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 2: Scope of the LLE
Question 8: Should all level 4 to 6 courses which are currently designated for HESF funding be treated as automatically in scope for the LLE? If not, why not, and what additional criteria for inclusion should be considered?
If the ambition is to create a level playing field through the LLE for all level 4 to 6 courses, then it is only right that all courses at these levels which are currently designated for HESF funding should be included in the scope for the LLE. What is key, however, is that: (i) these courses must be offered by registered and approved providers to help ensure taxpayers’ interests are safeguarded; and (ii) the courses should be part of a recognised qualification framework or pathway to prevent uncontrolled expansion and cost and, particularly, ward against unscrupulous providers from entering the market and using the LLE to offer courses for which they would otherwise charge a far lower amount.
Higher education qualifications in England are already structured to build towards clear educational outcomes and they from part of an established and accepted ‘currency’ which makes them easily recognisable and transferable between employers. This may not necessarily be the case for short courses. So, we must guard against the LLE becoming a means from which some training providers could make profit. That is why we believe the LLE should be focused only on courses that have the proven ability to contribute to an overarching qualification, irrespective of whether learners choose to complete this wider qualification or not.
As has been mentioned earlier in this consultation response, the ELQ exception rule should also be abolished alongside the roll-out of the LLE, so that adult learners are able to take courses and qualifications as they see fit to allow them to progress in, or change, their careers throughout their lifetimes – being led by personal preference rather than held back by an outdated and discriminatory rule that unnecessarily prevents people from switching career paths. If the LLE really is to be an entitlement for learners to do with what they will, and not be put towards only those courses and qualifications that the Government of the day thinks people should study, then all level 4 to 6 courses should be included in the mix without any exemptions or restrictions.
Question 9. Specifically, do you think that the following courses, which currently attract HESF, should be incorporated into the LLE, under the same repayment terms as other provision (i.e. fee loans count towards an individual’s four-year fee entitlement)? [A foundation year integrated into a degree course; PGCEs; Integrated Masters (3 years undergraduate plus 1 year Masters)] • If not, please explain why?
Yes. All of the above courses should be incorporated into the LLE if it is truly to become a resource that people can use as they see fit to advance and develop their own unique learning journeys. The Higher Education and Research Act (2017) seeks to expand and protect student choice. It is therefore imperative that the LLE works to enhance this choice and not restrict it by closing off certain study routes to individuals. For example, if Foundation Years are to be excluded from the LLE, then this would clearly prevent learners without prior qualifications from embarking on tertiary education, thereby disproportionately further disadvantaging the most disadvantaged in our society. Similarly, if integrated Masters are to be excluded from the LLE, then learners on these courses will be prohibited from completing their courses and succeeding, since integrated Masters courses are not eligible for separate postgraduate loans.
Question 10. What arrangements should be made under the LLE for courses which are over four years and are currently eligible for student finance – including medicine, dentistry and architecture?
To ensure we continue to bolster our domestic talent pipeline in key sectors of our economy, arrangements should be made in the LLE for courses that are over four years and are designated as being of significant economic or social value to the country. These include ‘key worker’ courses such as medicine, veterinary science and dentistry, as well as subjects such as architecture. The arrangements that should be put in place include providing extended access to the LLE for the duration of these courses and, on completion of the courses and successful entry into the labour market, the
Government could consider removing the interest rate added for the additional years of necessary study over four years as an incentive to learners to complete their qualifications and progress.
Question 11. We are proposing that all HTQs should be in scope of the LLE. Should approval as an HTQ be the sole route for qualifications that are ALL-funded to become eligible for the LLE? If not, why not, and what alternative route(s) would be appropriate?
It is right that all HTQs should be in the scope of the LLE but we do not have a strong view whether approval as an HTQ should be the sole route for ALL-funded qualifications to become eligible for the LLE.
Question 12. In particular, how could employer-relevance be tested as a basis for LLE eligibility?
We believe the key to a successful LLE is that it will be learner-driven, not employer-driven, nor centrally-planned. The training and skills which employers or the Government may want or need now may not be advantageous for learners in the future or help individuals to advance in their careers over their lifetimes. For this reason, it is important to balance employer-relevance against sustained learner-benefit, and we must avoid creating short-term skills pathways that benefit employers over long-term learner gain.
Question 13. We are aware that some courses (e.g. medical degree courses, some ALL-funded courses) are not currently structured around individual credit-bearing modules. Should such courses be excluded from any form of modular funding, and if so on what grounds and criteria?
In the interests of creating a fair and equitable system, we do not feel it right and proper to exclude any type of provision from modular funding.
Question 14. We are seeking views on whether to set a minimum amount per funding application equivalent to 30 credits. This is not a minimum module size, as smaller modules could be “bundled” together to meet the minimum application amount. What are your views on this proposal?
