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".
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".
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
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.
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 bodieseach
offering GCE A levels, GCSE and GNVQs".
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".
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".
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
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
|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
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".
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".
In common with others, Mr Hall pointed to delivery failures with
National Curriculum Tests, as a warning of problems that can ensue
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".
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.
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".
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. 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".
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".
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.
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".
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".
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".
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
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.
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".
Given the Secretary of State's enthusiasm for looking at "the
rest and the best",
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.
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".
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".
Similarly, researchers pointed out that Sweden, which operates
a type of franchised system, has experienced problems with grade
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".
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 systemsbut ill-founded serial intervention
in examinations does nothing to enhance the quality of provision.
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".
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
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".
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
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".
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
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.
Several submissions to us were critical of the involvement
of Government and its associated bodies in exams in recent years.
"Forget competition between awarding bodies," wrote
Professor Jo-Anne Baird in 2010, "the biggest driver of change
in this industry is Government policy".
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.
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.
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
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 effectsand desirabilityof
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
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.
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
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
58 Statement issued in response to Daily Telegraph
investigation, December 2011, http://www.education.gov.uk/a00200596/michael-gove-responds-to-the-daily-telegraph-investigation Back
"Exam reforms may see one board per subject, says Gove",
Daily Telegraph, 10 December 2011 Back
See appendix 1 to Chapter 2 of Techniques for monitoring the comparability
of examination standards, QCA, 2007 Back
Press release from June 1997, quoted in Techniques for monitoring
the comparability of examination standards, QCA, 2007, chapter
2, p79 Back
Science and Mathematics Secondary Education for the 21st century.
Report of the Science and Learning Expert Group, 2010 Back
The Sir Richard Sykes review, 2010, pp23-24 Back
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
Ev 145, paragraphs 6 & 7 Back
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
Ev 128 Back
See Q61 and Ev 175 Back
Ev 112 Back
Ev 175 Back
Review of Vocational Education-The Wolf Report, Department for
Education, March 2011, p57-58 Back
Ev 178 Back
Ev 179 paragraph 3.1 Back
Ev 131 paragraph 13 Back
Michael Gove speech to Ofqual standards summit, 13 October 2011
Ev 172 paragraph 11 Back
Q369 Michelle Meadows and Tim Oates Back
Ev w8 paragraph 2 Back
Ev 145 Back
Ev 201 Back
Ev 160 Ofqual, paragraph 4 Back
For list of recent Government initiatives, see Ev 136 OCR paragraph
26, also see for example, Ev w35 Roger Porkess, Ev 153 Back
Baird, J-A, The problem at the root of our education system,
Government Gazette, p16, 2010 Back
See for example, Ev 106, Ev 76, Ev w84, Ev w110, Ev w112, Ev 176
See for example Ev 153, SCORE Back