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Response to the Lifelong Loan Entitlement (LLE) Consultation

Q1. 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 aim of lifelong learning policy is to open the door to adult learning for those who have left formal education at an early stage in their lives (aged 16–18) and with only foundational qualifications (level 1–3). It is also meant to encourage people to think of themselves as learners, in that they incorporate a constant programme of knowledge and skills acquisition into the trajectory of their lives and careers. The core principles of the LLE are as follows: it is first and foremost designed for (1) formal learning at (2) level 4 and above through (3) credit-bearing course qualifications, and should above all be aimed at people who (4) do not yet have higher learning qualifications, and (5) are active workforce participants wishing to use these courses to reskill/upskill. Separate accommodation needs to be made for learners who do not have the ability to take up level 4 provision. The LLE is not primarily designed for learning at level 3 and below, which should be available free of charge and needs to be covered by other policies, such as the Lifetime Skills Guarantee. It is also not designed to cover all areas of learning, since there is still a healthy and necessary space for non-accredited informal learning that sits outside what education providers offer. The core aim of the LLE is to help learners overcome the financial hurdles they face in accessing skills training and education over the course of their lives and careers once they have left full-time education. That means the LLE cannot be built in the same way as the current student finance system, which safely assumes that learners will be taking monolithic level 3+ qualifications at timescales measured in terms and years. If the LLE is to help upskill learners while they are still in work, it must be primarily designed to support courses that suit a different set of teaching and learning formats: flexible, part-time learning through evening/night and weekend classes, remote and online/hybrid tuition, and in-work/on-the-job skills updating, refreshing, and improvement courses. These vary widely in duration and intensity, so it is a false equivalence to measure the funding that the LLE makes available to learners in terms of how much full-time education it corresponds to. Instead, the LLE should be based exclusively on a per-credit funding model. At the proposed LLE level available to learners of £37,000, or the equivalent of 4 years of annual tuition fees for level 6 courses, per-credit funding currently translates to an exchange rate of c. £77.08 of LLE funding per course credit. This will allow learners to use their LLE in the most efficient possible way, spending as much or as little as they can at any time based on how much spare time and capacity they have to take training and upskilling courses in parallel to their work.


Q2. What barriers might learners face in accessing/drawing on their LLE and how could these barriers be overcome?


International evidence show that lifelong learners are higher-educated and earn more. In the UK those who left school at 16 are the least likely to participate in adult learning. The LLE should be attractive to those who have not previously participated in higher learning and are less inclined (due to time and financial constraints). The LLE should allow those who are capable of participating at Level 4 and above to do so. The aim of tying the LLE to an online lifelong learning account will require learners to have at least basic digital and online literacy and accessibility, as well as the English language skills to navigate the available options. This could discriminate against older learners, learners without permanent residence, learners from a recent migrant background, and those from low-income backgrounds/households. These are often precisely the learners who would benefit the most from the additional knowledge and qualified capabilities the LLE is designed to help provide. The LLE system should draw on the existing expertise of UCAS and the Student Loans Company to inform how best to construct an easy-to-use inclusive and accessible online system. A sizeable number of dedicated LLE support hubs should also be placed in Jobcentre Plus and National Careers Service branches across the country to help learners who face difficulties in accessing the LLE system. Support for the digital and online aspects of managing the lifelong learning account should be provided where needed, but the LLE itself is not there to foster basic or key skills. Instead, these should be provided at level 3 and below for free as part of other policy areas, including the Lifetime Skills Guarantee.


Q3. What information and guidance should be displayed in a lifelong learning account to support learners to understand their options for using their LLE?


