The LLE’s chunks of maintenance support are an insult to anyone that doesn’t fit the dated “norm”

At the time my skim read caused a huge sigh, given it appeared to be largely retro-fitting the existing set of entitlements into the new credit-based system. My colleagues Michael Salmon and David Kernohan did an excellent summary here.

I know a fair bit about the way in which micro-credentials have been promoted across Europe, and England does seem to have developed the continent’s most over-engineered system for funding them.

But the more I’ve dived into the detail, the more baffled I’ve become when I’ve looked at some of the new rules surrounding maintenance for those taking full courses.

Same as it ever was

On the topline, maintenance loan amounts will depend on where a student lives (with toggles for being home or away, and in London, abroad or not), what they study, and their household income. No changes there.

Students eligible for an NHS bursary will be able to apply for a reduced rate of maintenance loan (as if the case now), distance learners will only be able to apply for a maintenance loan if they cannot attend their course in person because of a disability (as is the case now) and those on a sandwich course with a qualifying placement will be able to apply for a reduced maintenance loan (as is the case now).

But the LLE will not have different sets of rules for full-time and part-time students. That is a change from the current system. Basically, with a limit at the upper end, students’ maintenance loan entitlement is going to be chunked up or down based on the number of credits they’re studying.

As long as they have enough credits of tuition fee loan left in their balance, those taking 60 credits a year (I’m using ECTS here) will get what they get now – including the lower rate for being in their final year, and a higher rate if their course year lasts longer than 30 weeks.

Set aside the question of what counts as a “final year” in a system like this. The mooted upper limit is fascinating (I’ve rewritten to reflect ECTS rather than CATS):

If their total study is more than 90 credits in a single course year, they will not be eligible for support for any course or module that takes them beyond this limit.

You can make the case that students should be able to choose a provider and course where you can rack up more than 60 ECTS a year – that’s what accelerated degrees are.

But then there’s also this:

Learners taking more than 2.5 credits per week on average will not get entitlement for more than 2.5 credits per term week. This is equivalent to 50 hours of study per week.

Who on earth should be taking, and who on earth should be offering, courses which involve 50 hours of study a week in what we currently regard as normal term time?

Even the Working Time Regulations in the UK limit working hours to a maximum of 48 hours per week on average (calculated over a 17-week period).

On this September’s numbers, a student away from home outside London doing those 50 hours would be entitled to a maximum of £13,180 rather than £10,544.

Given that studying 50 hours a week will pretty much kill off any notion of part-time work, there are very few people able to live on £13,180. The National Living Wage (aged 21 and over), which is specifically calculated on the basis of cost of living these days, would be £18,315 on 50 hours for those 30 weeks.

Even the soon-to-be-abolished lower 18-20 rate would come to £15,000.

And anyway – if a course is “full time” (and studying for 40 hours a week is very much “full time”), why on earth would some students get £10,544, while others are getting £13,180?

The questions pile up

What if the student is on a course where the academic staff haven’t bothered to gauge the notional hours of effort for years? Is DfE saying that a student whose 60 credit year involves a lot more than 40 hours a week should be entitled to less loan than a provider that has been rather generous in its effort assumptions when calculating 75?

I dare you to say to a nursing student on 2 credits a week travelling to and from placement at all hours that they should be on a lower loan than someone AI-ing their way through a 2.5 credits a week classroom-based business degree.

If the working assumption inside DfE is that 50 hours a week is the maximum a student can study for, while 40 hours a week can be combined with part-time work, what it’s really doing is redefining the meaning of “full-time” altogether.

And if a student is enrolled on 45 credits in a year rather than the traditional 60 – and therefore studying for a notional 30 hours a week – why on earth would their maintenance support be any lower, particularly given both their own characteristics and those of the modules they’re on may mean that we’re looking at something closer to 35-40 a week?

