I have a lot of questions about the LLE

There haven’t been many reviews of student maintenance over decades – but those that exist have slowly started to recognise that student part-time work has been becoming a central feature of the experience.

I’m not counting the moment when Labour increased the grant in the mid-00s, and nor am I counting George Osborne’s scrapping of the grant in place of higher maintenance loans a decade or so later – neither were accompanied by much in the way of justification around need.

It’s about the assumptions that surround “full time” study that are baked into both our credit system and our student finance systems, all in the context of a growing volume of students undertaking a growing quantum of work alongside study. Let me explain.

Can you beat the Cubie

Scotland’s Cubie report (1999) noted concerns that “many students work excessively long hours and hence harm their studies”, and less than a year later Wales’ Rees review (2000) also observed that “many have to undertake excessive hours of paid work to supplement their income, which detracts from their studies” – but neither made recommendations tied directly to those hours.

In Northern Ireland, a Committee of the Assembly also had a go in 2000 – noting an increase in students’ working hours (to meet basic, not recreational living costs) and how this was “a critical factor in increased rates of student drop-outs from courses” – but again, the recommendations didn’t loop back to hours.

Wales’ Diamond Review (2016) changed things by specifically recommending that the maintenance package – a variable link of grant and loan dependent on family circumstances – be linked to the minimum wage, based on 37.5 hours per week over a 30 week period.

The Welsh Government accepted the recommendation, and that became a promise that was met for some time – but has not consistently been maintained, with last year’s uprating failing to keep pace with the link.

Scotland’s independent review of student financial support (2017) did something similar. That review actually backed maintaining the idea that employment should be for no more than ten hours a week during term time – and then recommended a “Minimum Student Income” based this time on linking the Scottish Government’s Living Wage to the maximum, albeit on 25 hours a week for a 38 week period.

That was a promise that was met for just one year – only for it to be quietly dropped when this academic year’s rates were frozen.

Phillip Augar’s Review of Post-18 Education and Funding (2019) pretty much copied that out – the panel concluding that the age 21 to 24 national minimum wage (NMW) provided an appropriate level for the majority of students – with the level set again assuming 37.5 hours a week of study and 30 weeks a year.

The panel even added that “in practice [students] are often studying for less than 37.5 hours” – without producing evidence – and so should “not receive a higher income than the minimum received by young people in full-time employment.”

That was a recommendation that the Conservatives simply never responded to – in the years that followed, the government largely pretended as if the whole of Chapter seven had never been written.

As I’ve watched both Wales and Scotland struggle with their respective commitments, I’ve noted that Scotland’s calculations always seemed a bit off – the “academic session” had always been thought of as 30 weeks, and 25 hours a week seemed a bit light.

It’s a kind of magic

It seemed light mainly because when the European Credit Transfer System (ECTS) (which maps onto the Scottish Credit and Qualifications Framework (SCQF) and the Regulated Qualifications Framework (RQF) in England, Wales and Northern Ireland) was being negotiated in the early 2000s, British exceptionalism somehow managed to get away with claiming that our universities could magically produce the same outcomes on 20 hours of student workload per ECTS point (or 10 per SCQF) – when every other country in Europe goes notionally higher.

On 60 credits a year, Scotland should have been looking at 1,200 hours a year – but it just so happened that the (higher) Living Wage and (higher) 38 weeks a year, multiplied by the (lower) 25 hours a week was only 950 hours a year that students were eventually only funded for for a single year – 250 hours short.

What I’d never noticed was that Wales’ and England’s calculations were short too. 37.5 hours a week for 30 weeks a year is 1,125 – some 75 hours short. Augar’s panel even argued that students were “often studying for less than 37.5 hours” and so shouldn’t receive more than young people in full-time work – despite the obvious additional costs faced by students.

Had the Augar/Diamond promise been met, students would this year be able to borrow a maximum (outside London, away from home) of £13,736 – it’s £12,345 for students from Wales this year, £11,400 for those from Scotland and just £10,544 for those from England (and all three have thresholds for their means test that have not been touched in years, so fewer get that max every year).

