a form of interventionism in pursuit of elite interests, rather than a position which holds that markets need to be freed from Government intervention.
To understand this, it is useful to explore the differences between 'Ordoliberalism' in Germany and the Chicago School of Law and Economics in the USA, which were both concerned with reinventing liberalism. The term 'neoliberalism' was coined within the Chicago School and it is this approach that has been dominant in the politics of the USA and UK since the 1970s.
With Ordoliberalism, the goal was the construction of the 'social market', with competition not dominated by corporations, and competition supplemented with a welfare safety net. A 'free' market was to be legislatively constructed by the state and protected from monopolies, cartels, price fixing, etc., by corporations who have the power to ' distort' markets. By contrast, the Chicago School initially saw corporate domination of a market as benign, because they held that it would eventually be undermined by competitors. They then eventually moved to see corporate domination of markets as positive. As Van Horn and Mirowski argue, for the Chicago School, neoliberalism 'is first and foremost a theory of how to reengineer the state in order to guarantee the success of the market and its most important participants, modern corporations ' (2009: 161). A major funding source for the Chicago School was the Volker Fund which saw freedom as the freedom of corporations to pursue their unfettered self-interest, with this enabling the Cold War US state to have the power to resist socialism (Van Horn and Mirowski, 2009: 157-158).
Ordoliberalism and the Chicago School had very different approaches to the role of the price mechanism, which reflected their differences concerning how the market was to be constructed. Davies (2014) argues that for Ordoliberalism the price mechanism was sacrosanct as the means for freely competing agents, in a market free from domination by large corporations, effectively to match supply and demand, between actors who were considered formally equal prior to competition. By contrast, for the Chicago School, it was important to recognise that capitalist activity by existing profit-seeking actors ' already was typically ideal. Certainly, it could not necessarily be improved upon through the intervention of regulators or law makers' (Davies, 2014: 50). The justification for this view being that corporate self-interest was 'more efficient in the aggregate' (Davies, 2014: 50). What this meant was that the possibility of future competition and the ability to make profits were sufficient for an efficient economy, with anti-corporate regulation damaging this by preventing the efficient accumulation of profit by successful market actors.
It is also argued by Davies (2014) that later neoliberals influenced by the Chicago School came to realise that actors as well as markets had to be constructed. He argues that that the assumption that individuals were rational choice utility maximisers came to be seen as empirically erroneous. That is, individuals did not list their 'preferences' for material acquisition in order of importance and then seek the most efficient means in market competition to realise these. However, such a model of actors was deemed normatively desirable for neoliberals, for the efficient functioning of the economy, so such behaviour had to be instilled. Davies argues that: With the rise of behavioural and happiness economics, visions of a rational In doing this, homo oeconomicus has to model itself on finance capital, and always seek 'investors' attracted to it by its own investment in its human capital.
However, in Foucault's rejection of Marxism, Brown (2015: 75) argues, he ignored the importance of capitalism in shaping agents, styles of thinking and Governments, and the potential for any resistance to neoliberalism. To this we can add the point mentioned above about needing to recognise the importance of contingencies.

Audit Culture and the Student as Customer
As above, the first phase of neoliberal interventionism in UK higher education redefined students as customers. During the 1980s and early 1990s the Conservatives reduced and then eliminated the welfare rights of students. So, for example, students became unable to claim 'housing benefit' to cover rent during the vacations. The maintenance grant was frozen in value and then in 1998 the Labour government replaced the maintenance grant with student loans and a £1000 tuition fee, with this fee rising to £3000 in 2004 (and then, following inflation, to £3290 in 2010).
