4 The way forward
Introduction
61. A recurring criticism of the current system of
multiple exam boards is that they compete by lowering their standards,
in order to increase market share, in the so-called "race
to the bottom". While this may not be overt, many have expressed
concern about the two-fold downward pressure on the system generated
by competition between exam boards and the accountability system
(of which more in chapter ten).
62. The concept of exam standards is complex, involving
the content of the syllabus and the demand of question papers
and tasks, as well as marking and grading.
Syllabus content
63. Exam boards develop syllabuses based on qualification
and subject criteria that are set by Ofqual. These criteria provide
parameters within which exam boards may develop distinctive courses.
Ofqual approves or accredits new syllabuses against the qualification
and subject criteria. GCSE subject criteria are based on the Programmes
of Study laid down in the National Curriculum, where applicable.
64. In the current system exam boards compete intensively
on syllabus features, offering a variety of syllabuses so that
"teachers can select approaches tailored to the needs and
interests of their students".[97]
Examiners, many of whom were also practising teachers, reported
that exam boards conduct extensive market research to help them
identify which aspects of subjects (for example, texts in English,
periods of history) are preferred by teachers. The choice available
to teachers within the current system is such that teachers can
choose the most appropriate syllabus for their classes or school
cohorts, rather than for individual pupils. The distinctiveness
of syllabuses varies between subjects, with duplication of very
similar syllabuses in some subjects.
65. Learned bodies were critical of a lack of innovation
in syllabus development across the exam boards. SCORE told us
that the "current model is not supportive of innovation [...]
sharing best practice and collaborative working are not embraced".[98]
Professor John Holman of the Wellcome Trust put it more bluntly,
telling us that "innovation is not engendered in the current
system because people aren't encouraged to talk to each other".[99]
We believe that it is unrealistic to expect significant collaboration
between exam boards on syllabus development in the current system,
as exam boards compete vigorously at this stage for market share
on the basis of syllabus features.
66. The DfE has also expressed its concerns about
content standards:
Central to our concern is that the nature of competition
seems to present significant risk of awarding bodies producing
more 'accessible' specifications, with content that is less intrinsically
challenging, in order to capture market share.[100]
This concern was echoed by Jon Coles, former director
general for education standards at the DfE, who told a recent
Cambridge Assessment conference that exam boards should stop marketing
qualifications as "accessible". Mr Coles suggested that
the tactic has promoted a "culture in which it is seen to
be acceptable to say to schools, 'do this [exam] because it is
easier' [...] even if you do not use those words, that is what
schools are hearing".[101]
Mr Coles also accused the exam boards of developing exams that
"barely meet" Ofqual's minimum requirements and called
for the boards to have the "moral courage" to ensure
their qualifications have the depth and quality to exceed Ofqual's
minimum requirements.[102]
67. Beyond Jon Coles' "moral courage",
no-one was able to help us identify incentives that exist in the
current system for exam boards to exceed the minimum requirements.
The evidence pointed instead to downward pressures in the system,
with the Minister for Schools telling us that we have "a
system that rewards awarding organisations with an incentive to
provide the most accessible [...] examination in order to increase
market share".[103]
SCORE argued that the commercial concerns of exam boards and their
need to maintain or increase market share have taken precedence
over educational ones, affecting syllabus content (chosen to be
easily assessable) and the demand of question papers (with fewer
questions requiring higher level skills of analysis, synthesis
and evaluation).[104]
68. Even if exam boards do not compete overtly on
standards, we agree with a TES forum post that "there is
every incentive for the exam boards to ensure their exams are
no harder than anyone else's".[105]
Strikingly, this issue was also raised as an area of concern by
a senior exam board official: AQA's Andrew Hall called for a "focus
on how we develop content standards for examinations", arguing
that the "safest thing for delivering the most secure improvements
for our students is to really tackle content standards".[106]
69. There were recurring calls in evidence for Ofqual
to be more robust in its regulation of content standards, specifically
to have more rigorous and transparent accreditation procedures,
with appropriate use of subject experts.[107]
Glenys Stacey, Chief Executive of Ofqual, described the accreditation
process as "our people at Ofqual trying almost to second-guess
the experts in awarding bodies".[108]
We suspect that this task may be made more difficult by a lack
of assessment expertise within Ofqual. As Professor Jo-Anne Baird
has pointed out "few individuals in [...] Ofqual have training
or even experience of designing and delivering educational assessments".[109]
70. We welcome the recent action taken by Ofqual
on content standards, requiring the exam boards to "tighten"
GCSEs in geography, English literature, history and mathematics.
