THE AGENCY'S OBJECTIVES #221>
There must be public confidence that quality of provision and standards ofawards in higher education are being safeguarded and enhanced.
Those who use and those who pay for higher education must have ready accessto reliable information about the performance of universities and collegesacross the extensive and diverse range of programmes of study offered.
The Higher Education Funding Councils have statutory obligations to securethe assessment of the quality of the provision they fund. Information must beprovided, and quality assurance arrangements undertaken by the agency in formsacceptable to the councils.
A national quality assurance system must meet these needs in a manner thatis effective, efficient and economical.
ASSURING STANDARDS AND QUALITY #221>
Assurance must be provided that each higher education institution isdischarging effectively its responsibilities as a body, granting awards thathave national and international standing.
To this end judgements are required on:
- the effectiveness of arrangements to ensure that all awards made in thename of the institution meet required standards
the setting and achieving of appropriate standards for each programme ofstudy
the quality of the learning opportunities offered to students. #205>#205>#205>
COLLECTING THE EVIDENCE #221>
Quality assurance must be rigorous and effective but it must not place adisproportionate burden on institutions and their staff. Internal reviewmechanisms and external scrutiny must work together to avoid duplication.
There will be reports on different aspects of quality and standards, but theevidence on which these will be based will be gathered from an integratedprocess of scrutiny of an institution and its programmes.
PUBLIC ACCOUNTABILITY #221>
The agency will publish periodic reports on:
- the exercise by each institution of its responsibilities as an awardingbody, and the arrangements at institutional level for maintaining and enhancingquality and standards
the quality of learning opportunities in each main subject area in eachinstitution
the standards achieved in each subject in each institution
an overview of standards in each subject across all institutions. #205>#205>#205>#205>
PURPOSES OF THE NEW APPROACH #221>
Assuring the standards of awards #221>
Bodies that award qualifications in respect of secondary, further andvocational education are subject to statutory regulation.
Higher education, which is largely self-regulating, must be able todemonstrate no less rigour in safeguarding its own standards.
Universities (and colleges with their own degree-awarding powers) arethemselves major awarding bodies. All grant awards in respect of the programmesthey offer on their own premises. In addition:
- some franchise programmes of study to other institutions, often in thefurther education sector or overseas
some validate individual programmes designed and offered in other highereducation establishments, or by industrial or commercial companies
some license or accredit generally other institutions to offer programmesin their name
some offer programmes through distance learning, with or without localtutorial support provided by others. #205>#205>#205>#205>
The role of universities in these areas has increased greatly in recentyears, and with it the importance of the function of granting awards forprogrammes offered through third parties. Further, the volume of provision nowoffered on institutions' own campuses is such that key aspects of the awardingfunction are sometimes delegated to faculties, schools or departments.
In the light of these developments there is a need for public assurance thateach institution maintains its degree standards, no matter how, by whom or whereprogrammes leading to those degrees are offered.
That assurance is required:
- by students, many of whom now study away from the main campus
by employers, who rely on common standards in recruiting
by higher education providers themselves, who need to know that theirprogrammes meet national standards
by the taxpayer, who meets much of the cost
particularly in respect of overseas provision, where the reputation of UKhigher education as a whole is at stake. #205>#205>#205>#205>#205>
Programme outcome standards #221>
There must be independent verification that programmes of study aredelivering their intended outcomes; and that student achievement meets thestandards required by the institution for its awards, by relevant nationalsubject benchmarks, and by any accrediting professional body.
- Students and employers require clear information about the standards thatwill be achieved and the skills that will be acquired through each programme ofstudy
Students need clear information about the extent to which a programme ofstudy will equip them to progress in their intended careers
Public concern that all degree programmes in a subject meet at least acommon minimum standard must be satisfied
Demonstrating that intended outcomes are being achieved helps show thatprogrammes represent value for money. #205>#205>#205>#205>
Quality of learning opportunities #221>
Potential students need an indication of the quality of the learningopportunities that will be available to them. Information is needed in relationto subject areas within institutions, and on the extent to which the institutionas a whole meets expectations of good practice in relation to support of studentlearning.
