Submission by the Association of Colleges
(AoC) to the Tomlinson inquiry (QCA 24)
INTRODUCTION
The Association of Colleges (AoC) is the representative
body for further education colleges in England and Wales established
by the colleges themselves to provide a voice for further education
at national level. Some 98% of the 420 colleges in England and
Wales are members.
CONTEXT
1. The Association of Colleges wishes to
set its comments within the context of positive endorsement of
Curriculum 2000.
2. It believes that any remedial action,
taken to address issues relating predominantly to assessment and
the definition of standards, should not have a negative impact
on the very positive attributes the new curriculum offers learners—namely
greater flexibility, greater feedback and greater choice. It is
to these principles that the Association refers, when advocating
any curriculum reform.
3. The Association regrets the narrow focus
of the remit. It believes that for developments and improvements
to be effective at level three, the whole of that provision, and
not just AS and A Levels, needs to be taken into account.
4. In the colleges' view, there are far
more critical issues to be addressed relating to AVCEs, for example,
that appear to fall outside this remit. Less than half of sixteen
and seventeen year olds still in learning are actually studying
at A/AS level. The critical issues pertaining to a unitised approach
to the curriculum (an approach we strongly support) also apply
to AVCEs and BTEC Nationals.
5. The FE sector has been fully supportive
of Curriculum 2000, and is keen that those principles that underpin
the curriculum reform will not be diluted or lost in the outcomes
of the inquiry, particularly the unitised approach. Indeed, the
Association's approach throughout this inquiry is to seek to develop
the curriculum further to create greater flexibility and more
choice, rather than retrench. The FE sector accounts for a third
of all A/AS candidates in the 16-19 age group; nearly two thirds
of those taking VCEs/GNVQs; and the overwhelming majority of those
taking other qualifications.
6. It is fair to say that the FE sector
has gone further to implement the spirit, as well as the structure
of Curriculum 2000 than any other sector. This was recognised
in the evidence of the Chief Executive of OCR in his submission
to the select committee on October 28, in which he singled out
colleges for their thorough preparation for the implementation
of the new curriculum.
7. Colleges fully support the new curriculum
and approach as suiting the needs of the broad cohort of learners
that it accommodates—far the broadest range of learners
than any other sector. There are 498,000 full-time learners in
the 16-19 age group receiving their education in Further Education
colleges which is 93,000 more than in schools; a further 165,000
learners in the same age group study part time on FE colleges.
8. Further Education colleges, it should
also be remembered, as well as catering for the 50% of 16 year
old learners who are capable of progressing to an A Level programme
at level three, also cater for the 50% who are not, or who choose
not to study via these routes. It accommodates those who only
just qualify, through their GCSE scores, for A Level study as
well as those with very high level two achievements. It has also
gone the furthest in encouraging those taking vocationally based
programmes also to take an AS.
9. The Association would advise that it
is imperative that the interests of all these learners in the
Further Education sector are borne in mind; that the new approach
becomes more inclusive in providing a measure of access to level
three study—and thence to HE—that was not available
to them before. These learners will be critical in contributing
to this government's targets at levels three and for HE participation.
10. The Association wants all young people
to be served by a curriculum that is based on the development
of relevant skills and attributes that will equip them for active
engagement in the workforce and the community; that fosters lifelong
learning; and that is flexible enough to continue to meet their
needs as they re-skill and develop throughout their working lives.
The structure and design of A Levels, including
the weighting given to AS and A2
11. The Association would therefore not
support any measure that limited the current flexibility and choice
in the curriculum at level three. It would be concerned if the
first moves towards greater modularity were lost, for example
if the suggestion that a reduction in units or changes to examinations
specifications should predicate a return to a linear mode of curriculum
delivery. This would be a retrograde step.
12. On balance the Association would counsel
as little change as possible to the structure of the qualifications.
It would, however suggest that the de-coupling of the AS qualification
from A2 deserves serious consideration, to create two distinct
qualifications comprising three units of learning. However this
development could not be implemented in isolation—a similar
arrangement to create three unit qualifications would need to
be considered for vocational A Levels and for BTEC Nationals in
order to maintain the long-sought parity between the qualifications.
