London Higher Response to the Lifelong Loan Entitlement Consultation: Part 1

Introduction:

This document provides London Higher’s response to the Department for Education’s consultation on the Lifelong Loan Entitlement (LLE), published on the 24 February, for response before 06 May 2022.

This consultation response was created after extensive discussion with the London Higher membership and seeks to represent the diversity of “London HE”.

Theme 1: LLE Ambition

Question 1: How can we best ensure that, compared to the current student finance system, the LLE will better support learners to train, retrain or upskill throughout their lifetime?

The Lifelong Loan Entitlement (LLE) is an ambitious reform which is welcomed by universities and higher education colleges across London as a means to unlock opportunities for learners and address pressing skills needs – many of which are felt acutely in the capital.

For the LLE to work as intended and enable people to access tertiary education flexibly at any point they desire throughout their adult lives, there needs to be major investment in raising awareness of the LLE and detailed consideration of how independent and impartial information, advice and guidance (IAG) is made available to people through multiple media and formats. As the LLE consultation document rightly acknowledges, this will require a significant culture change in the way we consider the role and place of tertiary education in the country; yet this is not going to occur overnight, or even in the short-term.

Telling school-leavers about the planned changes to the current student funding system will be the easier part, although it is still imperative that independent and impartial IAG sessions commence as soon as possible to ensure that all school leavers, irrespective of their location, background or circumstance, are aware of their options in time for the planned roll-out of the LLE in 2025. Indeed, research (published in 2022) from Dr Deirde Hughes and DMH Associates found a strong desire among school pupils and their teachers for clearer and more rigorous careers guidance covering a greater range of options, particularly early on in secondary school. This IAG should be provided as broadly and impartially as possible through schools, UCAS and local FE and HE outreach programmes, and also involving employers wherever feasible.

The more difficult part will be ensuring that all eligible adult learners are aware of the opportunities they will soon have to access the LLE. This will require a large-scale public information campaign to reach those individuals in society who need it the most. Mass marketing will be necessary in the mainstream media and through large-scale public information campaigns, as well targeted information through national bodies such as JobCentre Plus and the Citizens Advice Bureau, but also through local and hyper-local community organisations, charities and faith groups to ensure no individuals and communities are left behind. This information campaign must be sustained over the long-term to ensure awareness of the LLE grows across society and the uptake of the LLE increases.

Extensive user-testing should nevertheless take place in both learner groups, school-leavers and adults, as it is essential to ensure, before plans for the LLE are formalised, if genuine demand for such a modularised learning system exists in UK society and whether learners would actually be likely to draw on their entitlement. If not, we risk unnecessarily over-complicating the existing loan system.

Finally, to ensure the LLE delivers for all learners, it is vital that restrictions such as the Equivalent or Lower Qualification (ELQ) exception rule are not carried over from the current finance system to the LLE, to ensure that people are not inhibited from training, retraining or upskilling as appropriate throughout their lifetimes. For the LLE to work as intended, we need to be empowering learners to make the best choice of study appropriate to their own circumstances and, for that, they should be able to use the LLE as they see fit; not be constrained by outdated ELQ rules or similar. This means easing rules prohibiting access to funding for second degrees, ending barriers on study intensity and removing the requirement to follow a full course for a set qualification.

Question 2. What barriers might learners face in accessing/drawing on their LLE and how could these barriers be overcome?

Adult learners face multiple barriers associated with the complexity of their lives. Many adult learners are, for example, more likely to be ‘time-poor’, debt averse and constrained by work or caring commitments. For the LLE to work as intended, it is therefore imperative that measures are taken to:

(i) bring employers onboard so that they allow employees time for retraining alongside their work; (ii) encourage education providers to adapt the time and mode of course delivery to attract learners with limited time and other commitments; and (iii) communicate carefully to prospective learners how the student finance system works to avoid the concept of a ‘loan’ becoming a barrier to take-up.

