If higher education was not higher education, but a deregulated financial market, then universities would be guilty of mis-selling.

So said the auditor general of the National Audit Office, releasing a critical report today that raised particular concerns about a dearth of information made available to prospective students on their ¡°prospects, alternative options, and financial commitments¡±.

The report is just the latest shovel-load of manure heaped on higher education over the past few months. However, there are questions about how new much of the detail in it really is.

For example, the line that led the NAO¡¯s press release, and which The Guardian?followed in its splash today, is simply a reheated finding from an earlier Higher Education Policy Institute study, which claimed in June that only 32 per cent of students think that their course offers value for money.

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The other main thrust of the press release, which was picked up on by the BBC, our news story and others, was the point about ¡°mis-selling¡±. There are a couple of points to make about this. First, while it may or may not be fair to say that if universities were financial services companies they would be guilty of mis-selling, the point is rather a moot one. Because universities are not financial services companies. They are universities.

Rewind seven or eight years to the height of the debate about increasing tuition fees, and you may recall that there was widespread anxiety about the risk that fees would turn students into consumers. This must not be allowed to happen, almost everyone agreed, not least because it is students who would suffer if universities and higher education were reduced to a transactional business.

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Fast-forward to the present, and the great anxiety, it seems, is that universities are short-changing their customers and not taking their responsibilities as service providers seriously.

The NAO report is critical of the information that is made available to students ¨C that they are not warned that there is no guaranteed financial return on their purchase (presumably like the disclaimers used by share-dealing companies ¨C the value of your investment may go down as well as up). In reality, there¡¯s plenty of information out there for those who bother to look for it, and if you are only worried about value for money and return on investment, then one of the obvious resources now available is the Longitudinal Education Outcomes (LEO)?, which breaks down the average earnings on a course-by-course basis.

That¡¯s not to suggest that this is the way that students should be making their decisions (at least not in isolation), but it is there for those who want to look at it.

The other obvious point is that the whole point of income-contingent loans is that they offer a built-in protection, insofar as those who don¡¯t earn enough of a graduate premium to pay off their debts do not have to do so.

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A broad criticism of the NAO report is that the criticisms it levels are aimed, more often than not, at universities, when universities are just operating in a system created by the government. This is not their market, although its creation was the quid pro quo for the injection of funding delivered by fees.

By pulling together various bald facts that universities have little control over (such as, ¡°it is inherently difficult to choose a course before experiencing it¡±), historic data such as the Hepi report, and new data without proper referencing (for example, around incentives to offer cheap subjects ¨C at point 3.30 in the report), the NAO report feels like grandstanding or bandwagon-jumping.

A claim that universities have little incentive to drive up quality will also raise eyebrows, relying on an analysis of ¡°a well-known league table¡± and apparently ignoring exercises such as the teaching excellence framework (TEF) or National Student Survey (NSS).

Similarly, a section on students¡¯ ability to drive up quality once on a course, apparently relies on?Office of the Independent Adjudicator () complaints, ignoring course feedback, teacher evaluations, and so on. It¡¯s worth pointing out that OIA complaints are a final stage and a long way down the line from any of these.

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Despite these talking points, what the report does make abundantly clear is that the government is treating higher education as a market, rightly or wrongly. And we already know its answer to the issues raised by the NAO: the Office for Students. Cometh the new year, cometh the OfS.

John Gill is editor of Times Higher Education.?