The administration of examinations for 15-19 year olds in England - Education Committee Contents

Part II: Changes to the system

3  Fundamental reform of the exam system

40. As stated in chapter one, the Secretary of State has said that the current exam system is "discredited" and needs "fundamental reform".[58] He was reported to be planning a reform of the exam system "in the new year", to believe that a single board was "the most compelling answer at the moment" and to favour "having one exam board for each subject to stop the 'race to the bottom' for GCSE and A level tests".[59] The Minister of State for Schools, Nick Gibb MP, told us that "we are not ruling anything out or in [...] we are considering all [...] options and discussing them within the Department at the moment".[60]

41. The question of whether there should be multiple boards, a single board or a franchised system is not new. The system has evolved from many examination boards.[61] The current structure of three English exam boards dates back to 1997, when the new Labour Government, acting upon the recommendations of the Dearing review of Qualifications for 16-19 year olds, announced "we believe that there should be three awarding bodies—each offering GCE A levels, GCSE and GNVQs".[62] The question has persisted, as concern about exam boards competing on standards has sharpened against a backdrop of grade inflation and increasing pressures on teachers from the accountability system. In 2010 the Walport report recommended that, instead of a move to a single exam board, "the planned stronger regulation by Ofqual, the new regulator, is given a chance" but warned that "if stronger regulation by Ofqual does not work as a means of strengthening the quality of examinations, we would recommend that there is a closer examination of whether it is appropriate to continue with competing awarding bodies".[63] In the same year the Sykes review of qualifications and assessments, when considering the merits of a national examination in English and maths at GCSE, administered from the centre, concluded that "any government would be tempted to use that examination to justify its own performance, and confidence in its reliability would suffer as a result. We believe a contract with a particular awarding body, awarded every three years, could be an alternative".[64]

Balance of evidence

42. As the reports cited above show, there are three models which are most commonly discussed for the administration of the exam system. These are: multiple competing exam boards (the structure currently operating in England), a single board (a national body responsible for setting, administering and grading examinations) and franchising by subject, whereby individual exam boards are contracted to run examinations in a particular subject, so, for example, AQA might run GCSE English, while OCR could be contracted to run A level Mathematics. Evidence to our inquiry has been split on which system would be best. In written evidence, most support was expressed for retaining a system of multiple boards (over 40%), with just under 20% of submissions favouring a single board and notably little support for a franchised system (under 5%), although this may be because a franchised system is not widely understood. Over a third of submissions did not express a preference for any particular system. However, there are other options for reform which emerged during our inquiry. These include changes to distinguish the setting of the syllabus from the running of exams.

43. Table 1 shows a summary of the arguments made for and against different models in written and oral evidence to the inquiry.

Table 1: Advantages and disadvantages of different administrative models
Advantages Disadvantages
Multiple exam boards Choice of syllabus for teachers (but not individual pupils)

Competition encourages innovation which has led to improvements in marking and logistics

Incentive for exam boards to raise the quality of service and support for schools

Risk of system failure is diffused

Schools can express dissatisfaction by moving to a different exam board

Exam fees may be more competitive

Independence from Government so reduced risk of political interference

Cross-subsidisation of small entry subjects

System can handle large numbers of exams with high entries

Risk of exam boards competing on content and grading standards

Commercial interests may be put before educational ones

Issue of lack of comparability of standards between exam boards

No incentive for exam boards to collaborate on syllabus development

Dilution of examiner expertise (issue especially for shortage subjects with high entries, e.g. maths and science)

Inefficiencies and duplication, with similar syllabuses offered by several boards in some subjects

Difficult for HE/learned bodies/employers to engage with several exam boards

Increased bureaucracy for schools to administer exams from different boards

Single exam board Simpler system

Eliminates risk of competition on content and grading standards between exam boards

Could still offer choice of syllabuses

System failure would affect all, so no-one more disadvantaged

Economies of scale (although some point out that consolidation of exam boards in 1990s did not bring this)

Easier for HE/learned bodies/employers to engage with single board

Concentration of examiner expertise

Avoids duplication of very similar syllabuses offered by different exam boards

Many jurisdictions operate single exam board model successfully

Reduced bureaucracy for schools administering exams

Cost, disruption and risks incurred by moving to new system

Heightened risk of high impact system failure

Higher risk of political interference

Lack of diversity of provision

Lack of incentive to maintain quality and innovate

Increased likelihood of errors as damage to reputation would no longer result in loss of market share

Likelihood of higher fees over time in absence of downward competitive pressure

Issue of comparability of standards over time and between subjects remains

Schools no longer able to express dissatisfaction by moving to another exam board

Franchised system (one exam board per subject) Many of advantages of single board, with risk spread

Eliminates issues of comparability between exam boards within a subject

Concentration of examiner expertise

Avoids duplication of very similar syllabuses offered by different exam boards

Would allow three main GCSE and A level exam boards in England to continue

Easier for HE/learned bodies/employers to engage

Cost, disruption and risks incurred by moving to new system

Choice of exam board is made by Government not schools

Threat to provision of small entry subjects unless formally agreed.