The lifelong learning account should offer a simple breakdown of ‘how much has been used so far’ and ‘how much is left’ for both (1) the total amount of LLE funds for which learners are eligible, and (2) the total number of credits they have available. The account should also carry a summary of the learners’ course record, including assessment descriptions and results breakdowns. This would act as an ‘at-a-glance’ personal database that learners can use to (1) provide future institutions of study with a clear, transparent equivalent of an ‘academic record’, and (2) provide future employers with an overview of the learners’ credentialed skills. This could be informed by the expertise of professional social media networks and careers sites such as LinkedIn, Indeed, or Glassdoor. The lifelong learning account should also let learners access key information for their chosen courses where available, including: (1) total student numbers / cohort sizes and compositions for each course in the previous academic year (or most recent data); (2) cohort skill achievement rates for each course, in terms of result breakdowns; (3) cohort placement success rates, in terms of numbers in further qualifications or new employment within 12 months after completing each course; (4) employability data for each course, in terms of the proportion of specific industry position categories that require/favour it as part of their entry requirements; and (5) course satisfaction and fulfilment. The account should also have clearly-signposted links that allow learners to directly access the consultation services of the National Careers Service.


Q4. How can we best ensure that the LLE will enable learners to access technical as well as academic courses at levels 4 to 6?


There should be no distinctions made at any level between technical and academic courses in terms of their eligibility for LLE funding.


Q5A. 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?


This is the task of Unit for Future Skills, which should be upgraded to a National Institute for Future Skills. The most valuable contribution that FE and HE providers can make is to offer skills training and education now for the employment needs of the future—i.e., preparing learners of all ages for ‘jobs that do not exist yet’. LSIP partnerships need to help local employers and education providers engage in economic forecasting on 5-, 10-, 20-, and 50-year timescales, and the Unit/National Institute should support them in conducting the long-term planning that many smaller organisations, especially SMEs, are not able to carry out by themselves. This planning should join up expert expectations of local growth and decline in industry sectors to the changing resourcing/provision needs for sector-relevant teaching.


Q5B. How can we facilitate collaboration between FE and HE providers and employers, to ensure that provision keeps up with industry developments?


This is a task for LSIPs and above all Mayoral and Combined Authorities. Future devolved settlements should contain explicit measures to facilitate local skills training and education provision, in order to ensure that employers are involved closely in provision design. This needs to be supported by upgrading the Unit for Future Skills to a National Institute for Future Skills. This would act as a central resource with the roving function of providing specialist hands-on services that local areas can draw on for targeted help. Based outside London, it would operate as a strategic advice and consultancy body, or a ‘think and do tank’, working with local authorities through their LSIPs to identify their areas’ key educational and economic needs. It would connect local leaders and laggards among community stakeholders, and ensure that a broad spectrum of relevant local bodies is represented in LSIPs—including SMEs, trade unions, and education providers from Level 1 to Level 8. The NIFS would work with local authorities to help businesses get closer to their innovation frontiers by investing in skills and workforce development and help education providers target their course provision to the specific training needs of their local communities. A key responsibility of the NIFS would be to develop local implementation plans for a national approach to fostering green skills and transitioning to a net-zero economy. Low-productivity deindustrialised areas have historically been highly dependent on carbon-intensive industries and need extra help transitioning to low-carbon technologies. The NIFS would support local authorities in developing their local industrial strategies focused on the growth sectors of the 21st-century economy.


Q5C. 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?


Fundamentally, this is a task for LSIPs: employers must be integrated into the process of co-designing local FE and HE course provision (including HTQs and microcredentials), otherwise this will not sufficiently meet employers’ bespoke needs. The focus must be less on ‘unbundling’ existing offerings or creating ‘stackable’ modules that can fit into existing academic provision. Instead, qualifications must be designed around the needs of the local economy and the local labour market, even if this ultimately makes them standalone offerings that sit outside larger modularised structures (e.g., degrees). One of the barriers to joining up course provision with employer expectations about the skills needed to perform well in new job roles is the very limited overlap in personnel between industry specialists and training instructors. Even vocational qualifications are often heavily geared towards classroom-based teaching, which tends to favour theoretical over practical understanding. Two ways to overcome this would be: (1) introduce a mandatory minimum of 20% industry-relevant skills content into courses covered by LLE funding, with the content to be developed through collaboration between the education provider and local business partners, with the help of LSIPs as well as Skills and Innovation Audit and Knowledge Exchange Framework partnerships; (2) emphasise the need to bring in technical expertise into course delivery by fostering ‘dual professional’ frameworks that incorporate instructors that have extensive industry experience as part of the content design.