Further to this, the recent Covid-19 pandemic has not only exposed but widened inequalities in society when it comes to access to digital media. So, we are concerned that, if the LLE will be delivered exclusively through personalised online lifelong learning accounts, this is set to exclude those either without the means or the skills to access digital content. Putting information about the LLE online in this way, although in line with wider advancements in technology, will inevitably exclude people from the most disadvantaged parts of our society if they do not have other means of accessing this IAG or if alternative routes are overly complicated. The online delivery of LLE accounts is also set to disproportionately disadvantage older learners, who are more likely not to possess the prerequisite digital skills to use them. To bring down barriers to accessing the LLE for everyone, online IAG routes must therefore co-exist alongside alternative options: these may include a national IAG call centre with a dedicated helpline, or a network of regional advisers working within national organisations such as JobCentre Plus, who can be visited in person by prospective learners during opening hours.

Moreover, for any IAG to secure the widest reach, it is important that information is not just issued in English. According to the last national census for which we have data, two per cent of the population across England and Wales were found on average not to speak English well or at all, equating to 863,000 people. However, this number dramatically increases in certain areas of London, most notably in the boroughs of Newham, Brent and Tower Hamlets where between eight and nine per cent of the local population were found, in 2011, not to speak English well or at all. This number would have inevitably increased over the past decade. So, to ensure these learners are not being left behind and can use the LLE to upskill in key areas while also improving their English language competency, independent and impartial IAG on the LLE must be provided in a variety of languages and targeted appropriately.

Finally, as briefly alluded to in our answer to Question 1, the ELQ exception rule must not continue to be a barrier to learners under the new LLE system, for it threatens to go against all that the LLE seeks to achieve in opening up skilling, reskilling and upskilling opportunities to learners throughout their lifetimes. In its current guise, the ELQ rule prevents people from accessing funding for study on a course at the same or a lower level than a qualification already held; yet there is no place for such a rule in the lifelong learning agenda which should be empowering people to reskill whenever they may need it – and ‘reskilling’ itself implies repeating study at a similar level. Allowing the ELQ rule to continue under the LLE system would, therefore, be undermining the very nature of the LLE and restricting people’s access to opportunities.

Question 3. What information and guidance should be displayed in a lifelong learning account to support learners to understand their options for using their LLE?

LLE accounts need to display clearly the overall entitlement available to individual learners, how much they may have used (if applicable), how much entitlement they have left to use and, most importantly, impartial IAG about how they could be using it, including clear links through to an official Government database of all eligible courses between levels 4 to 6. This database should be organised in alphabetical order so as not to preference either FE or HE providers over one another, and users ought to be able to filter results by region, and the towns and cities within them, subject or discipline, and key words. For larger cities such as London, where there is a particularly high concentration of higher and further education providers, there should also be the additional functionality built in for learners to filter by borough or sub-region to help them better hone their results to their lives.

Moreover, to enable learners to make truly informed choices about their futures, the information shown on LLE accounts must be consistent across both HE and HE providers. This means creating new ways of assessing both HE and FE providers fairly using a clear common tertiary framework, while also being careful to minimise the bureaucratic burden on individual providers. For example, it is both unreasonable and unrealistic to expect the same style of B3 indicators currently being consulted on by the Office for Students (OfS) for HE providers to be applied to more granular short courses.

Question 4. How can we best ensure that the LLE will enable learners to access technical as well as academic courses at levels 4 to 6?

If the LLE is to cover all courses at levels 4 to 6, then it is only natural that eligible provision will be expansive and include both courses deemed to be “technical” and “academic”. As a membership organisation representing over 40 different higher education providers across London, we nevertheless find the distinction between “technical” and “academic” courses unhelpful and misleading because most courses contain an element of both and equip learners with transferable skills to enhance their employability.

As a system that seeks to provide eligibility to all courses, we believe the LLE should avoid branding courses as either “technical” or “academic” and seek, instead, to build pathways between courses to abolish the binary “academic-technical” divide. This will ensure the focus is put on the transferability of the skills that these courses provide and ensure they deliver long-term value to learners as the world of work changes and employers’ needs adapt.