The proposal to set a limit of 30 credits per funding application is problematic for two reasons: first, many current modules are already delivered on a 20-credit system, so there is a very real risk that a 30-credit limit could encourage credit-inflation among some providers and, therefore, further regulatory mechanisms would have to be put in place by Government to ensure baseline quality and standards for these modular courses across both the HE and FE sectors. Second, setting a 30-credit limit could be seen to stifle innovation in course development, particularly around micro-credentials, which would be worth fewer credits (likely 10 or 15 credits). Although we appreciate the fact that smaller modules such as these could be “bundled” together to meet the minimum application amount, the incentive for providers to develop such micro-credentials will inevitably be reduced if learners will need to pick two or three of them to complete a single funding application.
Question 15. Which (if any) courses should be funded per-academic year (i.e. using the same basis as the current-HESF-system), and which courses should be funded according to the number of credits in the course?
We believe this is for individual providers to decide.
Question 16. Do you/does your provider currently use a credit framework or follow credit rules, and if so which framework or rules do you/they use? (e.g. OfS credit table, Ofqual credit conditions).
Question 17. In brief, what internal processes do you/they have to ensure compliance with the framework or rules?
Question 18. What impact could modular study have on study mobility across the UK?
In theory, modular study should allow learners to be more mobile over their lifetimes if their qualifications are portable and they can build up credits from providers across the country. As a body representing a group of over 40 higher education providers across London, we clearly welcome this idea as a means of both attracting and retaining talent in the capital and encouraging people to undertake study at one or more of our member institutions.
As the UK capital, London has large domestic inflows and outflows of people and the city’s population growth and structure are heavily influenced by domestic migration. Traditionally, young adults tend to move to the capital in their 20s or 30s for work and to take advantage of London’s cultural offer, making London a prime location for the uptake of the LLE. It is as this cohort ages and forms partnerships or has families that people typically tend to move out of London (along with many who initially came to the capital as international migrants) either to the commuter belt or further afield.
While the number of people moving in and out of London remains high, GLA data show that inflows and outflows dropped considerably during the recent Covid-19 pandemic, with 219,000 people moving into the capital in 2020 (representing a fall of 36,000 on the 2019 inflow) and 320,000 people leaving London for another part of the UK (representing a fall of 29,000 on the 2019 outflow).
These sizeable flows of people in both directions enhance the need for the portability of all courses under the LLE at all stages – both to enable people coming to London to access funding for courses at the city’s providers and to enable those leaving the capital to continue their learning journey elsewhere in the country.
For courses from London providers to be part of a UK-wide lifelong learning agenda, it is essential the entitlement works seamlessly across the devolved administrations, and providers in all four parts of the UK should be subject to equivalent levels of scrutiny for quality and standards.
Question 19. How can the LLE promote and encourage flexible study across England, Scotland, Wales, and Northern Ireland?
Question 20. What should be the most important considerations when determining how the lifetime entitlement will work?
The four most important considerations to enable the LLE to work should be: (i) providing accessibility to everyone irrespective of location, background and circumstance; (ii) maintaining freedom of choice for learners and removing arbitrary restrictions on the choice of subject or course studied; (iii) ensuring employers do not get to remain ‘consumers’ in a skills system that ultimately comes to benefit them at the cost to individual learners and the taxpayer; and (iv) enhancing and facilitating appropriate student support, as the wraparound support that is needed for modular learners will clearly need to be funded sufficiently and delivered in a different way to that already offered for more ‘traditional’ students.
Question 21. What, if any, age-related restrictions should be in place for the LLE that would impact on an individual’s ability to access their loan entitlement?
None. Access to the LLE should be available to all adult learners aged over 18. If the LLE is truly to facilitate people entering and benefiting from tertiary education at any point in their lives when they choose, we should not seek to impose maximum age limits on access to loans. Instead, the LLE should be available to people throughout their working lives, allowing only for a reasonable amount of time for repayment towards the end of their careers.
Question 22. We propose that we only fund individuals taking modules that are derived from a full course. Do you think that there should be restrictions in place so that borrowers should not be able to use their whole entitlement on a succession of individual modules which are not on track to a full qualification? We would welcome views on what these restrictions could be.
Given the distinct risk of market expansion and the creation of work-based, short courses that are set to bring short-term benefit to employers rather than bring individuals long term career gain, we believe all courses eligible for the LLE ought to be part of a wider established qualification framework or be part of a pathway to a qualification, irrespective of whether learners choose to use their entitlement to pursue this wider qualification or not over the course of their lifetimes. This protects against new courses being developed purely for commercial profit and minimises risk to the learner and taxpayer. There should, however, be no restrictions on how learners choose to use their overall LLE – be it for a series of different individual modules or ones which amount to a full qualification.
Question 23. In a system where modularised study is widespread, how we can we ensure that learners and employers understand what programmes of study deliver the skills that employers need?
The programmes of study eligible for the LLE should ultimately deliver long-term benefit to learners and their careers and not be used to deliver only the short-term skills that employers need. That is why the LLE needs to be developed in parallel with other schemes through which employers can actively be brought into the skills system as co-creators and co-investors, such as by developing and increasing the flexibility of the existing Apprenticeship Levy (to be achieved through an increase to the overall funding available for skills). This way all employers, including SMEs, would have a means through which they could co-develop and fund short and immediate skills-based training courses that will address their business needs, while the LLE would be protected and reserved to provide educational opportunities to individuals with advantage for their future career prospects.
