It’s finally here.
More than a year since it opened for responses, and just over a week since MPs on all sides called for it during Second Reading, we have the consultation response from the government on the lifelong loan entitlement (LLE).
This Johnson-era prime ministerial commitment, drawing on work kicked off under Theresa May (a review of post-18 fees and funding including a report from Philip Augar), represents the biggest shake up of post-compulsory funding since 2012.
The policy is simple at heart – four years of higher education fee loan eligibility can be used on multiple shorter courses throughout your working lifetime across higher and further education, rather than just on a traditional three year undergraduate degree. It does prompt a huge number of technical and implementational questions, and although we don’t get many of the detailed answers this morning the parameters of the offer are clearer.
Alongside the full consultation response published this morning, there is also an impact assessment (at a very high level), an equalities analysis, and a written ministerial statement.
It’s your letters
The government received 1,253 responses to the LLE consultation, including 914 from individual learners with an interest in the plans. From the looks of the provided digest these have been taken into account in making the determinations presented. What is not included is any information from the Short Courses Trial or any other mechanisms used to determine demand for the new scheme – the early indications from the trial have not been positive, to say the least, and ministers have previously conflated the attractiveness of lifelong learning with interest in this particular fee loan scheme. It’s a continuing worry, and something that will most likely return in future debates.
The LLE as presented is a full replacement for existing higher education student finance (HESF) and advanced learner loans (ALL). These two systems are to be merged into one Student Loans Company (SLC) offer – a “bank style” personal account that will include personalised recommendations and other user-facing nudges. This appears to be the entirety of the advice and guidance for learners planned at this point – there’s nothing on links to other careers provision.
The offer is equivalent to four years of undergraduate level study – this has a current value of £37,000 but this would uprate as fee limits change (there does not look to be any built in inflationary increases). From 2025-26 all Higher Technical Qualification (HTQ) courses, plus some other technical qualifications will be funded through this system (ALL will be scrapped from August 2025). Other modular provision from levels 4 to level 6 will move into scope from 2027-28, when the government “can be confident of positive outcomes”. The bulk of undergraduate provision will be funded via annual fee loans exactly as currently from 2025, though these loans will be processed via the LLE system. There’s a technical consultation on which courses are eligible, particularly focused on former ALL courses, coming next year.
Learners will also have access to maintenance loans for in-person provision- these will be both means tested and responsive to length, level, and mode of study. There will also be “targeted grants” for priority courses – there’s more information coming on that in the next Spending Review.
The Equivalent Level Qualifications (ELQ) rules are gone – it is entirely within scope to do an undergraduate history degree and then some L4 modules on cybersecurity. This might well please large numbers of existing graduates – who will be eligible for some LLE funds based on their previous funded qualifications. Eligibility will continue until learners reach the age of 60 – and tracks existing HESF arrangements on immigration status and residency.
New to ALL funded provision but familiar to existing undergraduate fee loan customers will be a “robust compelling personal reasons mechanism” to support loan repayment, and the full terms and condition of the “Plan 5” loan offer. These are the extended repayment term, lower interest rates, and lower repayment thresholds announced alongside the consultation.
Quality and standards
All LLE providers will need to register with the Office for Students – OfS will be consulting on a new registration category aimed at former ALL-focused providers. A consultation on initial and ongoing conditions of registration will follow. However IfATE appears to maintain the employer and learner demand assessment function for non-HTQ provision, so it’s not quite one-stop regulation.
The intention appears to be that outcomes based regulation will be the means by which OfS will assess quality and standards – though the summary of responses to question 33 noted that many of the existing measures (continuation, completion, outcomes) may not be compatible with modular provision. There will be another OfS consultation to look forward to on this, but – we are told – no further legislation.
Providers have a pleasing degree of autonomy on which courses, and which parts of courses, are offered as modules. Anything offered by the module needs to be at a single level (between L3 and L6 only) – if your course has built in L3 (foundation) and L7 (masters) components this will only be fundable as a full course. There is a requirement that all courses offered through the LLE are at least 30 credits long and are a part of a larger course. The government is very keen on credit transfer, but has stopped short of mandating a credit framework (though there will be a mandated transcript format, something that Bologna Agreement fans will enjoy).
And the government is claiming that alternative student finance (“sharia compliant loans”) will be available “as soon as possible” after 2025, with an update on this later this year. As we’ve been promised this since 2010 I think we should wait and see.