Once students began to pay for their degree they could, as they were positioned as customers, then be asked if they were satisfied customers. The National Student Survey (NSS) was introduced in 2005 under Labour. Its implementation is compulsory in England, Wales and Northern Ireland, with participation by Scottish Universities being voluntary. With the NSS, final-year undergraduates report their levels of 'satisfaction' with their degree course. The stated purpose of the NSS was for it not to be used to allow a comparison between universities but to ensure that public money was spent efficiently with students being satisfied with the services bought from their university. HEFCE report 01/66 states that '[t]he results are generally not designed to be comparable even between departments within an HEI [higher education institution], let alone between HEIs, because their main purpose is improvement of individual programmes' (HEFCE 2001). Nonetheless, universities do use the data for the purpose of brand promotion via ranking in the 'market' for student customers (Holmwood, 2015(a)). This is reinforced by the rise of student / customer guide 'league tables' that seek to rate institutions comparatively using NSS data (amongst other data such as staff -student ratios), such as the Guardian University Guide 2016, which has three columns (out of eight) for NSS data. There are five problems, however, with the view that the NSS audit data can generate the trust required to know the quality of a degree programme.
First, it provided perverse incentives to manipulate the outcome. In one case that made the news, a department was removed from the rankings for telling students to give high marks or face unemployment when employers saw a low mark and assumed their degree course was substandard (Coughlan, 2008). Second, it could encourage intellectual conservatism. As Collini (2012: 185) and Mary Beard (2012) have argued, a good education experience should entail ' dissatisfaction'. Collini argues that he hopes that the students he teaches ' come away with certain kinds of dissatisfaction [. . .], and it matters more that they carry on wondering about the source of that dissatisfaction than that whether they "liked" the course or not ' (2012: 185). Students should be moved out of their ' comfort zone' by having their presumptions challenged. Trying to implement this though a student satisfaction measure risks having unsatisfied customers giving a poor NSS result. Third, recent research on medical students' degree grades indicates that the NSS results on 'satisfaction' are disconnected from teaching quality as measured by degree grades ). (2010) argue, there is no statistical significance in the differences from the mean between most institutions and so constructing league tables of universities on such data, to 'inform' customers of 'brand quality', is erroneous.

Fourth, as Cheng and Marsh
Finally, as O'Neill (2002: 43-59) argues, the opposite of trust is not lack of knowledge but deception. Indeed, using audits to try and make an institution or professional activity transparent is premised on a lack of trust and, at best, could only furnish confidence. One may have confidence that a product will be delivered on time if a company has good feedback online but this is not the same as relations of trust which are empathetic and not based on amassing data. Such confidence is fragile because it only takes an instance of professionals following perverse incentives to game the system to emerge and people can lose confidence.
It may seem as though an unintended consequence of the introduction of the NSS was the construction of a quasi-Ordoliberal market whereby the studentcustomer can use reported levels of 'satisfaction' as a surrogate for the price mechanism, to ascertain quality. However, the market was heavily constrained with Government imposed ' caps' on recruitment for universities and, for the reasons given above, it would fail in that role. Instead, if the NSS is approached in terms of neoliberalism, the concern with a surrogate for the price mechanism would not be a key issue. Of more importance would be the potential for the NSS to start generating a market rationality whereby students began to reconstruct themselves as customers.
What is important is the positioning of students into seeing themselves as individuals purchasing a product with which they should be satisfied, even if this was not meant to be in a competitive market with the NSS being used as a proxy for the price mechanism. The unintended use of NSS data in a comparative way served to reinforce this market rationality.
The next significant neoliberal intervention in UK Higher Education came in 2010. Indeed, the Browne Report (2010), commissioned by Labour, recommended replacing public funding of non-STEM subjects with fees, and removing the cap on recruitment to construct a free market, with universities also investing in scholarships if they charged higher fees. The stated objective was to put the student, as customer, at the heart of higher education using the price mechanism, in a constructed free market, to ascertain quality. The Conservative-Liberal Democrat Coalition, which came to office in May 2010, did not implement the Report in full and instead allowed the fee cap in England to rise from £3290 to a maximum of £9000; and the cap on recruitment was only lifted in 2015. The Liberal Democrats had campaigned on a platform of abolishing the university fee but, in coalition Government, preferred a £9000 fee cap to a free market with fees having no Government set fee cap. David Willetts (the then Minister of State for Universities and Science) also announced fee waivers and bursaries would be available, each worth up to a total of £4,500, for students coming from families earning less than £25,000 (Willetts, 2011). The expectation of the Coalition was that only a small number of institutions would charge £9000, but given the lack of any regulation to prevent £9000 becoming a fee-norm, £9000 quickly became the norm for English higher education institutions. This represents a policy failure, not least because it created a funding problem with the Government estimating that around 45% of all student loans would not be repaid in full to the Governmentowned Student Loans Company (McGettigan, 2013). As the government commits to underwrite the impairment on all of these income contingent repayment loans that are not paid off within a 35-year period, this yields a substantial government budget hole.
