Put your hand up if you think the LLE will arrive in 2025

Probably the biggest piece of news we got in March’s LLE consultation response was that modular provision at levels 4 to 6 – with the exception of Higher Technical Qualification (HTQ) courses, plus some other technical qualifications – would not move into the LLE’s scope until 2027–28, when the government could “be confident of positive outcomes.”

While tuition fee loans for existing higher education courses (those based on annual tuition fees) will be processed via LLE systems from 2025, this felt quite the setback given several years of “LLE” and “2025” forming an ever closer relationship.

Of course, 2025 is a lot closer now than it used to be. Is the initial (reduced in scale) rollout on track, do we reckon?

This morning has brought the LLE’s “assessment against accounting officer standards” from redoubtable DfE permanent secretary Susan Acland-Hood. This boilerplate publication is required for all government major projects, and involves evaluation of a project’s progress against four standards:

• Regularity – sufficient legal basis, parliamentary authority, and Treasury authorisation
• Propriety – meets the “high standards of public conduct” and Parliamentary control procedures and expectations
• Value for money – delivers value for the public purse “in comparison to alternative proposals or doing nothing”
• Feasibility – it can be implemented accurately, sustainably, and to the intended timetable.

We wouldn’t expect anything too dramatic in here, but it’s worth giving the assessment a close read.

The question of regularity is uncontroversial – various legislation is in place already, and the Lifelong Learning (Higher Education Fee Limits) Bill will continue its jolly and unamended progress through Parliament this autumn, with report stage in the Lords due for 5 September and Royal Assent likely not too far off now.

On the question of propriety, we hear somewhat surprisingly that “HM Treasury is being engaged on approval of the [outline business case] during summer 2023.” No reason to suspect issues on this end, as it’s really about following correct procedures, but worth bearing in mind for later.

Next, will the LLE provide value for money? Yes, because:

It is expected that the LLE will incentivise more people to study at levels 4 to 6, including those who would not have otherwise studied because of the barriers they face in the current system.

Because of the high lifetime returns of further and higher education, DfE expects that learners will benefit from LLE and generate positive economic returns to the economy. As such, the LLE programme would only need to have a small impact on behaviours to cover the public costs and will therefore continue to deliver value for money.

So even a small change in behaviour will cover the cost of implementing the LLE. This will come as welcome news to those worried that there is a lack of evidence for likely demand (“the behavioural response of students and providers remain very uncertain”). The impact assessment that accompanied the consultation response, you might remember, contained the zinger that DfE estimated “general and detailed familiarisation costs to providers and employers of LLE of around £4.7m in the first year and £0.1m for the second year onwards.” As long as that’s true (spoiler: it isn’t), then nothing to see here.

The final accounting officer standard, feasibility, is the only point in the assessment where a tad of doubt seems to creep in:

There is little leeway in the critical path to 2025, and there are factors outside of the programme team’s control that may delay the reform.

It is feasible to deliver, we’re told, but “with significant delivery challenges to meet the 2025 launch,” and “continued attention needs to be paid to the timeframe for reform.” A recent review has been conducted, finding that so far the programme has been successfully managed to deliver on time. Part of this could be because of the lack of specifics we’ve had so far about implementation, centred on a skeletal piece of legislation which leaves almost all the detail to future laying of regulations:

A substantial suite of regulations needs to be made under that primary legislation and DfE aims to lay these in 2024, before or early in the student recruitment cycle for the 2025 to 2026 academic year.

Right, so DfE has its work cut out to get this all in place next calendar year. The elephant in the room here is that a general election is coming, ministers are going to change (one way or another), and Westminster is going to grind to a halt. With “little leeway” left for 2025, it’s starting to feel like this start date has already gone out the window. It may fall to Labour to bite the bullet here.

The review concludes with the following:

I have therefore instructed officials to carry out a further accounting officer (AO) assessment at full business case stage in 2024 and re-test the AO standards.

A more usual framing at the end of such reviews is for the accounting officer to note that “if any of these factors change materially during the lifetime of this project, I undertake to prepare a revised summary, setting out my assessment of them.” You can see this for example in such well-oiled DfE major projects as the initial teaching training market review or school rebuilding.

We could charitably note that the LLE is not as advanced as these projects, and so a re-review one year later is not necessarily such a surprise, especially when “full business case stage” has not been reached. But the broader question is, if there are really only two academic years to go (and the recruitment cycle for 2025 even closer), why isn’t it further along?