Correspondence

Ofqual response to consultations on LLE and HE reform

Published 12 May 2022

Applies to England

The government’s consultations on Higher Education Reform and the Lifelong Loan Entitlement (LLE) set out its ambition for a significant increase in flexibility and choice for students engaging in learning at levels 4 to 6. At Ofqual, students of all ages and apprentices are our compass – their collective interests are at the heart of our regulation. Accordingly, Ofqual welcomes the government’s desire to increase opportunities for learning at levels 4 to 6. This consultation response focuses on modularity and credit transfer as these design features directly affect our statutory objectives in relation to qualification standards, public confidence, and awareness of regulated qualifications.

Ofqual regulates over 2,000 qualifications at levels 4 to 6, and our regulatory framework already permits modularity and credit-accumulation-and-transfer. An awarding organisation can assign credit to the different modules in a qualification, which a student can then take individually over time. In addition, an awarding organisation may choose to offer qualifications of different sizes, based on a common group of modules, that can be taken flexibly and have individual certification and therefore currency. Furthermore, the scope for ‘recognition of prior learning’ within our framework means an awarding organisation can already choose to use credit from a qualification offered by a different awarding organisation towards its own qualification.

In looking to protect the interests of students and apprentices, and indeed of all individuals and organisations that rely on qualifications, it is crucial that a qualification genuinely demonstrates its holder has the knowledge and skills which that qualification assesses. Ofqual supports the government’s preference to avoid relying on a ‘top-down’ framework to achieve its ambition, as our experience from the use of such frameworks (the Qualifications and Credit Framework (QCF) for example), is that an overly detailed approach which prescribes how awarding organisations must design modules and qualifications can undermine – and sometimes even prevent – the ability to design and award high-quality qualifications.

In the context of the Skills and Post-16 Education Act 2022, Ofqual is committed to engaging with the Institute for Apprenticeships and Technical Education, and others, in formulating any ‘common modular structure’, to ensure qualifications developed using such modules can be effectively regulated. Such a structure would need to prioritise the design of high-quality qualifications that reliably demonstrate knowledge and skills, so that in exercising a greater degree of choice and flexibility, learners are achieving qualifications that will help them secure their goals and reflect the needs of the economy. Ofqual also recognises that, in securing the government’s aims in this area, while the regulated qualifications system has an important role to play, it must cohere effectively with other parts of the higher education system, such as funding and inspection of training. Ofqual are committed to engaging with other stakeholders to that end.

As part of this response, Ofqual’s review of the QCF, our consultation on removing the QCF, and related decisions document following that consultation are appended. Many of the detailed findings across those documents are relevant to objectives around modularity, and credit-accumulation-and-transfer, and the significant challenges to designing high-quality qualifications where the design of such arrangements is too prescriptive.

Because of the significant technical challenges associated with modularity and credit transfer, detailed work will need to be undertaken to ensure that a high quality bar is retained for all qualifications, and where trade-offs are proposed to ensure that modularity and credit transfer can work as intended these do not compromise qualification quality and integrity. As the qualifications regulator we will bring our expertise to bear as we work with the Department and others in working through these critical aspects of design detail.

Ofqual advise, therefore, that it engages with the Department and the Institute for Apprenticeships and Technical Education and others to achieve the policy aims outlined in the consultations in such a way that avoids the negative effects of a too prescriptive design framework, and secures the availability of high-quality provision at levels 4 to 6 that meets the needs of students, apprentices and others.