Memorandum submitted by the National Association
of Schoolmasters Union of Women Teachers (NASUWT)
EXECUTIVE SUMMARY
The Importance of a National Framework for Testing
and Assessment
The need to sustain and develop a shared set
of understandings about learning necessitates the maintenance
and development of a nationally managed and regulated system of
assessment. Such a system secures the common entitlement of all
learners to effective and meaningful assessment and accreditation
of their learning and ensures that Government policy on testing
and assessment complements other elements of national education
strategy.
WORKFORCE REMODELLING
AND ACTION
TO TACKLE
TEACHER WORKLOAD
The remodelling of the school workforce and
action to tackle teacher and headteacher workload are at the heart
of the Government's strategy to raise standards and to ensure
that all learners can gain access to the high-quality learning
experiences to which they are entitled. Approaches to assessment
that add to the workload and bureaucratic burdens of teachers
and headteachers and ascribe responsibilities to teachers that
do not make the best possible use of their professional skills,
talents and expertise will work to reduce the quality of pupils'
learning experiences and will undermine efforts to raise standards
of educational achievement.
THE IMPACT
ON TEACHING
AND LEARNING
OF THE
CURRENT HIGH-STAKES
TESTING AND
ASSESSMENT REGIME
In relation to the current arrangements for
end of Key Stage statutory assessment and testing, the Committee
will be aware from its previous inquiries in this area of the
ongoing debate about the implications of this system for teaching
and learning at Key Stages 1, 2 and 3. The NASUWT acknowledges
that much attention is focused on the apparent difficulties associated
with the continued use of centrally set and externally marked
tests at the end of Key Stages 2 and 3 and notes that the DfES
faces continued pressure from a significant number of stakeholders
and other agencies and organisations for the discontinuation of
tests and their replacement by a system of moderated teacher assessment.
The NASUWT reasserts to the Committee its longstanding
view that such views are based on an incomplete appreciation of
the broader context within which National Curriculum tests are
undertaken and the implications of this on the current system
for statutory end of key stage assessment. The NASUWT believes
that National Curriculum tests are, of themselves, generally unproblematic
in terms of their impact.
THE USE
OF PERFORMANCE
DATA TO
SUPPORT PUPIL
PROGRESS
It is essential that the use of performance
data to inform policy and practice is moderated by an understanding
of the context within which such data is generated and the extent
to which test data is able to capture the full range of educational
progress and development achieved by pupils.
APPROPRIATE USE
OF TEACHER
ASSESSMENT, ASSESSMENT
FOR LEARNING
AND COURSEWORK
School-level arrangements for formative assessment,
assessment for learning and coursework can become problematic
when schools feel under pressure to implement approaches that
are unnecessarily bureaucratic and time-consuming as a result
of a perceived need to demonstrate to Ofsted inspection teams
or other external auditors of school performance that practice
in relation to assessment is effective.
EFFECTIVE PUBLIC
ADMINISTRATION AND
MANAGEMENT OF
THE ASSESSMENT
AND TESTING
SYSTEM
The Government, in collaboration with the NASUWT
and other social partners, should undertake an assessment of the
extent to which current national-level organisational arrangements
for the management and administration of the testing and assessment
system, including the provision of general qualifications, secures
overall policy coherence and delivers effective use of finite
public resources.
INTRODUCTION
1. The NASUWT welcomes the opportunity to
submit evidence to the House of Commons Education and Skills Select
Committee Inquiry into assessment and testing.
2. The NASUWT is the largest union representing
teachers and headteachers throughout the UK.
3. The NASUWT's response sets out the Union's
perspective on the key issues identified by the Committee in the
terms of reference for the inquiry and highlights aspects of the
current assessment and testing regime that the NASUWT believes
needs to be reviewed in order to ensure that future policy in
this area builds upon existing good practice and addresses less
effective features of the present system.