But if we actually matched the workload expectations in the credit system – which were both arrogantly light when compared to our compatriots in Europe, and fought for in an era when the student body was significantly less diverse – the figure should be a 40 hours a week workload. That’s 1,200 hours, and at £12.21 an hour (the UK’s current living wage), it would mean a max of £14,652 to be granted, borrowed or topped up by parents depending on the politics of the nation.

Some would argue that the big difference is partly made up of the significant increases we’ve seen to the minimum wage in recent years. They’re right – but the upshot is that while employers have been expected to meet the growing costs of living in the real world, governments have somehow let themselves off the hook when it comes to students.

Enter the Lifelong learning entitlement

This all creates some surreal incentives when (and if) the Lifelong Learning Entitlement (LLE) swings into action in 2027 for students from England.

Where there are students who might want, or need, to attempt less than the standard 60 credits a year – slowing down the accrual of 180 ECTS to more than 3 years – their maintenance entitlement will be reduced pro-rata by credit. I can confirm that while some countries don’t operate universal student maintenance systems, no other country in Europe chunks down what they do offer for a student on 45 credits a year rather than 60.

The perversity is that it incentivises (re-)enrolment rather than re-sit or completion. Under LLE, if a student knows they’re going to struggle to complete 60 credits in a given year they’d be daft to do anything other than pretend they can and will – as long as the university’s progression rules allow it, pre-emptively reducing their credit enrolment would reduce their maintenance entitlement.

So instead, again as long as the university’s rules allow it, they’re incentivised to enrol to fail, racking up tuition debt alongside the additional maintenance debt. It really would make a lot more sense for someone to be able to complete at their own pace.

Similarly, if a student is looking at examination re-attempts or coursework submission without attendance, they’d be daft to do so – as long, again, as their university allows it, if they struggle in a 30-credit (15 ECTS) module, they’d be better off re-enrolling onto it the following year at 75 credits in total – because the former attracts no maintenance while the latter does.

Under the current system, tuition fee loans for repeat study are tightly limited – usually to one “gift year” unless there are compelling personal reasons – but under the LLE providers will be able to charge again for repeated modules, and those repeat credits sit outside the normal per-course cap, meaning a student on a 360-credit degree who fails a 30-credit module could be charged for 390 credits in total.

Learners can still access tuition and maintenance loans for those repeats, but the way it affects their balance depends on the reason – if the repeat is due to academic failure it will eat into the £38,140 lifetime entitlement, whereas if it is due to compelling personal reasons such as illness or bereavement, the cost is added back onto the learner’s balance so their overall entitlement is preserved.

Because maintenance eligibility under LLE depends on having tuition entitlement left, that restoration also restores maintenance eligibility in principle, subject to the usual pro-rata and weekly caps.

Whose rules will apply, and how that will be policed, remains to be seen. If it’s the university’s rules on academic v personal, we’ll end up with wild inconsistencies between universities. If it’s DfE’s rules, we’ll end up with major disagreements between universities and DfE.

Meanwhile at the other end of things, there’s the ongoing mystery of the Department for Education’s apparent redefinition of “full time”.

50 hours a week

As it stands, a home UG student (away from home, outside of London) can borrow £10,544 a year – but can get a “long course” loan for courses that last between 30 weeks and three days, and 45 weeks – calculated at £113 a week.

There’s not been a lot of take up for that – on the provider side, the maximum fee chargeable is only 20 per cent higher (despite a usually 50 per cent higher credit load), and for students doing 45 rather than 30 weeks, their max loan is £13,030 – 23.6 per cent higher despite studying for 50 per cent longer.

The LLE, though, is supposed to all be about credit rather than “time”. Here a student can draw down 180 credits’ worth of fee loans – moderately improving the incentive for universities while apparently ramping it up for students – but in a way that seems unrealistic.

