DfE needs to tread carefully in its approach to non-prescribed qualifications

We're still waiting to hear on how qualifications that currently attract advanced learner loans fit into the lifelong learning entitlement. Dave Phoenix wonders if DfE is on the right track

Professor Dave Phoenix is the Vice Chancellor of London South Bank University.

It is just over three years since then Prime Minister Boris Johnson announced his intention to create a new flexible loan system, equivalent to four years of study, to replace the current student finance arrangements.

The 2025 target date for the introduction of this new Lifelong Learning Entitlement (LLE) was confirmed several months later in the Skills for Jobs White Paper.

Since that announcement, the UK has had two more Prime Ministers, four more education secretaries, and two additional universities ministers but the LLE has avoided becoming a casualty of this ministerial churn and, to their credit, officials in the Department for Education (DfE) have stuck resolutely to the ambitious time scale that the government set for them to completely up-end the funding of tertiary education.

However, their approach, which can perhaps best be described as “work it out as we go along”, is storing up problems for the future.

Advanced notice

The policy note, which the DfE published shortly after the Lifelong Learning (Higher Education Fee Limits) Bill received Royal Assent, sets out the work the department still intends to do, including multiple consultations and a second pilot scheme. While sector attention has largely been focused on the complexities of introducing modular-based study, there is another area of this which requires much greater scrutiny – and that is the LLE’s proposed replacement of Advanced Learner Loan (ALL) funded courses.

Advanced Learner Loans (ALLs) are the further education equivalent of university tuition fee loans. They are used to fund Level 3 courses that are not covered by the adult education budget and “non-prescribed” Level 4 and 5 courses.

“Non-prescribed” courses are those that, although awarded at a higher level, sit outside the higher education qualifications framework and are regulated by Ofqual. Rather than higher education providers, they are owned by awarding organisations (AOs) and professional bodies and are typically taught by colleges or training providers.

Examples of Non-Prescribed Qualifications

Award:  AAT Level 4 Diploma
Credits: Not Specified (390 Guided Learning Hours)
Taught by: Wigan and Leigh College
Awarded by: Association of Accounting Technicians

Award: Human Resource Management Level 5 Diploma
Credits: 44
Taught by: City and Islington College
Awarded by: Chartered Institute of Personnel and Development

Award: Level 4 Diploma for Financial Advisers (DipFA)
Credits: 40
Taught by: ICS Learn
Awarded by: The London Institute of Banking & Finance

Unified in theory

The Skills for Jobs White paper made it clear that a central characteristic of the LLE would be a unification of the student finance system for all loan funded provision across Levels 4 to 6.

In the first instance this means that prescribed Level 4 and 5 qualifications (such as HNCs and HNDs), will receive full student finance funding, whether they are taught in an FE or an HE institution, as long as they achieve the Higher Technical Qualification (HTQ) Kitemark from the Institute of Apprenticeships and Technical Education. This is a wholly positive development, which should open up more local learning pathways and create greater flexibility for prospective students.

But it also creates a question about what will happen to those non-prescribed qualifications that won’t be able to achieve HTQ status.

Between December 2023 and early 2024, DfE intends to review all ALL-funded qualifications that have been funded for the past three consecutive years for evidence of learner demand and meeting of the following criteria:

1. That the qualification’s purpose and outcome statements support student progression into employment and/or higher education and training.

2. That there is clear employer endorsement for the qualification. This could include existing professional body recognition, an existing inclusion as a mandated qualification in an apprenticeship or other types of endorsement.

If a qualification, such as those examples listed, meets these criteria, it will theoretically become eligible for student finance funding. To facilitate this, the Office for Students (OfS) is expected be asked to consult on the creation of a third permanent category of registration for the organisations teaching these qualifications – such as private training providers and professional bodies – which have not needed to register as a higher education providers up to this point. This will, presumably, bear some similarity to the basic category that the OfS initially proposed to include within the higher education provider register, but then later dropped in response to negative consultation feedback.

Problematic in practice

There are several reasons why the DfE should have second-thoughts about pursuing this process.

In the first place, funding such courses through the LLE will, from a learner perspective, give them the status of higher education qualifications even though a university or quality assured HEI is unlikely to have had any part in designing them. There is already an inherent risk that the LLE, in enabling students to build up their learning in chunks, may leave some learners with a collection of modules that don’t add up to a meaningful qualification, as has been seen in the development of micro-credentials in America, for example. The inclusion of non-prescribed qualifications exacerbates this risk, particularly if the criteria requires a course only to support progression into employment and/or higher education and training. While the DfE, OfS and IfATE will no doubt attempt to make the sign-off procedure rigorous, it also nevertheless creates a risk of train-to-gain style abuse of the finance system.

While universities can, and do, use accreditation of prior learning to recognise prior work, if a learner approached a university with 120 credits of certificates from professional bodies or awarding organisations I suspect there are few that would be willing to undertake the level of portfolio assessment required to enable access given there is no framework to assure their quality or relevance. As David Kernohan explains, it is difficult enough for institutions to facilitate credit transfer from other universities.

Employer wants and employer needs

Putting these operational questions to one side, I have a greater concern which is one of principle. I believe there is a wider question about what function bringing such qualifications into the student finance system is supposed to serve. Many non-prescribed qualifications are related to specific occupational skills and involve professional bodies, which would suggest they do have clear employer endorsement.

But if this is the case, why then shouldn’t employers be expected to fund them? Given there has been a 26 per cent drop in employer investment in training since 2005, the LLE should not provide an excuse for businesses to take further advantage of state and individual investment into a skills system of which they are one of the main beneficiaries. Since the level of employer investment per worker is half the EU average, the last thing we should be doing is transferring further burden from employers to students and the state – a risk that the OfS itself acknowledges.

The aims of the LLE to create greater flexibility within our higher education system is sound. It should not, however, be pursued at the risk of undermining the credibility of the higher education quality framework, nor should it risk further development of employers relying on a state benefit system for skills. DfE should give serious reconsideration about putting higher education and non-higher education qualifications on the same footing.

2 responses to “DfE needs to tread carefully in its approach to non-prescribed qualifications

  1. On the last point, there is a good argument for why the government should step in to ensure that sufficient occupational-specific training is provided – the risk otherwise is that training is under-provided due to the a company’s competitors free-riding on its training expenditure by poaching its staff. Historically, this was funded via training levies that funded Industrial Training Boards or apprentices themselves via accepting lower wages while in training rather than direct government funding.

    The big risk with individuals taking on financial responsibility for their own training is if it does not develop transferable skills that they can take to a different employer through them being useful beyond an individual firm and demonstrable via some kind of qualification, with unscrupulous employers using it to offload their training costs onto their staff and high deadweight costs. This would seem to be a far bigger risk in Labour’s plans for widening the apprenticeship levy to cover non-apprenticeship training than for incorporating ALL-funded qualifications in the LLE as at least you get a qualification in the latter. Mitigating this risk is also one of the arguments for why modular funding the LLE has been configured as a 30-credit minimum that is restricted to modules-of-courses.

  2. “……..the risk of undermining the credibility of the higher education quality framework,…”

    You are too late. The credibility of the HE quality framework died around 10 years ago when employers realised that there was no parity of any esteem let alone “quality” integrity of degrees from different universities or different subjects from the same University.

    The desire of each University to be independent and able to award its own degrees plus the emergence of UCAS, publishing the points required to be accepted for an individual institution for a specific subject, clearly indicated that the quality of a degree had a very wide range of variability.

    For me and many others, what made things even worse was the way universities clubbed together to make the state and individual students pay the same amount of £9,250 a year for any degree, implying that they were all of the same quality!!!!

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