Many sector colleges are moving away from AVCEs in favour of the
new BTEC National qualifications because of the way AVCEs are
assessed. It is therefore important that this qualification is
also similarly adjusted.
13. One solution to address this which would
maintain one of AoC's fundamental principles for curriculum development—that
is, to ensure increased flexibility and equivalence in the advanced
level—would be to consider setting papers in AVCEs at two
levels, one equivalent to the standard expected in year one of
level three study, and one at that required at the end of year
two. This would maintain the freedom to deliver the units in a
variety of ways over two years, maintaining the desired flexibility.
14. We recommend that energies are similarly
concentrated on addressing the vexed issues of standards of the
awards, and the disparity in difficulty between the subjects.
As we reported to the QCA review of Mathematics criteria, no learners
will be persuaded to take a qualification that is perceived by
learners to be more difficult than others, when their primary
objective is to maximise their UCAS score.
15. We agree with others that the new qualifications
were implemented too quickly—and indeed advised a more measured
introduction at the time. The Association has warned QCA and the
department on countless occasions that rushed implementation,
before practitioners in schools and colleges have been provided
with learning materials and exemplar models by which they can
ensure they understand the standard required, can only bring a
new qualification into immediate disrepute. This, unfortunately,
has been the fate of AVCEs.
16. The precise duties of awarding bodies
to ensure that institutions are provided with this information
needs to be clarified and strengthened. Any new qualification,
and any alterations to existing qualifications should include
a mandatory lead in time, before they become operational, and
staged according to the level of change incorporated. We are pleased,
for example, to note that the new Modern Apprenticeship frameworks
are adopting this principle, having lobbied for this feature in
the implementation groups.
THE
RELATIONSHIP BETWEEN
THE TIMING
OF A2 ASSESSMENT
AND RESULTS
AND THE
APPLICATIONS AND
ADMISSIONS PROCESS
FOR HE
17. It must first be reiterated that the
period of assessment and examination takes up far too great a
proportion of the academic year. Teachers must be trusted to apply
the same level of expertise and professionalism to internal assessment
as these same individuals apply to their marking contracts with
the awarding bodies. Additionally, there is far too great a reliance
on paper tests and written examinations at the expense of methods
that measure the acquisition of the skills young people need for
employability.
18. Dates for examinations are set to suit
the convenience and requirements of the awarding bodies, and not
the young people—and the many adult learners—who sit
AS and A2 examinations. With one third of the academic year now
devoted to examinations, the richness of the teaching and learning
experience has been eroded.
19. Some radical thinking needs to happen,
to ensure that young people are provided with the teaching they
deserve, rather than fitting their learning around the bureaucratic
needs of awarding bodies and admissions tutors.
20. Things need to change to address some
unintended consequences of the freestanding AS levels. The Association
is picking up some evidence that universities are now prepared
to make offers to students based on AS results alone; this is
undermining the second year of study and the currency of the A2
qualification.
21. There is a strong case to suggest that
the time is now right for university application to be on the
strength of actual, rather than predicted achievement. A move
of all university terms beginning, as the OU and continental HE
institutions already do, in January rather than in September each
year, would facilitate this. (This would also, incidentally, facilitate
the enrolling of international learners to UK universities.)
22. A recent AoC survey of its members (Curriculum
2000 Survey, 2001) showed overwhelming support for the summer
examination window to be moved back in the academic year, rather
than forwards, so that the peak of the examination period was
at the end of June and the beginning of July.
23. Were a January start in HE institutions
ever to be achieved (and AoC does not underestimate the cultural
shift required of HE in order to contemplate such a radical departure),
then awarding bodies might find the recruitment of examiners to
be alleviated and the UCAS/admissions process simplified and transparent.
