When top-up fees were introduced in England and Wales in 2006-7, squeamishness amongst MPs was mitigated by an obligation placed on universities and colleges to sign ‘access agreements’ with the newly-created Office for Fair Access (OFFA).

The fear was that higher fees would deter some potential students from applying to university. Each HE provider therefore had to spend part (in practice something like 20-25%) of the additional fee income to encourage wider participation in higher education. Its plans had to be set out in a document detailing projected spending on bursaries, outreach and similar activities. More than 100 access agreements were cursorily approved by OFFA, a one-man-and-a-dog operation headed by part-time director Sir Martin Harris. None were rejected.

In fact MPs’ fears were unfounded: over the last five years participation has continued to rise –although the numbers of non-traditional students attending our elite universities (Oxbridge, the Russell Group) still remain fairly low.

Things have moved on. A new fee cap of £9000 has been agreed, but the government seems to have underestimated the number of institutions raising their fees to this limit. It is panicking about the cost (because fees are paid upfront by the state), but also again about the possible deterrent effect on potential students of much greater debt. The Lib Dems in particular are complaining once more that top universities are too socially exclusive.

So OFFA, which in many people’s view should have been kindling for the promised ‘bonfire of QUANGOs’, is back, with a new remit and more powers. It has just published 35 closely-written pages of guidance to HE providers. If they want to charge more than £6000 – as all do, for this is less than most institutions currently get per student from HEFCE funding and existing fees –  they will now have to submit much more detailed annual plans (previously a five-year one would suffice), complete with targets, milestones and monitoring requirements. These will have to be completed by April 19th – i.e. in about six weeks.

Bursaries, which an OFFA report last year found to be ineffective in stimulating student demand, are now downplayed, although some universities will be required to produce matched funding to the new National Scholarship programme – about which next to nothing is known, and which could again largely be a waste of money. The focus of institutions’ plans is to shift to retention (for those universities which already have a broad intake) and outreach, which is not explained and is left up to universities to define. In the case of institutions with strong local recruitment, for example Queen Mary in the East End of London, it is easy enough to see what this might mean in terms of schools visits, open days, mentoring arrangements and so forth – but what about the University of Exeter, which recruits a large part of its intake from independent schools nationwide? How – and where – does it begin to attract a new demographic?

I estimate that these hastily-cobbled-together plans will commit universities to something like £700 million next year. Working out exactly how much spend you should put down in your plan will be a test in itself. OFFA gives some guidance. If you have ‘low’ participation from the loosely-defined ‘under-represented students’ – and you decide the indicators yourself– you should devote ‘around 30%’ of the fee above £6000 to access. Oxford, which plans to charge £9000, should be spending about £900 per student. With an ‘average’ level of participation you should spend ‘around 22.5%’, and if you have high representation of less-privileged students you need only devote ‘around 15%’. If OFFA thinks your ‘around’ is not close enough to the quoted figure, it may refuse to agree to your plan, in which case (in theory) you won’t be able to charge more than £6000 per student. Despite vagueness in many areas, in some areas the guidance is overly precise. It says, for instance, that OFFA will only agree to fee reductions for students from families ‘with a household income of up to £42,600’. This definition of a low income household could mean very different things in Gateshead and Guildford.

With no powers to determine admissions criteria, OFFA nevertheless makes it obvious that it wants to see universities use ‘contextual information’ to decide who is admitted. This means that UCAS offers to potential students should be based on relative rather than absolute criteria: lower grades for those coming from schools with poorer average results.

The new dispensation is far more intrusive than before. Universities and colleges are to be forced to spend large amounts of money on nebulous objectives, engaging in social engineering which experience suggests is unlikely to succeed. The government surely knows this, but presumably hopes that the new requirements will intimidate some providers into setting lower fees.

Elite universities already want to attract as broad a social mix as possible, but without significant improvements in state schools they face an uphill struggle. The danger with the revived OFFA is that it will chip away at the reputation and the will of our leading universities until academic standards are seriously eroded. I may be alarmist, but sustained political intervention over entry arrangements has destroyed universities in other countries before now.