This is to ensure that all students have to study the subject
in appropriate breadth and depth.[110]
However, the fact remains that the syllabuses that needed "tightening"
had been approved by Ofqual's accreditation procedures. We were
concerned at Glenys Stacey's analysis that "accreditation
at the moment is a process that has its worth, but it is part
of the way things were done".[111]
This seems to imply that Ofqual is moving away from its current
approach to accreditation. We return to Ofqual's regulation of
content standards, in particular its accreditation procedures,
in chapter five.
71. It is our view (and we have heard little to persuade
us otherwise) that the incentives in the current system lead to
downward competition on content standards. Strong incentives exist
for exam boards to reduce content to a minimum or to offer "content-lite"
routes through their syllabuses. The problem as we see it is that,
as Glenys Stacey herself stated, "there are no incentives
to go in a different direction".[112]
We agree with Rod Bristow, President of Pearson UK, that it is
fair to ask "what incentives can be put into the system to
raise standards".[113]
We have therefore considered two options for change which would
aim to provide such incentives: the first is national syllabuses
and the second is franchising by subject.
NATIONAL SYLLABUSES
72. National syllabuses would be accredited by Ofqual
and then regarded as a national resource that could be examined
by any of the English exam boards. There could be one accredited
national syllabus in each subject or more than one to provide
some choice for schools. This would remove the incentive for exam
boards to compete on syllabus content, while retaining current
incentives for operational efficiency, innovation and quality
of service to schools. Too often, competition on content adds
little value and, in some subjects, creates duplication of effort
for little genuine variation.
73. Such national GCSE and A level syllabuses could
be designed by exam boards in conjunction with representatives
from higher education, learned bodies and/or employers. Increasing
the role of learned bodies (and universities and employers) in
syllabus development would be one way to encourage collaboration
and a focus on best practice. Under a system of national syllabuses,
exam boards could be required to consult with a relevant learned
body or, at A level, higher education representatives, as part
of their syllabus development process. The syllabus could be endorsed
by the learned body or universities, as the Government envisages
for A level. Exam boards would be required to have at least one
syllabus accredited (in any subject) in order to offer question
papers linked to the national syllabuses developed by another
exam board. Ofqual would need to monitor question papers, but
its grading standards work (see chapter five) would take account
of, and adjust for, any differences in demand between question
papers.
74. An alternative approach to the creation of national
syllabuses, which would then be examined by the existing boards
in competition, would be to commission the syllabuses directly.
Successful bidders in this process should be required to be consortia
of examining boards, learned bodies, higher education and/or employers.
FRANCHISING OF SUBJECTS TO EXAM
BOARDS
75. The second option is franchising, which would
involve rather more fundamental changes to the way the system
is organised. In common with national syllabuses, it would offer
a way of eliminating competition on content standards and allegations
of a "race to the bottom", while retaining multiple
exam boards. Unlike national syllabuses, it would involve exam
boards developing particular areas of subject expertise, as they
would be contracted to offer only certain subjects at GCSE and
A level. A franchised system would make it easier for learned
bodies, higher education and employers to engage (they would only
need to engage with one exam board per subject) and would also
avoid the duplication of syllabuses and dilution of examiner expertise
that exist in the current system.
76. There are some very significant issues relating
to franchising that would need to be taken into account. Franchising
would require substantial Government and regulatory input to draw
up and award contracts to providers. Glenys Stacey of Ofqual told
us that experience (of regulating National Curriculum assessments
and in other sectors) would suggest that
you have to make a very real and significant investment
in getting the detail of the specification, the contract, and
the bidding and tendering processes right [...] my advice would
be to concentrate very hard on getting the legislation right,
and getting the mechanics and technicalities of it right. It would
be a significant and complex matter.[114]
The burden would be on those who procure to specify
correctly, as the success of the system would depend upon it.
Exam boards would have to devote significant resource to the bidding
process, which requires a different skill-set to that involved
in running exams. The impact on unsuccessful bidders should also
be considered.