Potential problems with continuity after lifetime of contract

Incentive to maintain quality and innovate would need to be built into terms of contract

Issue of comparability of standards over time remains

Issue of comparability between subjects (and exam boards) remains

Examiner expertise would be concentrated in one place and lost elsewhere, potentially problematic when franchise is up for renewal and if contracts change

Heightened risks when contracts change , as illustrated by difficulties with National Curriculum tests

Significant investment needed from Government/Ofqual to get contract right

Bidding process would be significant resource burden for exam boards

Costs may increase for schools as exam boards would build in risk premium to cope with policy changes over lifetime of a contract

Could be financially challenging for exam boards if lose profitable, large entry subjects.

44. Views among witnesses to our inquiry varied. Perhaps unsurprisingly, the exam board chief executives expressed reservations about change, although they did acknowledge that change (possibly significant rather than minimal) is needed to improve the system. Rod Bristow, President of Pearson UK, told us that "no suggestions that can be made to improve the system should be off the table".[65] Pearson has made six suggestions for improving the exam system in its consultation "Leading on standards". AQA and OCR expressed reservations about both alternative models. Andrew Hall, AQA's Chief Executive Officer, acknowledged that a single board model would "tackle in some ways the public perception that we three compete on standards" but cautioned that "it would bring very real system risk".[66] In common with others, Mr Hall pointed to delivery failures with National Curriculum Tests, as a warning of problems that can ensue with franchising.[67] OCR's Chief Executive Mark Dawe stated that "it would be a false confidence for the public if we said that we would create just one board".[68]

45. Assessment researchers we spoke to favoured a more robust approach to regulation over administrative reform. They supported the argument put to us by Cambridge Assessment:

creating a single awarding body does not of itself secure standards. There remains the issue of the need to ensure standards over time and standards between syllabuses in the same subject [...] A single board therefore does not eliminate the demanding task of managing comparability between syllabuses in the same subject, at the same level [...] the system needs a robust approach to comparability, not administrative re-organisation.[69]

The exam board chief executives agreed that strong regulation, with a focus on standards, is vital. Mark Dawe of OCR told the Committee that "changing the exam boards is not solving the problem. Standards are the vital thing; we have to define what standards we want".[70]

46. Other witnesses were less cohesive in their views. Examiners were divided over which model should be adopted, with views split between retaining the current system and moving to a single board. Representatives from universities and employers expressed a greater interest in outcomes than how the system is organised. The views of learned bodies varied, both in oral and written evidence. Professor Graham Hutchings told us that the Science Community Representing Education (SCORE) favoured a franchised system.[71] The British Academy view was that "there are some merits in plurality [...] perhaps it is that we need to find some kind of middle way, which may be with greater regulation and the role of subject committees, balanced against some degree of choice".[72] The Wellcome Trust suggested that "if we were establishing the exam system from scratch, a single awarding body would be most favourable. However, in the interest of stability the current model should probably be retained, but only with substantial improvements".[73]

47. The school leaders we spoke to were in favour of a single board, albeit with some reservations about its size and powers and how schools would express dissatisfaction.[74] Headteacher Martin Collier suggested that a single national board "could act as the custodian of examining standards as well as the academic integrity of qualifications" and would help to counteract the "erosion in examining standards".[75] Teresa Kelly, principal of Abingdon and Witney College, told us that "a single board would make sense for GCSE and AS/A2" but "would not cater for the needs of the majority of young people 16-19 who are taking vocational examinations".[76] Her view that a single board would not work for vocational qualifications is consistent with the findings of the Wolf review of vocational education which warned against "central attempts to impose a neat, uniform and 'logical' structure", arguing that "the great strength of the English system of independent awarding bodies is that it allows for multiple direct links between qualification development, the labour market and higher education".[77]

The international perspective

48. We considered the arrangements for exams in other countries by way of comparison. It would appear that many jurisdictions operate a single exam board system successfully. Jo-Anne Baird, Jannette Elwood and Tina Isaacs told us that "some countries appear to have a reasonably simple system of exam administration, with a single organisation, typically the Ministry, responsible for examinations".[78] Among the examples they cited were Denmark, France, the Netherlands, Hungary, Italy, Kenya and Uganda. Other countries, such as Australia, Canada and China, have regional exam boards for each state or province. A further variation is that exam board functions may be handled differently, so that several organisations may be involved in setting, administering and certifying exams.[79] The arrangements in England would appear to be unusual, if not unique. This makes international comparison difficult, as both high and low performing jurisdictions may offer a similar contrast in the way they administer exams. The Wellcome Trust told us that it has "yet to identify a country other than England, that operates a model of multiple competing awarding bodies".[80] Given the Secretary of State's enthusiasm for looking at "the rest and the best",[81] we were interested in the DfE's view that:

