More questions than answers on the Lifelong Loan Entitlement

The consultation on the Lifelong Loan Entitlement asks all the right questions, but at a high enough level to make David Kernohan suspect planning is at a very early stage

David Kernohan is Acting Editor of Wonkhe

A harmonisation of quality assurance systems across higher and further education, and a modern echo of the Personal Learning Record (PLR) in the form of an online “lifelong learning account” – never let it be said that the Lifelong Loan Entitlement (LLE) is not ambitious!

This morning’s consultation (and associated impact assessment) is pitched very much at the broad overview level. If we imagine a continuum of public consultation styles – one end at the level of principles and concepts (I offer you the “levelling up” White Paper), and the other end at the level of detailed technical implementation (for example, the recent clutch from the Office for Students) then we are on the principles side of the spectrum here.

Anyone can play guitar

While we should welcome a consultation that anyone can have a go at – especially on something as far reaching as the LLE – it does make one wonder why these proposals were initially supposed to be added to the Skills and Post-16 Education Bill (that concluded main scrutiny stages on Monday) when thinking was clearly nowhere near advanced enough. We’re pushing hard against the oft-repeated 2025 LLE start point – we were promised more primary legislation dealing with the LLE too, and looking at this stuff I feel like the 2022-23 session is looking unlikely.

We all know the overarching idea behind the LLE – the equivalent of four years of fee loans available to all for retraining and upskilling at any post-compulsory provider offering courses of any size. It’s Student Finance England (SFE) for everyone, in other words: allowing access to modules, short courses, higher technical qualifications, and other innovations away from the standardised three (or four) year full time undergraduate degree.

What we now know

The consultation finesses this a little:

  • We know that the LLE will replace both existing student finance and advanced learner loans, with a single product covering both use cases.
  • We have confirmation that study of any length between level 4 and level 6 is in bounds (level 4 is something like the old HNC, or year one of a degree).
  • We know the total value of loans available is equivalent to four years of education, and that there will be some degree of standardisation around prices.
  • The higher education short course trials, the gradual introduction of higher technical qualifications (HTQs), the work of the Institutes of Technology (IoTs) with learners already in employment, and the “emerging skills programme” will all feed in to the development of the LLE implementation.

Credit frameworks

There were fears that every course would become modular by default – this appears now not to be the case. DfE wants as many providers to offer modularised courses as possible, but recognises that some courses (medicine is given as an example) are best studied as a longer unit.

And the size of a “module” is to be set at 30 credits – equivalent to a quarter of one year of a degree in the Framework for Higher Education Qualifications (FHEQ), though the pedant in me notes that FHEQ defines levels of qualification and the volumetric credits used here are in fact from the Credit Accumulation and Transfer Scheme (CATS) and/or the Qualification Frameworks in the European Higher Education Area (QF-EHEA). Brexit means Brexit, I guess.

Of course the 30 credit module represents just one potential modular format that universities adopt. Should your provider go the more usual route of eight 15 credit modules a year (or a mix of 15 and 10 credit modules) prospective students would have to access more than one of your modules to access a “modular” fee loan. There’ll be much fun to be had in academic registries on that one.

There doesn’t seem to be an appetite to mandate or centralise any particular frameworks of credit to normalise credit transfer – no Credit Transfer Framework regulations or anything like that – rather a more general hope that somehow the wider sector can muddle through. This is at odds with the language seeking clarity and transparency for learners on what can be the hugely complex issue of getting college Y to recognise learning you have done at university X (or even your work at employer Z – prior experiential learning is also up for grabs).

History tells us that the sector has not been able to muddle through on this one in the past, without a degree of centralisation I expect the same will apply here – though there is scope for you to explain this to DfE in your consultation response.

Maintenance loans

The proposal on the table is that maintenance loans (no sign of the return of grants as Augar hinted) would somehow be linked pro-rata to the number of credits a student is taking, with some twiddles to take account of intensity and the type of study.

For something that is a huge part of the cost of this proposal, it does feel like the issue is given surprisingly little attention. You could imagine a world in which mature learners taking two modules part time to upskill might not want a maintenance grant, but make the system too welcoming and the option of an interest free loan with salary-linked repayments for a new kitchen or holiday in the sun may be tempting. Go too far the other way, and a 19 year old with caring responsibilities doing a law degree module by module may not be able to access the support they need to study.