On the maintenance side, the LLE caps support at 5 UK credits per teaching week (≈50 hours) and at 180 UK credits per year – i.e. 75 ECTS in a standard 30-week year and 90 ECTS in a 45-week year. The problem is Bologna compliance. Quite reasonably, the ECTS rules have 60 ECTS credits as a reference “full-time” student academic experience for a year.

Retaking failed modules while also starting the next year’s modules, or accelerated programmes in parts of the year that are usually holidays, are one thing. But more than 60 credits in a standard academic year? Working, in our case, for up to “50 hours a week”? How on earth?

Does DfE really think there are humans around – bearing in mind that story from the early 00s – that should be studying for 50 hours a week? Or that credibly are?

Everyone presumably should be avoiding any incentives for “over-enrolment”, either for student mental health and quality reasons, or for “maxing out the spending money” while “clocking up the unnecessary debt” reasons – but it’s not at all clear how those incentives will be neutralised.

And the opportunities for rank unfairness are vast if a set of courses haven’t been checked for workload in donkey’s years. You can see how a pretty intense at a traditional university might end up producing more “workload” for a student in its 120 credits a year than another one being run on an accelerated basis – why should the former student get less maintenance support than the latter one?

One of the key issues is the mixing of an old system which was really based on temporality and years with a supposedly pace-agnostic switch to funding by credit. They don’t seem to mix well, and the bodging so far raises more questions than answers.

The timings are off

One other question on my mind concerns when a student might become liable for paying fees. Universities that deal in years are used to setting fees for years and, for international students at least, charging large deposits for those years which result in (often much) more money being paid upfront than the credit being attempted in a given term or semester.

A modular system where the cost is explicitly linked to the credit rate seems to push towards the idea that you pay for said credits. But at the moment the system ties tuition fee liability to calendar points, not to the way modules are actually delivered. The Student Loans Company (SLC) pays universities in three instalments across the year – 25 per cent in the autumn, 25 per cent in the spring, and 50 per cent in the summer – and most universities mirror those dates in their own fee regulations.

Nobody runs a standard academic year where students undertake 30 credits in the autumn/winter, 30 in the winter/spring and then 60 in the spring/summer. Will the SLC switch payment dates based on when students enrol onto credits? In 30-credit clumps? Or will it continue to slice the year into thirds and ignore how the learning is actually packaged?

That matters, because the promise of a credit-based system is transparency – you pay for what you take. But if liability and loan release are still tethered to arbitrary calendar points, we risk carrying old disconnects into the new regime, with some students paying for study they haven’t yet attempted and providers banking cash for teaching they haven’t yet delivered, or – more likely – students not paying for modules they have started and providers not getting paid for them.

And if maintenance loans are still delivered on their old 3 term basis too, that also undermines any flexibility that student might want and a provider might deliver – not to mention stuff like the Renter’s Rights Act in England now forcing an abandonment of termly rent paying in off-street housing.

The whole rationale for moving to credits is undermined if the financing still runs on time, not learning. At that point, all we will have achieved is layering a new language of modularity onto the same old rhythms of cash flow — a bodge that solves neither student protection nor institutional sustainability.

The upshots of all this are that if nothing else, I’ll be keeping a close eye on maintenance policy for any more fast and loose definitions of hours – which consistently seems to have been plucked out of the air to make a spreadsheet add up rather than reflect real or intended workload. Universities should be checking their workload assumptions in modules with actual student reps, and the Bologna mob should probably ask the UK to do some demonstration around that 20 hour thing a few decades on – and subject some of the pace assumptions in the LLE to some detailed scrutiny.

Historically, incentives in higher education policy are almost always undercooked, with universities chasing cash flow and students navigating survival rather than neatly behaving as the models predict.

As it stands, the LLE risks repeating the mistake – importing old rigidities into a new credit framework – and the added problem this time is DfE’s lack of interest in flexibility for so-called “full-time” students, leaving those who most need room to breathe still locked into the very constraints the reforms claim to dismantle.