Thanks, Mike. I agree entirely that forging the rules will be a tough job. The question will be whether it can be done within the timeframe of the political opportunity.
It may end up falling into the category of policies that are good ideas, but just too complicated to deliver within the lifetime of any government (let alone a minister).
Given that I’m astonished (and impressed) that the Treasury let DfE make promises to fund billions of pounds of loans that will never be repaid in full (at the same time as arguing over a greater claw-back of student loans), the political road for LLE may be very rocky.

In my mind, I want to split the things that a provider might do and the regulations the DfE will need to write.

We have some models of open qualification frameworks – I’m thinking, say, of the Oxford Continuing Education Cert HE. This provides a framework for cognate work to be gathered in – the current rules need students to be aiming for a qualification and this gives a structure, with what the the Americans would recognised as distribution/concentration rules. As its all L4, it does need progression. If students are going to accumulate 360 credits in the LLE, then any qualification offered is going to need to match the qualifications framework . A bachelors degree will need the required amount of L6 – otherwise a student with 360 credits at L4 is just going to get three CertHEs.
That’s then where the government comes in. Given the stuff about outcomes, does it really want to loan money to take three CertHEs? Is it going to legislate for progression? Will it remove the ELQ rule? Will it allow credit that isn’t part of a degree? (that’s the only bit that’s currently in the Skills Bill). That would seem to mean only providers with DAP or programmes approved through validation/franchise can offer LLE approved courses. While a provider might be able to ‘control’ what a student studies – is the LLE going to allow concurrent study at different providers or on different courses? Developing the ELQ argument, does the government mind if I take an Introduction to Data Analysis module twice? Can I take it at two different providers? And, because you can always push these things to absurdity – what it I took such a module 20 times sequentially and what it if took it 20 times at the same time?

The LLE rules are going to be fascinating…