By Simon Ashworth
March was a busy month for the government’s new and ambitious Lifelong Loan Entitlement (LLE).
The aim of the LLE is to support Level 4-6 upskilling and reskilling in the context of a single system of Level 4-6 further and higher education.
DfE responded to the public consultation on the LLE and the Lifelong Learning (Higher Education Fee Limits) Bill started working its way through Parliament.
Lifelong Loan Entitlement consultation
In terms of the response to the consultation, DfE has agreed to end the equivalent and lower qualification (ELQ) rule. This will allow adults with a Level 4-6 to be eligible for fee-loans to study a subsequent Level 4-6.
At the same time, DfE has confirmed that maintenance loans and targeted maintenance grants will be extended to full-time, part-time and modular courses upskilling at Level 4-6 and, critically, reskilling at Level 4-6 especially through part-time and modular study.
Each of these reforms is extremely welcome.
A single Level 4-6 funding system
Underpinning the LLE is the creation of a single system of Level 4-6 education.
It will bring together Level 4-6 courses funded through the Advanced Learner Loan (c£20m) and full-time and part-time Level 4-6 higher education funded through Student Loans (c£10bn).
There are a significant number of Independent Training Providers who currently deliver Level 4-6 Advanced Learner Loan provision. The introduction of the LLE will clearly impact on them.
A third recognition route
For ITPs, it was positive to see that the DfE had taken on board our concerns and those of the Office for Students (OfS). The OfS will regulate LLE-funded provision.
If the LLE is to be successful, there needs to be a rich tapestry of further education colleges, higher education institutes and independent training providers.
AELP is pleased that the OfS will be consulting later this year on a new third recognition route for upskilling and reskilling at Level 4-6.
A personal learning account
The LLE will be worth £37,000. This is equivalent to four years of full-time higher education at Level 6, assuming the current fee limit of £9,250 per year.
Each adult aged 18 and over who is eligible for the LLE will be able to manage their entitlement through a personal account.
More details are expected from DfE later in the Autumn.
ITPs have a wealth of experience of working with economic agents who have an individual account. The apprenticeship funding system in England is devolved to each employer – levy-payer and non-levy payer – via a digital account. Adult basic skills funding was also devolved through Individual Learning Accounts under the last Labour government.
AELP looks forward to engaging with DfE and the Student Loan Company on the development of personal accounts in the months ahead.
Lifelong Learning (Higher Education Fees Limit) Bill
The Lifelong Learning (Higher Education Fees Limit) Bill centres on introducing a credit-based framework alongside a more modularised approach for the delivery of Level 4-6 funded through the LLE.
Substitution of employers funding Level 4-5 training to employees
AELP was invited to give evidence on the bill to the Public Bill Committee. One of the themes from that evidence session was around perceived employer behaviour.
Some MPs were concerned that employers would look to transfer responsibility for staff upskilling and reskilling at levels 4 and 5 to the employee.
This concern omits the fact that, for Level 4-5 courses to be funded through the LLE, employees must take out a fee-loan. In these circumstances employers would be in danger of coercing employees to take out a fee-loan in their own name.
The likelihood of this risk crystallising is low, but even so, the idea of employers forcing their employees to take out any kind of loan to fund their training is extremely unpalatable regardless of whether it is a scheme backed by the government or not.
On the other hand, if the risk is perceived as real it would be relatively easy to negate. Either a clause could be inserted into the bill making it explicitly illegal or, as is the case with apprenticeships, rules which would restrict such behaviour could be included.
The LLE is a learner-led reform
It is critical though not to lose sight of the fact that the LLE is ultimately a learner-led reform.
The aim is to assist adults – employees, self-employed and the unemployed – to achieve Level 4-6 qualifications which enables them to get better paid jobs and change careers.
30 Credits is a large amount of learning
At present, the minimum number of credits eligible for funding under the LLE is 30. It is widely recognised that a credit is equal to 10 notional learning hours, so this means 30 credits is around 300 hours of learning.
By comparison, the minimum number of hours for off-the-job training each year under an apprenticeship is 278.
We also know that the average number of training days received by each trainee funded by employers is 6, which (assuming 6 hours training per day) is equivalent to 36 hours of training per year.
The bill does not define a credit. But what we can say is that if eligibility to access fee-loans as part of the LLE is restricted to Level 4-6 provision of at least 300 hours per year, this is a large amount of learning by any standard.
Helping employers to give time off for study
Employers do not fund Level 4-6 courses as part of the LLE. Employees do through fee-loans.
Where employers will need to help employees upskill and reskill at Level 4-6, is through time off for study. Bearing in mind that 300 hours is a large amount of working time for employers, the government should consider tax breaks – such as zero-rated employer national insurance contributions – to incentivise firms to give time off for study.
Simon Ashworth is Director of Policy at AELP