The LLE bill reaching Commons Committee stage means that input from those it’s going to most affect has been sought – DK has rounded up the tentative warm words combined with puzzlement over the details from those who got an invite to appear in person, but written submissions have been invited as well (if with a very tight turnaround), and today we’ve seen the publication of some of these on the bill’s dedicated webpage. Look for the “written evidence” tab.
It’s a nice opportunity to see which aspects of the bill and the consultation response are attracting most polite disagreement from the sector, as well as foregrounding a few important points that no-one’s thought carefully enough about yet.
So we see the Lifelong Education Commission, adult education charity WEA, and The Open University in their submissions all question the continued lack of available student maintenance support for distance learners in what is becoming a common criticism of the bill’s approach to purported flexibility.
The Open University (which, to be clear, already offers a large number of short courses to lifelong learners) also warns that “integral features of the new policy framework that are crucial to its impact are being left to secondary legislation,” as DK’s argued on the site previously. WEA gently takes issue with the fundamental assumption of the legislation:
Building the new offer entirely around a loan risks excluding adult learners from lower income backgrounds who may not want to risk taking on debt when faced with other competing financial pressures.
If only some polling existed which could help us understand if this is the case.
The Lifelong Education Commission’s evidence also expresses concern about the additional cost of support for learners on modules compared to full degrees – this question (and the fact that no-one has yet done the modelling) reared its head in Parliament yesterday too.
Staffordshire University’s Annabel Kiernan picks up the ball from her recent Wonkhe article to suggest thinking how the LLE will work on a local level – sketching out the idea for a fundamentally different approach to the legislation which would think about Local Skills Improvement Plans and interaction with the apprenticeship levy, which feels pretty far away from the current approach, which I might uncharitably characterise as defining fee levels and hoping that the market, ministerial fiat and sector enthusiasm will sort out all the rest of it.
Staffordshire University and others also resume the argument that 30 credits is too long, and that employers and learners do not seem in love with the idea of 12-14 week courses.
Finally, sector grandee Mike Ratcliffe’s submission raises the question of how the proposed methods of calculating fee limits will apply to accelerated courses:
The higher annual fee limit for an accelerated course (£11,000) is less than 1.5 the fee limit for a three year degree (which would be £13,875). The introduction of a new method for calculating fee limits raises the question whether there will be a fee limit for providers who are offering an accelerated course. If this remains at £11,000 then this raises an issue that the fee limits for the individual modules on the accelerated course would be lower than the standard course.
He also wonders how summer schools, evening classes and a more US-style approach to the academic year would work in the new system.
Plenty of good questions – let’s hope we might get answers to them before long.
Update: submissions from Birkbeck, University of London, campaign group Right2Learn, edtech company Chegg, University of Westminster, and London Higher have been published in addition to the ones I covered above. We see many of the same concerns raised – maintenance for distance learners, minimum credit size, IAG, and others.
Birkbeck’s evidence, echoing Coventry’s Elizabeth Norton, also picks up the question of regulation and how OfS B3 conditions will apply, arguing that B3 is “a crude measure” at the best of times for widening access institutions, but in a credit-based system “seems irrelevant when learners will go at a different pace and not necessarily work towards a full honours degree.”