Q5D. How can providers support and facilitate learners gaining qualifications through modular study?


The key factor here is to use the LLE framework to encourage the development of microcredentials at level 4+ with the facility to bear credit and bundle into formal qualifications over a longer timeframe. The emphasis here must lie on making the process of accessing further qualifications as smooth and transparent for learners as possible. The key requirement here is to create a standardised credit framework based on the current 120 credits per year framework, which all courses can be slotted into based on how time-, resource-, and effort-intensive they are to complete. Education providers should provide a clear, transparent conversion system for all the multi-year qualifications they offer, which can be arranged into a structured framework of (1) introductory, (2) specialised (split into intermediary and advanced), and (3) capstone modules. These divisions are already in place to a large extent for multi-year degree courses, and would help orient learners in deciding which further modules would help them build on the qualifications they have already acquired. Providers should be encouraged to invest in arrangements for online, open access, and remote study to enable learners to participate part-time without having to uproot from their households, jobs, and local communities. FE and HE providers should also form place-based skills provision partnerships with relevant national and local employers, including creating workplace learning centre agreements for sector-specific skills improvement courses.


Q6. 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? Your answer could include information about both the potential challenges and the positive equality outcomes of this policy.


The available evidence suggests that class and income are the key barriers to education participation, yet neither of these are protected characteristics. Beyond these, learners need to be given access to individualised support services as they navigate a modular system. There needs to be a clear system for learners with support needs (disability, neurodiversity, mental health issues, etc.) to access support. There will be a practical challenge in making this work for learners taking a series of small modules with varied providers, and there will need to be a central service for brokering appropriate support. This should be linked to the system of dedicated LLE support hubs in Jobcentre Plus and National Careers Service branches across the country that are designed to help learners who face difficulties in accessing the LLE system. There also needs to be a central monitoring and intervention service to respond to any evidence of equality gaps in access or achievement, and to intervene to address any issues experienced by those with protected characteristics.


Q7. What barriers might learners with protected characteristics face in accessing/drawing on their LLE and how could these be overcome? Your answer here could include previous consideration of an alternative student finance product for students whose faith has resulted in concerns about traditional loans.


The available evidence suggests that class and income are the key barriers to education participation, yet neither of these are protected characteristics. Beyond these, learners need to be given access to individualised support services as they navigate a modular system. There needs to be a clear system for learners with support needs (disability, neurodiversity, mental health issues, etc.) to access support. There will be a practical challenge in making this work for learners taking a series of small modules with varied providers, and there will need to be a central service for brokering appropriate support. This should be linked to the system of dedicated LLE support hubs in Jobcentre Plus and National Careers Service branches across the country that are designed to help learners who face difficulties in accessing the LLE system. There also needs to be a central monitoring and intervention service to respond to any evidence of equality gaps in access or achievement, and to intervene to address any issues experienced by those with protected characteristics.


Q8. 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?


Yes. All level 4 to 6 courses should be eligible for HESF and LLE funding.


Q9. 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)


Yes, all of these courses should be eligible for LLE funding, especially where they can be disaggregated into credit-bearing modular components. But this should not crowd out availability of HESF for these courses for learners taking them as part of their immediate post-18 education.


Q10. 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?


There is a key distinction to be drawn here between the length of a course (i.e., the number of credit-learning hours) and the amount of time it takes a learner to complete it. Modularisation disaggregates these, allowing courses to run over more than four years. This is best met by placing the LLE on a per-credit funding model. We also recommend expanding the LLE in at least the medium-to-long term to cover 720 credits’ worth (i.e., the equivalent of 6 years) of courses. Beyond that, in the short term, there are two clear options: (1) add explicit lifelong availability provisions to the student finance arrangements for these specific courses; (2) create a system of lifelong learning pathways for multi-year highly-structured courses, modularise within these pathways to allow learners to step-on and step-off once they have embarked on their chosen pathway, and create specific exemptions to the upper years/credits funding limit for these courses. In both cases, a recognition is needed that not every form of skill or qualification can be subsumed into the same blanket framework, and that the LLE system needs to retain some flexibility based on learner and sectoral needs.


