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GCSE Thresholds for Eligibility for Student Loans Could Transform Access and Participation

  • 24 February 2022
  • By Mary Curnock Cook

This blog was written by Mary Curnock Cook, Non-Executive Director across the education sector and former Chief Executive of UCASYou can find Mary on Twitter @MaryCurnockCook.

There won’t be many people in the higher education sector who are surprised by the announcements about fees and funding for higher education in England announced today; and the proposals being consulted on have also been widely trailed.

I’ll leave it to others to comment on the freeze on the tuition fee cap, repayment threshold and interest rate reductions, but I wanted to set out some early thoughts on the proposed minimum entry requirement (MER) options.

Higher education providers are no strangers to minimum entry requirements, and you’d be hard-pressed to find any course on the UCAS system which does not stipulate them, with the obvious exception of the Open University. Universities have, by law, autonomy over admissions and can set entry thresholds wherever they wish. Government may not intervene in this respect. However, the Government can, and clearly now will, set a minimum eligibility threshold for access to tuition fee and maintenance loans. It is now consulting over whether to set this at two Grade E passes at A level (or equivalent) or a minimum Grade 4 at GCSE in English and mathematics.  

Not only do I think the GCSE threshold option is preferable for the HE sector, but, more controversially, I also believe that it could transform access and participation.

The reasons the proposed GCSE threshold is preferable are fairly straightforward. Firstly, it is (obviously) a lower threshold than the two E grade A level proposal. Secondly, most universities set a minimum entry requirement for all their courses at this level already. And thirdly, because there is less variety in the Level 2 qualifications taken at Key Stage 4, it is much less complicated to work out the qualification equivalences which would undoubtedly bedevil a minimum entry requirement set at Level 3. Lastly, given the threshold is primarily intended for school or college leavers, potential university applicants will be in compulsory education for a further two years when they are still focussed on education and open to coaching and support to achieve their aims. Potential applicants who miss the Level 3 threshold at 18 are much harder to keep on track to progress to HE once they leave school or college and enter the workplace. There is also an inbuilt escalator for demand for HE given that accountability measures for schools are focussed on GCSEs through the Progress 8 and EBacc measures. Every school in the country is hellbent on trying to get more pupils over the Grade 4 hurdle for English and mathematics, not just for progression to HE but also for its iconic status for many life chances. There is much less focus on accountability for KS5 outcomes.

The accepted wisdom in the sector seems to be that MERs are a bad thing: students from low-income or otherwise disadvantaged backgrounds typically have worse attainment in secondary education than those from more advantaged backgrounds, ergo a minimum requirement will disproportionately exclude more of them from higher education. 

Press trailing of the potential for GCSE loan eligibility thresholds has raised temperatures by suggesting that this would exclude around 30 per cent of students from access to higher education based on the proportion of young people who fail to reach Grade 4 English and mathematics at age 16. This is disingenuous because this is the time when 16-year-olds get sifted, on the basis of their GCSE results, into those that have done well enough to progress to A levels or other Level 3 qualifications (and therefore potentially on to HE), and those that are more suited to (usually) vocational courses at Level 2 or 3 to support progression to apprenticeships or work with training, often alongside a requirement to re-sit their English and/or mathematics GCSEs.

The more relevant metric to look at is the proportion of recent cohorts of school leavers who would have been excluded from their university studies had the threshold been in place. Informal data from UCAS suggest that in 2020 some eight per cent or c.20,000 18-year-olds were accepted to full-time undergraduate study without meeting the proposed GCSE threshold. What we urgently need to know is the background demographics of these students and the subject areas involved. That would give us a better idea of the potential impact of this proposal on participation and which groups would be most affected. 

My hope is that new MERs set for GCSE English and mathematics might have a positive impact on participation in HE. Currently, much of universities’ access activity is focussed on Key Stage 5 (sixth form) students and, arguably, does little to widen participation since the recipients of support are already on course to achieve the Level 3 qualifications (A levels, BTECs and so on) usually required to progress to higher education. Such access activity might be effective in keeping wavering students on course, or it might encourage some to apply for more demanding courses; it might also provide a good way for some institutions to attract more of the sought-after ‘poor bright’ students that they need to burnish their Access & Participation targets.  

