This document provides London Higher’s response to the Department for Education’s consultation on Lifelong Loan Entitlement (LLE), published on 24 February, for a response by 06 May 2022.
This consultation response has been created after extensive discussion with members of London Higher and seeks to represent the diversity of ‘London HE’.
Theme 3: Supporting quality provision and flexible learning
Question 32. How can we support flexibility while maintaining a high quality offer through the introduction of LLE?
An obvious way to support the flexibility of the system is to ensure that we apply less scrutiny to modular studies and short courses than is currently seen by the OfS for more ‘traditional’ higher education provision “. For short courses to grow effectively, providers ultimately need the space to innovate, and the current way of regulating the HE sector cannot simply apply to a world of modular courses without stifling progress. What is needed instead is a common and light regulatory approach to all tertiary providers, both FE and HE, to ensure that basic quality levels are met, but with the flexibility to enable providers of different sizes and abilities to continue to improve the lifelong learning landscape.
Question 33. How should the quality approach change to support the introduction of LLE?
The quality and standards proposals currently being viewed by the higher education sector regulator, the OfS, are already raising concerns about the increased burden they are meant to place on providers at ‘mainstream’ course level. Applying this approach to modular LLE courses would be impractical and, above all, unsustainable for a sector that is already exhausted as a result of the Covid-19 pandemic to deliver appropriate courses and overall support to students. “Micro” courses cannot be micromanaged.
Question 34. If applicable, what regulatory changes might be required to support a modular system?
A more flexible and lean approach to regulation will be needed to support a modular system, as it will be nearly impossible to collect the same amount of data for more modular course offerings to form indicators and benchmarks like this is currently the case. be consulted by the OfS for more ‘traditional’ higher education 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 measure of non-completion should be revisited for modular study, as should employment and further study outcomes to account for the non-linear work and study patterns of flexible adult learners. If the current proposals for higher education regulation were to be transferred to the LLE, it would stifle course innovation and discourage providers
create new courses and modules. It will also create an uneven regulatory playing field between education and higher education providers, thereby inhibiting partnerships and collaborative provision.
Question 35. Are there opportunities to simplify the regulatory regimes that will operate under the OLA?
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. This is why we should seize the opportunity to reconsider the current roles of the various regulators operating in this space. More appropriate to a more streamlined world of higher education would be to establish a new single tertiary funding organization that would help maintain quality and standards across higher education and higher education providers and administer funding for course and address skills shortages accordingly. This is similar to the tertiary systems currently being created in Scotland and Wales.
Question 36. How should government seek to facilitate new and innovative supply while supporting high quality supply?
The new benefits will be supported by proportionate regulation that minimizes the burden on providers and gives them room to innovate. This could be developed on a local basis to meet regional skills needs through cooperation with regional authorities and local skills schemes, with additional funding linked to the GSP.
Question 37. We welcome views on how quality assessment and regulation might work best for Levels 4 and 5 technical education within the broader context of technical and language education.
If a single tertiary funding body were created in line with our answer to question 35, then it would be easier to assess quality and regulate standards for technical education at levels 4 and 5 and better integrate mechanisms for established assessment such as Ofsted inspections, as they would no longer conflict with other regulatory schemes, such as that administered by OfS.
Question 38. What are the barriers to promoting greater recognition and credit transfer between providers?
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Question 39. How can the introduction of LLE promote the recognition and transfer of credits between providers? (Including those of decentralized administrations)
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Question 40A. How dependent is successful credit transfer on mutually recognized credit frameworks?
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Question 40B. Is a unique credit framework a prerequisite for easy credit transfer?
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Question 41. If applicable, please provide details of any bespoke agreements you have with other providers that support credit recognition and transfer.
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Question 42. What credit accumulation characteristics, such as size (ie minimum number) or subject, should apply to a credit recognition and transfer policy?
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Question 43. Should there be a time limit on how long modules stay up to date? Should it vary by subject?
As courses develop and the world of work changes, it is impractical to impose a standard time limit on how long modules remain current. However, to maintain the relevance of modules contributing to a qualification over time, we understand that the government may wish to put in place clear parameters for the validity of certain modules, particularly in rapidly developing fields and disciplines (such as AI and technology -subject-based) and also in cases where a module completed some time ago may no longer be deemed relevant for gaining 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 in the most transparent way possible.
Question 44. How can prior learning in the workplace or experiential be recognized more systematically for credit?
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Question 45. How could the government work with professional standards bodies to facilitate the recognition of prior learning in the workplace or experiential?
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Question 46. Are there any courses/subjects that would particularly benefit from the validation of acquired professional experience?
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Question 47. What data should be collected to facilitate the recognition and transfer of credits?
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Question 48. How can the process be more transparent?
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Read the rest of London Higher’s response to the Right to Life Loans consultation here:
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