1. The definition of a contact hour:
any activity that a student has to attend or undertake at a fixed point and that has no flexibility for when it is undertaken, and where the student also has access to an available staff member. This would include lectures, tutorials, seminars and online discussions that take place at a specified time.I predict widespread adoption of online discussions that take place at a specified time as a cheap way of driving up reported contact hours.
2. The role of private providers. Currently only a few subscribe directly to QAA and are covered by this requirement, but where they are in partnership with UKHEIs then the HEI will be responsible for ensuring that data are collected and published on the partner's website. As most of these partners will be migrating to direct subscription to QAA (but only getting their own degree-awarding powers much later, or not at all) there is ample scope for confusion here, as I've discussed before.
3. For modular courses (which is most courses) the reported contact hours and assessment methods should report a 'typical path' (para 74). I can see scope for substantial gaming here to present the most advantageous 'typical path' by concentrating resources on certain modules.
4. But the key issue is still the definition of a 'course'. HEFCE think there are just 23,904 'courses' (that is unique combinations of institution, subject, mode of study and qualification) in England. Even at that level, some 'courses' reflect aggregation of data across two years, or across very high-level subject groups. Data like this will fundamentally not be comparable between institutions. Suppose institution A has a set of Media Studies programmes which are very theoretical, and institution B has some theoretical programmes, and some practical, skills-based programmes. At these levels of aggregation, institution B's students will seem to have better employability outcomes and more contact hours if an average is taken across all programmes even if on the theoretical programmes which are actually comparable the contact and outcomes are very similar. So applicants choosing between institution A and institution B for a theoretical Media Studies course will be actively and seriously misled by the KIS.