The mooted rules on repeat study are just as baffling. “Additional entitlement” will be available for repeat study, which will involve DfE adding the cost of the affected study back on to the learner’s LLE balance for study affected by compelling personal reasons, such as illness and bereavement.

I’m assuming that means allowing them to borrow more rather than wiping the debt. Nothing says “fairness” like “more debt for a death in the family” or “pay the grad tax longer if you end up in hospital” or “your disability and our failure to adjust for it means you take longer to learn – here’s another £20k of debt”.

Who’s judging those compelling personal reasons? Will it run off the same judgement applied by the provider for its academic rules, which runs the risk of different students in identical situations being treated differently depending on the provider they’re in? Or are we looking at a situation where a provider thinks the personal reasons are compelling but the SLC doesn’t?

Above all, imagine a student has a setback or an illness. Why would it make sense to force them into pretending to attempt to complete 60 credits to keep the full maintenance loan, when switching down to 45 on a full maintenance loan would save them (and DfE) money?

The secret lives of students

I didn’t dive into the detail immediately on publication because we’re well into our SUs summer training season.

As well as helping new student leaders think through the policy challenges in the year ahead, both me and my colleague Mack tend to start the day by diving into the educational journeys of those who’ve been elected.

We’ve met students who’ve had a parent fall ill, who would have benefitted from going from 60 credits down to 45 so they could have found the time to go home more often. These rules would prevent that – because they’d lose some of their maintenance loan.

We’ve met students who would have wanted to go from 60 credits down to 45 so they could have found time to earn money to eat. These rules would prevent that – because they’d lose some of their maintenance loan.

We’ve met disabled students who found the intensity of their course a bit much because the adjustments they were entitled to weren’t really in place. They would have liked to go from 60 credits down to 45 so they could cope with it all. These rules would prevent that – because they’d lose some of their maintenance loan.

We’ve met students who wanted to do a PGT, but couldn’t afford to go full-time, and the time out from employment to go part-time wasn’t sufficiently supported by the loan. These rules would prevent that – because the LLE policy has always incongruously ignored PG.

We’ve met students who are passionate about connecting other students and building community on their course, but had a 20 hour a week job and a long commute. They would have liked to go rom 60 credits down to 45 so they could undertake those roles. These rules would prevent that – because they’d lose some of their maintenance loan.

We’ve met students who’ve had housemates with significant mental health problems. They routinely describe taking it upon themselves to go above and beyond on support because the university service was slow or the NHS was nowhere to be seen. They would have wanted to go from 60 credits down to 45 so they could juggle it all. These rules would prevent that – because they’d lose some of their maintenance loan.

We’ve met students who wanted to do distance learning for a term so they could support their relatives who’ve been ill or because they’ve been priced out of renting locally. But under these rules, distance learning attracts no maintenance support at all unless the student is disabled themselves.

I could go on – but you get the point. This is what happens when not an ounce of proper research or consultation has gone in to the actual contemporary needs of or situation of students.

We could change course

No other country in the world chunks maintenance up or down by credit. Maintenance support should be based around need – and be able to cope with diverse situations, characteristics, course types and intensities.

The very very least the LLE should do is retain a full-time maintenance loan at a single means-tested rate for anyone on more than 30 credits a year.

It’s bad enough that DfE is surreptitiously redefining the meaning of “full-time student” to mean someone who’s required to study, on average, 50 hours a week.

It’s worse that even on 50 hours a week, the maximum maintenance loan won’t come close to covering a student’s living costs.

It’s surreal that we’ve built a wildly over-engineed way of funding micro-credentials for which there’s little evidence of student demand, and little appetite among providers to supply.

It’s astonishing that DfE seems to be proposing the abolition of the definition of a “full-time” student without reference to the myriad other laws and rules that only apply to being full-time (council tax, the Renter’s Rights Bill, and so on and so on).

But the biggest scandal of all is that we seem to have spent millions building a system for future “flexibility” that will in fact penalise anyone not fitting the dated, cosseted middle-class norms of the past.