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We should not abandon the link between qualifications and student loans, but radical reform is necessary

  • 12 November 2021
  • By Tim Blackman

This blog was contributed by Tim Blackman, Professor of Sociology and Social Policy and Vice-Chancellor at The Open University (@TimJBlackman). He writes in a personal capacity.

The UK Government’s new Lifetime Loan Entitlement (LLE) for England will break new ground when it is introduced in 2025 to replace the current student loans system. It will make student loans available for studying short courses, conventionally described as modules, without the current requirement to register for a qualification.

It appears likely that these courses will be defined in terms of upper and lower limits to the number of study hours expected to complete them, using credits. The LLE will provide loan funding over a lifetime and probably to a maximum of 480 credits of courses or qualifications taken in either a university or college.

This is welcome flexibility when increasingly rapid economic and technological change mean that opportunities to learn need to be lifelong and not just concentrated into the late teens/early twenties. Currently, the majority of new higher education students in England register for a full 360 credit degree over three years. They can also take out further borrowing up to an additional 120 credits, often as a foundation year or an integrated master’s degree.

The reforms, however, raise two important questions. First, whether studying a module of say 30 credits — the minimum that the Augar review suggested could be loan-funded — should have the same claim on loan funding as a qualification. Secondly, what initial higher education qualification might be appropriate if it is not a whole degree, which might consume almost all a learner’s loan entitlement in just three or four years, undermining the LLE’s purpose to support lifelong learning.

In this blog, I argue that a free-standing module, even as part of an existing qualification, does not have the same currency or portability as a qualification, which qualifies a learner for something. It seems inadvisable to fund study of a single module using a loan scheme based on returns from qualifications. The need for smaller volumes of learning is real but for student loan purposes best met by certificating smaller amounts of credit as qualifications within the existing QAA higher education qualifications framework.   

I also argue that the 360/480 credit degree should no longer be the culmination of higher learning for a qualification at age 21 or 22. Instead, it should be possible to develop a portfolio of qualifications over several, perhaps many, years.

Finally, with the Augar review’s proposal for national minimum entry requirements (MERs) for degrees currently under active policy consideration, I suggest that an approach of stacking qualifications as a developing portfolio could avoid the potentially negative impact of MERs on both lowering the status of non-degree qualifications and making degrees even more socially selective.

To modularise or not to modularise

Most degree programmes are currently modularised, but the UK government rejected modularisation of its new advanced and higher technical qualifications in favour of linear programmes with final assessment. These include T-levels at Level 3, which are intended over time to replace many modularised BTECs as the vocational alternative to A-levels, and Higher Technical Qualifications (HTQs) at levels 4 and 5, intended to be alternatives to degrees.

A T-level or an HTQ, like a higher or degree apprenticeship, is mapped to an occupational area, such as cybersecurity technician (Level 3) or air traffic controller (Level 5). They are non-modularised in the belief that it is not possible to be partly qualified in an occupation but only fully qualified, with that demonstrated in a final assessment.

HTQs are intended to revitalise level 4 and 5 vocational study in England following the collapse in demand for Higher Technical Certificates and Diplomas (HNCs and HNDs). This collapse was accelerated by ending the capping of degree places in 2015, with students opting for the opportunity to study to level 6 with a loan and receive what is perceived to be the higher status of a degree credential.

Scotland retained student number controls for degree places and, as a result, demand for HNCs and HNDs has held up. These are studied predominantly in further education colleges, with progression to either employment or a degree top-up at a university. HNCs, HNDs and Scotland’s graduate apprenticeships are all modularised within a common qualifications framework that includes degrees.

In England, a fissure has been created between linear higher ‘technical’ qualifications and modularised higher ‘academic’ qualifications, meaning that the study of single modules is likely to be from ‘academic’ programmes, which is not the apparent intention of the LLE and its rationale of lifelong learning for a changing economy. For sure, many vocationally-oriented single modules will be proposed for loan funding in the current Office for Students pilot, but this also illustrates what is an essentially false distinction across most of higher education between ‘technical’ and ‘academic’ courses.   

The technical education conundrum

England has not gone down the Scottish route. Although its new HTQs and higher apprenticeships are aligned to national level descriptors for qualifications, there is no equivalence in the occupational standard that each HTQ meets between part of a standard and part of a degree programme. There are no formally defined bundles of knowledge in an occupational standard equivalent to the bundles of knowledge in a degree that are called modules.

This is the case even though there are plenty of examples of much the same content in part of an occupational standard and part of a degree. Both a marine pilot apprentice and a geography student, for example, will study a course in meteorology. Indeed, the first approvals of HTQs by the Institute for Apprenticeships and Technical Education have essentially badged adaptations of existing HNC/Ds, foundation degrees and Cert/DipHEs as ‘linear’ HTQs even though these original programmes are modular.