In Scotland, fees are not charged to 'young students', meaning students under 25 who are unmarried, not in a civil partnership and not parents. Those not classed as 'young students' are charged between £1200-£1800. In Wales, universities can charge £9000, but students can claim a £5190 grant and apply for a loan of up to £3810. In Northern Ireland, the fee is set at £3805 with a loan being available to cover this. Given the compulsory implementation of the NSS in Wales and Northern Ireland, and its voluntary implementation by some Scottish universities, and the implementation of fees in Wales and Northern Ireland (and in Scotland for non 'young students'), there is also a neoliberal construction of the student as a customer in these regions too, albeit in a less intensified fashion. The ramifications of grants being replaced by loans, the NSS and Browne Report, for all regions of the UK, suggest that the 2015 Green Paper, discussed below, which seeks to reconstruct the market in English higher education, will have an impact on all regions of the UK too. With the construction of a market rationality comes the expectation of audit data for the customer, such as that furnished by the proposed Teaching Excellence Framework for England.
A key member of the Browne Report was Sir Michael Barber, an influential advisor to Blair's New Labour Government (Wilby, 2011). In 2011 Barber became Chief Education Advisor to Pearson and, along with Katelyn Donnelly and Saad Rizvi, authored a report called 'An Avalanche is Coming: Higher education and the revolution ahead' (2013). They state that: '[T]he key messages from the report to every player in the system are that the new student consumer is king and standing still is not an option. Embracing the new opportunities set out here may be the only way to avoid the avalanche that is coming' (Barber, Donnelly and Saad, 2013). In the market, as claimed by Barber, universities cannot be akin to sluggish corporations who do not innovate. Instead, for universities to remain efficient market actors, they supposedly need to change by embracing new technology, such as MOOCs (massively open online courses), and by branding themselves to fit 'niche' markets in a context where people return to learning during their career, to reskill. It is claimed that this niche marketing will entail the 'unbundling' of functions with many universities focusing on 'delivering' teaching in a limited number of areas rather than trying to teach all disciplines. Barber's vision of higher education is thus one of students as customers making consumer demands on universities that compete in niche markets to attract 'investment' from customers. To survive, universities must adopt a new market rationality and 'unbundle'.
The shift from grants to loans and fees, and the creation of the NSS, started redefining students as customers who need to be satisfied, with this being intensified by the comparative use of NSS data, contrary to the original intention. It can be argued that the inadvertent tripling of the tuition fee further contributed to this redefinition of students as customers. A report, commissioned by the BBC in 2015, stated that 4 out of 10 graduates surveyed, especially in the humanities and social sciences, did not believe their degree had been 'good value for money' for the £9000 fee, because of what was perceived to be a lack of contact time. With a high fee came expectations of a service supporting the customer more directly (BBC News, 2015). There is also anecdotal evidence from academics about the fee increase making students who see themselves as customers more demanding. An anonymous academic in the Guardian wrote: 'when one of [a colleague's] students was asked to leave a seminar for not completing the reading, they retorted: "I pay you to teach me what's in the article, not the other way around". The comment was prompted following one student putting up posters stating "[a]ll I'm asking for is a little respect seeing as I pay you £9,000 a year"' (Guardian, 2015).
In response to the partial implementation of the Browne Report (2010), Gurminder Bhambra, Michael Farrelly, John Holmwood and Lucy Mayblin, founded the Campaign for the Public University and argued that higher education was a 'public good' and not a 'positional good' (Holmwood, 2011(b)). Their argument was that people who have taken part in higher education tend to be more active in the public sphere which is good for democracy, and therefore higher education is a public good that should be paid for by general taxation. By contrast, if people have to pay for higher education, especially if the fee is high, then they may see a degree only as a means to secure labour market advantage. The actual advantage may decline as the number of people holding degrees increases, and it depends on the availability of graduate level jobs.

