From education to employment

London Higher Response to Consultation on HE Reform: Part 4

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This document provides London Higher’s response to the Department for Education’s consultation on
HE Reform,
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.

National Scholarship Scheme

Question 18: What are your views on how the eligibility for a national scholarship scheme should be set?

London Higher welcomes the proposal to increase funding to support underrepresented students. However, we seek clarity on the definition of both ‘talented’ and ‘disadvantaged’ in this context. Extensive research demonstrates that attainment presents the largest barrier to progression to higher education and to highly-selective higher education. This has been highlighted by the Director for Fair Access and Participation, John Blake. A scheme which is only available to those disadvantaged (however this is defined) students who currently achieve the highest grades would only reach a very small number of students, the vast majority of whom already progress onto highly selective institutions.

London Higher would also note that ‘Care Experienced’ should be included as a specific eligibility criterion for this scheme.

In addition, we would welcome further detail on how such a scheme would differ from the previous National Scholarship Programme implemented from 2012-2015, and whether the previous scheme had demonstrable impact. It would be of particular importance for the DfE to provide evidence for the efficacy of this type of scheme, given the drive from the OfS to ensure that all institutions demonstrate the impact of their access and participation work through evaluation and evidence.

Finally, we seek reassurance that any national scholarship scheme would be accessible to all eligible students irrespective of where they live and choose to study in the country and that London students would have fair and equal consideration in the scholarship-awarding process. Given the priorities of the Government’s ‘Levelling up’ agenda, we are clearly concerned that the relative affluence of London compared to other parts of the country can mask pockets of deprivation and high levels of student need, when in reality poverty among young people is highest in London (38%). It is therefore imperative that the government does not bring politics into play when opportunities for young Londoners are at stake and that it commits to publishing the criteria it intends to use to select the students that are to benefit from this scheme imminently.

Level 4 and 5 Courses

Question 19: How can Government better support providers to grow high-quality level 4 and 5 courses? You may want to consider how grant funding is allocated, including between different qualifications or subject areas, in your response.

London Higher welcomes government support to grow high-quality Level 4 and 5 courses across all areas, including existing provision with higher education as part of the drive to expand choice and flexibility for all learners. Across London there exists a vast diversity of Level 4 and 5 courses and any changes to the system should protect and enhance this existing provision. We are concerned that the scale and focus of the demand for further Level 4 and 5 provision from both students and employers remains unclear, and suggest further research needs to be undertaken to understand both the demand and the way in which this could and should be met. We are also concerned that the assertions made within the consultation regarding the benefits of Level 4 and 5 provision may have been overstated from the research which the claim appears to be based upon. On p.2 of the ‘Post 18 Education – who is taking different routes and how much do they earn?’ (CVER 2020) states that ‘the results are also heavily determined by some specific subject areas. For these reasons, it should not be assumed that massive expansion of sub-degree-level qualifications will yield similar returns to those reported here, especially if in different subject areas.’ This suggests that the expansion of Level 4 and 5 on the basis of this evidence is premature and may not lead to improved outcomes for students.

London Higher notes that the expansion of Level 4 and 5 courses is currently set against a backdrop of curtailing of Level 6 provision through the proposals such as SNCs and MERs outlined earlier in this consultation. We note the comparatively smaller grant funding associated with Level 4 and 5 and question the motivations surrounding the limiting of Level 6 provision and the expansion of Level 4 and 5. Level 4 and 5 provision should also be understood in the context of the wider LLE and as such, we raise the challenges and opportunities in both consultation responses.

Partnership working between employers and Level 4 and 5 providers will be critical to the successful expansion of Level 4 and 5 provision. This should be region specific, beginning with local pilot programmes to better understand the way in which these partnerships and processes could work and to address local needs and skills shortages. As noted in London Higher’s LLE consultation response, it is important that both employers and providers are part of these discussions. 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.

Although employer interests must be recognised across Level 4 and 5 provision and embedded into provision, 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 further Level 4 and 5 courses could add relatively little to individual learners’ overall education, especially if they are not recognised as part of an established qualification framework.
Question 20: What drives price differences at level 4 and 5, where average fees in FE providers are significantly lower than in HEIs?

Price differences are partly driven by the experiences and qualifications of staff within the HE sector, who command higher salaries. Course fees also contribute towards providers’ centralised student support and experience offers, which ensure that students achieve good outcomes and are prepared for the next stage of their education or employment. Lower funding risks creating a vicious cycle in which Level 4 and 5 courses are not properly resourced to meet the needs of students, leading to a drop in student outcomes and potential regulatory action from the OfS, which results in the closure of this provision. As we have highlighted in our response to the OfS’ Student Outcomes consultation, the proposals around regulating student outcomes will create an environment wherein institutions are disincentivised from continuing to offer courses that present a high risk of regulatory action.

Question 21: To what extent do the drivers of fees at levels 4 and 5 differ from those for level 6 (including between universities, further education colleges and independent providers)?

Current evidence of the Level 6 market suggests that students equate price with quality and therefore, all providers act to protect their reputation within a marketised system by charging the higher fees. Some evidence suggests that particular groups of students, for example mature students, are more debt averse than others and this should be taken into account as part of the wider system for delivering the LLE entitlement.