Question 5A. How can we best ensure that the LLE will encourage FE and HE providers across the country to offer provision that closes the current skills gap and supports future upskilling?

Owing to the diverse geography of UK industry, with different regions having different industry strengths, we believe skills gaps are best identified and supported at the regional level and in conjunction with existing devolved governance structures. This will help build an understanding of more specific local skills and talent needs. For example, in London, the Greater London Authority (GLA) has recently published The Skills Roadmap for London, which is intended to develop a more integrated skills and employment system which meets the needs of local London businesses and employers and fosters flexible learning across the capital that supports progression into locally-relevant work. The LLE should, therefore, be developed in a way that integrates into it these different regional skills plans from across the country and works with relevant local authorities to offer incentives for further and higher education providers within specific regions to offer provision for courses that will address local skills gaps which have been designated as priorities by local government.

Local skills systems should also be linked to the Strategic Priorities Grant (SPG) administered currently by the Department for Education, so that providers offering courses in acknowledged areas of regional skills shortages are given more funding as an incentive to take on learners and help them to succeed. This would help London, for example, where the creative and cultural sector has been designated as one of five areas of acute skills shortages in the capital, yet national policy has dictated that funding for these subjects should be halved. If the LLE were linked to regional skills needs, however, which attracted top-up funding from the SPG, then this would help London and the nation’s economy to build back better post-pandemic and reverse crude, broad-brush funding cuts that severely hamper each region’s ability to address their own specific skills shortages. Measures such as this would also work in harmony with existing regional measures, such as the Mayor’s Academies Programme currently being rolled out across the capital.

Question 5B. How can we facilitate collaboration between FE and HE providers and employers, to ensure that provision keeps up with industry developments?

By aligning the LLE to specific regional skills shortages, as detailed in our answer to Question 5A, it will make it easier for partnership models to form, including further and higher education providers coming together with employers to address specific skills needs and keep up with industry developments. At London Higher, we are already part of a successful partnership model of this kind through the Mayor’s Academies Programme alongside Middlesex University, the Capital City College Group and Film London, having come together to address specific skills shortages in the screen industries – a major contributor not just to the Greater London economy, but to the UK economy as a whole. Through the Mayor’s Academies Programme, employers are able to tell us in which areas of the workforce they are experiencing acute skills shortages and the FE and HE partners are, in turn, able to source the appropriate talent, develop effective pathways and signpost learners to opportunities that they might not otherwise have known exist. This is particularly true for students of Law and Accountancy, for example, who maybe unaware that their skillsets are highly sought-after by the screen and film industry.

Question 5C. How can we help FE and HE providers to provide modules and courses that offer real value to employers and improve employment prospects for learners?

If regional skills plans, such as The Skills Roadmap for London, were to be incorporated into the LLE, then it would make it easier for employers to be involved early on in the process of identifying skills gaps and working with education providers (and regional representative bodies for education providers like ourselves) to address them. For courses where industry-specific standards must be met, this could involve validation of modules by employers or relevant Professional, Statutory and Regulatory Bodies (PSRBs). However, this must not become the norm across the whole suite of modular qualifications on offer as part of the LLE, as the Government has a duty to respect institutional autonomy over course design and delivery and must not, therefore, seek third-party validation across every course offered.

Although employer interests must be recognised in the initial design of the LLE, what we must ultimately guard against is creating a system that exonerates employers from the obligation to pay for training for their staff and puts the expectation firmly on to employees to take out an LLE for their own work-based training. This would effectively benefit employers and enhance their role as ‘consumers’ of the skills system, and certainly does not set individual employees up for better long- term career prospects. There is the very real risk in the creation of the LLE system that short courses could add relatively little to individual learners’ overall education, especially if they are not recognised as part of an established qualification framework.