Independent assessment also helps institutions to enhance the quality oftheir provision:
- by identifying strengths and weaknesses
by offering recommendations for improvement
by disseminating good practice. #205>#205>#205>
SUPPORTING THE NEW APPROACH #221>
To support the new approach, work will be completed on:
- the qualifications framework -- to ensure that qualifications that share acommon title are of a common level and nature
guidance on developing programme specifications -- to help institutions setout clearly the intended outcomes of their programmes
subject benchmark standards -- to set agreed national standards in eachsubject
codes of practice in the areas recommended by the Dearing report -- topromulgate good practice in relation to support of student learning andmaintenance of academic standards. #205>#205>#205>#205>
THE SCRUTINY PROCESS #221>
Quality assurance must be rigorous and effective, but it must not place adisproportionate burden on institutions and their staff, or distort the teachingprocess. To avoid duplication, internal review mechanisms and external scrutinymust work together.
There will be an integrated process of scrutiny of institutions, with a moveaway from a series of single events to an engagement with an institution's ownreview processes over a cycle, wherever those processes are shown to besufficiently robust that they can be relied on for this purpose. The cycle willinclude a summative assessment of the effectiveness of overall academicmanagement systems, particularly those relating to assuring the standards ofawards. Reporting on standards and learning opportunities by subject will occurthroughout the cycle of review.
The review cycle #221>
Each institution will be able to propose to the agency a cycle, of not morethan six years in length, which meets their internal validation or reviewcycles, so as to minimise duplication of effort and paperwork on the part of theinstitution. The agency will seek to accommodate these proposals, subject to theoverriding need to secure national consistency and comparability of judgementsbetween institutions in the same subject area.
To meet these needs there will have to be some parameters within whichagreements will be reached with institutions about their individual cycles. Inthe first cycle the order in which subjects are reviewed will also need to takeaccount of the availability of national benchmarks for each subject.
The first cycle will be six years in length, and will be divided into twohalves. Each subject will be allocated to one half. This will mean thatinformation on any subject is generated within a period of no more than threeyears, thus ensuring it is not so old as to invalidate comparability. First halfsubjects will include those first assessed in the earlier stages of TQA cycles;second half subjects will include those that fall later in the schedule forproducing benchmark information.
In each year of the cycle a number of programmes will be reviewed byacademic reviewers. A single process of programme review will produce theevidence needed for the separate reports on outcome standards and on quality oflearning opportunities.
Where a course is subject also to accreditation by a professional orstatutory body, the institution should seek to agree with that body the timingof the review within the cycle. The agency will make every effort to cooperateso as to avoid duplication of effort, whilst ensuring that the professional orstatutory body is able fully to satisfy its accreditation responsibilities.
The agency will agree with each institution the point in the cycle at whichit will report on the awarding body function and other matters of overallacademic management.
Units of review #221>
There will be standard, subject based units of review. These will be used toreview both quality and outcomes. Institutions will be able to proposeaggregating the units for the purpose of quality reviews, particularly toreflect modular schemes and the grouping of small programmes with larger cognateprogrammes. Where subjects are aggregated, the quality review reports will stillcomment on separate subject areas if they display different qualitycharacteristics.
There will be 42 subject units, corresponding to the subject areas for whichnational benchmark standards will be produced. (A list of the units is at Annex4). The agency will work with the funding councils and the Higher EducationStatistics Agency to ensure that these units can be mapped on to other HEsubject groupings.
Academic reviewers #221>
Academic reviewers will be appointed by the agency to review both theprovision in each institutional subject grouping, and the institution's overallcapacity to assure the quality and standards of its awards. The number appointedwill depend on the scale and diversity of provision under review. Academicreviewers will be practising academics with relevant expertise, or persons fromprofessional and employment backgrounds with relevant knowledge and experience.They will be trained and remunerated by the agency.
The agency proposes to have a single cadre of academic reviewers, to reflectthe integrated and inter-dependent nature of the processes it will operate. Fromwithin this cadre individuals will be selected according to their experience andexpertise to make up teams appropriate to the matters to be reviewed. Withineach team:
Reviewers reporting upon outcomes will be practising academics with subjectexpertise in the programme area concerned. In some professional or vocationalfields some reviewers might be from an appropriate field of non-academicemployment.
Reviewers reporting upon the quality of learning opportunities will havegeneric assessment experience likely to have been gained through subject review.
Reviewers considering the overall academic management of an institution,and especially those systems relating to the awarding function, will be senioracademic figures with a background similar to that of existing academicauditors. #205>#205>#205>
Senior and experienced reviewers would be capable of being used in any orall capacities.
