OfS call for evidence on positive outcomes for students studying on a modular basis

The Lifelong Loan Entitlement (LLE) – enabling student loan support for individual modules – will be introduced for the 2025-26 academic year. In preparation for this change the OfS asked the sector for evidence to inform its thinking on how to regulate the LLE. As long as it aligns with their general approach to regulation; so, how will the B3 outcomes measures of “continuation”, “completion”, and “progression” work for short courses? These become more tricky if the policy trajectory for students to study, train, retrain and upskill – possibly part-time and across multiple subjects and providers – throughout their lives rather than pursue complete qualifications comes to fruition.

The OfS has committed to a formal sector consultation in 2024, so the EPC has not submitted evidence at this stage, in consideration that:

  • Most modular provision at levels 4 to 6 (other than HTQs) would not move into LLE scope until 2027–28.
  • Demand for (and the possible impact of) LLE-style provision has not been well researched. We do not have any evidence of risks or opportunities to engineering as a result of funding at a modular level.
  • Our members did not share views with us on this subject yet. We are keen to get a better understanding of our members position on this during the Access and Admissions Forum in December in advance of the OfS consultation in 2024.

We are minded that:

  • In our response to the consultation on regulating student outcomes we highlighted that the measures of quality (student outcomes) proposed by OfS had not taken adequate consideration of the LLE.
  • The B3 positive outcomes are unsurprisingly inappropriate for the change in delivery of HE courses to modular provision. The OfS indicated in Jan 2022 that they would review their approach in light of LLE implementation; it is disappointing that OfS is now simply asks the sector how to fit modular qualifications into a regulatory framework ill-designed to accommodate them.
  • OfS’s approach is a concern in relation to regulation hierarchy – specifically for high-cost subjects; burden on providers; workload and impact on students; and – in engineering especially – the onward impact of international standing.
  • The alignment with accreditation is a complicating factor in engineering as there may be a disconnect between what qualification content might properly belong at different levels and what level of learning outcome might be expected. To comply with international standards, full-time accredited degree courses are unlikely to be broken up into stand-alone full-time modules, or to facilitate cross-provider attendance.
  • Engineering could potentially benefit from subject changeability through the adoption of try-before-you buy engineering modules at levels 4 and 5 as alternative routes to level 6 which would serve to introduce the subject which is largely not taught in schools. This could include study across more than one provider but mobility (of the part-time and mature students this is likely to appeal to) is likely to be seriously limited in most city and all rural areas.

If you would like to engage in this debate come to our Engineering Academics Network Events in November and December. At our Access and Admissions Forum webinar on 22nd November at 2pm we will hear from the Department for Education’s leads on LLE and T levels. This will tease out some of the considerations in preparation for a fully interactive delegate workshop on the topics at the in-person Forum at City University, London on 6th December. Opening with an auspicious panel on the admissions landscape, there we will delve into lifelong learning, T levels, and maths on entry before workshopping some key dilemmas. Free early bird tickets are available to EAN members until 19th November.



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