Audit Culture and Excellence for Business: The TEF
In the May 2015 general election the Liberal Democrats suffered heavy electoral loss, partly for allowing the fee to rise to £9000 (Weaver, 2015), and the Conservative party gained an overall majority. In the Conservative Manifesto -authored by the now Minister for Higher Education, Jo Johnson -there was a commitment to introducing more change to English higher education, as outlined below. Had they remained in coalition it may have been the case that the Conservatives had to trade some of the proposals away to get some or most of the educational changes they wanted accepted by their coalition partners. Or they may have all been traded away, in order to realise another objective. Without the Liberal Democrats in coalition, though, the Conservatives were free to put forward the changes without compromising them. This brings us to the second phase of neoliberal interventionism, which sees a strongly neoliberal political party seeking to reconstruct the market overtly to meet what it takes to be the needs of business in England.
The full implementation of the Browne Report (2010) would have created a more Ordoliberal outcome, but the Liberal Democrats resisted this. If it had been implemented then, given the changes now proposed by the Conservatives, it is likely, given the statements in the Green Paper discussed below, that the Conservatives would have hoped for a free market to lead to customers choosing more STEM degrees. Even though, as argued below, the claim that non-STEM subjects are less 'useful' for business is flawed (Warrell, 2013); and many MPs have non-STEM degrees (Crace, 2013).
In that scenario, an Ordoliberal means would have been hoped to furnish a neoliberal end. Now that the Conservatives have won the General Election, I will argue that the focus is on seeking to use a neoliberal means to realise a neoliberal end.

In November 2015 the Department for Business Innovation and Skills (BIS) published a Green Paper entitled 'Fulfilling our Potential: Teaching Excellence, Social
Mobility and Student Choice'. The Green Paper opens with five issues to address. The first is the 'productivity challenge', with the report stating that 'increasing productivity will be the main driver for economic growth in years to come, and improving skills are an essential component of this' (BIS, 2015(a): 10). It goes on to note that 20% of graduates are not working in high skilled employment three years after graduating and that employers of STEM graduates are concerned about shortages in the supply of applicants, while in other areas people with non-STEM degrees are underemployed (BIS, 2015(a): 10-11). Given this it is then alleged that there is a 'mismatch' that is undermining the economy. The second issue is the 'transparency challenge', with the report noting that current data does not record contact hours in sufficient detail, and that far more contact time -or 'teaching intensity' -is needed to meet customer demands. 4 It also notes that there is grade inflation and that with most graduates now getting upper second class or first class honours degrees, employers have trouble differentiating between graduate applicants. The third issue is the need to ' drive up teaching standards'. The report states that: Prospective students will be able to use the TEF results to help inform their decisions about which institution to attend, and employers can consider it in their recruitment [. . .]. The TEF will increase students' understanding of what they are getting for their money and improve the value they derive The fourth issue is that of increasing social mobility, with the goal being to increase by 20% the number of black and minority ethnic (BME) students in higher education by 2020. Finally, the Green Paper proposes making it much less bureaucratically cumbersome for new providers to enter the market, noting that these ' can offer programmes that are attractive to hard-to-reach communities' (BIS, 2015(a): 15).
Dealing with the last two points first, we can note that the Green Paper seeks to address the issue of encouraging new providers into the market as follows. The Green Paper holds that existing providers may be reluctant to validate potential competitors, especially when the Government has now explicitly stated it regards 'exit' from the market through, for example, bankruptcy from falling student numbers, to be an acceptable outcome of increased competition. To tackle this, the Green Paper makes several suggestions including using a new Government body, called the Office for Students (OFS) (which may be very similar to HEFCE), to validate degrees, and for Government to 'give DAPs [degree awarding powers] to non-teaching bodies, with no incumbency interest' (BIS, 2015(a): 49). In other words, businesses could gain DAPs to validate new providers offering vocational degrees. The Green Paper also envisages an increase in the types of award as well as an increase in the types of institution awarding degrees, with 'degree apprenticeships' becoming possible. It states that: '[t]he degree apprentice will be employed throughout and so have the opportunity to develop skills directly required by employers' (BIS, 2015(a): 21). While this is not explicitly linked to new providers, such courses would probably be the preserve of those branding themselves on low cost and vocational relevance, rather than other more established institutions who may rely on a more traditional brand. These new providers are also tacitly expected to be the group to address the target set for increasing BME students in higher education by 20% by 2020, because such providers are described as being better suited to accessing 'hard-to-reach communities'.