THE IMPORTANCE
OF A
NATIONAL FRAMEWORK
FOR TESTING
AND ASSESSMENT
4. Any effective national system of testing
and assessment must secure three important objectives:
— Reliable—assessment information
and data must give an accurate indication of the level of skills,
knowledge and understanding attained by learners during a course
of study;
— Valid—an assessment system
must ensure that the nature of the learning subject to assessment
is readily identifiable from associated information and data;
and
— Comparable—assessment information
and data should allow comparisons to be made between different
levels and forms of learning.
5. The absence of any of these essential
elements of assessment would prejudice the effective and coherent
accreditation and recognition of learning on a system-wide basis.
The ability of learners, parents, employers, teachers and other
relevant stakeholders to interpret assessed learning using a shared
set of terms and descriptions of the type of learning undertaken
and the standards learners have attained, on both an individual
learner and aggregated basis, is essential if meaningful dialogue
and exchange about learning is to be made possible.
6. The need to sustain and develop a shared
set of understandings about learning necessitates the maintenance
and development of a nationally managed and regulated system of
assessment. Analysis of comparable education systems, both within
the United Kingdom and elsewhere, demonstrates that while features
of the assessment system may take different forms, the existence
of a system-wide approach to the formal recognition and accreditation
of learning is a common feature.
7. However, it is important to acknowledge
that a national framework for the assessment of learning also
secures other key policy objectives. Of particular importance
is the right of learners across the education system to have access
to a minimum set of entitlements in respect of the way in which
their learning will be assessed. In this respect, the ability
of the Government to set out the basis upon which these entitlements
will be delivered in practice is an important means by which equity
and consistency within the education system can continue to be
secured.
8. The legitimate rights and expectations
of learners in relation to their employment and lifelong learning
opportunities also underscore the importance of national frameworks
for the accreditation and recognition of learning. In an economic
and social context where the migration of labour between nation
states is of increasing significance and scale, it is essential
that effective means are in place to ensure the international
transportability of qualifications. The work being undertaken
by the European Commission on the European Qualifications Framework
depends critically on the existence of consistent national examination
and assessment systems against which qualifications originating
in other countries can be compared. The maintenance of an effective
national qualifications system therefore enables learners to access
their labour mobility rights as EU citizens and supports the economic
and social life of the UK by facilitating the inward migration
of qualified workers.
WORKFORCE REMODELLING
AND ACTION
TO TACKLE
TEACHER WORKLOAD
9. The ability of the Government to establish
and develop a national framework to recognise and accredit learning
has important implications for the effective implementation of
policies affecting the employment and professional status of teachers,
headteachers and other members of the wider school workforce.
10. The implications of the contractual
changes introduced by the National Agreement "Raising
Standards and Tackling Workload", and the wider workforce
remodelling agenda are particularly important in this respect.
The aim of the Department for Education and Skills (DfES), the
NASUWT and other social partners in taking forward these important
reforms is not only to ensure that effective action can be taken
to drive down teacher workload but also to ensure that work to
raise standards can be sustained through the creation of an environment
that actively supports the ability of teachers and headteachers
to concentrate on their core responsibilities for teaching and
learning and leading and managing teaching and learning.
11. The remodelling of the school workforce
is at the heart of the Government's strategy to raise standards
and to ensure that all learners can gain access to the high-quality
learning experiences to which they are entitled. If the assessment
system is to play an effective part in the achievement of the
aims of this strategy, it must operate in a way that is consistent
with the changes being introduced by the workforce remodelling
agenda. Approaches to assessment that add to the workload and
bureaucratic burdens of teachers and headteachers and ascribe
responsibilities to teachers that do not make the best possible
use of their professional skills, talents and expertise will work
to reduce the quality of the learning experience of pupils and
will undermine efforts to raise standards of educational achievement.
12. In this context, the existence of a
national framework for assessment and testing is essential as
it provides the means by which a necessarily diverse and complex
national education policy agenda can be taken forward coherently.
While the need for an appropriate level of local and school-level
flexibility in relation to the implementation of aspects of the
assessment system remains an important consideration, particularly
in respect of efforts to embed effective approaches to the personalisation
of learning, an overemphasis on local autonomy and control over
assessment at the expense of the ability of central Government
to manage and administer key elements of the national education
system, including assessment and testing priorities, risks undermining
the effective implementation of policies legitimately determined
at national level.