THE
NUMBER AND
VARIETY OF
A LEVEL SUBJECTS
AND OPTIONS
24. If AVCEs are considered to have parity
with A Levels, then the time has come to remove any distinction
in the title of the qualifications. However, this does not mean
that all level three qualifications should be examined in the
same way. This is one of the major criticisms the Association
has of the current qualifications (including Key Skills)—the
ideology is right, but in many cases, the examination is wrong.
25. Far more creative and relevant means
of assessment need to he devised—whilst maintaining standards
and rigour—to ensure learners' skills—both practical
and theoretical—are appropriately measured. This does not
necessarily mean a written examination.
26. The Association believes that alternative
assessment measures have already been developed and applied. What
may have been lacking in the past, however, is a sufficiently
robust verification system, and, yet again, insufficient preparation
of practitioners to establish the expected standards prior to
implementation.
27. Addressing the number of qualifications
on offer, Further Education colleges are well equipped to cope
with the range of subjects offered (though it should be pointed
out that the disadvantageous funding of the FE sector is causing
real difficulties in recruiting and retaining staff—many
of whom are migrating to the schools). It is aware that institutions
with a small sixth form may hold the view that the curriculum
offer is too large, based on the grounds that they do not have
the capability to deliver it, and that their cohort of learners
is too small to form viable groups.
28. We would strenuously resist any reduction
in choice, based on the view of institutions representing the
interests of only a small number of learners. The mechanisms and
the encouragement now exist to form partnerships with institutions
such as FE colleges, so that the broader curriculum and minority
subjects might be available to all learners, whether in a small
school sixth form or large college.
INSTITUTIONAL
ARCHITECTURE
29. As AoC pointed out in the QCA quinquennial
review, the relationship and tensions between the remits and responsibilities
of QCA, the awarding bodies and the DfES can be, from AoC's perspective,
problematical. Each is subject to the demands of the others, and
from the user's perspective, can lead to difficulties in determining
where decisions have been made, or policies devised, and where
responsibility rests. Given its position as guardian of standards,
it is clear to the Association that QCA needs to be able to provide
ministers with clear messages and advice—that by necessity
may sometimes be at variance with ministerial aspirations.
30. Whilst not expressing a preference for
QCA's accountability, AoC's advice is that the organisation must
be seen to operate independently, if it is to discharge its function
effectively.
31. We would advise that one approach that
would facilitate greater transparency would be the publication
of advice from QCA at the point at which it is given to ministers.
32. We also recommend a clarification of
QCA's remit. It currently has the role of being both a guardian
of standards and a developer of the curriculum. We have stated
in our response to the quinquennial review that this is not an
appropriate mixture of roles. QCA should cease to be an awarding
body but should maintain a proper regulatory function.
33. The Association believes it would be
helpful if it and other associations were consulted in the process
of setting parameters and producing guidelines relating to curriculum
development. It can call on a wealth 01 experience through its
close contact with its members and other providers with whom it
works.
34. As a guardian of standards, the relationship
between QCA and the awarding bodies needs clarification. More
needs to be done to ensure consistency of approach in the administering
and marking of examinations and to ensure that a proactive approach
is adopted early in any case where the awarding body wishes to
implement a significant shift in grade boundaries. We recommend
a named person at QCA becomes responsible for checking and approving
such a change, wherever an awarding body wishes to implement one.
35. Whilst the Association has already developed
good working links with QCA, we would advocate a much more clearly
defined channel of communication between QCA and organisations
such as our own.
36. AoC, for example, predicted very early
in the development of Curriculum 2000 the issues that needed to
be addressed, and provided evidence of the concerns of the sector
drawing on feedback from principals and the AoC surveys. This
is an independent resource, which could be usefully incorporated
into QCA's intelligence gathering, to inform its monitoring role.
37. It is a concern to our organisation
that QCA still appears to be largely school-centric, despite the
statistical evidence we have provided above that the majority
of learners in this age range receive their education in colleges.
Improved communications with AoC might go some way to address
this anomaly.
