Michelle Donelan may not have quite registered the size of the dirty great hole in the middle of the Skills and Post-16 Education Bill, but you’d better hope a large number of DfE officials are actively working on addressing it.
For those just joining us, most of the detail of the way the Lifelong Learning Entitlement (LLE) will work – only the biggest single reorganisation of post-compulsory education funding since the Robbins Review – remains a closely guarded government secret. More of this detail will be inserted at the Lords Committee stage (via a government amendment), the remainder will be exercised via secondary legislation in 2024.
There will, apparently, be a consultation of some sort before this. As of last week it feels like this won’t be the full “how do you feel about £7,500 fees?” job that’s been bubbling under in the mainstream press and stalking vice chancellor’s nightmares over the past month or so. But there is rather a lot to sort out, and in the spirit of public spirited scrutiny I thought I’d put together a list of talking points.
Why do it like this?
Why launch a bill with text that is incomplete – and, specifically, why launch it in a House of Lords packed to the rafters with higher education policy and practical expertise? The architects of the last major reforms sit, perhaps precariously, on the government benches currently – the Lords still has an opposition majority in theory and practice, and although it tends not to muck about too much with the Salisbury Doctrine the times it has in the past tend to be around either shockingly badly written law, or higher education policy, or both.
You can pretty much bet that four pages of essay-crisis tweaks to HERA17 for inclusion in the new Bill are going to go down like a bucket of cold sick with the Lords Spiritual and Temporal, especially the described measures will fall apart in the first strong critical breeze (like the Free Speech Bill, say). The existing text simply adds “or modules” wherever law says “courses”, and makes provision for the Secretary of State to set a “lifetime limit” by reference to finance or course characteristics via secondary legislation. And a “module” becomes a thing the Student Loans Company can fund.
Defining a module would feel like an important part of this work – we don’t quite get that, although we learn that a module can last less than an academic year (thanks for that), and that two or more modules can be treated as a single module, and modules don’t have to be delivered in the UK to be fundable.
A need for definitions
Defining a “course” is a legendarily difficult undertaking. The closest we get is a kind of resignation that a course is what a provider says it is, under the very broad umbrella of:
there is a broadly common model of a student registering on a thing that is made up of components (which might include sub-components) and which is defined by some sort of outcome
I’m a fan of this level of pragmatism. Although it makes data collection and analysis very tricky, it also captures the width and diversity of higher education provision. Fans of the collected works of Gavin Williamson will also understand that, for all the “low quality courses” rhetoric, he’s really arguing about low quality CaH subject groups within providers – it is vanishingly rare that we see a course in public data (even unistats uses mainly subject aggregations in all but the most basic descriptive data).
We never see module data, though it is collected in quite astonishing detail. Indeed, institutional data specialists will happily explain their delight in expending significant effort in collecting data that is rarely used and never published. Module level data from the HESA Student collection does (after a fashion) underpin the allocation of provision to OfS Price Groups and plays a role in the aligning teaching costs to HESA Cost Codes – it’s also used in the calculation of Welsh medium premium funding by HEFCW.
Data fans will have spotted that this is data that is collected for a very specific set of largely aggregative purposes, and it will be carefully “optimised” at the collection state to ensure it best addresses the needs expressed within these purposes. If we start using it for something else, it may not work as we might expect.
The plan before us is an environment where learners apply to, and government funds, and regulators therefore regulate, much smaller units of learning. My first question would be whether this would be a top down or bottom up approach:
- Top down: learners still apply to larger traditional qualifications like BSc, MEng, LLB, or even a Higher Technical Qualification, but also have the opportunity to apply to other, new, qualifications based on modules and other short courses.
- Bottom up: everything is a module – an application to a BSc is just an application to a specified 360 credits worth of modules. Or maybe you would apply for a year of modules at a time.
Depending on the degree of change DfE is after, each of these routes has advantages and drawbacks. If the modular offer is to be a complementary one (and we ignore all the stuff that has been said about qualification proliferation at sub-degree level and moving away from the degree norm) we simply have a range of new courses of differing sizes for learners to apply to. If we are going as radical as Williamson and Johnson like to pretend, modules would need to be the default approach with infinite on/off points.
One of these options requires some more data and capabilities, but scales naturally from what is currently done (because, really, it is business as usual but with more courses to fit into your Student Record System). The other requires an order of magnitude change in the collection and use of data across HE and FE.
There is an increasing sense that flexible, “hop-on, hop-off” learning will become the default. As the Secretary of State put it last week:
Our student finance system currently favours and pushes people towards a three-year full-time degree at the expense of lifelong and higher technical learning. But most people need more flexibility in their lives to study, to train or retrain and upskill as both their circumstances and the economy change.