THE IMPACT
ON TEACHING
AND LEARNING
OF THE
CURRENT HIGH-STAKES
TESTING AND
ASSESSMENT REGIME
13. In relation to the current arrangements
for end of key stage statutory assessment and testing, the Committee
will be aware from its previous inquiries in this area of the
ongoing debate about the implications of this system for teaching
and learning at Key Stages 1, 2 and 3. The NASUWT acknowledges
that much attention is focused on the apparent difficulties associated
with the continued use of centrally set and externally marked
tests at the end of key stages 2 and 3 and notes that the DfES
faces continued pressure from a significant number of stakeholders
and other agencies and organisations for the discontinuation of
tests and their replacement by a system of moderated teacher assessment.
14. The NASUWT reasserts to the Committee
its longstanding view that such views are based on an incomplete
appreciation of the broader context within which National Curriculum
tests are undertaken and the implications of this on the current
system for statutory end of key stage assessment.
15. The NASUWT believes that National Curriculum
tests are, of themselves, generally unproblematic in terms of
their impact. National level testing and sampling is a well-established
feature of approaches to the assessment of the progress and attainment
of individual pupils and cohorts and is the basis upon which studies
such as those currently undertaken by the Organisation for Economic
Co-operation and Development's (OECD) PISA programme are based
and were also used by Her Majesty's Chief Inspector of Schools
to inform the work of the former Assessment and Performance Unit
in judging the overall effectiveness of the education system.
It should also be noted that the use of tests remains a well-established
and legitimate element of the assessment repertoire of teachers
in determining effective approaches to the assessment of pupils'
learning.
16. However, the purposes to which the performance
data generated by National Curriculum testing are put remain the
principal cause of the problems for teachers, headteachers and
learners created by the current statutory arrangements for assessing
pupil progress at the end of Key Stages 2 and 3. In particular,
the publication of tables of pupil performance, with their attendant
significant consequences for perceived failure in respect of pupil
outcomes, has led to the creation of a destructive and high-stakes
environment within which National Curriculum tests remain located.
While the publication of tables of school-level performance data
is intended to hold schools and teachers publicly accountable
for the attainment of pupils in the core subjects of the National
Curriculum, their practical effect is to contribute to a skewing
of the curriculum, generate unacceptable levels of pressure and
workload at school level and entrench a competitive rather than
collaborative culture between schools. They are also responsible
for many of the pressures that inhibit the ability of teachers
to exercise an appropriate level of professional discretion and
autonomy. Although this was recognised to an extent in Excellence
and Enjoyment, the Government's Green Paper on teaching and
learning in the primary sector, the reported experience of NASUWT
members working with pupils at Key Stage 3 suggests that performance
tables have a comparable impact in the secondary sector.
17. The use of tests to generate performance
tables has seriously affected the potential value of tests as
an educational tool and has given them a prominence that distorts
the real contribution they can make to pupils' learning. The Committee
is right to question to extent to which the apparent decline in
rates of pupils' progress between Years 6 and 7 is explained by
the high-stakes context within which pupil data for pupils at
the end of Key Stage 2 is generated. It is for this reason that
the NASUWT continues to have serious reservations about calls
to replace end of key stage testing with a system of externally
moderated teacher assessment. Proponents of this view often fail
to appreciate that many of the problems associated with testing
relate to the high-stakes environment within which end of key
stage assessment takes place. The NASUWT maintains that there
is a significant danger that such an approach would result only
in the replacement of one high-stakes assessment system with another
and generate significant increases in workload for teachers and
headteachers with no commensurate educational benefit. It is for
this reason the NASUWT undertook national action in 1994 at the
launch of the tests at Key Stage 2 to secure external marking
which the Dearing Review of the National Curriculum confirmed
should be the approach adopted to statutory end of Key Stage assessment
beyond Key Stage 1.