This means that almost identical content in two or more occupational standards cannot be accredited as equivalent and then ported from one qualification to another in the way that credit transfer is often possible between degrees.

The inflexibility of England’s new technical qualifications contrasts starkly with how a key driver for smaller units of study is the changing nature of work as technological change speeds up knowledge and skills becoming obsolescent. The reality is that no one will ever be fully qualified in an occupation or discipline for very long.

For degree programmes, it will be relatively easy to make available single modules for study, putting aside whether this makes sense educationally — but for HTQs and apprenticeships it is currently impossible without breaching the principle that an occupational standard is a single, coherent and unique ‘thing’.

To bundle or nor to bundle

Proponents of linear programmes argue that there is an integrated whole that is necessary to achieve occupational, professional or disciplinary competence, whether as a market research executive or a historian. This raises the question of what really is foundational for a trade, profession or discipline: does a plumber really need a four-year level 3 apprenticeship, a network engineer a two-year HTQ or a historian a three-year degree? And to what extent should these be starting points for subsequent lifelong learning rather than end points?

The answers will depend on what people need; much of what is learned on these programmes will be needed, some will not be needed but enjoyed (a consumer experience of value in itself), some will not be needed, some will be needed but date rapidly and some will be needed but not taught. The last situation will become more acute over time as knowledge advances more and more quickly beyond what was taught at a particular time.

Undoubtedly, specific suites of modules are needed to qualify as a competent ‘something’, especially if this is a regulated trade or profession. But this ‘something’ should be as disaggregated as possible to a tradeable minimum: a qualification that is tradeable for a job, a promotion or further study. It should also be stackable to enable people to develop their own bundles of knowledge, rather like workers in the trades acquire more ‘tickets’ to practice particular specialisms. This not only hedges against obsolescence but would enable learners and employers to choose what they need, including mixed ‘academic’ and ‘technical’ portfolios.

These accredited bundles of knowledge should form certificated qualifications, drawing either from occupational standards or degree curricula and national subject benchmarks. Their integrity as a qualification can be achieved by requiring pre-requisites and a stated qualification goal.

Stackable qualifications

Unfortunately, however, occupational standards are very prescriptive with no progression between defined levels, while national subject benchmarks are more indicative and allow for milestone qualifications that work towards the degree benchmark. It would certainly be helpful to create more alignment between these frameworks and undertake an exercise to credit rate the parts of an occupational standard that can then be bundled into coherent smaller qualifications within the standard. This is exactly what has been widely done with CertHEs and DipHEs sitting within degrees.

This approach of stackable qualifications is preferable to studying single modules because module credit is not a qualification but a quantum of learning achieved. A learner, provider or employer wants to know what the module qualifies the person who studies it to do, whether to install boilers, manage a project or make a legal argument. Such a level of disaggregation will mean that more is necessary before someone can, for example, practise as a domestic heating engineer or a lawyer, but the principle is one of stacking qualifications, each of which can be useful in their own right but also count towards other outcomes such as a registered practitioner. 

Loan funding needs to be available for qualifications at the lowest tradeable quantum upwards. This smallest quantum should be a demanding qualification needing sustained commitment and achievable either part-time or full-time. This could be down to 30 credits, still a substantial 300 hours of study, but in a range of 30 to 120 credits.

Thus, as at present, a CertHE or HTQ could be awarded at level 4, a DipHE, HTQ or foundation degree at level 5, and a degree at level 6. The overall volume of the qualification should probably still increase with level. But this should be designed in a way that makes available loan funding for certificates so that they can be studied over time up to a total of 480 credits. For diplomas, a minimum volume of say 90 credits for the qualification would apply but also with the ability to build up to 480 credits. Similarly, degrees could be awarded in the 240 to 480 credits range. Progression from one level to the next would require achievement of at least 60 credits at the prior level, and award at a given level similarly require at least 60 credits at that level (and possibly 30 for certificates).

Instead of trying to improve credit transfer opportunities, a system of qualification recognition would be easier to encourage or incentivise, treating prior credit as an entry qualification rather than something that has to be mapped onto another programme of study. For example, The Open University has extensive articulation agreements with Scottish colleges creating degree pathways from HNCs and HNDs, including changing subject or career focus.

Re-thinking the full-time degree

There is a need to re-think the full-time degree as the gold standard of tertiary education, predominantly concentrated into the late teens / early 20s of life and often studied on an expensive residential basis. The LLE is an opportunity for both learners and employers to give recognition both to how much of the LLE has been used and how much of it is still available, which represents potential for further learning.  

Much of this learning may be available and appropriate as small modules down to perhaps five credits as a microcredential. But loan funding at such a small and often repeated scale would entail significant additional costs to administer. The student premium grant that currently supports part-time study in England is also a vital part of the funding package that helps keep fees lower than they would otherwise be and would get very thinly spread if extended pro rata to small modules. The same applies to maintenance support (much of which is currently consumed by students who choose to re-locate for residential study; maintenance support could be capped at the living at home rate and extended to short qualifications).

