Our response to the Office for Students’ call for evidence on positive outcomes for modular study

The government is introducing the Lifelong Learning Entitlement (LLE) from 2025. This will enable learners to access loans for smaller chunks of study. As we’ve commented before, the LLE is a real opportunity for the higher education sector to widen opportunities and meet the country’s skills gaps. 

However, making the most of this opportunity will mean ensuring that the regulation in place is fit for purpose. We welcome this call for evidence to explore this more, particularly how the OfS will design condition B3 (student outcomes) for modular study. 

• We welcome the OfS’ approach to policy development, particularly the call for evidence before a more formal consultation is launched. Developing student outcome measures for modular study will be new territory for the OfS and higher education providers experiencing it. As the OfS develops its plans, it should assure the sector that for the first few years there will be a transition period of its regulatory approach to ensure it is proportionate and meets the aims as set out. 

• We agree with the OfS that the approach to regulation will need to change because of the LLE. However, the scope of these changes should not place additional burden on providers offering full-time level 6 study, which is likely to remain the dominant study path. 

• We support the exploration of completion measures for modular study, as if a learner starts a course, it’s right that they can expect to complete it. To understand the burden this may place on providers, the OfS should produce a burden impact assessment.  

• Understanding where students go after studying, whether that’s through further study or employment, is important. However, we know that progression is likely to be the most complex measure to implement. We want to work with the OfS to help get the balance right, so that regulation for modular study has the right backstops in place to protect quality, while also developing an approach that’s proportionate and enables growth.  

• There was a specific choice to connect eligibility for LLE funding to a parent course to support with quality assurance. Furthermore, when providers review the outcomes of a full course, they do so by examining data and concerns at the module level already. In isolation, this won’t be enough to provide regulatory assurance at the modular level. However, the OfS should explore where regulatory duplication can be reduced. 

• We think there’s value in considering how the reflective questions in the Higher Education Statistics Agency (HESA) graduate outcomes dataset could inform what successful study looks like for modular learners.