18. Experience of similar changes in Wales
is instructive in this respect. Following changes to assessment
arrangements in Wales, a survey of members of the NASUWT undertaken
in 2006 indicted that 72% of respondents in the primary sector
felt that these changes had lead to increases in teachers' working
hours and workload overall.
19. In this respect, the consequences of
the changes to the arrangements for statutory assessment at Key
Stage 1, introduced in 2004-05, are particularly instructive.
While the previous system of dual reporting of the results of
centrally set tasks and teacher assessment were associated with
higher levels of teacher workload than at Key Stages 2 and 3 as
a result of the lack of external marking arrangements, the move
to teacher assessment-only arrangements has placed significant
additional demands on teachers as a result of the increased emphasis
on the results of teacher assessment of pupils' work undertaken
during the course of the year. The NASUWT's survey of schools
involved in statutory assessment at Key Stage 1 found that over
60% of teachers had experienced an increase in workload as a result
of requirement to engage in more intensive moderation of pupils'
work as part of the revised arrangements. It is likely that workload
increases would be even more pronounced by the introduction of
comparable arrangements at Key Stages 2 and 3 given the relatively
higher stakes generated by the publication of performance tables
for pupils at ages 11 and 14.
20. It should be recognised that similar
difficulties are generated by the publication of tables of pupils'
performance in respect of general qualifications. While it is
inevitable that the pressures faced by pupils and teachers in
this respect will be influenced by the implications for the future
education and employment choices of candidates of the results
of general qualifications, the incorporation of GCSE, A-level
and equivalent qualifications into performance tables exacerbates
needlessly the stress and anxiety faced by pupils, teachers and
headteachers.
21. The NASUWT has no objection to an effective
and development-focused approach to school accountability. However,
the continued use of performance tables in England for this purpose
works to undermine rather than support the efforts of teachers,
headteachers and members of the wider school workforce in sustaining
rates of pupil progress. There is little evidence that performance
tables have contributed to raising standards of attainment. A
growing number of international studies show that other comparable
education systems, including those in Wales, Scotland and Northern
Ireland, have reached and maintained high educational standards
without use of the performance tables. The NASUWT believes it
essential that the DfES, in collaboration with the NASUWT and
other social partners, commence work to examine effective and
viable alternative approaches to school accountability and that
an investigation of the operation of such systems in other education
systems would be an effective basis upon which the development
of a more progressive and supportive system of accountability
and school improvement could be based.
22. However, the NASUWT recognises that
positive reforms to the current testing and assessment regime
are being examined. Most significantly, in response to the themes
set out in the Report of the Teaching and Learning in 2020 Review
Group, which sought to identify effective approaches to the personalisation
of learning, the Government has set out its intention as part
of its Making Good Progress proposals to trial approaches
to National Curriculum testing where pupils are entered for assessment
on the basis of teachers' professional judgements about their
rate of progress rather than their chronological age.
23. The commitment of the Government to
retain external marking as a central element of reformed testing
arrangements and to give greater emphasis to the skills and expertise
of teachers in national testing arrangements is welcome and highlights
other opportunities for reform. In particular, the NASUWT contends
that the division of the National Curriculum into fixed key stages
to mark points at the end of Years 6 and 9 at which pupils' test
results are reported in performance tables contributes significantly
to inconsistency across the National Curriculum as a whole. In
light of the proposals to pilot testing on the basis of pupils'
stage of development rather than chronological age, there is a
case for examining the potential advantages of removing key stages
from the National Curriculum and investigating the extent to which
this would allow for the development of more consistent and coherent
approaches to the assessment of pupil progress.
THE USE
OF PERFORMANCE
DATA TO
SUPPORT PUPIL
PROGRESS
24. Notwithstanding the NASUWT's concerns
about the context within which National Curriculum assessment
is undertaken, the Union is not opposed to the use of national
tests as a means of providing data in respect of pupil performance.
The data provided by such tests can yield valuable evidence to
inform the development of national education policy and can act
as a powerful tool to support the work of teachers and headteachers
in meeting pupils' learning needs.