As a country, the UK already has one of the lowest levels of investment in training and skills among OECD countries. Further research from the Social Mobility Commission shows that the UK spends relatively little on adult skills and that people from the lowest socio-economic backgrounds are the least likely to access adult learning. This problem is not going to be solved by the LLE alone, particularly since the concept of a ‘loan’ is still going to detract the most disadvantaged in our society from taking out an LLE. That is why we should be incentivising employers, in parallel to creating the LLE, to invest in their staff by developing and embedding further flexibility into the Apprenticeship Levy scheme to make it more accessible for small and medium-sized enterprises (SMEs) and enable them to invest in the skills their businesses need. This should be done by increasing the overall funding available for skills, not by shrinking the money available for the LLE.

Question 5D. How can providers support and facilitate learners gaining qualifications through modular study?

As a membership body representing over 40 different higher education providers across the Greater London region, we feel compelled to point out the rich diversity of educational provision that is already on display across England’s higher education sector. While some institutions are already developing modular provision in selected course areas, others (particularly small specialist providers) simply do not have the capacity to do so, or do not feel it is appropriate to their particular disciplinary offering or specialism. That is why it would be folly to assume that the future of tertiary education is completely modular and can be made so without infringing on important questions of institutional autonomy, as enshrined in the Higher Education and Research Act (2017). A modularised learning system must therefore be established to complement and not replace more traditional modes of tertiary education.

For those providers that are developing modular provision, it is imperative that they are funded sufficiently by Government over the coming years so that they can continue to provide and develop bespoke support to lifelong learners who, like commuter students, will most certainly require increased assistance to enable them to participate fully in their tertiary education experience and succeed. Anecdotal evidence from our diverse members which are already offering adult education us that mature learners going into tertiary education for the first time later in their lives have extremely complex needs. To enable many mature learners to undertake their desired courses, providers have to invest much time, money and effort into equipping learners with essential study skills, support with academic writing and research, and even basic English language skills, since learners from London’s diverse ethnic communities, in particular, may not necessarily speak English in the home and lack the basic communication and literacy skills.

These high levels of essential wraparound support to enable mature learners to participate in tertiary education and succeed require significant financial resource and investment. This means that the administrative burden of providing one module to adult learners certainly cannot be calculated as simply a fraction of that for a 3-year ‘traditional’ undergraduate degree, as the support needs of adult learners are greater and putting these modular courses on will clearly come at a higher cost to providers. Higher education providers in England are already being financially penalised by the decision by the Department for Education to freeze fees for full-time students at £9,250 under the current student finance model, particularly at a time of rising inflation and increasing operating costs– and providers in London also need to factor in the recent loss of the London Weighting from the

SPG, which has seen funding to the capital’s higher education sector cut by over £64million. That is why it is imperative that the LLE does not financially penalise providers even further by underfunding the costs of delivery and making adult education a loss-making exercise for providers.

To enable providers to support and facilitate learners gaining qualifications through modular study, it is therefore vital that the Government recognise first and foremost its responsibility to increase the unit of resource for providers so that they can adapt and expand their suite of learner support accordingly. This is similar to the rationale behind the fee increase that was passed for two-year accelerated degrees in 2019, which allows providers to charge up to 20 per cent more to cover the increased costs of added teaching time and wraparound support out of traditional term time. Clarity is therefore needed urgently as to the fees and funding proposed for similarly ‘unconventional’ modular courses.

Moreover, given the expected rise in demand for higher education in the London and South-East region by 2035, on top of London’s already significant commuter student population, we appeal to Government to reinstate the London Weighting in the SPG at least to coincide with the roll-out of the LLE, but preferably before, to ensure that learners in the capital receive the same baseline investment in their education and support as learners elsewhere in the country. If London providers continue to be left without the London Weighting amidst a climate of rising inflation, then it will be very difficult for them to deliver the LLE in the UK’s most populous city to the high quality and standards that are expected of them.

Question 6. Do you think the move to the LLE will have any particular impacts on people with protected characteristics? If so, which groups and in what ways?

