MillionPlus warns government against minimum entry requirements

A mission group of universities has warned that minimum entry requirements would create a distinction between post-18 courses, perhaps to the detriment of technical routes

A group of post-’92 universities has argued that the government must not impose minimum entry requirements for student finance in England if it is “to make a success” of the Lifelong Learning Entitlement (LLE). 

Earlier this year, the government launched three consultations that affect universities: on the LLE, higher education reform and the UK research assessment. All three close today – and all week, university mission groups have registered their views.

MillionPlus – which represents 23 universities, including 17 in England where most of the consultation proposals would apply – said the LLE has “potential to be a transformative” but labelled minimum entry requirements a “key barrier“. 

“A key part of the target market for the LLE is those looking to re-skill and up-skill. By definition, re-skilling often entails training yourself in a new area, that can be at the same or even at a lower educational level than is held by the individual,” MillionPlus argued. 

Places should be assigned based on “the benefit” to the learner and society, “rather than a fixation on what level of education people have previously taken”, it continued.

MillionPlus warned that minimum entry requirements would “perversely” make degrees an “even more attractive proposition” to students and employers, as it would infer that further education and apprenticeships have “lesser quality and status”.

The organisation’s chief executive said that the size of consultation document suggests the government has yet to resolve how to make the LLE workable.

The number of questions within the LLE consultation demonstrates the level of complexity still to be resolved in delivering a modular funding successfully
– Rachel Hewitt, MillionPlus

MillionPlus said improved information, advice and guidance was crucial if learners were to access and benefit from the LLE system. This need has also been highlighted by the University Alliance (UA) and Universities UK (UUK) this week, with the former advocating regional education hubs to offer outreach and guidance to would-be students. 

MillionPlus urged refrain from introducing new regulations, which would, it said, “simply add more burden for providers which will make the whole system less dynamic and ultimately inhibit progress”. In particular, it said the Office for Students should consider new metrics for monitoring quality in higher education to reflect a more diverse student body. 

The mission group said it was developing a credit transfer system so students can complete modules with multiple providers and stack their credits into qualifications or certificates, like a degree. It argues that, ultimately, universities should decide their own approach to transferability through pilot schemes – rather than moulding to fit one nationally-set standard. This signals a slight difference of opinion to UA, which supports using the Quality Assurance Agency’s credit framework as the national standard. 

Sweeping higher education reform

The central proposal of the higher education reform consultation is student number controls in England, a move MillionPlus vehemently oppose, citing “significant logistical challenges”, such as how and where to impose caps and what data could judiciously support decision-making.

The mission group warned: “It is not clear from this consultation what the purpose of such a policy would be.” 

If used to reduce students, said MillionPlus, “then at both a principled level, and at a practical level, it would be a mistake and run counter to what has been the government’s stated overall approach to higher education for the past decade.

“If it is to save money, then in order to achieve its objective it would need to be set at a level that would have a real impact on student numbers, with a clear consequential impact on widening access, and therefore the thrust of the levelling up agenda.”

Other proposals and recommendations: 

  • MillionPlus supports including foundation year degrees in the LLE – but not PGCEs and integrated masters. 
  • The OfS’s B3 regulation conditions would be “inappropriate” in an LLE system and new metrics should be found. 
  • Offering more level 4 and 5 courses will cost and although MillionPlus accepts it might not necessarily justify an increase in fees, it warned that “if a strong alternative to degrees is the government’s ambition, then it would be incredibly hard to achieve this with ever diminishing resources”. 
  • An alternative to the Research Excellence Framework (REF) must be found. The current form of assessment criteria “penalise[s] universities with an emerging and developing research environment”, it claimed. An alternative should recognise “quality research in different forms” and encourage more research collaboration between universities.
  • Greater weight should be given to the geographical location of universities when scoring research output to encourage levelling-up. 

Rachel Hewitt, chief executive of MillionPlus, said: “The policies under consideration in these consultations have profound and far-reaching implications for the higher education landscape in England.

“The LLE has the potential to be transformative, driving growth in areas that have been in decline, such as mature learners. However the number of questions within the LLE consultation demonstrates the level of complexity still to be resolved in delivering a modular funding successfully. As highlighted in our consultation response, MillionPlus is keen to work with government to make the LLE a success for learners and universities.

“MillionPlus has made repeated calls for the way research is funded to be made more equitable, so the opportunity to feed in about how the system could better reflect the diverse research landscape across the sector and avoid widening sector inequalities has been welcome. 

“MillionPlus remains fundamentally opposed to minimum entry requirements, which are against the core principles of inclusion, aspiration and the power of education. Universities are best placed to make a determination as to the suitability of each candidate on their own merits. On a purely practical level, minimum requirements are likely to be unworkable, due to the number of exemptions that would need to be taken into account, for example for students with special educational needs.”


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