Question 24. When considering restrictions by level and subject, how could the government ensure that the LLE is used for high-value learning that meets the needs of employers and the economy?
No government, no matter how hard they may try, can claim to understand the skills needs of the future; neither can employers. And no government should dictate what or where people should study and, ultimately, deprive individuals of studying a subject for which they have a genuine passion or flair, only to force them, instead, on to a course in which they have no interest just because it appears to work well for the present labour market. Moreover, with UK regional economies so different across the country, what may be deemed a superfluous skill in one part of the country, may well be deemed a necessary and highly sought-after talent in another. That is why we believe the LLE should be linked to local skills plans and remain free from any unnecessary restrictions on level and subject, save for ensuring courses are related to wider qualification frameworks to uphold quality. This will enable learners to make their own judgements about how courses will advantage them for their own futures and leave open the possibility for them to be mobile in the future should they so desire.
Question 25. Are there other restrictions we should consider on the use individuals can make of their entitlement?
Question 26. Do you think a future system should include a facility for provider-based bursaries, which providers allocate directly to students?
Question 27. Should maintenance support, like fees, be proportional, so that e.g. modules which amount to one-quarter of a full-time year of study carry an entitlement to one quarter of the maintenance support that the latter does?
Yes. With mature learners typically more debt averse than younger learners, it is essential that measures are put in place to prevent leaners taking on more debt than they might otherwise want or need. This will also protect the future taxpayer, as an unrestricted LLE system is likely going to result in a higher RAB charge for the Treasury, so keeping maintenance proportionate to course-length will help in this regard – provided, of course, that other means-tested measures are put in place to ensure that those who need access to extra support can access it should they need to.
Question 28. Are there courses or circumstances for which maintenance should not be offered (e.g. where students are studying below a certain level of intensity)?
No. There should not be any restrictions on access to maintenance support for those who need it.
Question 29. Currently means-tested elements of the maintenance system relate to family income. Should this be reconceptualised for a system with more adult participation, and if so, how?
Yes. The current student finance system already unfairly disadvantages some students, particularly estranged students, who may not be supported by their parents, yet their maintenance allowance is still determined by their family income. This system is clearly unsuitable, too, for adult learners, and access to maintenance should be based on solely the individual learner’s income and, importantly for people living in expensive cities like London, their disposal income after basic living costs have been accounted for. In recognition of the higher living costs in London, we appeal to Government to maintain the London supplement in the LLE for learners living and studying in the capital and, contrary to the current system, this should be accessible to learners irrespective of whether they have moved to London from elsewhere in the UK or whether they have previously lived or grown up in the Greater London region. Living costs in the capital are the same regardless of where in the country you originated from and research from the Trust for London shows that 28 per cent of Londoners (2.5 million people) are already living in poverty, with households in poverty in London facing housing costs that, on average, in 2020, amounted to 56 per cent of their net income. For London providers to better support these learners, the London Weighting should also be reintroduced to enable providers to target essential wraparound student support appropriately.
Question 30. To what extent do you think maintenance support would be a consideration for learner access to, and progression through, LLE funded courses?
Maintenance support will be a significant consideration for learner access to, and progression through, LLE funded courses, since risk aversion generally becomes greater in more mature student cohorts who typically have greater financial worries, e.g. through childcare responsibilities, mortgages and other household bills and debts. With adult learners typically having no other means to support themselves through study, maintenance support can be an essential lifeline, particularly if employment hours have to be curtailed to allow for more study time or even ceased completely, and if relying on personal savings is also not an option. Given London’s specific poverty profile,
maintenance support will be essential to encourage uptake of the LLE in the capital and other large UK cities. As stated in our answer to Question 25, just under a third of all Londoners (2.5 million people) live in poverty, while the costs of living are between 15 and 58 per cent higher in London than the rest of the UK – and that was measured before the current rising rate of inflation. More specifically, the Black and Minority Ethnic poverty rate is 38 per cent in London (nearly twice that of White groups at 21 per cent), so maintenance support is vital if we are serious about closing the gap in access to tertiary education between different learner groups.
Question 31. Do you think a maintenance offer should differ by course type, mode of study (e.g. part-time), or learner circumstances such as age, income, or caring responsibilities?
No. The basic rate of maintenance should be consistent across course types and disciplines. The factors that should be used to determine whether a learner ought to receive a higher level of maintenance are: (i) a learner’s net income after basic living costs have been accounted for, including costs of dependents if applicable; (ii) their age (should they still be supported in some way by parents or guardians); and (iii) their geographical location, with learners in London being specifically entitled to a London supplement to cover the increased costs of living in the capital.
Read the first part of London Higher’s Response to the Lifelong Loan Entitlement Consultation here: