Creditworthy: how to fix the LLE

This blog was kindly authored by Mike Ratcliffe, Academic Registrar at City St George’s, University of London.

One of the issues on the new ministers’ desks is the Lifelong Learning Entitlement (LLE) in England.  The most obvious manifestation of this will be 30-credit level four, five and six modules that students can take and receive student loan company (SLC) support for tuition fees and maintenance loans for. (Although it is unlikely that maintenance loans will be available for distance learning.) It seems doubtful this will happen to the timescales previously announced, but that accentuates the need to leave some things alone. 

If you’ve studied or worked at most of the UK’s universities since the mid-1990s you’ve probably taken for granted the technical terms above. We have credit, levels and modules.  For most of us, there are modules that are added together to make courses. The modules have a size that is measured in credits or credit accumulation and transfer points (CATS). The sector is also now used to the national qualification framework (NQF) levels, four, five and six for undergraduate and seven for postgraduate.  

The Council for National Academic Awards (CNAA) took the lead in the late 1980s with a credit accumulation framework. This was promoted among the colleges and polytechnics. In a remarkable move, most of the autonomous universities moved to adopt credit as the organizing principle for courses, although the credit frameworks that developed in consortia remained voluntary.  That means we have significant variation in how we organise credit – particularly in the size and duration of modules. The biggest change envisaged with the LLE is that most providers move to credit-based funding.

Transfer

If credit accumulation is live and kicking as the building blocks of our degrees, then what about transfer? The CNAA framework accepted that transfer was mostly for ‘non-traditional’ students. Early negotiated pathways allowed for the import of credit, and Recognition of Prior Learning (RPL) continues to provide opportunities to build programmes. Where we have an established system of transfer, this tends to operate as a year-end mode, or a programme to programme mode.

The sub-degree quandary: Higher Nationals, DipHE & Foundation degrees

Historically the UK has had a range of qualifications which have been viewed as higher education but not leading to a degree. These sit in the national qualifications framework and students can take the credit into degrees. The sub-degree qualifications include HNC, CertHE,  HND, DipHE and foundation degrees. 

Often these qualifications have been in partnership groups, with a hub and spoke model with the sub-degree part being offered at a local provider and the ‘top-up’ at the university that has validated or franchised the courses. This was required with foundation degrees. There are some providers that have specialised in offering top-ups. For example, there’s an online top-up in performing arts run by a private provider. The International Year One (IYO) has also developed as an option, where a pathway provider teaches the first year of a degree, with the students transferring to the university campus for the remainder of the degree. 

In pure CATS systems, these transfers are similar to the very established system in the US where students might start at a community college and then transfer to a university.  These processes are best inside a state system that establishes the eligibility of transfer – if you complete the first two years you are guaranteed that transfer. English universities’ autonomy over admissions, coupled with our specialized curriculum, mitigates against a guaranteed transfer.  As a result, there is a huge array of agreements, some with progression between a foundation degree and a particular degree, others with articulation agreements and some with particular requirements (say setting a minimum average mark).

One of the policy goals when OfS was set up was to promote transfers – switching provider is a good consumer mechanism.  If it’s hard to switch bank, then switching higher education providers is really tough. Students are often reluctant to do a semester or year abroad (often another form of credit transfer) but moving provider completely has all sorts of complications.  We saw one ‘challenger institution’ try to offer a switcher bursary to try and deal with the practical complications of moving city, and therefore accommodation, at a semester break.  This hasn’t been much of a priority, but the LLE brings this back into focus.

Another policy goal was student protection – the Midlands Credit Compass facilitates transfer but there was also a suggestion it could be used if courses were closing.

What about quality?

The OfS has incorporated the qualifications framework within its work on quality. The credit framework which evolved from the CNAA through various voluntary credit consortia remains with the QAA. The simplest thing is for the Department for Education (DfE) to leave this alone. There’s a challenge in using the OfS outcomes-based system for the LLE – what does a positive outcome on a module look like? The new OfS business plan says ‘we intend to publish our response to the recent call for evidence’ (it closed in November 2023).

Awards in the qualifications framework can only be made by providers with degree-awarding powers (or via BTEC). The LLE can only be used for modules which are parts of awards in the qualifications framework. A simple extra step would be to confirm the only credit that the LLE will fund comes from one of those providers using the credit framework.  In turn, credit that’s been funded, would have an implicit quality mark.

There are issues with courses advertised using NQF levels ‘regulated by Ofqual’ but which will not attract LLE funding. In some cases, providers make claims that a level four or five qualification which doesn’t lead to an HND or DipHE could allow access to a top-up degree; that may be so, but they won’t attract LLE funding because its not part of a qualification. There are also continuing issues about franchising (see the recent NAO report). Outcomes-based quality assurance could be slow to pick up potential problems; if LLE fundable modules are franchised as stand-alone to learning providers or companies, then the OfS registered and DAP holding provider probably needs a more active quality assurance process to head off any issues. 

Conclusion

The LLE needs a credit accumulation and transfer system in order to work. Given the delays in agreeing important details, DfE and OfS should work with what the sector already has in place.