Study of single small modules also raises complex issues about fee capping. At the moment, there are two separate fee caps for full-time and part-time study. The LLE is an opportunity to move to one fee cap that is then applied pro rata to all qualifications. Grant funding can be used to support priority subjects and modes of study.

There is a strong argument to focus student loans, student premium funding, maintenance support and the apprenticeship levy on qualifications, and to encourage employers to fund smaller modules such as microcredentials using tax incentives. In Scotland and Northern Ireland, the OU has also received government grant funding to make microcredentials in certain target areas free to learners as part of their skills strategies, and this is potentially an important focus for local and national government skills funding.

Moving to a system of funding qualifications of different volumes and levels within a common framework would diversify higher education qualifications beyond just once-and-for-all degree study to certificates, diplomas, HTQs and degrees built up over a lifetime. It would also create an opportunity to align degrees, HTQs and apprenticeships so that a 120-credit level 4 HTQ, for example, could be made up of two 60 credit qualifications that could, now or later, also count towards a level 6 degree. Alternatively, a learner may want to develop all their learning over a lifetime at level 4, even up to 480 credits.

Minimum entry requirements

Progression pathways to degrees would still be important, not least so that DipHEs or HTQs are not seen as dead ends. But this should not be at the cost of the option of continuing to study at equivalent or even ‘lower’ levels if that is what is needed. Indeed, there should be the ability to use the LLE for additional level 3 study; why not fulfil an interest in the arts with a level 5 DipHE in humanities but then study to be a tree surgeon at level 3?

Progression pathways could also address the current UK government’s concerns about students being admitted to degree programmes with very low prior academic attainment. The policy rationale for this still seems unclear. It appears to be either a means to make degree education more selective to control public spending or divert demand to other qualifications or, as articulated by the last Education Secretary, about an expectation that all degree graduates have levels of numeracy and literacy that have been evidenced with good GCSE passes.

To introduce a mandatory prior qualification threshold for degree study at level 6 runs a serious risk of sending a signal to young learners that if they do poorly at 16 or 18 they will never be able to achieve a level 6 qualification. Qualifications below level 6 will then become seen as ‘softer’ options, stigmatising them when we need to increase their status.

Many people do better in their studies later in life, sometimes because they are differently motivated or had tough times in their school or college years and sometimes because they are better taught. Study at level 4 and 5 is often an opportunity to catch up with earlier lost opportunities to develop numeracy and literacy for example, and mature students should not be expected to return to GCSEs or A levels as a further hurdle before they can progress to level 6 on a degree programme.

It would be fairer and more responsive to learners’ biographies and ambitions to make the first certificate in higher education, at level 4, available at a range of institutions’ self-determined admission thresholds, including the OU’s successful open entry model (which is a model based on supported self-assessment). Loan funding for progression beyond level 4, at the same or another institution, could then require successful completion of at least 60 credits as a CertHE or HTQ for progression to level 5, and a DipHE, HTQ or foundation degree for progression to level 6.

To do otherwise, especially if it is perceived as making degrees more selective, would deepen the already deep social class divide between ‘vocational’ and ‘academic’ pathways. This may still leave people sharing Gavin Williamson’s concern that even with successful completion of level 4 and 5 qualifications some degree graduates may not be able to obtain good passes in GCSE Maths and English.

This may be an issue for some but is best addressed by occupational standards and degree subject benchmarks including adequate numeracy and literacy requirements at levels 4 and 5 within the context of what is required to qualify in the occupation or discipline at that level. If the UK government insists on the policy, MERs should be achievable not just by completing secondary qualifications at a certain standard but by passing an approved access module prior to or alongside level 4 or 5 qualifications.


While England’s landscape of existing and new higher education qualifications and funding support is a picture of dots that are not yet joined up, it is possible to join the dots to create a system fit for the twenty-first century. I have tried to outline in this piece how they can be done.

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  1. Silvia Logan says:

    I think that they should to create an education systems suited for the 21st century.

  2. albert wright says:

    Very interesting observations on a very important issue.

    It is vital that the fundamental structure of the new approach to Life Long Publicly Funded Learning delivers the right results that benefit the individual and the wider community with an appropriate balance.

    The timing of access to funding for individuals over decades needs careful consideration. What happens on death, to unspent funds? Will the money become part of a persons estate or just returned to the Treasury like underspends on the Levy?

    Should funding be restricted to study that is linked to qualifications?

    Given that people learn in different ways and at different speeds, should we abolish the concept of “Minimum Learning Hours” ?

    Should the funding be based on a financial Life Time Allowance?

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