Or in the words of the White Paper:
The loan entitlement will be useable for modules at higher technical and degree levels (levels 4 to 6) regardless of whether they are provided in colleges or universities, as well as for full years of study. It will make it easier for adults and young people to study more flexibly – allowing them to space out their studies, transfer credits between institutions, and partake in more part-time study.
So: let’s build back, as they say, better – here’s what we’d need to do to make a “bottom up” system work:
Every module on offer at a higher education provider should have a module descriptor attached to it – setting out everything from quality assurance requirements, to subject coverage, to learning outcomes, to the way it articulates with other modules. All of this would need to become externally facing and externally readable – if “Mixed Media Techniques 2” articulates with “Mixed Media Techniques 1”, an applicant would need to see this articulation expressed as an entrance requirement and you’d need some way of assessing whether someone meets this.
Are you running a PSRB-accredited course? The above applies, but also requires that you set out precisely which mandated material the module covers and any prerequisites, on the off chance an applicant wants to use your module in combination with a collection from other places to qualify as, say, a mental health nurse.
How many credits are your modules worth and how long do they last? Most providers have ping-ponged between 10,15, and 20 credit modules – and may have a mixture of long-and-thin and short-and-fat modules. There may be sound pedagogical reasons for these differences, or your pro-vice chancellor might have just woken up and decided one morning. Anyway, these choices may now have financial implications in terms of income, and may make your module more or less attractive to applicants. When faced with two “Introduction to Marketing for Business” modules, one of which lasts 3 months and “costs” 10 credits, the other lasts for 4 months and “costs” 15 credits, learners may be making choices for non-optimal reasons.
We’ll assume that there will be a UCAS or UCAS-like service that aggregates courses offered by all or most providers. Clearly, the amount of data submitted to and processed by UCAS is going to go up – and if “everything is a module” it will go up astronomically. You may need some more good data people, is what I am suggesting here – you will also need capacity in the marketing team to describe “Statistics for Social Science Researchers 3” in a way that makes the offer really pop.
There’s work to be done, too, in defining aggregations of modules as longer courses – especially where a selling point or defined feature has been optionality – it is good in recruitment terms to permit a “cars” or “bikes” track in your “BEng Performance Engineering” pathway – depending on how the system works a learner would need to apply up-front to a pathway, or there would be an annual reconfiguration. This, of course, would all have to happen at the last minute because of a move to Post-Qualification Application, so good luck with that capacity planning!
Just as an aside – will the UCAS forms work with applications to a single module? Would you need to apply to only six?
The best bit of the last spending round was where the Student Loans Company got £50m to update computer systems. The SLC offer extends far beyond three year fee loans now, to include the full range of fee and maintenance offers – over four nations, at adult learning, undergraduate, and post-graduate levels. It is a complex thing to do – bringing in FE and skills provision, and doing everything at a micro level might require some more systems expansion.
The SLC higher education data system currently only works on an annual basis, and simply collects attendance data at three points to release fee and maintenance loans. It would need to expand to do this for each module – a huge increase in administrative overheads for providers and the agency itself.
Data collection and regulation
With a move to a modular “norm”, talking about “low quality courses” makes even less sense than it does now. Learners would apply to and study modules – leaving us with the spectre of DfE or OfS producing earnings or “skilled job” rankings of all the “Women’s Writing 1900-1950” modules in the system, and comparing them as a whole with “Advanced macroeconomics and forecasting” modules.
Providers, and at best subject areas within providers, are the default units of publication for higher education data. Students currently engage one level below this, at the course granularity, engaging with modules makes that two. How useful would, say, “Discover Uni” (don’t laugh, that’s not fair) to somebody scoping out the best “Contemporary issues in housing policy” module? Could we provide her with any meaningful and statistically valid data to help her decide?
Though HESA Student already includes the collection of modular data – not all of it will be suitable for new regulatory or informational use. There will need to be investment both in capacity and retraining – smaller providers (perhaps those most likely to already be offering smaller courses) would struggle in particular. And – lest we forget, not all providers map to the same credit frameworks – credit is commonly but not universally understood. And some courses don’t even have modules. All good news for Data Futures.
Straight to the top
I’ve taken a preliminary look at what could be construed as a “worst case scenario” here – but I can’t help thinking that all of the transformational, revolutionary rhetoric does point in a bottom up direction. There’s a lot more thinking to do about the administrative impact – at sector agency and provider level – but in trying to sketch out some things that may need to be considered I hope I’ve made it clear just how much work will be involved.
Expanding the administrative capacity of universities and UCAS is neither sexy nor an easy sell on the doorstep, but it is the only thing that addresses the lived learner experience of interfacing with the new sector. It’s a good thing that university finances are so stable and there are no cuts on the horizon, really, isn’t it?