77. Glenys Stacey also advised that the Government
should "truly evaluate the risks and [...] recognise the
trade-offs." Pricing, in a franchised model, would need close
monitoring: "one might expect that pricing would be a dark
art, or would be lacking in transparency" and "there
is likely to be an increase in pricing", in comparison to
the current system.[115]
Exam boards would include a premium for risk and to cover the
implications of changes in government policy (which, recent experience
suggests, would be highly likely during the lifetime of a contract).
78. A particular concern would be how to encourage
innovation, and the associated financial investment, such as improvements
to question paper setting processes. Innovation is commonly cited
as one of the benefits of multiple competing exam boards. As Cambridge
Assessment observed, "whenever one board achieves an advance,
the others compete vigorously to catch up and overtake".[116]
Within a franchised system, innovation linked to service delivery
would need to be built into the terms of a contract, as would
the provision of small entry subjects.
79. As well as removing competition on syllabus development,
one of the main benefits of franchising, acknowledged by many,
would be the concentration and development of subject expertise
within an exam board.[117]
This would encourage a focus on enhancing the quality of syllabuses
and their associated materials, rather than "just meeting"
the minimum regulatory requirements. The flip side is that, as
Tim Oates argued, "over a period of time, the expertise becomes
entirely concentrated in individual institutions [...] your choices
then become profoundly limited".[118]
Glenys Stacey described this as "a one-way street. When you
get towards the end of a franchise period, it is much harder to
attract true competition and real bidders".[119]
80. Several witnesses pointed out to us that there
are salutary experiences of how a franchised system can go wrong
to be found in the history of National Curriculum tests.[120]
Should the option of franchising be pursued, the Government needs
to consider the legal implications of a franchised system very
carefully, including the need to constrain schools' choices of
syllabuses to those provided by the franchisee and to prevent
other exam boards from marketing alternative "equivalent"
qualifications. Any major structural change to the exam system
needs to be managed with extreme care in order to minimise the
disruption caused, bearing in mind that the greatest threat to
standards is at moments of change and that the bigger the change,
the bigger the risk.
CONCLUSION ON OPTIONS FOR CHANGE
81. We
believe that the current system incentivises downward competition
on content standards and we recommend that the Government act
immediately to change these incentives. We consider that national
syllabuses would offer a way of addressing downward competition
on content and provide reassurance on standards, without the risks,
lost benefits and disruption involved in moving to a single board.
The Government should begin by piloting a national syllabus in
one large entry subject as part of the forthcoming A level reforms.
Ofqual should review the effectiveness of the pilot, with a view
to extending the approach across GCSE and A levels if appropriate.
We believe that national syllabuses, coupled with a stronger Ofqual
and greater involvement of subject communities in GCSEs and A
levels, should help to maximise the benefits of having multiple
competing exam boards while minimising the shortcomings.
82. While we
can see that the second option we outlinefranchising of
subjects to exam boardsoffers a way to address downward
competition on content, we have concerns about the long-term impact
and suggest that there may be serious downsides to such a change
that need to be better understood before it can be recommended.
Grading standards and grade inflation
83. The Wellcome Trust told us that "it is important
that the public, employers and universities understand and have
confidence in the process by which grades are arrived at. Yet
little is known publicly about how awarding bodies proceed from
marked scripts to final grades".[121]
The issue of grading standards is complex and the awarding of
grades a technical process, involving a blend of the professional
judgement of examiners with sophisticated statistical data. It
is a difficult area, which quickly becomes impenetrable to non-specialists.
Therein lies much of the challenge for the exam boards and Ofqual
when seeking to provide reassurance about grading standards. Furthermore,
as Glenys Stacey observed,[122]
the language used to discuss grading standards, including commonly
used terms such as 'grade inflation', is emotive and loaded. Recently,
Ms Stacey has been more outspoken, stating that there has been
"persistent grade inflation" at GCSE and A level.[123]
It is an area of long-standing debate and one that has strong
influence over public confidence in the exam system.
84. When considering grading standards, we were concerned
with several questions. First, whether increasing numbers of students
achieving higher GCSE and A level grades reflect genuine improvements
in standards of attainment; second, how the system of competing
multiple exam boards has contributed to the year-on-year increases
in results. Third, how the system should balance the requirement
to maintain standards over time with the need to adapt to ensure
that GCSEs and A levels remain fit for purpose.