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 £64 million. In order to maintain investment facilities, as well as the quality of teaching and learning provision, providers have a strong incentive to charge the maximum fee.

Question 22: How can we best promote value for money in the level 4 and 5 market to avoid an indiscriminate rise in fees?

There are many existing mechanisms which seek to assure the quality of teaching provision and ‘value for money’ to the taxpayer and the student. The recent OfS proposals to monitor student outcomes seek to demonstrate the value of higher education in economic terms. London Higher has criticised these proposals as narrow in scope and failing to identify the full value of higher education to learners and society. This concern would extend to Level 4 and 5, whereby existing courses attract a diverse range of learners and proposed new provision would seek to expand this.

In the current environment of real term cuts to the funding of higher education, experienced particularly acutely in London due to the removal of the London Weighting, undercharging for Level 4 and 5 provision would reduce its appeal to providers and risk undermining the quality and success of any provision in this space.

Question 23: Which learner types are more or less price-sensitive and what drives this behaviour? As part of your response, you may want to specifically consider the learner cohorts described above and the equalities considerations set out in the level 4 and 5 section of the equality analysis document, published alongside this consultation.

Evidence suggests that some learners, particularly mature, part-time and those from some underrepresented groups, are more debt-averse and price sensitive than others.
London Higher suggests that both the independent and impartial IAG and maintenance support offered to these groups should be tailored with their specific needs in mind. In addition, IAG surrounding Level 4 and 5 provision should be expanded more broadly, in order to ensure that such provision was actively considered by potential students. We detail this further in our LLE Consultation response.
Question 24: What are your views on the current barriers, including non-financial barriers, that providers face in offering and marketing level 4 and 5 courses?

London Higher suggests there are four key barriers that providers face in offering and marketing Level 4 and 5 courses. First, ensuring that funding for such courses recognises the cost of establishing and delivering this provision is crucial to ensuring that the aims to expand all Level 4 and 5 provision are realised. In the current environment of real term cuts to the funding of higher education, experienced particularly acutely in London due to the removal of the London Weighting, undercharging for Level 4 and 5 provision would reduce its appeal to providers and risk undermining the quality and success of any provision in this space.

Second, we are concerned that the scale and focus of the demand for further Level 4 and 5 provision from both students and employers remains unclear, and suggest further research needs to be undertaken to understand both the demand and the way in which this could and should be met. Whilst we strongly support the increased flexibility and choice that the LLE and expanding choice at Level 4 and 5 offers, this needs to be underpinned by an understanding of the nuanced demand for this at a regional and local level.

Third, in establishing Level 4 and 5 provision, the awareness and engagement of employers must be increased in order to ensure qualifications at this level are recognised and appropriately utilised. Efforts to do so should be supported by government as well as providers in order to establish viable pathways for Level 4 and 5 provision into employment. Current recruitment practices, focused on a binary ‘graduate’ and ‘non-graduate’ divide would need to be significantly nuanced in order to make Level 4 and 5 courses appealing to learners.

Finally, there needs to be a fundamental change in how we understand and recognise Post-16 learning. For the potential of the LLE and specifically, Level 4 and 5 provision to be appropriately valued, learners must be supported to ‘step on’ and ‘step off’ their education journey at different points and take different pathways, without penalty to either the student or provider.
Question 25: We want to ensure that under a flexible study model, learners studying HTQs still develop occupational competence. We also want the quality and labour market value of individual higher technical modules to be signalled. Which of the approaches below, which could be introduced separately or together, do you prefer for delivering these aims, and why?

  • Introducing requirements for each module to be individually assessed and/or for students to complete a summative assessment at the end of a qualification;
  • Awarding bodies submit qualifications with a modular structure and the Institute carry out an assessment of the quality of individual modules to provide assurance of their value to learners and employers;
  • An Institute/employer-led process to develop a common modular structure for HTQs, to support credit transfer and labour market currency of modules.

London Higher supports the drive to ensure the higher education courses meet the needs of students and providers. However, we suggest such work is already undertaken between employers and providers. We
suggest that introducing additional, burdensome and unnecessary regulation will undermine the core aim of both the LLE and the expansion of HTQs, which is to increase flexibility for learners across the system and over the course of the lives.

Question 26: How would these approaches align or conflict with OfS and/or university course approval requirements?

London Higher consider these proposals to be unnecessary and significantly increasing the regulatory burden associated with such provision. This would risk deterring providers from entering or continuing to offer Level 4 and 5 provision.

Question 27: Are there any other approaches we should consider?

London Higher supports an appropriate and proportional risk-based approach which balances the needs of learners without creating over-burdensome regulatory requirements. The English higher education sector is currently considered world leading and higher education is a major export for the UK government. The consistent rhetoric around low value courses and the ongoing high profile focus on the minority of courses and providers where provision is deemed to be falling below particular standards risks unduly damaging public confidence both within England and internationally.

The significant increase in the regulatory burden incurred by the OfS proposals around student outcomes and the TEF should not be exacerbated further by LLE or HE reform proposed by the DfE.

Read all from the 4-part series here:

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