(For further information about academic reviewers, see Annex 1).
Working with institutional processes #221>
Academic reviewers will form their judgements through observation of theinstitution's own programme validation and review events, by drawing on thefindings of external examiners, by seeking feedback from students, staff andemployers, and by scrutiny of some overall institutional processes.
In all cases there will be a minimum of two academic reviewers for any groupof programmes, or for any institutional review, to guard against the risk ofidiosyncratic individual judgements. In most cases a larger team will berequired.
MAKING AND REPORTING JUDGEMENTS #221>
The subject/programme level #221>
The scope of a programme review will reflect the pattern of provision withinan institution, and may cover several related subjects. However, in reporting onoutcomes, separate judgements will be made by academic reviewers on eachstandard subject unit. This will allow comparison between institutions, and willinform revision of national subject benchmark standards. (For furtherinformation about benchmark standards, see Annex 3).
For each standard subject area, in each institution, a report will beproduced in each review cycle covering:
- the extent to which student attainment matches any applicable subjectbenchmark standard, qualification definition and/or level descriptor in thequalifications framework
the extent to which students are achieving the objectives set out in theprogramme specification (including any relating to key skills)
the effectiveness of the design, content and organisation of the curriculumin delivering the intended outcomes
the appropriateness of student assessment methods as instruments formeasuring the intended outcomes. #205>#205>#205>#205>
External examiners' reports and accreditation reports by professional orstatutory bodies will be important sources of evidence in reporting uponoutcomes.
Quality of learning opportunities #221>
Judgements will be made by academic reviewers in relation either to singlesubjects, or to agreed combinations of standard subject units which reflectpatterns of provision within the institution (for example, within modularschemes). For each subject or group of subjects in each institution,a reportwill be produced in each review cycle covering the extent to which each of thefollowing aspects of provision contributes to meeting the stated objectives ofthe programmes:
- Teaching and learning Student support and guidance Learning resources ; and Quality management and enhancement. #205>#205>#205>#205>
To make their judgements, academic reviewers will observe validation andreview events, and a sample of meetings of course committees, faculty boards ortheir equivalent; and will discuss with those responsible the outcomes of thoseevents and the evidence used in them to make internal judgements. They will seekviews directly from students and staff, and, where necessary, will observe asample of teaching and learning activities.
The agency will publish a handbook describing the method that will be usedby academic reviewers. In order that judgements can be made on a broadlycomparable basis, this handbook will state principles and expectations for theinternal review procedures which should apply. In the absence of suchprocedures, it may be necessary for institutions to continue to produce separateself-assessment reports for the purpose of external review.
The institutional level #221>
Arrangements to maintain quality and standards #221>
Academic reviewers will assess the robustness of institutional arrangementsto safeguard the standards of awards.
Some of the evidence on which this assessment will be based will be drawnfrom the involvement of reviewers at programme level. External examiners'reports, and any action taken in response to these, will be particularlyimportant evidence.
Reviewers will also need to observe directly some procedures at theinstitutional level, including those covered by the codes of practice to bepromulgated by the agency. In some cases, and especially where there arecollaborative schemes with other institutions, some further scrutiny ofinstitutional arrangements may be required.
Effectiveness of institutional support #221>
Drawing in part on reviews at programme level, academic reviewers willassess the extent to which student learning is supported effectively byinstitution-wide arrangements dealing with such things as student support andguidance, and the particular needs of groups such as postgraduate and overseasstudents. Many of these matters will be covered by codes of practice publishedby the agency.
The institutional report #221>
In the light of all of the evidence gathered during the review cycle, theagency's reviewers will discuss with each institution the effectiveness of itsoverall academic systems, and will produce a published report dealing with:
- The effectiveness of the exercise of the awarding function (or, where theinstitution does not award its own qualifications, the effectiveness of itsacademic management systems)
The effectiveness of institutional management of the support of studentlearning. #205>#224>#205>
The purpose of institutional review, and the subsequent report, is to helpthe institution safeguard its future. It is not merely a retrospective judgementnor is it only about identifying areas for improvement, important though thatis. It is to provide a detached and analytical view to help an institution toknow itself, to help it to be aware not only that things work, but why they areworking. In that way the factors that have contributed to past success can beapplied to secure the success of future innovation.