Q11. 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? Please include detail on the process and eligibility criteria that would be used in any alternative route.


No. HNDs and HNCs are full qualifications that should have the same access to funding as level 6 qualifications, and should remain eligible for ALL, HESF, and LLE funding.


Q12. In particular, how could employer-relevance be tested as a basis for LLE eligibility?


Mechanisms need to be put in place to ensure that courses can receive explicit employer and industry endorsement. A precondition for this is to encourage employers to make the eligibility/qualification requirements for their hiring processes more transparent, in order for job market candidates to have explicit information about what baseline skills employers expect them to be able to demonstrate. This could help inform the ‘employability’ data for individual courses and modules that is included in the key information available to learners on their lifelong learning accounts. This data could be supplemented by regular survey data of employers’ assessments of the ‘usefulness’ of particular skills areas and qualification types, ideally in as granular a form as possible.


Q13. We are aware that some courses (e.g. medical degree courses, some ALLfunded 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?


No, all courses should be eligible for modular funding. The Government should set an ‘exchange rate’ of 120 credits per each year of any non-modular courses. This would allow learners to use their LLE funds transparently and systematically for such courses without risk of being overcharged or making inefficient use of their LLE. Along these lines, the decision about how much of their LLE to spend on non-modular courses should be left to individual learners.


Q14. 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?


We do not oppose the idea of a minimum amount per funding application as such. But if we use the standard measure of 120 credits per year of full-time teaching, a 30-credit minimum is fairly high (the equivalent of a quarter-year of full-time or half-year of part-time learning). There is no clear definition of what counts as (e.g.) a ‘microcredential’, including how many credits these typically equate to. Often, education providers also deliver small courses without credits until learners reach a certain minimum threshold number of courses taken (e.g., from 20 credits upwards), typically because enrolling learners on courses is less bureaucratic than registering them for an accredited award. This varies significantly between providers, and this power should remain in their hands. But learners should nonetheless be able to use their LLE to finance courses of any size. In order to offer learners maximum flexibility in how to use their LLE funds for any combination of modular courses, including microcredentials, we recommend a lower minimum amount of 10 credits.


Q15. 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?


All courses should be funded on a per-credit basis. At the proposed LLE level available to learners of £37,000, or the equivalent of 4 years of annual tuition fees for level 6 courses, per-credit funding currently translates to an exchange rate of c. £77.08 of LLE funding per course credit.


Q16. 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).


N/A.


Q17. In brief, what internal processes do you/they have to ensure compliance with the framework or rules?


N/A.


Q18. What impact could modular study have on study mobility across the UK?


Modular study is likely to have a two countervailing effects on study mobility. (1) If modular courses are available in an online/remote-learning format, or through local FE-HE partnerships, they could lead to fewer learners moving out of their local areas in order to ‘go to’ colleges or universities that are based elsewhere. What would otherwise be in effect local modules would thus become national (perhaps even international), allowing learners to access them no matter where they live. (2) If modular courses retain a significant in-person/hybrid component, this could foster ‘study tourism’ by learners who move from one locally-based education provider to the next as they accumulate additional qualifications. But this is much more likely to be the case for early-career learners than mid-/late-career learners, as the latter are likely to have family ties and financial and care commitments that leave them firmly rooted in one particular place.


Q19. How can the LLE promote and encourage flexible study across England, Scotland, Wales, and Northern Ireland?


In order to accommodate study that is both accessible nationally and place-based, the LLE can support the formation of regional integrated tertiary education partnerships that focus on a number of explicit sectoral specialisations. These specialisations should play to the strengths of local economy, which will both (1) integrate local residents and communities more closely into their local areas’ educational and economic strengths, and (2) attract high-quality learners and workers from across the country who want to specialise in the sector/industry in question.