The other three points would be tackled using the Teaching Excellence Framework (TEF). It is proposed that those institutions which receive the highest rating for teaching excellence be able to raise their tuition fee above £9000 in line with inflation. A key objective of the TEF is to ' change providers' behaviour' (BIS, 2015(a): 19). 5 and the financial incentive is seen as a complement to the furnishing of audit data to customers and employers: the fee increase and the possibility of gaining more customers is the ' carrot'; and the possibility of losing customers, having a fee declining in real value due to inflation, and getting a tarnished brand with employers, especially when employment data is to be used in arriving at TEF level, is the 'stick'. The TEF level would be based on a five-yearly rolling panel assessment and metrics. The panels would be made up of 'independent experts' defined as academic experts in teaching and learning, student representatives and employer / professional representatives (BIS, 2015(a): 28). The metrics would come from ' existing data collections' on: employment / destination; retention / continuation; and student satisfaction indicators. As the TEF developed, it would include data on: 'teaching intensity' (more contact time, staff time spent on teaching and student time spent studying); 'learning gain' (once a system is devised to measure such 'gain'); and the 'training' of academics (BIS, 2015(a): 33-34). Metrics data from the Higher Education Careers Services Unit's (HECSU) Futuretrack project gives a flavour of the sort of data that may come to be used to arrive at the TEF levels, with this project asking graduates about their perception of their degree's financial worth and usefulness.
Regarding grade inflation, the Green Paper holds that employers need a system to 5 This is unlikely to lead to investment and more likely to lead to ' disinvestment' in courses that are not seen to perform well, if the behaviour of universities responding to REF scores is repeated with the TEF (Jump, 2013). help them identify the 'best applicants' and that universities would need to supply evidence to the TEF panels of how they are tackling grade inflation. While it is recognised that a Grade Point Average (GPA) system 'will not tackle "grade inflation"' (BIS, 2015(a): 25-26) by itself, it is thought to be useful because it avoids the ' cliff edge' effect, whereby academics, with an eye on the NSS (and internal teaching audits) may be tempted to award an upper second rather than give 1-2 % less for an assignment, with it then falling into a lower degree class. 6 Apart from panel assessments and metrics, there are expectations about academics consulting with business. The Green Paper states that: Higher education providers need to provide degrees with lasting value to their recipients. This will mean providers being open to involving employers and learned societies representing professions in curriculum design. It will also mean teaching students the transferrable work readiness skills that businesses need, including collaborative teamwork and the development of a positive work ethic, so that they can contribute more effectively to our efforts to boost the productivity of UK economy (BIS, 2015(a): 11).
So, in addition to putative 'transferable skills' like problem-solving and critical thinking, higher education is expected to help increase economic productivity by addressing what the Conservatives perceive to be a 'skills mismatch' in the economy, and fostering the right ' ethic'.
Four problems with the Green Paper are addressed here in relation to the above history of neoliberal intervention in UK higher education. First, the new providers the Green Paper discusses are to be for-profit providers, and this raises serious concerns about quality. Jones argues that: The obvious rationale of all this is to deflate the notion of what constitutes "quality" higher education in order to allow private providers who cannot 6 It is worth noting that in the USA which uses a GPA system there is grade inflation driven by ' elite' universities, as reported by the Campaign for the Public University (2011). meet current standards to enter the market. An example of what is presumably envisaged is Coventry University College Ltd (CUCL), a subsidiary of Coventry University. CUCL offers part-time degrees in vocational areas like law and accountancy. Its staff teach 40+ weeks per year and consequently are not engaged in research; most are not "academics" but merely "deliver" teaching. Its students are denied access to facilities afforded to Coventry University students, like library borrowing rights or participation in the student unionjustified explicitly on the grounds that such things are "added extras" and not all students want the same "student experience". As a result of shaving its provision and costs to the bone, CUCL charges fees below £6,000 per year.