THE
ORGANISATION OF,
AND THE
RELATIONSHIP BETWEEN,
THE AWARDING
BODIES
38. As alluded to above, it is the Association's
view that some of the criticisms levelled at awarding bodies could
have been addressed or alleviated earlier, had more open communications
been established earlier. The Association is pleased to report
on a significant improvement in its communications with the awarding
bodies, through regular meetings and frequent communications,
which has allowed it to support the significant improvements the
boards are making, with many of AoC's suggestions beginning to
be adopted.
39. In support of this dialogue, the Association
has been able to draw on the two major Curriculum 2000 surveys
it has undertaken, and the three monitoring surveys relating to
examinations it has conducted since the start of Curriculum 2000,
all of which have provided authoritative and independent data
to support the awarding bodies' work.
40. AoC has also been working closely with
Edexcel as they seek to support the professional development of
examination officers through the introduction of a new qualification.
41. Although the justifiable frustration
of principals in the FE sector last year manifested itself in
the call on the part of some for a radical overhaul of awarding
bodies—for example by creating just one body—nevertheless
the Association feels that the competition and different character
of the awarding bodies, each serving different constituents of
users, is, on the whole, good for learners provides more choice,
specifications and models, which are more likely to meet the needs
of all.
42. We have observed that the competitive
position the awarding bodies find themselves in can lead to greater
creativity in devising new qualifications to meet the needs of
all learners, at a point when rationalisation of existing qualifications
might have left some learners very poorly served.
THE
PROCESS FOR
SETTING, MARKING
AND GRADING
OF A-LEVELS
43. The A-Level qualification bears the
burden of both trying to provide the ranking of students at the
same time as it demonstrates their level of attainment. Decisions
need to be taken at the highest level to determine what it is
we are measuring and the purpose of level three qualifications.
44. The unitised approach to assessment
has inevitably thrown into sharper relief the issues associated
with overall grades determination, given that a certain inexactitude
is necessarily built in to the assessment of each unit, an inexactitude
compounded as marks are aggregated to achieve a final mark. The
process by which grades are than determined can further compound
the issue and resulted in confusion in the minds of the press
and public this year.
45. The Association would recommend therefore
that the statistical method by which results are determined is
reviewed, to see how well it serves both those learners on the
"cusp" of one grade and another (where the compounding
of the inexactitudes might count unfairly against them) and those
learners in the majority one year, that might have a different
profile from the achievement of the majority the year before.
46. In term of standards, the Association
would advocate a standard for AS set appropriately for those at
the end of one year's study, and that the A2 standard should be
equivalent to that expected under the legacy A Levels.
PROMOTING
PUBLIC AND
PROFESSIONAL UNDERSTANDING
OF THE
A-LEVEL SYSTEM
47. We take issue with the narrowness of
focus of this question, which confines itself to the perception
of A-Levels. It is only when the whole curriculum—critically
AVCEs, BTEC Nationals and other vocational qualifications at level
three are as well understood by the public and employers as A-Levels,
that progress will be made in opening progression routes to a
wider cohort of learners.
48. To talk about the promotion of A-Levels
alone is divisive, and does not give the widening cohort of learners
(who tend to choose to learn in FE colleges and who tend to be
attracted to work related programmes) the credit they deserve.
This is of particular concern to the Association when related
to the perceptions of employers and HE who desperately need to
understand the content, skills acquisition and level of all qualifications.
49. Whilst it is of course vital to restore
any credibility in an examination where it has been lost (and
in our view the case for AVCEs in this regard is far more pressing),
we see this as a short-term imperative.
50. Much more critical long term is to establish
once and for all the currency and relevance of quahfications to
Higher Education admissions tutors and employers. There may now
need to be a consideration as to whether a voluntarist approach
is working, or whether qualifications with proven currency automatically
provide progression for those who want it.
51. The Association suggests therefore that
serious consideration should be given as to whether an entitlement
should exist to progress to degree level study, including Foundation
degrees, where a certain level of qualifications, or in future
an overarching diploma, has been achieved.
52. The Association holds the view that
the purpose of qualifications in general is being distorted in
the minds of the public—particularly parents—because
they are being used for purposes other than the promotion of the
interests of young people by preparing them for future employment
or further training.