Q20. What should be the most important considerations when determining how the lifetime entitlement will work?


The aim of lifelong learning policy is to open the door to adult learning for those who have left formal education at an early stage in their lives (aged 16–18) and with only foundational qualifications (level 1–3). It is also meant to encourage people to think of themselves as learners, in that they incorporate a constant programme of knowledge and skills acquisition into the trajectory of their lives and careers. The core principles of the LLE are as follows: it is first and foremost designed for (1) formal learning at (2) level 4 and above through (3) credit-bearing course qualifications, and should above all be aimed at people who (4) do not yet have higher learning qualifications, and (5) are active workforce participants wishing to use these courses to reskill/upskill. The LLE is not primarily designed for learning at level 3 and below, which should be available free of charge and is covered by other policies, such as the Lifetime Skills Guarantee. It is also not designed to cover all areas of learning, since there is still a healthy and necessary space for non-accredited informal learning that sits outside what education providers offer. For this, the following considerations are the most important: (1) a credit-based funding framework that uses (2) a standardised credit framework, which (3) supplements but does not replace existing HESF frameworks, and which (4) is paired with detailed granular data available on an accessible lifelong learning account system that helps learners know what they can reasonably expect in terms of their future skills and work prospects.


Q21. 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?


LLE eligibility should start at 21, and there should be no upper age restriction for accessing it. However, in order to ensure that LLE helps contribute to economic development and boosting labour productivity, we recommend adding an intermediary condition that learners must use at least 60% of their LLE funds by the time they are 51. This would allow the LLE to capture learners not already covered by existing HESF provisions, and balance giving learners freedom to distribute their LLE funds over their whole lives and careers with the need to ensure that the LLE is not just used to support ‘retirement projects’.


Q22. 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.


We strongly reject the idea of introducing a blanket restrictions so that the LLE only funds modules that are ‘unbundled’ as part of a larger course structure. Upskilling often relies on ‘short, sharp’ in-work micro-learning and specialised skills improvement courses that are independent of larger qualification systems, such as computer and digital literacy, management and teamwork, and other ‘business skills’ training. This means the system as a whole neds to be agile in order to remain responsive to labour market challenges. At least part of the LLE funds must be available to use on free-standing courses of this kind. At the same time, we recognise that it is helpful for learners’ intensive skills development to pursue some modules that fit into an overarching ‘introductory–specialised–capstone’ structure. But it is ultimately not the responsibility of learners to ensure that structures along these lines are put in place by education providers. We therefore recommend reserving at least 50% of LLE funds for learners to use without any restrictions, including on individual free-standing modular courses.


Q23. 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?


It is crucial that the available forms of careers advice act as a bridge between learners’ and employers’ expectations. To help inform this, the government must commission an annual report on overall skills levels and economic output across the UK, which examines: (1) cohort sizes and compositions of all qualifications from entry level up to level 8; (2) cohort skill achievement rates, in terms of result breakdowns; (3) cohort placement success rates, in terms of numbers in further qualifications or new employment within 12 months after achieving each qualification; (4) job retention and labour market turnover; (5) labour productivity; and (6) job satisfaction and fulfilment. This report should include granular regional and demographic breakdowns for each of these entries. It should be used to inform publicly-available employability data for each course, in terms of the proportion of specific industry position categories that require/favour it as part of their entry requirements, and employers’ surveyed rankings of the courses’ desirability and efficacy.


Q24. 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?


This is a consideration that is best left to local government authorities as the leading members of LSIP partnerships. LSIPs should foster collaboration between local education providers and businesses to develop courses that meet the needs of the local economy. In order to ensure a long-term strategic view, the Unit/National Institute of Future Skills should work with LSIP partnerships to identify likely future skills gaps and steer course development towards anticipating these developments.


Q25. Are there other restrictions we should consider on the use individuals can make of their entitlement?