VARYING THE INTENSITY OF SCRUTINY #221>
The new approach is based upon existing internal processes, with academicReviewers appointed by the agency engaging with these to the extent necessary tomake independent and reliable judgements about standards and quality. Where, indue course, experience gives a high level of confidence in the procedures ofinstitutions, the level of external scrutiny needed to make reliable independentjudgements may reduce.
Subject/programme level #221>
Variation in the intensity of scrutiny at subject/programme level will be inthe extent of engagement with internal processes. If in a subject area, there isa high level of confidence, the involvement of Reviewers is likely to beconcentrated on the latter stages of the internal revalidation exercise, withreliance being placed on evidence gathering and evaluation carried out earlierby the institution itself. Pending the establishment of that level ofconfidence, reviewers would be more directly involved in those earlier stages,and, for the purposes of quality reviews, would scrutinise a higher proportionof the provision within the subject area (outcomes reviews would in all casescomment on the outcomes of each programme). Evidence for a high level ofconfidence would come from the agency's experience of working with internalprocesses, and from earlier assessment and audit reports.
Conversely, if there is a low degree of confidence in internal procedures itmay not be possible to rely on them at all. In that event, the agency would haveto carry out directly full reviews of provision at subject level.
The agency will produce a code of practice on programme monitoring andreview as a part of its overall guidance on the assurance by institutions oftheir quality and standards. The agency will have regard to this code in makingjudgements about the confidence that can be placed in institutional procedures,and will produce criteria against which decisions about varying the intensity ofscrutiny will be made.
Institutional level #221>
At institutional level the agency, acting through senior and experiencedacademic reviewers, will review with the institution the evidence gatheredthroughout the review cycle about overall academic systems. It will discuss itsfindings with the institution. If, in the agency's view, the evidence is bothsufficient and satisfactory, little further scrutiny may be required before theagency reports. If the evidence is insufficient or incomplete, further scrutinyalong the lines used at present in the agency's academic audits may be requiredto enable the academic reviewers to report.
Where an institution has significant involvement in collaborative provision,especially franchised and overseas provision, it is unlikely that reviews atprogramme level within the institution itself will yield sufficient evidenceabout the integrity of the awarding function in these circumstances.Accordingly, within the review cycle, the agency may schedule separate audits ofcollaborative and overseas provision to obtain this evidence.
UNSATISFACTORY PROVISION #221>
An unsatisfactory report on either outcomes or quality in respect of anysubject area will result in a further report within 12 months. As with thecurrent arrangements for subject review, it is assumed that a secondunsatisfactory report could result in a loss of funding from the relevantfunding council. The further report would be produced as a result of directobservation and enquiry by academic reviewers, and not by drawing upon internalprocesses.
Where a report found that provision in any subject area was notunsatisfactory, but indicated significant scope for improvement, an institutionwould be required to produce an improvement plan against which progress could bemonitored by the agency.
If the agency considers that an institution's ability to safeguard thequality and standards of its awards is in jeopardy, it will seek from theinstitution the development and implementation of a recovery plan.
In all cases, the relevant funding council will be notified immediately.
STYLE OF REPORTING #221>
Institutional reports will adopt the narrative style of the current auditreports, identifying areas for commendation, concern, or need for urgent action.Twelve months after the report is made, the institution should advise the Agencyof progress made in addressing those issues identified as requiring action.
Reports will assess whether institutions have in place arrangements havingan effect equivalent to that intended by the codes of practice published by theagency. In the great majority of cases the agency would expect to find evidenceof arrangements that were appropriate, given the circumstances and mission ofthe institution. In rare cases, arrangements might be found to be inappropriateor inadequate. In some cases arrangements might be found, in respect ofindividual codes, that were exemplary and worthy of emulation by others.
At subject level it is important that reports should provide a similaridentification of strengths and weaknesses. The aspects of the quality oflearning opportunities that will be reported upon are similar to some of theaspects now used in reporting at subject level in England.
Reporting on outcomes is more complex, as there are two main dimensions tobe considered. Achievement of the intended outcomes of the provider is somethingthat has either occurred fully or not. To the extent it may not have occurred, anumerical rating of any shortfall is not particularly helpful. A narrativeaccount, identifying clearly any remedial action that should be taken, is ofmore practical use.
The second dimension to reporting on outcomes concerns national subjectbenchmarks. In this case it would be possible to comment on the intellectualdemand the programme placed on students in relation to the benchmark. It wouldbe possible to form a view on whether satisfactory provision was at the levelof the benchmark, above that level, or significantly exceeding it.
The funding councils have made clear that in principle they consider ithighly desirable that the QAA assessments should include summative quantifiedratings as well as narrative descriptions of strengths and weaknesses; and thatthat is particularly important to underpin any link between funding and qualityof the sort currently used by SHEFC and HEFCW. Further consideration is neededof the form of reporting needed to meet this requirement.
TRIALLING THE NEW APPROACH #221>
The agency proposes to trial aspects of the new approach as follows.
Subject/programme level #221>
There will be a two year trial period, commencing in October 1998. This willmainly involve institutions in Scotland and Wales, because the existing reviewcycle has already been completed there, whereas the TQA programme is scheduledto continue in England until December 2001. In 1998/99, the focus of thetrialling will be on using benchmark information and programme specifications totest the generation of reliable reports on outcomes. Some 20 institutions,mostly in Scotland and Wales, will be involved in this work.
In 1999/2000, trials on outcomes will be extended to a wider range ofsubject areas, and will be combined with trials in generating the intended newstyle of quality and institutional level reports. During the trial period, theagency will also agree with all HEIs in Scotland and Wales a review cyclecovering all of their provision with a view to commencing the implementation ofthe new framework with effect from 2000/2001.
Transitional arrangements for audit #221>
The existing QAA audit programme will run as scheduled to 2001. Thereafter,the new model of institutional reports will be used, drawing in the firstinstance on the early findings of the new programme reports, as well as subjectreviews carried out under existing procedures.
To assist the transition to the new model, from 1999 audit reports willinclude a view of the confidence that may be placed on the reliability of theinstitution's management of its academic quality and standards.
NEXT STEPS #221>
The agency will seek to enter into agreements with the funding andrepresentative bodies (who have been fully consulted on the development of thismodel) for its further development and trialling, commencing in the 1998/99academic year.
diagrammatic representation of the new approach
annex 1 #221>
academic reviewers: time commitment #221>
the time commitment for an academic reviewer assessing programme outcomes islikely to be five or six days per institution, and could well involve visits tothe institution at various key points in the assessment cycle, not only at theend of the programme. to ensure that broad comparability was being maintainedacross the sector it would be desirable for academic reviewers to act inrelation to more than one institution. if reporting on a subject in allinstitutions is spread over a three year period within a review cycle, thiscould be achieved without the reviewer having to deal with more than one or twoinstitutions per year.
the time commitment for academic reviewers assessing the quality of learningopportunities would depend on the intensity of scrutiny that was required, butit would not be greater than the commitment now associated with a subjectreview.
the time commitment for academic reviewers involved in institutional reviewwould be comparable to that required for continuation audit at present.
time commitments of this level are no more than those now expected ofacademics involved in subject review or continuation audit. they should ensurethat academic reviewers are able to be drawn from the ranks of practisingacademics of high standing and, as such, be seen to be a part of a peer reviewprocess. however, others would be eligible for appointment, in particularpractising professionals or other persons in relevant employment.
reviewers from a professional or employment background would be particularlyappropriate in respect of professional or vocational courses. professional andstatutory bodies might be able to nominate suitable persons; this wouldfacilitate opportunities for the bodies and the agency to work together in thereview process, using a mix of academic and professional reviewers.
in all cases there would be a minimum of two academic reviewers for anygroup of programmes, or for any institutional review, to guard against the riskof idiosyncratic individual judgements. in most cases a larger team would berequired. pending the development of the confidence needed to rely to a greaterextent on institutional procedures at the subject/programme level, the resourcedevoted to review will be comparable to that now used for subject assessment.
the agency will develop criteria for the appointment of reviewers, and willkeep records of those who meet those criteria and are willing to be called upon.
annex 2 #221>
external examiners #221>
the dearing report proposed an enhanced role for external examiners inrelation to outcomes. the agency's consultation paper canvassed two possibleways forward. the first was an elaboration of the dearing model, involving someexternal examiners reporting directly to the agency. the second envisaged anacademic reviewer, appointed by and reporting to the agency, working withexternal examiners and the associated internal processes of institutions.
the consultation demonstrates a clear preference for the latter model. theformer is seen as confusing the reporting responsibilities of externalexaminers, creating conflicts of interest, and undermining the frankness of theexaminer as "critical friend".
however, some features associated with the former model were supported.these include the promulgation of guidelines or a code of practice on externalexamining, and the availability of training and development opportunities toensure that all external examiners are able to meet criteria of effectiveperformance.
the agency proposals involve use of the second model. this will be testedthrough trialling. work continues on developing a code of practice on externalexamining. draft criteria of effective performance to inform training anddevelopment are being developed by the agency.
in preparing their reports on outcomes academic reviewers will draw upon thereports of external examiners. this will enable the benefits of the experienceof external examiners to be available, but without compromising the ability ofexternal examiners to continue to report frankly and exclusively to theinstitution.
whether, in addition, a register of external examiners is required is anopen question. if it were felt helpful to have a register of those who metcriteria of effective performance in the role, the agency would be willing tomaintain such a register. however, its existence is not critical to the modelnow proposed.
annex 3 #221>
subject benchmarks #221>
the development of subject benchmark standards was a key recommendation ofthe dearing report, being seen as essential to ensure public and employerconfidence that awards, especially at first degree level, were nationallyrecognised and widely understood. some concerns about benchmarking have emergedfrom the consultation. fears were expressed that they might become tantamount toa national curriculum, or alternatively that they would be so general as to bemeaningless. some felt that the subject based approach did not cater adequatelyfor inter-disciplinary programmes. there was a concern that if thresholds wereset at the level of the pass degree this would lead to a reduction in standards.
public concern that the transition to mass higher education may haveresulted in erosion of degree standards needs to be addressed, and subjectbenchmarking has the potential to do that. the agency believes that the fearsexpressed in the consultation should be addressed through the work of the firstbenchmarking groups.
the agency commends the following points to the benchmarking groups:
the prime focus should be on the intellectual attributes associated withsuccessful study of a discipline to degree level, so as to avoid the risk ofseeming to dictate a curriculum
in professionally related fields institutions should make clear whether ornot a programme is intended to meet the requirements of a professional body.elements of a benchmark that are included solely to meet a professionalrequirement should be identified clearly as such
in determining the level at which a benchmark should be set, a group shouldnot be bound to adopt the pass/fail borderline. a group might find it morehelpful to express a benchmark at a modal level.
the agency is encouraged by the initial work of the benchmarking groupsestablished so far. it believes the work should be taken forward by:
evaluating the utility of the initial benchmarks through trialling
extending the benchmarking trials so as to widen the range of subjectsagainst which the benchmarking approach can be refined
including within the next tranche at least one inherently interdiscplinarysubject, such as business studies
establishing an advisory group to advise on benchmarking inmulti-disciplinary and modular programmes generally
drawing on the emerging conclusions of the benchmarking groups to inform thedevelopment of a level descriptor for the honours degree level of thequalifications framework.
subject benchmarking groups will also have a role to play in revising thebenchmarks in the light of experience. for each standard subject area there willbe a subject overview report at the end of each review cycle. this will draw onall of the reports on outcomes achieved by institutions, will give a generalpicture of the health of the subject area, and will inform any necessaryrevision of subject benchmark standards. a senior academic in the field,possibly the chairman of the subject benchmarking group, would be commissionedto prepare the report in conjunction with the academic reviewers in that field.in the light of this report the benchmarking group would consider whether anyamendment to the benchmarks was required.
annex 4 #221>
standard subject units #221>
(some of these units are themselves aggregations of cognate disciplines andthe detailed work of a subject benchmarking group may lead to proposals forsub-division or disaggregation. where there is the potential for this to occur,subjects will be placed as far as possible in the second half of the firstsubject review cycle, to allow time for consideration of this. )
5nursing and midwifery
6subjects allied to medicine
7social policy and administration and social work
8sociology and anthropology
9physics and astronomy
14earth and environmental studies
15agriculture, forestry, agricultural and food sciences
18building and surveying
19town and country planning and landscape
20mathematics, statistics and operational research
22librarianship and information studies
29language and related studies
30classical languages and ancient history
34theology and religious studies
35communication, media, film and television studies
36art and design
37drama, dance and performance arts
39hospitality, leisure, recreation, sports and tourism
40business and management