Recommendations & Conclusions
17 items
3
Recommendation
Twenty-Eighth Report - Student loans is…
Accepted
The current regulatory system does not ensure sufficient oversight over franchised providers. OfS publishes conditions that registered providers must meet, and continue to meet. These are designed to protect students, assure quality, and ensure 6 Student loans issued to those studying at franchised higher education providers good governance. But only …
Government response. The government will consult on proposals to strengthen oversight of partnership delivery in higher education, setting out these proposals by January 2025, and will develop options for legislative change if required.
HM Treasury
4
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
DfE, OfS and SLC recognise they have a shared responsibility to tackle fraud and abuse of student funding although this is not yet fully embedded in their ways of working. In our July 2023report on tackling fraud and corruption across government, we concluded that tackling fraud cannot be left to …
Government response. The government states that a data sharing protocol and a joint incident response plan are now in place between DfE, OfS, and SLC, detailing existing collaboration on risk management and reporting, and confirming OfS has a strategic risk on its …
HM Treasury
5
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
Despite the complex regulatory system, roles and responsibilities for fraud prevention, detection and intervention are undefined. The system for paying loan monies and overseeing providers is complicated, involving multiple bodies. The Government Internal Audit Agency (GIAA) and C&AG both found that there were gaps between DfE, OfS and SLC responsibilities, …
Government response. The government confirms that DfE, OfS, and SLC have agreed a joint Incident Response plan which clearly sets out the roles and responsibilities of each organization for identifying and addressing providers of concern.
HM Treasury
6
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
Although SLC uses data on attendance to show student’s course engagement, and therefore pay loans, there remains no agreed definition of what constitutes attendance or engagement. SLC requires providers to confirm that students are attending their courses before it will make tuition fee and maintenance payments. However, DfE, SLC, OfS …
Government response. The government published guidance on attendance management on the Student Loans Company website in May 2024, clarifying expectations for student attendance and engagement after extensive stakeholder engagement, and will take action if providers have weak approaches.
HM Treasury
1
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
On the basis of a report by the Comptroller and Auditor General, we took evidence from the Department for Education (DfE), Office for Students (OfS) and Student Loans Company (SLC) on student loans issued to those studying at franchised higher education providers.1
Government response. The government states that the OfS intends to publish student outcome indicators for a pilot group of lead providers and their delivery partners in 2024, with full publication for all partnerships expected during 2025.
HM Treasury
7
Recommendation
Twenty-Eighth Report - Student loans is…
Accepted
OfS publishes information on a registered provider’s performance that shows whether students have completed their course and progressed into work or further study. OfS publishes information for each lead provider and any registered franchised provider. Around two-thirds of franchised providers are not registered with OfS. While lead providers give OfS …
Government response. The OfS intends to share, in autumn 2024, student outcomes indicators with each lead provider that show the performance for each of its delivery partners. The OfS intends to publish student outcome indicators for a pilot group of lead providers …
HM Treasury
8
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
OfS told us that, for full-time students doing first degree subjects, it would normally expect at least 80% of students to complete their course and progress to further study or professional employment. Across the higher education sector, around 90% of students complete and progress, compared to just over 80% at …
Government response. The OfS intends to share, in autumn 2024, student outcomes indicators with each lead provider that show the performance for each of its delivery partners and intends to publish student outcome indicators for a pilot group of lead providers and …
HM Treasury
10
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
Some providers use agents or offer financial incentives to recruit students, practices that are not regulated.20 DfE told us it is planning to look at the use of agents, focusing particularly on whether there is any mis-selling of courses from agents to individuals, such as promising individuals guarantees on to …
Government response. The government will ask the Office for Students (OfS) to consider requiring providers to publish details on the proportion of tuition fees they retain and for what purposes when the OfS next makes changes to ongoing conditions of registration, and …
HM Treasury
13
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
In June 2022, we reported that higher education providers face long-term, systemic, pressures on their financial sustainability and viability.30 We asked about the sector’s current financial sustainability. DfE referred to the most recent OfS report, published in May 2023, which concluded that the overall financial position of the sector is …
Government response. The OfS intends to publish an Insight brief that sets out the risks and benefits of franchise arrangements, with a focus on the expectations placed on lead providers for effective management and governance of partners, and will consider financial arrangements …
HM Treasury
18
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
Universities UK described how it is developing a new governance framework to support providers in identifying the ‘triggers’ (through data monitoring and/or observation) which can alert them to potentially unusual or suspect behaviour. It will set expectations that providers have robust policies and systems in place to monitor, record and …
Government response. Universities UK (UUK) published governance framework for lead providers to support senior leaders in universities to spot and manage risk in franchised partnerships.
HM Treasury
19
Recommendation
Twenty-Eighth Report - Student loans is…
Accepted
We asked why, considering that student loan payments are made based on attendance data, there is no guidance on what constitutes attendance.45 DfE noted that ‘effective’ course attendance and engagement will vary by course and institution. DfE pointed to, for example, Open University students for whom there would be very …
Government response. The department published on the Student Loans Company website (May 2024) guidance on attendance management, against which providers can be held to account in relation to the release of SLC tuition fee payments.
HM Treasury
22
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
The C&AG’s report noted that GIAA concluded that neither SLC nor OfS have a formal fraud enforcement role and highlighted the challenges in gaining assurance over the legitimacy of funding applications.57 DfE told us that it is looking at formal roles and responsibilities, including whether aspects needed to be strengthened …
Government response. The department has agreed a joint Incident Response plan between DfE, OfS and SLC for responding to cases where there is a potential risk to public funding which sets out the roles and responsibilities of each organisation.
HM Treasury
23
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
OfS told us that it has significantly stepped up its regulatory activity for certain providers that feature in the C&AG’s report. This includes additional independent audit to test whether lead provider’s internal controls work effectively in relation to franchise providers. OfS said it has also imposed additional mandatory reporting requirements …
Government response. A data sharing protocol among DfE, OfS and SLC, and a joint incident response plan, are now in place.
HM Treasury
24
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
SLC told us that one reason behind increases in the value of detected fraud was its investment in using data to detect issues.60 SLC uses a range of data, not just its own. To help with identifying individual-level fraud, it is now part of the National Economic Crime Centre, so …
Government response. The department and SLC already collaborate on setting risk appetite and on risk management arrangements.
HM Treasury
25
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
The C&AG’s report identified that a provider had raised concerns with OfS about a franchised provider in May 2022, but DfE was not informed of the issue at the time.62 We asked witnesses why DfE was not told. OfS said that, in looking back, this is clearly a learning case, …
Government response. A data sharing protocol among DfE, OfS and SLC, and a joint incident response plan, are now in place.
HM Treasury
26
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
DfE explained that, in response, it has established more detailed information sharing protocols. DfE, SLC and OfS meet regularly to share information earlier, including information which may not have been previously shared. DfE told us it also has an intelligence and data sharing group that meets frequently, focusing on individual …
Government response. A data sharing protocol among DfE, OfS and SLC, and a joint incident response plan, are now in place.
HM Treasury
27
Conclusion
Twenty-Eighth Report - Student loans is…
Accepted
DfE recognised the advantages in having transparency between the three bodies, which enables them to take a collective view across an issue.66 OfS noted that there are some legal constraints on how it can share information, so it needs to work within its legal parameters. However, it now has clear …
Government response. A data sharing protocol among DfE, OfS and SLC, and a joint incident response plan, are now in place.
HM Treasury