The LLE, with its ambition to be a truly flexible resource which learners can access at any point in their lives, in theory offers people from a wide range of backgrounds and circumstances the opportunity to access education wherever and whenever they need it. In practice, however, the current plans are set to disadvantage those who cannot access their LLE accounts online for reasons of digital poverty and lack of digital literacy. There is also the risk that those from the most ‘hard to reach’ and disadvantaged parts of society might never know about the opportunities afforded by the LLE because vital IAG is not getting through to them either in a language they can understand or a medium they can access. That is why the Government should first invest time to create established structures through which HE and FE providers can work more closely with other agencies, such as JobCentre Plus, to ensure these people are reached.

Moreover, empirical evidence shows that people from the most disadvantaged backgrounds are far more likely to be debt averse than those from more advantaged backgrounds, and that debt aversion also increases with age as people take on more financial responsibilities such as mortgages, loans for household items, cars and childcare costs. The fact that the term LLE includes the word ‘loan’ is therefore likely to inhibit the very people at whom the LLE is targeted and who could most benefit from it. It is also set to remain inaccessible to some Muslim learners and members of other faiths, who may be reluctant to use their LLE due to concerns over the interest added to the loan product and who are already under-represented at the most academically-selective institutions.

The question of whether barriers to access for loans for some Muslim students can be removed has been a long-running issue under the current student finance model and it would be particularly insensitive to carry over the same barriers into the LLE without developing a more inclusive and Sharia- compliant loan offering first. This is also an issue that is particularly acute in some parts of London since, for example, the London borough of Tower Hamlets is home to the highest percentage of

Muslims in the UK (32 per cent) and the East London borough of Newham is home to the second- highest percentage of Muslim residents. To prevent this significant group of London learners from being further disadvantaged from accessing education at all stages of their lives, we would therefore suggest the roll-out of the LLE be delayed until this known barrier has been removed.

Another group of learners set to be excluded disproportionately from the LLE are disabled people if sufficient IAG about disability-friendly training environments is not provided. A new study for the GLA shows that disabled people already report facing additional costs and inadequate provision for reasonable adjustments in tertiary education settings. So, to encourage them to enrol on education later in their lives, it is important they are aware of the specialist facilities and inclusive environments provided by individual education providers. Without this tailored IAG, disabled students may find themselves reluctant to take out an LLE, believing all tertiary education settings are not spaces they can trust or feel welcome in.

Where the LLE does offer some advantage for people with protected characteristics, however, is when it comes to students with children, as they are far more likely to study as mature students. It is also well-established that people leaving education at age 18 are also more likely to start families earlier in their lives than those who go on to some form of tertiary education, therefore adding to the need to make the LLE available for all adult learners over 18. For learners with children, the LLE could be beneficial because it would enable them to access funding for courses on a timescale decoupled from the traditional academic year. The structure of the ‘traditional’ academic year is often disproportionately difficult for students with children. So, the ability to apply for, access funding for and then study parts of a degree at times in the year that fit around caring responsibilities would therefore be a positive change and might enable more adults with children to access tertiary education in the future. This is something which can only be advantageous, as we know that children’s educational aspirations are strongly correlated with those of their parents, and seeing their parents embark on tertiary education and succeed is a good way to positively influence the attitudes, aspirations and behaviours of young people when it comes to educational attainment for future generations.

Question 7. What barriers might learners with protected characteristics face in accessing/drawing on their LLE and how could these be overcome?

As has already been mentioned in answers to previous questions in this consultation, learners without basic levels of digital literacy or access to technology will struggle to access their online LLE account if other formats are not made available to them and clearly signposted to them. Learners without good knowledge of English will also be inhibited from accessing or drawing on their LLE if personal accounts, associated IAG and Government course databases are not provided in other languages widely spoken by ethnic minorities in the UK. Finally, some Muslim learners and those from other faith groups may be unable to access their LLE due to the interest added to the loan product, so a Sharia-compliant version of the product should be developed before roll-out of the LLE commences in the interests of fairness to those in multicultural and diverse cities like London.