England is unusual internationally in having a regulated qualifications market with a number of commercial and not-for-profit providers of pre-19 qualifications. However, the fact that we are unusual is not a reason to think we are wrong.[82]

49. Some issues, such as standards setting and maintaining public confidence, are common to all systems, regardless of how they are organised. Furthermore, evidence from other countries operating different models suggests that problems such as grade inflation, would not necessarily disappear. Tim Oates, Group Director of Assessment, Research and Development at Cambridge Assessment, told us that "if you are concerned about particular technical problems with measurement and particular problems with public confidence, you will find those problems emergent in all other systems, too, in different forms".[83] This was echoed by Dr Michelle Meadows of AQA's Centre for Research and Education Policy (CERP), who warned that "if one looks at one awarding body countries, such as Scotland, and how their outcomes have gone up over time in their equivalent qualifications, they almost match identically what has happened in England. So, one awarding body does not solve that".[84] Similarly, researchers pointed out that Sweden, which operates a type of franchised system, has experienced problems with grade inflation.[85]

Implications and risks of change

50. Fundamental reform of the exam system would clearly constitute intervention on a large scale. We have heard several warnings of the disruption that would be caused by organisational reform. The Association of School and College Leaders (ASCL) cautioned that "there would have to be considerable evidence in favour of a change in order to balance the turbulence it would bring to the system".[86] According to Cambridge Assessment:

constant reform, re-structuring and re-organisation of the qualifications system is a major threat to standards [...]democratic governments have an entirely legitimate interest in control of education and training systems—but ill-founded serial intervention in examinations does nothing to enhance the quality of provision.[87]

Tim Oates of Cambridge Assessment told us that "maintaining standards in times of change is one of the most significant challenges to any assessment system".[88]

51. There is also the question of legislation and associated timescales. According to Glenys Stacey, Chief Executive of Ofqual, reform of the exam system would be likely to require legislation.[89] The Minister for Schools, Nick Gibb MP, told us that "we are actively considering a number of options. We are of the opinion that some of those options would not require primary legislation".[90] He would not elaborate, but it is self-evident that changes requiring legislation could not be introduced quickly and there would be a period of uncertainty while the legislation was being developed and passed.

Conclusion on fundamental reform

52. We accept that there are advantages and disadvantages in all of the three systems we have examined and acknowledge the truth of Ofqual's observation that "no delivery model is risk-free and there are many factors that could influence the pros and cons of each".[91] We are also clear that any change would be disruptive, potentially very expensive and would bring added risks. As the Minister for Schools suggested to us, this risk increases in the context of multiple reform:

if you are reforming the curriculum, putting in changes to modularisation,[...] and an increased emphasis on spelling, punctuation and grammar at the same time as a major restructuring of the awarding organisations, that presents risks.[92]

Several submissions to us were critical of the involvement of Government and its associated bodies in exams in recent years.[93] "Forget competition between awarding bodies," wrote Professor Jo-Anne Baird in 2010, "the biggest driver of change in this industry is Government policy".[94]

53. We appreciate that there are some strong arguments in favour of a single exam board. It is a simpler system, with no risk of competition on standards (although other issues regarding the comparability of standards over time and across subjects would remain). Examiner and assessment expertise would be concentrated and it would be easier for learned bodies, higher education and employers to engage with a single national body. However, certain benefits of the current system, such as schools being able to express dissatisfaction by changing boards, would be lost. Moving to a single board would involve the creation of a new body, at arm's-length from Government, with substantial cost implications for resourcing such a new provider (and we note the limited appetite of the current Secretary of State for creating arm's length bodies). We believe that such a change would require primary legislation. Alternatively it might involve the expansion of one of the current providers. This would involve significant scaling up and we doubt that the not-for-profit providers would be in a position to do this. The prospect of a single, for-profit, provider of GCSEs and A levels may be of limited appeal, given that many have already expressed misgivings about exams being run on a for-profit basis.[95]

54. We also note that the creation of a single board for GCSE examinations in England would not, in itself, prevent schools using other examinations, such as GCSEs offered by WJEC and CCEA and the iGCSEs offered by some of the existing exam boards. Similarly, BTECs and OCR Nationals would, presumably, continue to be available and in competition with the national GCSEs. Many of the issues of credibility and comparability of standards would therefore remain unless schools were compelled to use only the examinations of the national board and that board offered vocationally-orientated examinations accepted as equivalent to GCSEs as well as GCSEs themselves. At A-level, similar issues would arise and similar compulsion might be required to head off the risk of creating a new market in qualifications claimed to be equivalent to A-levels.