Obviously, HEIs [higher education institutions] like CUCL, or its longerestablished private counterpart, the University of Law, could potentially multiply rapidly if the existing quality threshold was lowered, because the costs of provision -and associated QA [quality assurance] processes -could (in theory) be cut substantially. "New providers" would be enabled to undercut existing ones on price, triggering the price war that David Willetts always hoped to unleash. (Jones, 2015) These new entrants to the market will seek validation from the OFS or businesses unless, like CUCL, they are subsidiaries of an existing university. They will likely take full advantage of the opportunities to start up on a low cost base by using casualized staff or staff paid less than traditional academics because they just ' deliver' preprepared material, as the CUCL model does (although, as noted below, all sectors are moving to increased casualization). These new providers are expected to raise the number of BME students, with the Government saying that such new providers can be better able to reach out to hard-to-access communities. Profits could be made by accessing a pool of potential customers not currently accessed by most traditional universities. Indeed, such potential customers are likely to be geographically immobile and so with aggressive marketing a for-profit provider could acquire a significant market (Holmwood, 2015(a)). Willetts' 'price war' may happen among these for-profit providers but it is unlikely to happen between them and most of the already established universities. This is because reducing the fee significantly below £9000 would send out a negative message to potential customers about the worth of a particular university's degrees, in the context of being given the opportunity to raise the fee, if its ' excellence' could be established. It is important to stress, though, that there is meant be no strong reliance on market signals for quality (contra Ordoliberalism), because that would make audits such as the TEF redundant. The TEF level can be used as a 'value proxy' that can be more easily controlled than relying on 'sticker prices'. Now, as Holmwood (2015(a)) argues, the 'Harkin Report' in the US held that forprofit providers targeting disadvantaged groups with cheaper degrees were the educational version of 'sub-prime' mortgages. Senator Harkin stated that in his report: you will find overwhelming documentation of overpriced tuition, predatory recruiting practices, sky-high dropout rates, billions of taxpayer dollars spent on aggressive marketing and advertising, and companies gaming regulations to maximize profits. These practices are not the exception -they are the norm; they are systemic throughout the industry, with very few exceptions. (Protect Students and Taxpayers, 2012) Holmwood (2015(b)) goes on to argue that: returns to shareholders and high executive salaries arise as a potential issue of for-profit providers, but, given the absence of a research function, these can all be assigned as either 'management costs' of teaching or returns to those providing the ' capital investment' in teaching. In 2009, according to the Harkin Report, 22.4 percent of all revenues of for-profit providers in the USA was spent on marketing, advertising, recruiting and admissions staffing, 19.4 percent on profit distributions and just 17.7 percent on instruction.
With 'overpriced tuition' and 'sky-high dropout rates', for-profit providers are not exemplars when it comes to facilitating social mobility. If the same problem occurs in England then the outcome will just be the reproduction of disadvantage (McGettigan, 2013). Indeed, as McGettigan argues, in the US, the for-profit 'Bridgepoint Education, described as a "scam" by Harkin, had dropout rates above 84% while still making profits' (2013: 104).
The second problem is that a course could be given a low rating in the TEF after someone has graduated, meaning that they find their degree is retrospectively devalued (Holmwood, 2015(a)). One could, in such circumstances, appeal to the TEF rating at the time of a cohort's start. This would be 'suboptimal' though, because an employer may simply look for currently highly rated courses to be efficient with time and resources when faced with large numbers of applicants.
Furthermore, if a course got a low rating shortly after one graduated, potential employers may have doubts about an earlier high rating, or may focus on what they took to be the subsequent drop in 'quality' during the years between the different TEF levels being awarded.
