I had fascinating a new experience recently: giving evidence to a House of Commons Bill Committee.
In this case, the committee was considering the Lifelong Learning (Higher Education Fee Limits) Bill – which supports the wider government policy of introducing a Lifelong Loan Entitlement (LLE).
Although the primary purpose of such sessions is to consider the text on the face of the Bill, this committee chose to start with evidence from the sector. Much of the ensuing discussion was focused on the implications for providers who intend to respond positively to the policy, and open up new opportunities to study at higher education level.
We all welcome this bill and the policy it supports, we really do.
We would like to see opportunities extended to taught postgraduate (L7) as well, as we think that would lend itself well to the implied short course model. We also appreciate the policy intent behind it – to make sure that, in up-front financial terms, students will pay a proportional amount for the credits they study vis a vis the “fixed method” amount.
However, while that will act as an incentive to students to take up modularised courses, it also acts as a disincentive for providers to engage. Even if they are keen to do so, the complexities of delivery undermine the business case as extra resources will be needed to introduce and run small modular programmes.
Thinking through the process
To illustrate this for the committee, I ran through a number of key areas where the plans could have unintended, and burdensome, consequences.
On marketing the most effective approach to admissions for LLE programmes is unknown. Putting courses up on the UCAS website might not seem unduly onerous, but representing the multitude of permutations of learning – including those combinations within and without the institution – is in reality quite a task and should be seen alongside marketing efforts to ensure sufficient take up.
Trying to explain a complex set of options to prospective students will take time and effort with sophisticated information, advice, and guidance (IAG) requirements to make sure that whatever combination of modules they wish to do adds up to something that achieves the desired academic and developmental objectives. And – coupled with this – the volume of admissions may well increase but these also become more complex, especially where prior learning needs to be evaluated and an assessment made of the fit within a programme.
Student records built on the premise of programmes with modular structures sat within them will need to manage the implications of such a flexible system. The configurations need to cope with a wide variety of eventualities.
And coupled with this, we will see increased demand for student support and other student services (including but not limited to wellbeing, library, IT, and careers advice) – and we will need to work quickly to understand eligibility for students to access these services in the gaps between study periods.
Of course we are also faced with the issue of student data returns: the implications remain unclear and recent engagements on Data Futures has left the issue of data linked to short course and modular study open ended. It is likely returns on a modular basis will be required to meet funding and regulatory requirements, and probably with greater frequency than currently. The prospect of two parallel systems does not feel farfetched which exacerbates current frustrations about multiple data returns.
Need to know
In reply to a question from the committee, I did suggest that some seed funding to help providers get started on building capacity to deal with these issues before we settle into business as usual might be sensible, if we want this policy to be as radical as envisaged.
Members were very interested in potential tensions between the LLE and the current regulatory framework, expecting that modular courses will need a differentiated approach. Obvious examples where problems could arise include the notions of completion when the target award is uncertain, continuation in a world of modularisation (where ongoing engagement beyond a year is a judgement neutral concept), and graduate outcomes given the possibility that “success” as a graduate could be attributed to several possible HEIs depending on the route a student has taken. To use that lovely expression, success has many fathers but failure is an orphan.
Other tricky areas which need to be bottomed out include who will provide IAG on a sector wide basis, who owns (if anyone) students between modules, how do you track them and who awards the actual degree. We need also to think about links to the apprenticeship levy, responsiveness to the needs of employers, and how we make sure the LLE has better take up than T Levels. The most obvious answer here is clarity – and with that, comms, comms and more comms!
Welcome as the concept behind LLE is, we should prepare on the basis that it will lead to a high regulatory and administrative burden on universities and colleges, with a new regime being added onto an existing one. This makes the work within the sector on reducing the current regulatory burden even more time critical.
Right now I am chairing a Task & Finish Group on this theme for the Russell Group and, as illustrations help tell a story, all examples of unreasonable burden are welcome.
I think in the same way that being able to give the Committee concrete examples of how extra complexity would bite was really helpful, to bring issues like this to a relatable level so we need concrete examples of current complexity and suggestions for how we can improve the situation for us all. All such examples are very welcome!