25. Nevertheless, it is essential that the
use of performance data to inform policy and practice is moderated
by an understanding of the context within which such data is generated
and the extent to which test data is able to capture the full
range of educational progress and development achieved by pupils.
26. For this reason, the NASUWT continues
to have concerns about potential overemphasis on performance data
in analyses of pupil progress where insufficient account is taken
of the impact of the school accountability regime on the context
within which such data is generated. This feature of end of statutory
National Curriculum assessment highlights the need for the DfES,
the NASUWT and other social partners to develop a shared understanding
of the potential impact of the school accountability system on
Key Stage 2 and 3 performance data. The NASUWT takes the view
that it would be timely to use the opportunity created by the
Making Good Progress pilots to select a relatively small
number of schools where National Curriculum testing would be carried
out in line with arrangements in other pilot schools but where
the results of the tests would not be reported in DfES performance
tables. This would provide an opportunity to examine the impact
of aspects of the school accountability regime on the approaches
adopted by schools to National Curriculum assessment and the effects
of the accountability regime on support for pupil progress.
27. The NASUWT recognises the concerns expressed
by the Government and other stakeholders about the rates of progress
of specific groups of pupils, particularly in respect of pupils
with special educational needs, in receipt of free school meals
or with patterns of poor attendance. However, the Union has reservations
about the Government's proposed use of existing performance data
to establish expectations in respect of acceptable rates of pupil
progress as part of its Making Good Progress proposals.
In particular, the expectation that pupils should be able to demonstrate
progress of least two National Curriculum levels within each key
stage is based on an assumption that the rate of progress required
to move between levels is consistent across the National Curriculum
as a whole and that level descriptors in the National Curriculum
are consistent between different key stages.
28. There are important and longstanding
concerns about the credibility of this assumption in the light
of teachers' experience of assessing pupils in Key Stages 2 and
3. While these concerns do not undermine the importance of the
emphasis in Making Good Progress that work must continue
to ensure that all pupils can reach the standards of which they
are capable, they serve to highlight the importance of exploring
approaches to the development of effective progression measures
that avoid the potential difficulties associated with the use
of National Curriculum level descriptors for this purpose.
29. In light of the increased levels of
interest in the use of performance data, generated to a large
extent by the proposals set out in Making Good Progress,
to support the work of schools and local authorities in continuing
to work to raise standards, it would be timely for the Government,
in collaboration with the NASUWT and other social partners, to
examine in more detail the ways in which data can be used effectively
and in an appropriate context.
EFFECTIVE USE
OF TEACHER
ASSESSMENT, ASSESSMENT
FOR LEARNING
AND COURSEWORK
30. The NASUWT shares the view of the Government,
set out most recently in its Making Good Progress proposals,
that formative assessment is an integral feature of effective
teaching practice. Formative assessment and assessment for learning
exemplify the benefits for children of teachers being given the
scope to make appropriate use of their professional judgement
to shape approaches to curriculum content and assessment to meet
learning needs.
31. However, school-level arrangements for
formative assessment can become problematic when schools feel
under pressure to implement assessment for learning in ways that
are unnecessarily bureaucratic and time consuming as a result
of a perceived need to demonstrate to Ofsted inspection teams
or other external auditors of school performance that effective
approaches to formative assessment have been put in place. Assessment
for learning conducted in this way is of limited use to parents
or pupils in identifying and working towards future learning goals
and distracts teachers from activities directly related to supporting
pupils to make progress.
32. The NASUWT believes that the pilots
of the Making Good Progress proposals provide an opportunity
for the DfES to work with the NASUWT and other social partners
to develop approaches to assessment for learning that do not lead
to inappropriate burdens being placed on teachers but which serve
professional assessment needs and support the work of teachers
in engaging pupils more effectively in evaluating their own progress
and areas for future development.