53. Instead, results are being employed
as a means by which institutional performance is being assessed.
We refer to league tables. We believe that the crude way in which
examination results are being used as a so-called quality measure
does nothing to celebrate the achievement of the individual (to
achieve a D at A-Level might represent outstanding performance
in the case of a learner excluded from school, for example). This
form of reporting is a particularly problematical for inclusive
FE colleges, whose remit is to remedy the underachievement of
learners in compulsory schooling and provide a suitable learning
programme for those with the whole range of learning abilities,
prior achievement and aspirations.
The use of information and communication technology
in the A-Level assessment and awarding process
54. The Association would advocate that
thorough research is need before embarking on the extensive use
of on-line assessment. We identify some of the issues to be explored
in the following paragraphs.
55. We accept that there should be a move
towards to use of IT to support assessment, but would wish to
point up the potential limitations of this medium as being capable
of measuring skills. The screen should not replace the pen and
paper as a means by which learners are examined—this only
reinforces the limitations of the written examination.
56. The Association has long lobbied for
the relevance of a written examination to be investigated; this
investigation in our view should precede any development of screen-based
assessment.
57. The technology also may set up barriers
for the inclusive cohort of learners that the Association champions.
Even if the use of computers is confined to the more "paper-based"
subjects, traditionally examined in written examinations, nevertheless
this may prove to be discriminatory.
58. It could favour, for example, those
learners whose parents have provided them with a computer at home
and who are comfortable with the technology. As such, it again
favours the middle classes. It is likely that girls may do less
well than they do now, and it may provide insurmountable problems
for the less able, less co-ordinated learner.
59. The Association would advise that government
should guard against any development that could undermine the
achievement of the "first generation" of 16-19 year
olds who have stayed in education for the first time in their
families' history. This is a fragile and vulnerable cohort of
learners that FE has worked hard to engage and inspire. These
learners are likely, however, to withdraw wherever the hurdles
they are asked to face are too large. Many do not yet have confidence
in, or competence with, Information Technology at present.
60. However, the Association is clear of
the benefits of the use of IT as a management device. The sector,
in its efforts to raise standards and improve retention and achievement
has led the education sector in using software to track, register
and monitor students' progress.
61. Similarly the electronic registration
of candidates for examinations has made the process more effective
and efficient.
62. The Association believes the time is
now right, and the technology available, to further streamline
the system and reduce the bureaucracy for institutions by introducing
a single standard registration form, by which all candidates could
be registered at a central "clearing house". Awarding
bodies could then convert the standard information supplied to
suit their own format and processes. We would also suggest a similar
process used for the reporting of results.
CONCLUSION
63. To summarise, the main recommendations
from the Association are:—
— any remedial action, taken to address
issues relating predominantly to assessment and the definition
of standards, should not have a negative impact on the very positive
attributes the new curriculum offers learners—namely greater
flexibility, greater feedback and greater choice.
— for developments and improvements
to be effective at level three, the whole of that provision, and
not just AS and A-Levels, needs to be taken into account.
— there are far more critical issues
to be addressed relating to AVCEs than A-Levels
— the sector is keen that those principles
that underpin the curriculum reform will not be diluted or lost
in the outcomes of the inquiry, particularly the unitised approach.
— it is imperative that the interests
of all learners in the Further Education sector are borne in mind;
that the new approach becomes more inclusive in providing a measure
of access to level three study.
— the Association wants all young people
to be served by a curriculum that is based on the development
of relevant skills and attributes that will equip them for active
engagement in the workforce and the community; that fosters lifelong
learning; and that is flexible enough to continue to meet their
needs as they re-skill and develop throughout their working lives.
— the Association would therefore not
support any measure that limited the current flexibility and choice
in the curriculum at level three.
— de-coupling of the AS qualification
from A2 deserves serious consideration, to create two distinct
qualifications comprising three units of learning.
— one solution would be to consider
setting papers in AVCEs at two levels, one equivalent to the standard
expected in year one of level three study, and one at that required
at the end of year two.