The document also chucks in the idea of providers offering bursaries (a repurposed reheat of the failed 2014 policy on selective fee reductions). But we are missing a huge chunk of modelling about the behaviour of individuals and providers within this system. The consultation questions are the right ones (though do we really need to ask: “To what extent do you think maintenance support would be a consideration for learner access to, and progression through, LLE funded courses”?) but there is a lot of very interesting social sciences research that needs to be done as well.

Quality matters

As a policy proposal, LLE shares a bloodline with the Individual Learner Accounts (ILA) – a 2000 policy which saw the government provide an account that could be spent on a number of learning opportunities and quickly became a byword for fraud and scams. So the LLE needs to have some means of assuring the quality of provision funded by the government – as it does for higher education (the OfS register and, nominally, the UK Quality Code), further education (ESFA, Ofsted) and in the various other systems .

With all of these systems now receiving funding (via the LLE) in the same way, the consultation hints gently at the idea that the quality should be assessed in a similar way. If you are fearing (or fervently hoping for) Ofsted rocking up to University College Oxford looking for stuff to audit I can only assume that things won’t go that far – the presumption is towards aligning regulatory approaches as a way to minimise burden while offering a consistent minimum level of quality and taxpayer value via a simplified burden-reducing system. With prices for modules looking like they will be set pro-rata to university fee caps, you’d imagine levelling up (as it were) rather than a race to the bottom.

Again, the action is in the questions – and the questions are almost impossibly broad.

The learner experience

At the policy launch, in front of an invite-only audience at the Centre for Policy Studies, Michelle Donelan enthused – as she tends to – about the LLE. This morning, her interest was piqued by the prospect of a “bank style” Lifelong Learning Account that would show your current and previous study, your remaining balance, and offer pseudo-AI course recommendations to further your career goals.

The mock-up provided in the consultation does bear more than a passing resemblance to the 2008 Personal Learning Record (itself an attempt to rethink the failed ILAs), which still technically (in the sense that you can write to DfE to ask for a copy of your own) exists – though the fancy web interface is long gone. The PLR was the learner-facing aspect of a wider initiative (MIAP) that aimed to standardise data across the post-compulsory sector.

In reality, the time has very much come for MIAP2 – lots of the assumptions baked into the LLE and the associated account interface only work if all of the data definition ducks are lined up in a row. I know it is only a mock up but the sight of an SFE customer reference number rather than the standard ULN that the rest of the post-compulsory sector has been using for years does not fill me with any hope that this history is well known among the current crop of policymakers.

If it was, they’ll know that the PLR failed as a learner-facing resource because of a lack of use by learners – something which the consultation does not address as it offers us some whizzy new technology.

Failure to model

And it is that lack of understanding about the likely consequences of these decisions that is – for me – the biggest disappointment in this documentation. The impact assessment relies on the same few small surveys that we already know, and draws inferences from LEO to cast the applicant as a rational economic actor (it also starts with the phrase “As we Build Back Better…” which is unforgivable).

We get – as is required – a best estimate of £5.1bn in costs (to employers, not even to providers!) over the next 10 years. The expected benefits of the LLE have not been monetised, because the underpinning assumptions on learner and provider behaviour are little more than hunches. So we see the possibility of:

  • An increase in demand for further education courses or shorter higher education courses from individuals that previously would have stopped study at level 3.
  • An increase in demand for further education courses or shorter higher education courses from employed individuals looking to upskill or retrain.
  • A shift away from 3-year undergraduate degrees towards level 4 and 5 qualifications or standalone modular study

Each has an impact on providers (in terms of income expectations and the need to plan and resource provision) and on the Exchequer (more borrowers, even if the course costs may be lower) and we don’t get even the smallest attempt to quantify either, though there is an assumption tucked away in the “business costs” section that higher education enrolment will rise by anything from one to ten per cent – anything between 4,000 and 38,000 new learners. DfE is designing a complex system of overlapping incentives but has not modelled how this system will work in practice.

Sharia compliant finance

Annex A of the LLE impact assessment is where you will find detail of the latest proposals to finally fix a glaring hole in the student finance system – the availability of Sharia compliant loans. Although it starts by minimising the scope of the problem

Around 12 per cent of undergraduates identify as Muslim, and many of them are using existing SFE loans – a similar proportion to other religious groups. Twelve per cent of Muslim undergraduates don’t go via the loan system – compared to 11 per cent of Christian students and 23 per cent of Jewish students.

The government feels that low income Muslim students are particularly likely to see a benefit from Sharia compliant finance. But the question is still “if and how” rather than “when”, which – more than a decade after David Cameron’s initial promise – rings a little hollow.

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