I take your point, but I guess it depends on how seriously your institution takes the PGCHE calamitous. Our provision was quite woeful when we started 15 years ago, but it has been heavily invested in over the last five years (new programme-specific research-active teaching staff for a start). I would be concerned about a PGCHE (or similar) being pitched or interpreted as increasing staff responsibility for student learning, when it should be promoting strategies for independent learning.
At the heart of all of this IMO is how fees had changed relationships in the HE sector. I feel increasingly pressured to "provide answers", rather than "facilitate independent study" as students (and, more often, parents) see "stuff" (such as endless module handbooks, readers etc) as constituting "value for money". The reporting about "contact hours" makes me want to scream too.
One seminar group was having a moan about printing costs recently, and how unfair it is given that they paid £9,000 per academic year. One of their number piped-up that they had not actually paid anything yet, and quite a lot of them might never pay anything back which made me chortle. Anyway, they were quite surprised to learn that our budget has not increased with tuition fees - it barely covers the gap that has arisen following the withdrawl of central funding in 2012.
I think that we would be a lot better-off promoting what we are good at and why it should be valued as a unified sector (a swerve away from "employability" would be great). I guess exposure to market forces make that unlikely though, as indicated the rise and rise of discrete groups (e.g. RG).
Sorry about going rather off-topic!