This blog has been kindly contributed by Professor Dave Phoenix, Vice-Chancellor of London South Bank University
The Augar Review has provided much to consider; and one area on which it shines a gentle light is that of “Non-Prescribed” qualifications. For those who are unfamiliar, Non-Prescribed courses lead to qualifications, which, although at Levels 4 and 5, are not considered to be “higher education” and therefore sit outside of the higher education framework. They are instead classified as “higher level” skills courses and lead to certificates, diplomas and other awards in a wide range of vocational areas.
Non-Prescribed qualifications are owned by awarding organisations (AOs), including City and Guilds, Pearson and professional bodies, and are delivered principally by Further Education Colleges or private training providers, although a few universitiess also offer them.
According to a report by ICF Consulting undertaken on behalf of the Department for Education, in 2016/17 there were 666 Non-Prescribed qualifications (compared to 2,734 Prescribed). Of these, 284 were diplomas, 169 were certificates, 127 were awards and 55 were NVQs. 46% of learners on these programmes were studying qualifications in Business, Administration and Law; with a further 15% studying Health, Public Services and Care; and 11% Studying Education and Training.
Being outside of the Higher Education quality framework, Non-Prescribed qualifications are regulated by Ofqual, which assesses their Level and determines the number of credits they comprise, based on the Regulated Qualifications Framework (RQF). A substantive difference between Prescribed and Non-Prescribed qualifications is their varying sizes. A Prescribed Level 4 qualification generally amounts to 120 credits. Non-Prescribed qualifications, such as those listed below, vary significantly in the number of credits awarded with some having fewer than 30 and some over 120.
|Examples of non-prescribed qualifications:|
Level 4 ACCA Diploma in Accounting and Business (89 credits) Awarded by: the Association of Chartered Certified Accountants
Pearson Edexcel Level 4 NVQ Diploma in Construction Site Supervision (Construction) (123 credits) Awarded by: Pearson Ltd
Level 4 Diploma in Advanced Hairdressing Techniques (50 Credits) Awarded by: City and Guilds of London Institute
CIPD Level 5 Certificate In Human Resource Management (32 credits) Awarded by: Chartered Institute of Personnel and Development
City & Guilds Level 5 Diploma For Assistant Practitioners in Healthcare (120 credits)Awarded by: City and Guilds of London Institute
Unlike Prescribed qualifications (such as HNCs), learners on Non-Prescribed courses are not eligible for HE loans or maintenance support. Instead, they are able to take Advanced Learner Loans, with the maximum loan amount determined by the Education and Skills Funding Agency based on the subject, the educational level and the number of credits/learning hours required. In 2017/18, the average cost of a Non-Prescribed qualification was around £2,700.
The Education Skills and Funding Agency has the authority, but no formal duty, to fund Non-Prescribed higher education. If a qualification does attract funding then, under the Common Inspection Framework applicable to FE provision, it is liable for inspection by Ofsted.
The Augar Review recommends that this current system of Prescribed and Non-Prescribed be replaced by new employer-led national standards, against which qualifications will be kite-marked. The DfE has subsequently launched a consultationon these new “Higher Technical Qualifications”. Kite-marked qualifications would be eligible for full HE funding (£7,500 under Augar’s proposals), student loan support and the same teaching grant as Level 6 qualifications. Previously non-prescribed qualifications, which do not receive the kitemark, will remain outside the higher education framework. The Review further recommends that ‘once national standards are fully established, there is a case for government to review this group of qualifications’ – presumably with a view to encouraging their discontinuation, perhaps by ceasing to assess them under the RQF.
We can probably assume that many of those Non-Prescribed qualifications with current enrolments are valued by the employers that pay to send their employees on them. Should Augar’s proposals be implemented, we might therefore expect a good number to be endorsed by these same employers and thence to become kite-marked and be eligible for student loans. Although these programmes are already eligible for Advanced Learner Loans, being kite-marked may increase their attraction and increase the associated funding to HE levels. This is likely to be an area that the Treasury will wish to look at in some detail.
However, even if a qualification receives a kite-mark from employers by meeting occupational standards, this does not necessarily mean that it will meet the educational standards to become Prescribed. Many qualifications may also be too narrowly focused or simply too small to evidence the learning and achievement expected from a Level 4 or 5 qualification. The Augar review recommends that ‘The OfS should become the national regulator of all non-apprenticeship provision at Levels 4 and above’. The DfE consultation suggests that this will include all kite-marked qualifications. Given that non-prescribed qualifications are currently quality-assured by Ofsted, it remains to be seen how they will match up to the quality requirements of the QAA.
There is also a further question about how these newly kite-marked qualifications might interact with the Review’s proposal for a Lifelong Learning Allowance (LLA). Augar proposes that learners should be able to use their LLA to fund individual 30 credit modules; building these over time into a degree. But it is difficult to see how a kite-marked but highly-specific vocational certificate at Level 4, for example, would necessarily develop the skills for a learner to enter into the second year of a degree; and it further raises questions regarding the extent to which universities might be expected to reconstruct their courses to accommodate learners presenting such qualifications.
Augar, in examining this little explored area, raises some interesting possibilities for learners and providers but at the same time brings to the fore a number of questions about funding, regulation and institutional autonomy. This area certainly warrants further discussion; and there is a danger that in potentially rushing to a solution we end up with a more confusion rather than less – more complex ranges of courses; more confusion over the regulation and assurance of HE; and increased cost; without additional educational benefit for learners or employers.