The UK Government is coming to the end of a major consultation in England on ‘higher technical education’, that is, work-focused qualifications at Level 4 and 5. This consultation is significant not least because it is the first from the Department for Education (DfE) dealing with policy proposals trailed in the Augar Report. That report was always pitched as feeding into a broader government review of Level 4 and 5 HE in England, which this consultation encapsulates. It is unclear the extent to which this agenda will be taken forward by the Johnson administration given that the consultation was issued in the dying days of Theresa May’s government.
What are the proposals?
The proposals in the consultation stipulate that all types of providers must meet certain conditions to be eligible for higher levels of fee loan support for programmes at Level 4 or 5. Each programme from every provider in England should be approved by the Institute for Apprenticeships and Technical Education (IfA). To secure approval, the provider would have to demonstrate they have matched their curriculum and assessment methods to current occupational standards. Providers of these new ‘approved’ higher technical education qualifications will have to register with the Office for Students (OfS). Both existing and new providers will face new OfS registration conditions stating that their higher technical courses are IfA approved, assuring the OfS that these programmes are taught by those with industry experience and expertise.
High-quality provision that meets the needs of students and employers is vital, regardless of the programme. Modern universities work closely with employers on ensuring that the curriculum is fit for purpose and that their programmes have proper input from them. The consultation highlights the high standard of university provision at this level, and helpfully calls for employer-informed occupational standards to span the whole range of job roles by 2022. The consultation also proposes positive steps for awareness-raising, advice and guidance in this space, an important point given both the low profile and the lack of understanding of these qualifications. The emphasis on mature students and those without a high level of prior academic attainment taking higher technical education qualifications to upskill or reskill is also welcome – this reflects flexible admission practices in modern universities for mature students that help such students succeed.
Concerns about the consultation
Despite the positives, some of the proposals prompt serious concern. The consultation takes as a given a case for change that is premised on a simplistic understanding of current Level 4 and 5 provision at universities, based on a misleadingly overstated emphasis on a so-called ‘missing middle’ of provision at these levels, something I have critiqued previously. The proposals appear to be measures designed to check on quality and industry-relevance for newer and smaller HE providers. Yet increasing regulatory requirements on all providers, with the aim of improving quality in a set of newer providers not used to delivering sub-degree provision at scale, needs to be balanced against the genuine risk of generating unnecessary burdens for universities with a strong track record of high-quality delivery.
The proposal to ask IfA Route Panels of employers to vet and ‘review the assessment materials and methods’ of every higher technical programme offered, from almost a thousand providers of such qualifications across England, each running possibly dozens of such programmes, seems a recipe for overload, potential micro-management, or both. Universities are already subject to exacting regulatory requirements from the OfS and the range of professional bodies with which they accredit their technically related programmes. As autonomous qualification-awarding bodies, it is fundamentally for universities to manage their own assessment methods for their awards, in accordance with the regulatory framework and sector-recognised standards. A centrally approved curriculum and assessment process, administered by a public body, is a clear break with the UK’s long-standing (and highly successful) approach to such matters.
The DfE consultation also risks the creation of a binary split between higher ‘technical’ skills on the one hand and work-focused higher education on the other. The high-quality work-focussed HE so widespread in modern universities contains strong work-based skills elements, complementing these skills with relevant educational content. This is advantageous for students in the long run, as it gives them a grounding not only of current job-specific skills but also of an underpinning knowledge that is vital for sustainable career success. This theoretical understanding can help people adapt to changes in the workplace, helping them to flexibly retrain when specific job functions are increasingly taken over by AI as the Fourth Industrial Revolution bites.
There is a real lack of clarity in the consultation about those Level 4 and 5 qualifications that currently attract eligibility for a student loan, but (for good reason) don’t fit the narrower mould of ‘higher technical education’. These include qualifications, such as a DipHE, which may be appropriate for a student from a background that may make them less confident of completing a full degree in the humanities or social studies. The Augar Report rightly spoke of the need to be more flexible in allowing adults to move in and out of learning as they progress through life and their career. It suggested that 30-credit modules should be eligible for student loans for those wishing to step in and out of study as the demands of life require. Yet these higher technical proposals seem to knock back the idea of modular learning because ‘approved’ qualifications by the IfA would be of a minimum 120 credits to constitute the smallest Level 4 qualification.
This could have a negative impact on the smaller professional development modules that universities provide and may block the adoption of new ‘microcredentials’ for ‘on-the-job’ learners.
In summary, the consultation contains positive elements but at the same time shortcomings that should be corrected during the consultation process. Regardless as to whether there really is a ‘missing middle’ of provision in this area, there is a consensus that better options for this form and level of HE study should be available to prospective students. We should now focus on ensuring that these consultation proposals can be adjusted and shaped into a policy that can help meet our pressing future skills and educational needs.