INCREASING NUMBERS ACHIEVING HIGHER
GRADES
85. Rising GCSE and A level pass rates and increases
in the numbers of candidates achieving good grades are well-documented
and have prompted ongoing debates about grade standards. Figures
1 and 2 below show the trends in A level and GCSE pass rates since
their introduction in 1951 and 1988 respectively.[124]
Professor Alan Smithers observes that in the past 30 years, the
A level pass rate has increased from 68.2 per cent in 1982 to
97.8 per cent in 2011. He notes that since norm-referencing was
superseded by criterion-referencing in 1987, the proportion of
candidates achieving a grade A has increased from under 10 per
cent to 27 per cent in 2010.[125]
Professor Smithers comments that the GCSE has seen "almost
continuous grade improvement in the twenty-four years of its existence".[126]
Figure 1: Trends in A-Level Entries and Passes

Source: A levels 2011, Alan Smithers, Centre for
Education and Employment Research, University of Buckingham, 2011
Figure 2: Trends in GCSE Passes

Source: GCSEs 2011, Alan Smithers, Centre for
Education and Employment Research, University of Buckingham, 2011
86. The National Association of Schoolmasters/Union
of Women Teachers (NASUWT) told us that "there is no evidence
that standards in the qualifications used most regularly in the
14-19 sectors have fallen over time".[127]
However, few other stakeholders, including assessment specialists,
appeared so confident. Doubt is cast by the critical comments
from universities and employers (see chapter two) and by the contrasting
static performance of English pupils on international surveys
such as PISA. Tim Oates of Cambridge Assessment stated in a debate
on exam standards in 2010 that there is "sufficient evidence
from diverse sources to generate concern" about grade drift.[128]
87. The DfE pointed to the findings of research by
Robert Coe and Peter Tymms at Durham University, which, it told
us, "raise important questions about grading".[129]
The research found that between 1996 and 2007 the average grade
achieved by GCSE candidates of the same "general ability"
rose by almost two-thirds of a grade; for A level candidates the
increase between 1988 and 2007 was over two grades.[130]
The Secretary of State warned last October and again recently
that "there will be years, because we are going to make exams
tougher, when the number of people passing will fall".[131]
This has led to discussion in the media of the prospect of "grade
deflation".[132]
88. AQA's Centre for Education Research and Policy
(CERP) argued that grade awarding procedures and checks, along
with associated research exercises, are "robust, efficient
and effective" and that, given the rigour of the current
grading system, "confidence in standards in general, and
in inter-year and inter-AB [awarding body] comparability in particular,
should be high".[133]
Exam boards explained to us how they share data with each other
and the regulator at key stages prior to the publication of results.
While exam board chief executives defended their awarding procedures
as robust, they acknowledged that "whilst actual grades have
been going up, our performance on international league tables
has not" and that "there has been a creep in grading
standards".[134]
89. AQA suggested to us that
the progressively high-stakes nature of general qualifications
partly explains the year-on-year increases in results, which amount
to a handful of extra students in each school exceeding the grade
boundary each year. Teachers focus intensively on supporting borderline
students, aided by the increased availability of mark schemes,
past papers, information and support, and transparency as to the
skills and knowledge required and how to demonstrate them [...]