The third problem is that there may be an increase in casualization, not because of competition, but because traditional universities come to construct themselves more like corporations, by cutting labour costs. The consequence of this would be the increased use of a casualized labour force. In the USA, according to the American Association of University Professors, taking part time and full time staff together, 76% of academics are not tenured or on tenure track (AAUP, no date; Donoghue, 2008;Readings, 1996). The trend to casualization is already well established across all sectors of higher education in the US. Furthermore, as the government expects universities to bear the cost of the TEF (BIS, 2015(a): 28), and as the fee increase would only be in line with inflation, which is low at the moment, the TEF would be a costly endeavour (McGettigan, 2015). Therefore universities in England may look to increased casualization as a way to cut costs. The University of Warwick planned to introduce a scheme called 'TeachHigher' which would have seen hourly paid staff experience a decline in their pay and conditions, but this was abandoned following negative publicity and protests (Grove, 2015(b)). This can undermine teaching, because while causalized staff will often be experts in a particular field, they may not be selected to teach their specialist subject.
The fourth problem concerns the argument about STEM subjects. The empirical claims made by the Green Paper are flawed. As Warrell (2013) argues, non-STEM graduates are not 'less useful' for the economy, with many subject areas playing key roles in the 'creative industries'. Interestingly, a large number of MPs have non-STEM degrees, with the Oxford taught PPE (philosophy, politics and economics) degree being held by many MPs (and journalists) (Crace, 2013). Furthermore, according to a 2013 report by the UK Commission for Employment and Skills '[s]upply and demand calculations for 2020 under both the "2007" (prerecession) and "2011" (recession) scenarios do not suggest an overall shortage of STEM graduates (in terms of numbers) in most regions or nations of the UK' (Gov.UK, 2013). Indeed, the report by the Higher Education Statistics Agency (HESA) entitled 'Destination of Leavers from Higher Education' covering 2011-2014 showed that the highest rate of unemployment is amongst computer science graduates, and that 'Social Studies' have lower unemployment rates than 'physical sciences' and mathematics (Gilby, 2016).
While the claims made about non-STEM and STEM subjects may be flawed, they contribute to previous messages about what is and is not deemed to be of value. As a further example of this, in 2015 the UK Government proposed removing the topics of feminism, sex / gender, gender inequality and patriarchy, from the Politics A level syllabus (Grierson, 2015); only to reverse this following protest (Press Association, 2016). Also, in 2014, Nicky Morgan, the Secretary of State for Education, stated that students choosing arts and humanities subjects over science and maths may be 'held back for life' (Paton, 2014). This coincided with the launch of an 'industry-led' and 'Government supported' campaign called 'Your Life' (no date), which is designed to get more schoolchildren studying science and maths at A level and university by showing them the 'dynamic career opportunities' than can stem from studying these subjects. Careers advisors often tell young people they need to market themselves as a brand seeking investors (Middleton, 2011). So, while there is no remit for the TEF panels to comment on the intellectual content of curricula, there are messages from Government which suggest to potential students that STEM subjects are 'worth' more in terms of attracting investors to their brand. 7 So, the Green Paper seeks to reconstruct the market through 'liberalization' to attract more 'for-profit' providers. In terms of audit culture, the TEF assessment panels would have employer and professional group representatives, in addition to aca- It is therefore recommended that to increase efficiency panel peer review ought to be complemented in all subjects by the use of metrics (BIS, 2015(a): 73). However, a recent HEFCE report entitled 'The 'Metric Tide' (HEFCE, 2015(b)) stressed the value 7 In Japan the Government have stated that universities need to close humanities and social science subjects to focus on courses that 'better serve society's needs' (Grove, 2015(c)).
of peer review and held that data concerning, for example, journal impact factors, could be misused as a proxy for an output's quality. The Green Paper also holds that it is necessary to 'build on the success' around funding for impact (BIS, 2015(a): 73).
Three points need to be made concerning any move towards metrics in the social sciences and humanities. First, it will encourage intellectual conservatism, with academics focusing on established debates (currently fashionable thinkers or topics) to push up citations, rather than risk undertaking any more innovative research or research for its own sake. Second, it will benefit economics and the natural sciences more than the humanities and the rest of the social sciences, which often have lower citations. Third, the increased weighting that may be given to impact would mean more emphasis on working with Government and the private sector to solve their problems rather than engaging in purely intellectual or politically radical research (HEFCE, 2015(b) ;Holmwood, 2014;Holmwood, 2015(b); Martin, Nightingale and Rafol, 2014).
