Labour wants to set up a new skills body for England. Labour wants to review the post-16 landscape. Labour wants to repurpose the apprenticeship levy to include other training opportunities.
Given all this, should we really be expecting the Lifelong Learning Entitlement to continue in its current form under the new government?
The party is in a potentially awkward position, having supported the policy intention and its accompanying legislation – though striving to be clear during parliamentary debates that the detail wasn’t there. It was mildly noticeable that it didn’t commit to it in its manifesto, though the same could be said about much else.
The new government is now in full “lifting the lid” mode, spotting all kinds of problems in every government department which it couldn’t possibly have known about while in opposition.
And the LLE has been beset by gremlins throughout its development, as we’ve covered exhaustively and some would say obsessively on Wonkhe. It’s got to the point where at the absolute minimum a delay is surely on the cards. And hidden within the issues that have persisted throughout development, there are a number of reasons why Labour might want to put the brakes on the project.
Rollout goes clunk
First up, the nuts and bolts of the LLE timeline are causing headaches.
The current plan, in theory, is for students in September 2025 to be able to apply for LLE funding for certain technical courses beginning in January 2026 – which in itself is a small delay from the original schedule.
But this is predicated on a number of actions that are supposed to be taking place right now: the laying of secondary legislation covering fee limits, a consultation on modular funding, and further information on the qualification “gateway” (the forthcoming approval process for new qualifications). Some of those things were originally planned for spring 2024, have slipped to summer on the official timetable, and clearly are now not going to happen before we all hit the beach.
Last summer DfE permanent secretary Susan Acland-Hood warned of “little leeway in the critical path” to LLE rollout, partly due to the volume of regulations that needed to be laid. These haven’t materialised, partly (but only partly, you sense) due to the election.
So where we are now is a situation where an unrealistically tight turnaround to get the systems up and running has missed key milestones. It feels inevitable that Labour will need to announce further delays – and the politics of this means that there is scope for a pause pending a review or other post-16 strategy-making, or simply the announcement of a re-think laying the blame at the door of the previous government’s mismanagement. The approach Labour will take to lots of different aspects of running the country, in other words.
We’re sorry there’s no money
Would Labour want to simply press on though, with just some time, civil service attention and additional investment of technical resources to iron out the problems?
The question of wider plans for a new levy and changes to the skills system which still need to be consulted on make it seem like an odd way to move forward in the short term. And there are spending review-adjacent concerns around where DfE is going to invest its money.
This leads to the vexed question of how much making the LLE work is really going to cost. The impact assessments for the policy have been one of the most dispiriting parts of the process, with total lack of curiosity on the last government’s part about institutions’ capacity to take on the design and administration work necessary. The sector made its case, but you never felt the government was listening.
This is likely to change now, with Labour at least not wanting to be visibly ignoring what universities are saying. Back at committee stage in the Commons, then shadow higher education minister Matt Western gave the Labour-via-the-HE-sector line at the time:
It cannot be logical that the costs per student unit will remain the same for modular learning provision. There will be a significant increase in the cost burden to institutions through the delivery of courses, but also in the administration and onboarding of students, and in managing departing students, and all the data needs around those changes.
Another Labour member of the committee, with an eye to the future, suggested that the Conservatives would be handing over a policy with great additional investment needed. This contains a skeleton of the prudent Labour case for a rethink: the LLE has the potential to require additional government investment, and cannot be justified when times are tight, priorities are elsewhere, and the fiscal inheritance is a newsline to be hammered home at every opportunity.
Labour’s in-tray will also contain questions about the franchising of higher education courses, off the back of the unresolved Public Accounts Committee inquiry earlier this year. As I suggested in April, there’s a need to think about how this all interacts. Maybe the consultation that was supposed to have taken place several months ago would have covered it. The new DfE will need to ask itself whether now is really the right time to further open the student loan book to untried new programmes of study.
If incoming ministers want to put the brakes on the LLE and set out their own vision, then whether privately or publicly the issue of accessing loan funding for shorter courses and modules should be front and centre. There’s no chance that Labour will come out against the vague-but-eternally-popular idea of reskilling as a silver bullet for productivity. But it can question whether recourse to the Plan 5 student finance system is the right way to do it – and it can make the supplementary point that it’s partly about rigour in the government’s control of the loan book.
The business case
Will Labour agree that accessing loan funding for shorter courses is really as desirable as the last government assumed? To the extent that the Conservative opposition is in a position to mount a pushback, the attack line would be that the government is stymying efforts to promote alternatives to university, “upskilling and reskilling”, and aspiration more generally, a criticism also likely to be levelled – though more diplomatically – by providers keen to get access to modular funding. Labour would be able to point to its plans for a “growth and skills levy”, which will encompass shorter training opportunities. But the issue of debt aversion is a powerful case for change as well.
