Conclusions and recommendations
Fundamental reform of the exam system
1. 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. (Paragraph 55)
2. 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. (Paragraph 60)
The way forward
Sylabus content
3. 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. (Paragraph
81)
4. While we can see
that the second option we outline—franchising of subjects
to exam boards—offers 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. (Paragraph
82)
Grading standards and grade inflation
5. 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. (Paragraph 91)
6. 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. (Paragraph 95)
The role of Ofqual
Ofqual's regulation of standards
7. We
recommend that Ofqual seek to build its assessment expertise and
finds the resources to do so. We further recommend that Ofqual
appoint an assessment expert to its board as soon as possible.
(Paragraph 102)
Ofqual's international standards objective
8. We
are concerned that the amendment to Ofqual's qualification standards
objective could over a period of time pull it simultaneously in
different directions and recommend that the Government give a
clear indication to Ofqual about which should be the priority:
the comparability of standards over time in England or benchmarking
against the standards of qualifications in other countries. (Paragraph
104)
Government policy changes
9. We
recommend that the Government make its priorities clear to Ofqual,
whether these are the maintenance of standards over time or making
exams tougher, and that both the Government and Ofqual be open
about the consequences of these policies for young people. (Paragraph
105)
10. If A levels are
going to become more varied in structure, Ofqual needs to ensure
that its collection of evidence and monitoring of standards are
sufficiently robust to provide convincing reassurance that content
standards are being maintained. (Paragraph 106)
GCSE changes and devolution
11. We
recommend that Ofqual review its arrangements for ensuring comparability
of standards between England, Wales and Northern Ireland, and
that it continue to monitor standards in GCSE and A level examinations
offered by WJEC and CCEA, as well as the English providers as
part of its ongoing regulation of standards. We also believe that
a debate is needed on the importance of standards comparability
between the home nations, with a Ministerial conference to decide
whether and what action is necessary. (Paragraph 107)
Accreditation
12. We
recommend that individual accreditation of all new syllabuses,
including our recommended national syllabuses, remain a part of
Ofqual's continuing regulation of GCSEs and A-levels and, indeed,
of any qualifications that are deemed equivalent to GCSEs and
A-levels. With this in mind, Ofqual needs to demonstrate that
its accreditation procedures are rigorous and transparent, and
that it draws on appropriate respected subject and assessment
expertise when reviewing draft syllabuses and their associated
materials. We recommend that Ofqual review and strengthen its
regulation of content standards, including accreditation procedures,
seeking and acting upon advice from its standards advisory group
as appropriate. (Paragraph 110)
Ofqual and subject expertise
13. While
we accept Ofqual's rationale for its lack of in-house subject
expertise, criticisms from the subject communities lead us to
conclude that Ofqual needs to be more transparent about its consultation
with and use of external subject experts. (Paragraph 112)
National subject committees
14. We
recommend that Ofqual convene national subject committees in large
entry GCSE and A level subjects, drawing their membership from
learned societies, subject associations, higher education and
employers. Such committees should include in their remit syllabus
development and accreditation, as well as on-going monitoring
of question papers and mark schemes, and oversight of comparable
qualifications offered in the devolved nations. (Paragraph 115)
Ofqual and the Joint Council for Qualifications
15. Ofqual
should instigate discussions with the JCQ to clarify roles and
responsibilities in areas where there is a joint interest and
publish information about this to schools and colleges as appropriate.
(Paragraph 117)
Conclusion
16. It
is clear from the issues raised with us that further improvements
are needed if Ofqual is to be a stronger, more challenging and
more effective regulator. As AQA's Andrew Hall put it "Ofqual
is, in fairness, on a journey". We believe that there is
a strong argument in favour of allowing time for a strengthened
Ofqual to take effect, as the changes it is making will take time
to settle and bear fruit. But Ofqual must demonstrate that it
is collecting the right sort of qualitative and quantitative evidence
and using robust methodology to regulate effectively. Details
of the evidence used by Ofqual in the regulation of standards,
and any specific findings and regulatory action on standards,
should be set out clearly in annexes to Ofqual's annual report
to Parliament. Ofqual must continue to show that it is prepared
to take vigorous action when needed, in order to help increase
public confidence in the exam system.
(Paragraph 119)
Forthcoming A level reform
17. We
recommend that the Government and Ofqual seek to increase the
involvement of learned bodies as well as universities in the content
of A levels, while allowing exam boards to retain control of question
papers and examination design to ensure best assessment practice.
The Government and Ofqual must also ensure that the whole
of the university sector is consulted on the proposed A level
reforms, as well as schools, colleges, learned bodies and employers.
(Paragraph 128)
18. We recommend that
Ofqual involve national subject committees in the development
of criteria for and accreditation of new A levels. (Paragraph
130)
Market share and price
Changes in market share
19. We
are pleased that Ofqual has recognised the need for closer monitoring
of changes in market share between exam boards and recommend that
it prioritise this work, in order to establish the reasons for
changes at individual qualification level and whether there is
any link to standards. (Paragraph 135)
Examination fees
20. The
area of pricing is complex and Ofqual studies so far in this area
have been limited. This hinders Ofqual from making a robust public
critique of the high costs to schools. We agree with the Government
that reassurance is needed that fees are set at an appropriate
level. Ofqual also needs to demonstrate that overall the charges
made to the public purse by the exam system are fair and appropriate.
We also stress that any changes to the system, in particular a
move to franchising, will need close attention to pricing by Ofqual.
(Paragraph 141)
Support: training and textbooks
Training
21.
We welcome Ofqual's decision to end exam board training on specific
qualifications. Ofqual needs to monitor the impact of its decision
and the activities and materials produced by exam boards to replace
their seminars. We also recommend that Ofqual monitor other training
offered by exam boards, such as marketing events to promote new
syllabuses, and more general training, for example on improving
results, taking further action if needed. Ofqual must ensure that
a school's loyalty to a particular exam board cannot be rewarded
with access to information not available to others. (Paragraph
149)
Textbooks
22. We
are concerned that there is a potential conflict of interest for
examiners involved in question paper setting also writing textbooks
that are linked closely to the same syllabus. We welcome indications
that exam boards may place tighter restrictions on the role of
examiners in textbook authorship. We recommend that Ofqual make
clear the expected future role of examiners in textbook authorship,
in order to ensure a consistent industry-wide approach. (Paragraph
154)
23. We recommend that
Ofqual consider restricting exclusive endorsement arrangements
between exam boards and publishers in future. (Paragraph 156)
24. Ofqual needs to
be satisfied that Pearson has sufficient firewalls in place to
ensure that its publishing and examining activities are separate,
including syllabus development, and to say so publicly. (Paragraph
157)
25. We have serious
misgivings about the language used to market some endorsed textbooks
and would urge exam boards and publishers to move away from marketing
textbooks in this way. (Paragraph 158)
26. We welcome Pearson's
statement that it is moving away from a shared design between
Edexcel syllabus materials and Pearson textbooks, as we agree
that this can unhelpfully overstate the link between the two.
Pearson should give even-handed treatment to Edexcel Own
and endorsed resources from other publishers on the Edexcel website.
(Paragraph 159)
27. In order to strengthen
the links between textbooks and the curriculum, as well as assessment,
we recommend that in future A level textbooks be endorsed by the
universities involved in developing a particular syllabus rather
than by the exam board. At GCSE much will depend on the outcomes
of the National Curriculum review and the ensuing reforms to GCSE,
but a possible way forward might involve learned bodies endorsing
textbooks instead of exam boards. (Paragraph 167)
Ofqual's regulation of exam board support
28.
We agree with Ofqual that the market has not been regulated tightly
enough with regard to training and textbooks and we believe that
this has allowed conflicts of interest to arise. Ofqual's healthy
markets work is welcome, if overdue, as it is clear that many
of the issues raised with us have gone unchecked for some time.
We welcome Ofqual's recent report on exam board seminars and look
forward to its publication of an action plan relating to textbooks
and study aids in September 2012. Proper regulatory control and
scrutiny of these issues will help to increase public confidence
in the exam system.
(Paragraph 169)
29. We recommend that
Ofqual, as part of its healthy markets work, take a clear view
on the broader question about how much exam boards should be involved
in helping to improve results as well as in the impartial assessment
of attainment. (Paragraph 170)
Service: question papers and marking
Question paper errors in summer 2011
30. We
welcome the findings of Ofqual's investigation into the errors
in summer 2011. It is vital that Ofqual acts swiftly and robustly
(including, where appropriate, using its power to fine) in the
event of errors in order to protect the integrity of the system
and the interests of young people. (Paragraph 172)
31. Ofqual must investigate
allegations of improper conduct by exam boards thoroughly, taking
vigorous action if necessary, to ensure that candidates are awarded
the grades they deserve and to protect the integrity of the exam
system. (Paragraph 177)
Reliability of marking
32. We
welcome Ofqual's work to agree a common approach across exam boards
to deal with concerns about marking and to ensure students are
treated fairly across the system. (Paragraph 178)
Online standardisation
33. We
accept that there is some research evidence to show that online
standardisation is as effective as (but, if our reading of the
research is correct, not necessarily more effective than) face-to-face
standardisation. We can also see that it brings other benefits,
such as reduced costs, an accelerated marking process and real-time
monitoring of marking. We believe, however, that exam boards should
continue to monitor the effectiveness of online standardisation
and should consider offering opportunities for face-to-face discussion
between examiners. (Paragraph 181)
Exams and school accountability
The burden of assessment
34. We
have seen no evidence to suggest that having competing exam boards
has contributed to the burden of assessment. The number of exams
taken by young people is linked to Government policy and to decisions
made by schools responding to pressures from the accountability
system. (Paragraph 185)
Early and multiple entries to GCSE examinations
35. We
recommend that the Government ask Ofqual to gather data from the
exam boards to enable it to identify the extent of multiple entry
and then offer advice on whether, and what, action is needed to
limit the practice (Paragraph 188)
Wider changes
36. The
Government should not underestimate the extent to which the accountability
system incentivises schools to act in certain ways with regard
to exams. Sometimes these may be in students' interests; sometimes,
however, they are not. We
recommend that the Government look afresh at current accountability
measures, with a view to reducing the dominant influence of the
measure of 5 GCSE A*-C or equivalent including English and mathematics
and to increasing the credit given to schools for the progress
made by all children across the ability range.
(Paragraph 192)
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