At the start of 2015 the Campaign for Social Science anticipated the possibility of cuts to social science funding, given the politics of austerity, and sought to defend the social sciences by emphasising their ability to generate research with impact for business and the state. Their report entitled 'The Business of People' (CFSS, 2015) took it for granted that a main task of the social sciences is to inform policies that can help construct people to better fit neoliberal market realities. As Holmwood (2015(c)) argues: What is striking about the report is that it comes in the wake of the publication of Thomas Piketty's Capital in the Twenty-First Century documenting the rise in inequality in Western countries over the last decades. This found its way into the mainstream media, as well as in reports by agencies such as OECD. Yet structured social inequality is not mentioned at all in the report, nor is race and ethnicity, or any other research on social structure. These profoundly affect the circumstances of people's lives, yet all the report has to say about them are their derived consequences in terms of people's attitudes and behaviours and how those may be a problem for policy makers and practitioners in attaining their objectives.
The Campaign for Social Science is not alone is seeking to construct social science in such a way as to attract investors by showing its impact-relevance (Gov.UK, 2015). Bastow, Dunleavy and Tinkler (2014), for instance, foreground the importance of impact and advise academics on how to undertake research to achieve this. Similarly, Lupton (2013) holds that the use of big data can help academics fashion their ' academic quantified self', meaning they can use metrics on citations and impact to enhance their 'brand'.
So, some academics are shifting to constructing themselves as neoliberal subjects seeking investors by showing their worth to the neoliberal state and business interests. The use of a more metricised REF combined with more emphasis on impact would reinforce this.

Reviews of Research and Spending
Two further developments need to be discussed. In November 2015 the 'Nurse to coordinate research strategy, distribute interdisciplinary funds and speak to Government' (Matthews, 2015(a)). RUK, the report recommended, should be led by a ' distinguished scientist' and communicate with a new ministerial committee attended by ministers responsible for science budgets, with this possibly being chaired by the Chancellor of the Exchequer (Matthews, 2015(a)). Another proposal was for the creation of an interdisciplinary ' common research fund' to respond to 'grand challenges'. One concern stemming from this, as articulated by Matthews (2015(a)), is that Government may now have far more direct control over the allocation of research money. The Green Paper stated support for the 'Haldane principle' (BIS, 2015(a)) which sees researchers not politicians decide how research funds are allocated, but the suggested changes cast doubt on the continued meaningful existence of that principle.
The Spending Review sought to increase the repayment of student loans by freezing the repayment threshold and increasing repayments. 'Student Opportunity Funding' for the poorest and disabled students was cut (Morgan, 2015) and, prior to the Spending Review, it was announced that maintenance grants for poorer students were to be replaced with loans. On 14 th January 2016 a Delegated Legislation Committee made up of 18 MPs voted 10 to 8 replace maintenance grants with loans (McGettigan, 2016), prompting criticism because it bypassed debate 'on the floor of the House of Commons' (Ali, 2016). In terms of STEM funding, science funding was protected in 'real terms', with this including funding for a new 'Global Challenges Fund', which makes it likely that research funding for other subjects will be cut; and students undertaking a second undergraduate degree could have access to a loan if it was for a STEM subject (Matthews, 2015 (b); Morgan, 2015).
So, all those seeking to invest in their human capital will need to take on the cost for this, irrespective of their family's financial circumstances, and the loan repayment arrangements will ensure more of the money is recouped from such self-'investors'.
While the science budget is protected, there is the possibility of non-STEM research funding being reduced, unless money from the RUK was used to fund interdisciplinary work, addressing problems set by Government.

Final Remarks
Two phases of neoliberalism in English higher education have been discussed. In the first, students were redefined as customers, and in the second, following the General Election in 2015, the Conservatives sought to reconstruct the market in English higher education to meet what they perceive as business interests. Contingencies show that neoliberalism is not monolithic and resistance can work, as was seen in the protest about attempt to remove feminism from the A level politics syllabus and Warwick University abandoning its 'TeachHigher' scheme.