Because make no mistake, the Augar assumption – that bitesize student loans whose repayment plans will behave in unpredictable ways are the way to get students doing a range of shorter study programmes – is looking ever more difficult to sustain.
The evidence in its favour is a yawning gap, and important for Labour policy wonks to grapple with. The higher education short course trial debacle – let’s be blunt – needs little rehearsing at this point. If you’ve blocked it from your memory David Kernohan’s assessment of the final report is on hand. The trial was designed to “test the interest of both students and employers in shorter provision” – whatever was said later – and clearly failed on its own terms.
Meanwhile, polling by Public First in 2022 for “longevity think tank” Phoenix Insights found that an aversion to taking on new debt was the top reason why potential learners would not want to use the LLE, and that for those wanting to retrain there was no statistically significant impact of having the loan funding available or not. A more recent round of polling last autumn suggested that older people and those without existing higher education qualifications were particularly ill-disposed to taking out loans. Which is to say, those adults who represent a large segment of the putative target market.
Since the short course trial fiasco, DfE has been running what has been given the ungainly title of a “modular acceleration programme” (MAP), badged as part of the LLE but also serving as a demand-side companion to its previous “skills injection fund” which provided the kind of seed funding for HTQs that’s clearly also going to be needed to make the LLE work.
The modular acceleration programme is like the short course trial except that students aren’t required to pay, and the modules must form part of full higher technical qualifications from an approved list of providers, mostly further education colleges. The link to the LLE is that the funding which students access – again, which doesn’t need to be repaid – is deducted from future LLE entitlements.
A cynic might describe this as “handing out free HTQ modules” in an attempt to manufacture evidence of demand; the old DfE would have likely made the case that it’s about testing systems and gathering evidence, the same justification that was (retrospectively) applied to the short courses trial. But it’s noticeable that they’ve given up on the “take out a small but unpredictable loan” element of the development process.
Does it pass the vibe check?
Fundamentally there is a question of whether the LLE as currently conceived fits in with Keir Starmer and the Labour Treasury’s growth-and-industrial-strategy approach to government. I’ve been talking so far about the decisions new DfE ministers will take, but all the signs are that the big HE policies – when they do emerge – will come out of teams at Number 10 and 11.
We’ve gone over the cynical view of the modular acceleration programme, but with fresh eyes it could have the seed of something interesting for lifelong learning. The fact that students’ tuition fees will be covered but they will lose residual entitlement to future study is much more along the lines of what lifelong learning advocates have called for all along – an allowance, rather than permission to take on debt, which can be used throughout one’s life.
This was always going to be a tough sell. But the MAP idea has a tighter focus, with planned subject areas – business and administration, construction, design and build, digital, education and early years, engineering and manufacturing, and health and science – and a bidding process that has restricted it to specific further education colleges and a handful of universities extremely well-versed in the HE/FE common ground.
Something like this, but bigger and across a much longer funding envelope, feels much more in keeping with the Labour vibe, if it can rustle up the investment for it. It would speak to devolution and labour market responsiveness, and have an eye to subject area in a way that the last government’s grand ambitions for the LLE never did as set out – though the existence of the MAP and plans for a validation gateway suggest it was slowly coming round to this way of thinking anyway. More purposeful planning of who, what and where would also avoid what to me seem likely issues around unsuitable franchise agreements, whereby LLE funding is pushed to students in popular subject areas in already well-catered-for locations, with even less regulatory oversight possible.
Along with the MAP, another touchpoint for Labour could be the Office for Students-funded AI and data science postgraduate conversion courses. From the independent review earlier this year, these look to have been a largely successful use of targeted funding in a priority subject area for the government.
Wherever we go
Much of the LLE’s architecture will come in handy wherever we go – per-credit funding, student maintenance being delivered more flexibly, the removal of the equivalent and lower level funding rule, the initial sketch of an idea for better credit transfer between FE and HE. All the back-breaking labour that the Student Loans Company has put in at its end is unlikely to be wasted.
There have also been calls for higher technical qualifications to be at the front of the queue for levy funding, as Labour looks to shake up how this not insubstantial chunk of employer-derived skills funding is spent. There’s a big political vulnerability here if apprenticeship numbers fall – as you assume they must, at this stage – but the idea of employers paying for a broader slice of the skills system also looks like a promising source of funds for Labour to tap up, and one which could go to interesting places in the longer term.
One way or another, it’s verging on ridiculous to think that training-focused modular provision can be funded both by the levy and the Plan 5 student loan system. And Labour will have to address it.