55. Overall, we conclude that the costs, heightened risk and disruption likely to be generated by moving to a single board outweigh the potential benefits. Furthermore, evidence suggests that some key issues identified with the current system, such as comparability of standards over time and across subjects and the role of examiners in training and textbooks, would remain. New problems, such as a lack of incentive to innovate, the risk of higher fees and a reduced quality of service to schools, may be generated. There may also be the potential for increased political interference, as well as the issue of whether to limit schools' choice of exams to those offered by the single board.

56. Moving to a franchised system would be potentially less disruptive, as the three main providers could remain. Costs would be borne largely by exam boards rather than by Government. Franchising by subject would, however, still involve fundamental change, with significant resource commitments on the part of Ofqual and the exam boards.

57. The question of whether there should be multiple organisations, or just one, involved in examinations is generally discussed in terms of the system as a whole. But we consider that exam boards in England currently have three interrelated, but distinct, functions:

1. Creation of the syllabus

2. Management and administration: collecting exam entries, setting and marking of exams and associated administration, issuing exam results, handling queries from schools

3. Provision of textbooks and teaching materials and training for teachers.

For each of these the effects—and desirability—of competition differs.

58. The potential benefits of competition in areas (2) and (3) seem clear: in a well-regulated and quality-assured system, competition around management and administration should keep exam boards on their toes and mitigate the risk of system-wide failure, and can help keep prices down; the regulator should be able to ensure consistency in the stringency of marking. A diverse market in teaching aids should help to make the subject material engaging and interesting to more students, and there is the incentive for innovation.

59. In area (1), however, the benefits of competition do not seem clear at all. We can absolutely see the benefit of having some choice in syllabus for certain subjects, for example in historical periods or English Literature texts. But we have not heard any compelling reasons to want to have exam boards competing over syllabuses. It is implicit in a number of the pieces of evidence we have received that such competition is one of the contributory factors to the grade inflation that is widely acknowledged.[96] Put simply, in a world where schools are under pressure to achieve ever-better exam grades, and exam boards measure their own performance by market share, there is an obvious inbuilt incentive for competing exam boards to provide syllabuses which make lesser demands of students.

60. If the system of multiple exam boards is retained, substantial improvements are needed in order to increase confidence in the system and maintain its credibility. We have serious concerns about the incentives in the current system for exam boards to compete on standards, in particular on content standards. We think that significant changes are needed to alter these incentives. We discuss these changes, including the option of franchising, in chapter four.

58   Statement issued in response to Daily Telegraph investigation, December 2011, Back

59   "Exam reforms may see one board per subject, says Gove", Daily Telegraph, 10 December 2011 Back

60   Q647 Back

61   See appendix 1 to Chapter 2 of Techniques for monitoring the comparability of examination standards, QCA, 2007  Back

62   Press release from June 1997, quoted in Techniques for monitoring the comparability of examination standards, QCA, 2007, chapter 2, p79  Back

63   Science and Mathematics Secondary Education for the 21st century. Report of the Science and Learning Expert Group, 2010 Back

64   The Sir Richard Sykes review, 2010, pp23-24 Back

65   Q250 Back

66   Q537 Back

67   See also Ev 144 Cambridge Assessment, which points to problems experienced with national curriculum tests in 1997, 2004 and 2008, paragraphs 2, 19-21, Ev w3 Andrew Hall, Q366 Tim Oates Back

68   Q250 Back

69   Ev 145, paragraphs 6 & 7 Back

70   Q501 Back

71   SCORE comprises the Association for Science Education, the Institute of Physics, the Royal Society, the Royal Society of Chemistry and the Society of Biology.  Back

72   Q460 Back

73   Ev 128  Back

74   See Q61 and Ev 175 Back

75   Ev 112 Back

76   Ev 175 Back

77   Review of Vocational Education-The Wolf Report, Department for Education, March 2011, p57-58 Back

78   Ev 178 Back

79   Ev 179 paragraph 3.1 Back

80   Ev 131 paragraph 13 Back

81   Michael Gove speech to Ofqual standards summit, 13 October 2011  Back

82   Ev 172 paragraph 11  Back

83   Q337 Back

84   Q362 Back

85   Q369 Michelle Meadows and Tim Oates  Back

86   Ev w8 paragraph 2 Back

87   Ev 145 Back

88   Q367 Back

89   Q590 Back

90   Ev 201 Back

91   Ev 160 Ofqual, paragraph 4 Back

92   Q652 Back

93   For list of recent Government initiatives, see Ev 136 OCR paragraph 26, also see for example, Ev w35 Roger Porkess, Ev 153 Back

94   Baird, J-A, The problem at the root of our education system, Government Gazette, p16, 2010 Back

95   See for example, Ev 106, Ev 76, Ev w84, Ev w110, Ev w112, Ev 176  Back

96   See for example Ev 153, SCORE Back

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Prepared 3 July 2012