33. Teacher assessment also plays a significant
role in the general qualifications system in respect of coursework
requirements in subject specifications. The NASUWT believes that
assessment procedures for all general qualifications should be
designed so that candidates' learning can be assessed in a valid,
reliable and manageable way. An essential feature of effective
assessment systems in this respect is the extent to which they
minimise bureaucracy and workload for teachers, students and other
members of the school and college workforce, and candidates.
34. The NASUWT remains concerned that the
way in which coursework is used to assess learning in many GCSE
and AS/A-level specifications fails to meet these key criteria.
This view is also reflected in the findings of the Qualification
and Curriculum Authority's (QCA) review of GCE and GCSE coursework
published in November 2005.
35. For GCSE examinations in particular,
the weighting of coursework, which is not lower than 20% in any
of the specifications of the 10 most popular subjects, has placed
an emphasis on coursework that is problematic in many key respects.
While the general qualifications system must assess learning in
a way that is valid, reliable and comparable, the NASUWT agrees
with the QCA review's finding that the pressures on teachers to
ensure that these objectives are met in relation to coursework
are significant.
36. The difficulties associated with plagiarism
highlighted by the QCA review are a particular cause for concern
in this respect. The confidence of teachers, candidates, employers
and higher and further education institutions in coursework as
an effective and reliable method of assessment is undermined by
the considerable problems that plagiarism creates. The NASUWT
is concerned that attempts to tackle plagiarism through the adoption
of increasingly elaborate and time-consuming anti-plagiarism systems
will not only add to the bureaucratic burdens on school and college
staff but will also fail to resolve concerns about the fitness
for purpose of coursework as an assessment technique. Regardless
of the sophistication of the systems employed to counter plagiarism,
the fact that coursework is open to significant abuse by learners
and their parents suggests that, where possible, the use of coursework
should be limited to learning that cannot be assessed effectively
in any other way.
37. The analysis by the QCA review of the
areas of learning assessed by coursework in the most popular subjects
at GCSE demonstrates that coursework is being used inappropriately
as a method of assessment in an excessive number of specifications.
It is imperative that the QCA accepts the recommendation in the
review that the syllabus and specifications of all GCSE and GCE
examinations should be re-assessed to ensure that coursework is
only used where it can be shown to be the only effective method
of assessing learning and the NASUWT welcomes work that is ongoing
in this respect. However, the Union has increasing concerns that
where it is felt that coursework is no longer appropriate, it
is being replaced by "controlled assessments" that,
while resembling examinations in many respects, are not described
as such by awarding bodies. Not only do such assessments fail
to tackle workload burdens effectively, given the continuing requirement
on teachers to mark candidates' work, they also invite pressure
to be placed on teachers to be present during such assessments
where this would contradict their contractual right not to invigilate
examinations. It is essential that effective action is taken to
ensure that controlled assessments are only used where they are
necessary to ensure effective assessment and that it is made clear
that teachers are not required to be present during such assessments
for the purposes of invigilation.
38. Limiting the use of coursework to learning
that cannot be assessed by alternative means would not only serve
to support public confidence in the examinations system but would
also reduce the burdens that teachers and centres face as a result
of requirements associated with the assessment of coursework.
39. However, given the fact that an objective
review of the effectiveness of coursework would be almost certain
to recommend a reduction in its use, it is clear that in some
areas of learning in some subjects an element of coursework will
need to be retained where the ability of students to generate
pieces of work over an extended period needs to be assessed. It
is also clear that coursework can be of particular value for assessing
and accrediting the achievements of a significant number of pupils
with special educational needs. In reviewing the use of coursework
in general qualifications, it is important that the important
steps being taken to tackle workload and to remodel the work of
teachers so that they are more able to concentrate on their core
responsibilities for teaching and learning are recognised appropriately.
40. A clear example of concerns raised on
a consistent basis by members of the NASUWT in this respect, including
those involved in teaching GCSE mathematics, involves the requirement
in some awarding body specifications for teachers to annotate
candidates' work in unnecessary detail. The NASUWT is concerned
not only by the variation in practice between awarding bodies
in setting out requirements for annotation but also by the significant
impact that this has on teacher workload. It is difficult to sustain
the position that excessive annotation is necessary to ensure
the validity and reliability of coursework in circumstances where
some awarding bodies are able to accept a significantly lower
level of annotation than others.
