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London Higher Response to the Lifelong Loan Entitlement Consultation: Part 3

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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 3: Supporting quality provision and flexible learning

Question 32. How can we support flexibility whilst maintaining high quality provision through the introduction of the LLE?

One obvious way to support flexibility in the system is to ensure we are applying less scrutiny to modular study and short courses than that which is currently being consulted on by the OfS for more ‘traditional’ HE provision. For short courses to be developed effectively, providers ultimately need space to innovate and the current mode of regulation in the HE sector cannot simply be applied to a world of modular courses without stifling progress. What is needed, instead, is a common, light-touch regulatory approach across all tertiary providers, both FE and HE, to ensure baseline quality levels are being met but with the flexibility to allow providers of different sizes and capacities to continue to enhance the lifelong learning landscape.

Question 33. How should the approach to quality change to support the introduction of the LLE?

The proposals for quality and standards currently being consulted on by the higher education sector regulator, the OfS, are already causing concern over the increased burden they are set to impose on providers at ‘traditional’ course level. To apply this approach to modular LLE courses would be impractical and, above all, unsustainable for a sector that is already stretched to capacity following the Covid-19 pandemic to deliver courses and appropriate wraparound support to students. ‘Micro’- courses cannot be micromanaged.

Question 34. What, if any, regulatory changes might be needed to support a modular system?

A more hands-off, light-touch approach to regulation will be needed to support a modular system, as it will be nigh-on-impossible to collect the same amount of data for more modular course offerings to form indicators and benchmarks as is currently being consulted on by the OfS for more ‘traditional’ HE courses. There is also the risk that data from small modular courses will be statistically insignificant and inappropriate to form robust metrics. In particular, the current non-completion measure would need reconsidering for modular study, as would employment and further study outcomes to account for the non-linear work and study patterns of flexible adult learners. Should the current proposals for HE regulation be carried over to the LLE, this will stifle course innovation and disincentivise providers

from creating new courses and modules. It will also create an uneven regulatory playing field between FE and HE providers, thereby inhibiting partnerships and collaborative provision.

Question 35. Are there opportunities to simplify the regulatory regimes that will operate under the LLE?

If the LLE is to create a level playing field for FE and HE providers offering courses between levels 4 to 6, then the current regulatory regime will no longer suffice for this new system. That is why we should embrace the opportunity to reconsider the current roles of the different regulators operating in this space. More appropriate to a more simplified world of tertiary education would be to establish a new single tertiary funding organisation that would help to maintain quality and standards across both HE and FE providers and administer funding for courses and address skills shortages accordingly. This is similar to the tertiary systems currently being created in Scotland and Wales.

Question 36. How should government look to facilitate new and innovative provision while supporting high quality provision?

New provision will be supported through proportionate regulation that minimises burden on providers and gives them scope to innovate. This could be developed on a local basis to address regional skills needs through cooperation with regional authorities and local skills plans, with top-up funding linked to the SPG.

Question 37. We welcome views on how quality assessment and regulation could best work for level 4 and 5 technical education within the wider LLE context.

Should a single tertiary funding organisation be created as per that outlined in our answer to Question 35, then it would make it easier to assess quality and regulate standards for level 4 and 5 technical education and better integrate established assessment mechanisms such as Ofsted inspections, as they would no longer stand at odds with other regulatory regimes, such as that administered by the OfS.

Question 38. What are the barriers to encouraging greater credit recognition and transfer between providers?


Question 39. How can the introduction of the LLE support credit recognition and transfer between providers? (Including those across the Devolved Administrations)


Question 40A. How far does successful credit transfer depend on mutually recognised credit frameworks?


Question 40B. Is a single credit framework a precondition for easy credit transfer?


Question 41. If relevant, please provide details of any bespoke arrangements you have with other providers that support credit recognition and transfer.


Question 42. Which features of credit accumulation, such as size (that is a minimum number), or subject, should apply to a credit recognition and transfer policy?


Question 43. Should there be a time-limit on how long modules stay current? Should this vary by subject?

As courses develop and the world of work advances, it is impractical to impose a standard time limit on how long modules stay current. However, to maintain the relevance of modules contributing to a qualification over time, we understand the Government may wish to put in place clear parameters for the validity of some modules, particularly in subject areas and disciplines that are developing quickly (such as AI and Technology-based subjects) and also in instances where a module taken some time ago may no longer be deemed relevant to obtain a professional qualification for practice. This will require close consultation with PSRBs and employers as well as providers, and decisions should be made, justified and communicated as transparently as possible.

Question 44. How can prior workplace or experiential learning be more consistently recognised for credit?


Question 45. How might government work with professional standards bodies to facilitate recognition of prior workplace or experiential learning?


Question 46. Are there courses/subjects which would particularly benefit from accreditation of prior workplace learning?


Question 47. What data should be collected to facilitate credit recognition and transfer?


Question 48. How can the process be more transparent?


Read the rest of London Higher Response to the Lifelong Loan Entitlement Consultation here:

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