The student complaints body has expressed "disappointment" with Lord Browne's idea that it should be absorbed into a "super-quango".
The Browne Review recommends that four bodies - the Higher Education Funding Council for England, the Quality Assurance Agency, the Office for Fair Access and the Office of the Independent Adjudicator - should be replaced with a single Higher Education Council.
But the OIA called the relevant section of the Browne report "evidence-light, lacking in detail and devoid of analysis". It criticised the "untested assumption" that a super-quango would be a cost-effective "cure-all" free of conflicts of interest.
The OIA questioned whether its "actual and perceived independence" could survive moving its operations into a super-quango "with no tradition of impartiality".
In an interview with THE, Rob Behrens, the independent adjudicator and chief executive of the OIA, warned that if students lost confidence in the impartiality of the process, they would be more likely to take complaints to the courts.
In Austria, he said, the body handling student complaints is based in the ministry but its ombudsman wanted to move to the English model.
Mr Behrens acknowledged that the sector needed a protocol setting out the responsibilities of different bodies and a more "joined-up" regulatory framework, but he said it was wrong to assume that the only way to achieve this was to merge corporate bodies.
Regarding the super-quango proposal, the Higher Education Policy Institute said: "There is no suggestion that the functions performed by the existing bodies are...not being satisfactorily performed. The OIA was created five years ago, and it would have been possible then to incorporate it into an existing body if that were a better arrangement."