41. The degree of variation in practice
between awarding bodies, exemplified by different requirements
in relation to the annotation of coursework, is unacceptable and
unnecessary. NASUWT believes that, as part of an overarching review
of coursework, it is necessary for more robust minimum standards
of practice to be established that ensure that all awarding bodies
implement specifications that contribute positively and consistently
to the embedding of remodelled approaches to professional practice
within schools and colleges.
42. Similar concerns about the use of teacher
assessment in relation to the extended project element of the
14-19 specialised Diplomas can also be identified. The proposed
degree of learner collaboration and topic scope inherent in the
extended project could present teachers with significant difficulties
in ensuring that individual candidiates' learning is assessed
in a way that is sufficiently valid, reliable and comparable.
It is likely that the moderation demands on teachers in particular
will be considerable and that, as a result, the benefits for learners
and teachers of the reforms to coursework requirements as part
of existing general qualifications could be undermined by bureaucratic
and workload-intensive arrangements that will be required to make
the extended project as proposed currently a viable and credible
element of the diplomas. As part of ongoing going work to review
the implementation of the reforms set out in the 14-19 White Paper,
the Government should work with the NASUWT and other social partners
to ensure that the extended project is embedded within the specialised
Diplomas in a way that will not undermine work to drive down teacher
and headteacher workload and school-level bureaucracy.
EFFECTIVE PUBLIC
ADMINISTRATION AND
MANAGEMENT OF
THE ASSESSMENT
AND TESTING
SYSTEM
43. At present, executive management and
administration of the curriculum and assessment system in England
is delegated by the Government to the QCA and the National Assessment
Agency (NAA) while general qualifications are provided currently
by three competing awarding bodies.
44. These arrangements contrast to a significant
extent with practice elsewhere in the United Kingdom. In Wales,
the Welsh Assembly Government (WAG) has taken back into central
control the curriculum and assessment responsibilities previously
devolved to the Qualifications, Curriculum and Assessment Authority
for Wales (ACCAC) in order to ensure greater coherence between
the development and execution of policy in these areas. In respect
of the role of awarding bodies, the system in Scotland operates
on the basis of the Scottish Qualifications Authority (SQA) acting
as the sole awarding body for Standard Grade and Higher Grade
qualifications.
45. These distinctions between policy and
practice in England and elsewhere in the United Kingdom invite
reflection on the extent to which current arrangements would benefit
from reform. The NASUWT believes that ensuring coherence in the
development and implementation of education policy and making
the most effective use possible of necessarily finite public resources
must be core elements of an effective national strategy for education.
In relation to the operation of the testing and assessment system,
it would be timely for the Government, in collaboration with the
NASUWT and other social partners, to consider the extent to which
the experience and expertise currently located within the QCA
and the awarding bodies might be best deployed within an organisational
context that brings together the development and execution of
policy under the direct authority of the DfES and examines possible
alternatives to the provision of general qualifications through
several competing awarding bodies in receipt of significant indirect
state subsidies.
46. The need to ensure that effective arrangements
are in place to secure the coherent and accountable management
and administration of testing and assessment policy is highlighted
by proposals set out by the Leitch Review of Skills in its report,
Prosperity for all in the Global Economy—World Class
Skills, to devolve significant decision making authority about
the range and nature of qualifications eligible for public funding
to the Sector Skills Councils (SSCs). It is entirely inconsistent
with the establishment and maintenance of a co-ordinated and effective
qualifications system for this essential function to be undertaken
by an unelected set of employer-dominated quangos with no meaningful
accountability to elected ministers, Parliament or other legitimate
stakeholders. It will be essential for the Government in its response
to the Leitch Report, due in the Summer of 2007, to set out clearly
that such an approach to qualifications policy has no place in
the development of coherent qualifications policy and to reject
this proposal.
June 2007
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