But the real barrier to access to higher education has always been at Key Stage 4/ GCSE attainment level where failure to achieve strong enough results means missing out on any pathway to higher education. And this, of course, disproportionately excludes students from disadvantaged backgrounds.

There is a reasonable logic that students without basic levels of literacy and numeracy are unlikely to succeed in, or gain value from higher education, hence the usual requirements from universities for GCSE English and mathematics. What this policy could create, however, is a welcome shift of higher education access activity to younger pupils with a real chance that this would help raise attainment and aspiration earlier in students’ education and contribute to a new era of widening participation in higher education. This could be a transformative outcome – although that is perhaps not what the policy is designed to achieve.

On Thursday 10 March 2022 HEPI and Advance HE are jointly hosting a webinar on equality and diversity. To register your place, please click here.

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  1. “Every school in the country is hellbent on trying to get more pupils over the Grade 4 hurdle for English and mathematics.”

    That is undoubtedly true for every school in the country. Jumping the hurdle, though, is made devilishly difficult by two fundamental flaws in that hurdle’s design.

    Firstly, the hurdle ensures that one-third of runners trip up. So however hellbent the school might be, however athletic the student, the bar is fixed so that one-third don’t make it. The ‘Forgotten Third’ seems to continue to be forgotten. (

    Secondly, the hurdle is both ‘leaky’ and ‘opaque’ at the same time, allowing some to jump it that shouldn’t, but stopping others that should.

    To explain: in the summer of 2019, the last time ‘real’ exams were taken, about 700,000 candidates in England sat GCSE English. Of these, about 175,000 were awarded grade 3 (“fail”), and about 125,000 grade 4 (“pass”).

    Of the 175,000 who “failed”, about 26,000 should have passed, 25,000 with grade 4, and a further 1,000 with grade 5. Some 15% of students – 1 in every 7 – who “failed” didn’t.

    And of the 125,000 who “passed”, about 25,000 should have failed. So about 1 in every 5 students who “passed” didn’t.

    It seems to me that any criterion for admission – GCSE grade 4 in key subjects, 2 Es at A level, whatever – must be fully reliable and trustworthy.

    As Ofqual themselves admit, all exam grades are “reliable to one grade either way” (

    Until Ofqual fix this, and deliver reliable and trustworthy assessments (, I suggest it is most unwise, if not deeply unfair, to use any criterion based on grade [this] or grade [that] for any purpose, let alone a potentially life-changing one such as admission to HE.

  2. Cath says:

    “… students without basic levels of literacy and numeracy are unlikely to succeed in, or gain value from higher education, hence the usual requirements from universities for GCSE English and mathematics. ”

    This is just not true.
    Firstly, it’s assuming that GCSE English and maths are “basic levels of literacy and numeracy”. They are not.

    I know plenty of people in professional occupations who wouldn’t be able to go into GCSE Maths and pass it, and similarly I know quite a few professionals who wouldn’t pass GCSE English. Does that really mean they lack “basic levels of literacy and numeracy”?

    Secondly, it’s assuming GCSE grades always fully reflect young people’s abilities, skills and knowledge. There are many confounding factors that can mean they do not.

    And thirdly, it is ignoring that people may be one sided. Why should being not the best at English prevent someone from doing a maths or physics degree? Why should finding maths tough preclude a degree in Fine Arts or English Literature?

    Minimum entry requirements at level 2 are better than having them at level 3, granted. But that doesn’t make them acceptable.
    This is an attack on institutional autonomy, but far worse, it’s closing the door to HE to many like those who currently succeed despite not having these qualifications. Even if it drives a focus on raising attainment at a younger age, there will still be those not reached by this, for a multitude of reasons. This will shut them out.

  3. Albert Wright says:

    This looks worth supporting. The sooner those from disadvantaged backgrounds can get support the better.
    It would be useful to know how the 20,000 who were accepted by Universities without the desired GCSE grades performed- if successful then it might be worth accepting more but if a high percentage failed to complete or failed to get a degree at the end of their time, it might be better to increase the minimum entry requirement.

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