— energies need to be concentrated
on addressing the vexed issues of standards of the awards, and
the disparity in difficulty between the subjects.
— qualifications should not be introduced,
before practitioners in schools and colleges have been provided
with learning materials and exemplar models by which they can
ensure they understand the standard required.
— the precise duties of awarding bodies
to ensure that institutions are provided with this information
needs to be clarified and strengthened.
— the period of assessment and examination
takes up far too great a proportion of the academic year.
— one third of the academic year now
devoted to examinations, the richness of the teaching and learning
experience has been eroded.
— universities are now prepared to
make offers to students based on AS results alone; this is undermining
the second year of study and the currency of the A2 qualification.
— that the time is now right for university
application to be on the strength of actual, rather than predicted
achievement.
— a move of all university terms beginning,
as the OU and continental HE institutions already do, in January
rather than in September each year, would facilitate this.
— there is overwhelming support for
the summer examination window to be moved back in the academic
year.
— were a January start in HE institutions
ever to be achieved then awarding bodies might find the recruitment
of examiners to be alleviated and the UCAS/admissions process
simplified and transparent.
— the time has come to remove any distinction
in the title of the qualifications, but this does not mean that
all level three qualifications should be examined in the same
way
— far more creative and relevant means
of assessment need to be devised—whilst maintaining standards
and rigour- to ensure learners' skills—both practical and
theoretical are appropriately measured.
— Further Education colleges are well
equipped to cope with the range of subjects offered. We would
strenuously resist any reduction in choice, based on the view
of institutions representing the interests of only a small number
of learners.
— QCA needs to be able to provide ministers
with clear messages and advice that by necessity may sometimes
be at variance with ministerial aspirations.
— one approach that would facilitate
greater transparency would be the publication of advice from QCA
at the point at which it is given to ministers.
— it would be helpful if it and other
associations were consulted in the process of setting parameters
and producing guidelines relating to curriculum development.
— a named person at QCA becomes responsible
for checking and approving such a change, wherever an awarding
body wishes to implement one.
— we would advocate a much more clearly
defined channel of communication between QCA and organisations
such as our own.
— it is a concern to our organisation
that QCA still appears to be largely school centric. Improved
communications with AoC might go some way to address this anomaly.
— the Association feels that the competition
and different character of the awarding bodies, each serving different
constituents of users, is, on the whole, good for learners. It
provides more choice, specifications and models, which are more
likely to meet the needs of all.
— the A Level qualification bears the
burden of both trying to provide the ranking of students at the
same time as it demonstrates their level of attainment. Decisions
need to be taken at the highest level to determine what it is
we are measuring and the purpose of level three qualifications.
— the Association would recommend therefore
that the statistical method by which results are determined is
reviewed
— in term of standards, the Association
would advocate a standard for AS set appropriately for those at
the end of one year's study, and that the A2 standard should be
equivalent to that expected under the legacy A Levels.
— it is only when the whole curriculum—critically
AVCEs, BTEC Nationals and other vocational qualifications at level
three are as well understood by the public and employers as A-Levels,
that progress will be made in opening progression routes to a
wider cohort of learners.
— to talk about the promotion of A-Levels
alone is divisive, and does not give the widening cohort of learners
the credit they deserve.
— much more critical long term is to
establish once and for all the currency and relevance of qualifications
to Higher Education admissions tutors and employers.
— serious consideration should be given
as to whether an entitlement should exist to progress to degree
level study,
— the purpose of qualifications in
general is being distorted in the minds of the public—particularly
parents—because they are being used for purposes other than
the promotion of the interests of young people by preparing them
for future employment or further training.
— results are being employed as a means
by which institutional performance is being assessed. We refer
to league tables.
— the Association would advocate that
thorough research is need before embarking on the extensive use
of on-line assessment.
— the Association is clear of the benefits
of the use of IT as a management device.
— the time is now right, and the technology
available, to further streamline the system and reduce the bureaucracy
for institutions by introducing a single standard registration
form, by which all candidates could be registered at a central
"clearing house".
October 2002
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