Is the government really re-immersing itself in the MERs debate?

Last time we as a nation had a conversation about minimum entry requirements was during the Boris Johnson era.

Then, one of the proposals was for a subject specific GCSE minimum eligibility requirement for student finance, something that we’ve been hearing rumours about resurfacing in recent weeks.

It’s worth going back to the consultation response summary from back in the day.

Consultation respondents argued that a minimum eligibility requirement at either two E grades at A level (or equivalent) or at a GCSE level could negatively impact the most disadvantaged students, and act as a barrier to them reaching their potential. In particular, respondents felt that a subject-specific GCSE minimum eligibility requirement (set at grade 4 in English and maths, or equivalent) could unfairly impact students with special educational needs and disabilities (SEND) and may not be appropriate for those undertaking certain degrees (such as creative arts).

And Universities UK concurred:

Requiring certain grades at GCSE access loans would be unfair to disadvantaged students. It wouldn’t recognise the positive outcomes that many students who don’t meet these requirements achieve.

So what has changed since then? In many senses the system is now even less well suited to this kind of intervention. The Lifelong Learning Entitlement, set to accept applications from September and start paying out in January of 2027, has been designed to “enable individuals to learn, upskill and retrain across their working lives,” via focused modules at higher education level. This should – if the government is able to stimulate demand – bring more mature learners into higher education.

The majority of UK domiciled people currently studying full-time undergraduate degrees with their highest qualifications below level 3 are mature students – those aged 25 and over. Based on information supplied by HESA Just over 5,000 under 25s had no formal qualifications, compared with more than 26,000 over 25s.

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Note that these figures do not describe the whole sector – many smaller providers (and some larger ones like BPP University and the University of Law) do not consent to the use of their data in information passed to the media. Because rounding is applied at provider level – to the nearest five – the overall totals are likely to include larger rounding errors.

It is very likely that many learners encouraged into short courses will be mature students, and it is fair to suggest that many of them may currently be put off further learning that would benefit them (and society or the economy more generally) because they don’t have the required entry qualifications for a degree.

Many respondents to the 2022 consultation argued that mature students should be exempt from such rules – given the focus on skills and the LLE it would be likely that the current government might agree. But what of the few thousand under 24 students that do not have formal qualifications at at least level 2?

Nearly half of these students are registered at one of seven providers, which are either arts-based providers (who have a long tradition of admission by portfolio) or those engaged in substantial franchise or partnership provision. A similar pattern applies if we consider qualifications at level 2 or below, and “other qualifications”.

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In both cases there are reasonable questions to ask around data quality. Previously, data collected on entry qualifications has been used to monitor equivalent level qualifications (ELQ) study, which did not attract student finance – and is used to calculate student premium funding. The ELQ rules have been scrapped as part of the move to the LLE funding system from September. And franchise or partnership provision is no longer eligible for student premium funding.

So, the entry qualifications field is rapidly becoming less important for providers to complete correctly: and, in general, data that is not used for anything is of lower quality. Certainly, given the difficulties faced in getting even basic data returned from partnerships or franchise arrangements, I wouldn’t put too much weight on what is returned: it is likely that UK domiciled students on franchise and partnership courses do have at least some qualifications, given their participation in the compulsory schooling system.

Even if you do take the data at face value, and you are concerned about young people attending university without GCSEs, there are other measures on the way designed specifically to slow and/or reduce the franchise or partnership enrollment where this might be happening. There will be new duties on providers to demonstrate a level of control over recruitment practices, and larger providers of franchised provision will be required to register with OfS.

In other words, a GCSE MER would conflict with the aims of the LLE, and have little to no effect elsewhere given other planned policy changes. And it would require a substantial investment in data collection and assurance.