Moment of impact
Reading the impact assessment really brings home how early we are in the process of understanding how LLE will work in practice. The Department for Education has been unable to put a meaningful value on the the possible benefit to learners and the possible impact on providers – the, frankly ludicrously low, figure of £6.4m is the finger in the air we are offered on the latter, and there are some very indicative calculations on the impact on business.
So much of the impact on learners and providers is dependent on learner behaviour, and it remains surprising that such radical reforms are being implemented based on such limited demand side evidence. It’s not clear, for instance, whether LLE demand will replace existing demand for undergraduate courses or become an additional recruitment route – questions with an existential impact on the providers involved.
We’ll watch for more work on these questions alongside the secondary legislation that will follow and in the debates around the Lifelong Learning (Higher Education Fee Level) Bill as it receives parliamentary scrutiny.
Post-implementation, the Department will have an eye on a variety of data sources – from OfS, HESA, and UCAS (interestingly the only mention UCAS gets in this documentation), and survey data covering learner outcomes and value for money. And there will be a post-implementation review.
The other wild card here is a likely change of government before implementation is complete. Signals from the opposition suggest that at least some elements of the LLE would be taken forward, but until we know more quite a lot of the above needs to be taken as advisory.
I have to say there were a number of things I read in the document that were above my (admittedly low) expectations. So much so that I kept wondering how they were intending to pay for all of this.
Then I found this nugget on P18:
“Entitlements under the current system may be reviewed in some areas to ensure an expanded system remains affordable.”
And there we have it – my (wild) speculation = they’re going to reduce maintenance loans to courses they deem undesirable. I hope I’m wrong.
Great summary.
One small point. DfE will be ending Advance Learner Loans (ALL) from 2025-6 onwards for courses at Level 4 and above but the majority of these loans are currently for Level 3 courses and, as I understand it, there’s no decision as yet.
Numbers taking up advance learner loans has halved since mid-2010s for various reasons (including growth in foundation years displacing access courses) and Level 3 qualification reform may wipe out some popular loan-backed but DFE calculate the same RAB charge for ALLs as for HESF so it would be a shame to remove this element of adult learning support.
Reading the detail this doesn’t seem to be as radical the change as it is purported to be. Yes, funding is now based on credits but with the restrictions that courses need to be at least 30 credits long and are a part of a larger course this is not much different to the current funding rules. It doesn’t encourage providers to innovate and provide the smaller courses which would support the lifelong learning and skills agenda.
It also seems a backwards step in restrictions of funding to four years (I might be wrong, but couldn’t find the details) and those students who might have issues along their journey. Whilst this would cover the most traditional route of three year degrees, giving students an extra year if they need to repeat, etc., it would put a tight limit on those doing four year programmes (integrated foundation years and masters) and likely lead to a reduction in this type of provision. Current regualtions are length of course plus one year.
Even worse: there are currently five-year undergraduate degrees (integrated masters with a year-long industrial placement for example; the year in industry has a reduced tuition fee, but there is a tuition fee). How does that fit with the four-year entitlement?
Reading the foreword, it is very clear – if it wasn’t already – that the focus of government for the LLE is on skills training to provide technical skills to do specific occupations. This can be seen in the limiting of modular funding to such courses and the signalling that this is likely to continue.
The consultation also reminded us that the response to the HE Reform consultation – and the mooted introduction of Minimum Eligibility Requirements for access to student loans – is similarly overdue: the Augar Review recommended that a MER set at either CCC or DDD be introduced to drive a shift in provision from “low-value degree courses” to “an attractive higher technical alternative” though cautioned against doing this before “introducing high-quality alternatives to degree study”. Most Conservative MPs also think that far too many people are going to university, partly as they – wrongly – attribute this to their unpopularity among the under 40s.
The 30 credit minimum would seem to be an enormous barrier to innovation within the sector and its ability to deliver the agile, reactive, compact learning needed to address skills gaps in increasingly dynamic workplace contexts. Recent work by ResRepublica and the University of Staffordshire has highlighted the gulf between HE’s and industry’s understanding of the term ‘short course’ (where there is huge latent demand) – and 300 hours (i.e. 30 credits) is a long way from ‘short’. I fear an enormous opportunity is about to be missed…