as education becomes increasingly centred on passing examinations,
outcomes go up.[135]
90. Glenys Stacey was recently reported as saying
that "the grade inflation we have seen [at GCSE and A level]
is virtually impossible to justify".[136]
We explored with assessment experts the elements that have most
contributed to increasing numbers achieving higher grades. Several
factors were cited. These seemed to us to fall into four broad
categories: genuine improvements (for example, more efficient
teaching, better quality teachers, harder-working pupils and pupils
with better support from home), changes in the structure and design
of qualifications (for example, modularisation, re-sits), factors
linked to underlying drivers such as the accountability system
(a culture of increasing results and expectation of increased
performance, schools focusing heavily on GCSEs, teaching to the
test) and finally factors linked to exam board procedures (greater
transparency, improved reliability, examiners giving students
the "benefit of the doubt", tolerance of small increases
year-on-year). We note the point made by Tim Oates, that there
is a lack of evidence identifying which of these factors lead
to actual improvements in underlying attainment (as well as improved
grades).[137]
91. Increasing numbers of students achieving higher
grades in GCSEs and A levels is an undisputed trend. What is less
clear is whether this is matched by improvements in knowledge,
skills and understanding among students. While we appreciate that
this is a technically complex area, we agree with SCORE that "the
impression that standards are either slipping or becoming incomparable
between year groups cannot be ignored".[138]
More young people may be doing well because they are better prepared
to pass their GCSE and A level exams. However, we feel that there
is sufficient evidence from a variety of sources, such as universities,
employers, England's flat PISA profile and research by Durham
University cited above, to cast doubt over whether GCSEs and A
levels indicate improved preparation of young people for further
education and employment and whether higher grades reflect genuine
improvements in their underlying knowledge, skills and understanding.
The findings of Ofqual's most recent set of GCSE and A level standards
reviews cast further doubt in this respect. Ofqual reported that
many of the reviews "raise concerns about the maintenance
of standards" and that in several cases changes to the way
content was assessed had reduced the demands made by exams.[139]
This doubt devalues qualifications and young people's achievements
and undermines public confidence in the system. Ofqual
should continue to investigate grading issues as part of its programme
of standards reviews and to engage publicly with debate on exam
standards. Ofqual needs to be able to account for what AQA's Andrew
Hall described as the "creep in grading standards",
particularly in the commercially significant large entry subjects
at GCSE, which are key to schools' performance in league tables
and also in large entry A level subjects, commonly used for university
entrance.
92. We can see that the requirement on Ofqual and
the exam boards to maintain standards over time may present challenges
when trying to ensure that GCSEs and A levels adapt and remain
fit for purpose. A levels, for example, cater for a broader ability
range, with larger numbers going on to university, than they did
thirty years ago. As Professor Nick Lieven of Bristol University
told us, "the median area that you are trying to focus the
qualification on has shifted: it has to, in order to be fair".[140]
We suggest that occasional explicit recalibration of grading standards
may be required and is preferable to slow creep downwards or upwards.
Slow drift or creep in grading standards, such as that seen over
recent years, is difficult to interpret and leads to the system
courting controversy, with obvious consequential risks to public
confidence. We return to this in chapter five.
COMPETITION ON GRADING STANDARDS
93. There is clearly a public perception that exam
boards compete on grading standards. The Wellcome Trust told us
that "it seems likely that grade [boundaries] have reduced
in part because the awarding bodies are competing for custom and
teachers are likely to choose those qualifications that will yield
the best performance for their schools and for their students."
The Trust cites evidence of one exam board marketing their syllabus
as "proven to help improve grades".[141]
94. According to the Wellcome Trust, "Mark Walport,
chair of the Science and Learning Expert Group, observed that
when giving evidence [to his inquiry], awarding bodies openly
admitted that they struggle to avoid competing with each other
on grade standards".[142]
This was not our experience. Exam board chief executives were
emphatic that they do not compete on grading standards, telling
us that "there is no scope for competing on standards"
and that "it is the standards agenda that brings us into
a collective, but we compete on everything else".[143]
A key factor in this appears to be recent action taken by Ofqual
to control grade inflation. Since summer 2010 Ofqual has monitored
the interim outcomes from summer awards to secure comparability
between exam boards and minimise any grade inflation. As Tim Oates
explained, "the regulator has increasingly said, 'if you're
erring, err in this direction, not that direction'".[144]
The approach seems to have been broadly welcomed by assessment
experts and the exam boards. AQA's Andrew Hall told us "we
share datawe share it with the regulatorand we have
made a great leap forward now".[145]
Ofqual has said that it is "committed to containing grade
inflation, whilst making sure that awards reflect accurately students'
achievements"[146]
and that it plans to adopt the same approach to the award of GCSEs
in summer 2012.
95. We welcome
Ofqual's recent action to regulate grading standards and recommend
that it continue with this approach for A level and, from summer
2012, for GCSE. The effect of this action is twofold: first it
helps to control grade inflation and second it provides reassurance
that the exam boards are not competing on grading standards. We
recognise that the effect will take time to filter through the
system and to help increase public confidence.
97 Ev 114 paragraph 2.6 (AQA) Back
98
Ev 153 Back
99
Q445 Back
100
Ev 170 Back
101
Jon Coles, speaking at Cambridge Assessment event "Learning
comes first: shifting the focus from examining to the curriculum",
31 January 2012 Back
102
Ibid. Back
103
Q646 Nick Gibb Back
104
Ev 155, paragraph 7 bullet 2 Back
105
TES forum post, 27 October 2011 Back
106
Q537, Andrew Hall, Back
107
See for example, Ev 128, Ev w78, Ev 153 Back
108
Q603 Back
109
Baird, J-A. The problem at the root of our education system, ,Government
Gazette, February 2010, pp16 Back
110
These changes are in addition to those already announced by the
Government, namely the move to end-of-course assessment and increased
assessment of spelling, punctuation and grammar in some subjects.
Back
111
Q603 Back
112
Q615, Glenys Stacey Back
113
Q253 Back
114
Q590 Back
115
Q590 Back
116
Ev 147, paragraph 30 Back
117
See Ev 153, Q372 Jo-Anne Baird, Ev w78, Ev 128 Back
118
Q372 Tim Oates Back
119
Q590 Back
120
In particular delivery failure in 2008, detailed in the Sutherland
inquiry: an independent inquiry into the delivery of National
Curriculum tests in 2008 and in a report by our predecessor Committee:
Policy and delivery: the National Curriculum tests delivery
failure in 2008, Sixth Report of session 2008-09, HC 205.
Back
121
Ev 128 Back
122
A new look at standards, Glenys Stacey, Ofqual standards summit,13
October 2012 Back
123
"A level overhaul to halt 'rampant grade inflation'",
Daily Telegraph, 28 April 2012 Back
124
A levels 2011 and GCSEs 2011, Alan Smithers, Centre for Education
and Employment Research, University of Buckingham, 2011 Back
125
Between 1963 and 1987 the A level grading system was norm-referenced;
that is, a fixed percentage of candidates achieved each grade
in any given year, regardless of the standard achieved. In 1987,
criterion-referencing was introduced, whereby grades awarded were
on the basis of examiners' judgement of the quality of work and
were associated with a particular standard achieved (as in the
driving test). Grade awarding these days is a blend of criterion-referencing
with statistical analysis, including cohort-referencing (comparing
individual performance against that of the overall cohort). Back
126
A levels 2011 and GCSEs 2011, Alan Smithers, Centre for Education
and Employment Research, University of Buckingham, 2011 Back
127
Ev w70 Back
128
Exam Standards: the big debate, Cambridge Assessment, 29 April
2010 Back
129
Ev 170 Back
130
Coe, R & Tymms P, "Summary of research on changes in
educational standards in the UK" in Harris M (ed), Education
Briefing Book, Institute of Directors, London 2008, p97. Back
131
Michael Gove to Ofqual Standards Summit, 13 October 2011 and "Michael
Gove: Get set for new age of exam failures"; the Independent,
22 February 2012 Back
132
Glenys Stacey interview on Today programme, BBC Radio 4,
24 February 2012 and "Michael Gove wants universities to
create new A levels", BBC News, 3 April 2012 Back
133
Ev 193, paragraph 3.4 Back
134
Q502 Rod Bristow and Q494 Andrew Hall Back
135
Ev 117, 7.6 Back
136
"A level overhaul to halt 'rampant grade inflation'",
Daily Telegraph, 28 April 2012 Back
137
Exam Standards: the big debate, Cambridge Assessment, 29 April
2010 Back
138
Ev 153 Back
139
Standards reviews: a summary, Ofqual, 1 May 2012. Ofqual published
reports on reviews in GCSE Biology, GCSE Chemistry, GCSE Mathematics,
A level Biology, A level Chemistry, A level Critical Thinking
and A level Geography. Back
140
Q111 Back
141
OCR 21st century science syllabus suite, see http://www.twentyfirstcenturyscience.org/?q=content/faqs#seven Back
142
Ev 129, paragraph 4 Back
143
Q252 Andrew Hall and Q253 Gareth Pierce Back
144
Q389 Tim Oates Back
145
Q252 Andrew Hall Back
146
Ev 161 paragraph 9 Back
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