Education CommitteeWritten evidence submitted by the Federation of Awarding Bodies

Executive Summary

The Federation of Awarding Bodies believes that teachers and their learners are best served by allowing a competitive market to operate, subject to rigorous independent regulation by Ofqual and, in the case of GCEs and GCSEs, to common qualification and subject criteria. We agree that the aspiration should always be for error free examinations but this is a significant challenge given the thousands of questions that have to be produced each year. In relation to awarding body commercial activities, FAB believe that these properly support the teaching and learning associated with the qualifications and therefore are seen as beneficial by teachers and learners.

Introduction

1. The Federation of Awarding Bodies is the trade association for vocational awarding bodies with over 130 organisations in membership ranging from large generic awarding bodies to those working in specific occupational areas, including professional bodies. Our members provide vocational qualifications to the full range of providers - employers, training providers, schools and colleges. We do not seek to represent their interests in relation to academic qualifications – GCEs and GCSEs - which is a role taken by the Joint Council for Qualifications (JCQ). Although the focus of the Select Committee’s inquiry largely falls outside the Federation’s area of work, we have an interest in the Committee’s deliberations and wish to make the following submission for your consideration.

The Arrangements for Awarding Bodies in England

2. When considering the number of awarding bodies delivering General Qualifications to 15 to 19 year olds, the arguments for healthy competition will often be countered by concerns about the consistency and level of quality standards. The Federation believes that the qualifications industry should be as open and competitive as any other and that the well rehearsed benefits of competition should be made available to customers in this market. Equally we acknowledge that this is a market where the products – the qualifications – are critically important for individual learners, for the schools and colleges, for employers and ultimately the Government and, as such, we accept that independent regulation by Ofqual provides a necessary oversight of the awarding bodies operating in this market.

3. As the Department for Business, Innovation and Skills (BIS) states: “competitive markets provide the best means of ensuring that the economy’s resources are put to their best use by encouraging enterprise and efficiency and widening choice”. FAB believes that competition between awarding bodies is a driver of performance and innovation and delivers the theoretical benefits of competition in the qualifications industry which can be summarised as:

a discipline to keep costs down and keep prices low: an example of this is the fact that awarding bodies absorbed the cost of moving all their qualifications to the Qualifications and Credit Framework (QCF) which ran into tens of millions of pounds rather than pass this cost through to schools and colleges

greater use of technology to provide improvements: we have seen this both in qualification and assessment design and in awarding bodies interaction with their customers, as demonstrated by significant investments in web-based tools and developments such as faster handling of examination scripts

a high level of quality of service and support (including after-sales service) : shown by the substantial amount of free support and training made available on-line and face-to-face to teachers and other staff by awarding bodies

the availability of a variety of products providing choice: While the General Qualifications have to be developed to defined subject and qualification criteria, awarding bodies translation of these into qualifications provides a choice of approaches that allows teachers to purchase the qualifications and associated support that best suits their own teaching expertise and style and the interests and learning styles of their pupils.

4. The Federation believes that the principles of quality of content and assessment, consistent standards, cost effectiveness and accountability, quality of service and choice remain central to qualifications and that these continue to be delivered by having an element of competition offered by having three major awarding bodies operating in England.

5. At a time when the Government’s expressed intention is that the National Curriculum review should lead to a slimmed down curriculum with the ability for schools to “have greater freedom to construct their own programmes of study”, we believe that this freedom would not be effective if there were to only be one specification for each subject at GCE and GCSE.

6. It is clear that teachers and their managers value choice and many exercise their ability to switch awarding bodies when new GCE and GCSEs are developed and, to a more limited extent, between the main changes in specification. The three awarding bodies compete vigorously for these markets, ensuring that a full range of support material is available to support teachers and others who adopt their version of the GCSE or GCE.

7. The Federation believes that it would be useful for the Select Committee to explore the ways in which staff in schools and colleges make their decisions about purchasing qualifications. In our experience this is a complex decision making process involving a number of factors including the content of the specification, the support material available, the training provided by the awarding body, the customer service offered and the price.

8. FAB acknowledges that an open competitive market in such a critical area as education should be subject to strong independent regulation which is now in place with the establishment of Ofqual. They have a remit to regulate awarding bodies and in order to ensure that:

(i)regulated qualifications give a reliable indication of knowledge, skills and understanding, and indicate a consistent level of attainment;

(ii)regulated assessment arrangements are developed and implemented which give a reliable indication of achievement and indicate a consistent level of attainment;

(iii)public confidence in regulated qualifications and regulated assessment arrangements is promoted;

(iv)there is the promotion of awareness and understanding of the range of regulated qualifications available and their benefits; and

(v)regulated qualifications are provided efficiently and in particular that any relevant sums payable to a body awarding or authenticating a qualification in respect of which the body is recognised represent value for money.

9. These objectives are far-reaching and will act as a powerful limitation on any perceived drift towards any of the more unhealthy aspects of competition, including downward pressure on quality and standards.

10. The use of technology to deliver improvements and efficiency has been released in the qualifications industry with the introduction of improved services to schools and colleges and their learners. These range from the electronic data exchange to the release of results on-line, from techniques to speed up the handling of scripts to the level of feedback on performance offered to teachers.

11. The Federation questions whether a single national examination board would have the incentive to invest in these ground-breaking technological advances and wonders whether these developments would be seen as a priority when competing for public money with all the other Government IT projects. Further if a single organisation were to be responsible for all the examinations in England this would concentrate the risk of a system failure with significant implications, particularly close to the results time.

12. When the possibility of moving to a single awarding body was considered in 1997 in the DfE consultation on “Guaranteeing Standards”, there was broad support at that time for a rationalisation of awarding bodies to the current three unitary bodies (this from having had some 20 Boards in the 1980s) but only 7% of respondents favoured a move to only one awarding body. The view was that choice and consistency of standards are the primary principles that should underpin the development and offer of qualifications. In 2002, Sir Mike Tomlinson stated that the evidence given to his “Inquiry into A level standards” indicated that these arguments were still valid and the Federation has no reason to believe that this situation has changed significantly since then.

13. The Select Committee has suggested that an alternative arrangement could be the “franchising” of examinations in different subjects to examination boards. We envisage that this would ensure fierce competition between awarding bodies in order to gain the contract(s) for each subject or groups of subjects at the time that they come up for tender. This might lead to downward pressure on fees initially and promote innovation when the contract is first awarded but there would be little incentive to continue this in the middle and latter years of any contract. The Federation also wonders who would contract manage this arrangement and how this would relate to Ofqual’s role as an independent regulator and whether this would result in additional costs that would have to be borne by the State.

14. In such a contract management approach, it would be open to the Government to limit the contract period, for example to two years, in an attempt to encourage the contract holder to continue to deliver the benefits seen in a normal competitive market. However in the qualifications market this has a number of disadvantages. These include:

(i)the adverse impact on teachers and learners of a frequent change of contractor leading to changes in the qualification and associate support material and the lack of certainty for school and college managers when planning their curriculum offer;

(ii)the lack of willingness of the contract holder to take on and put in place unforeseen changes that result from shifts in Government policy (such as the current year on year changes in some GCSEs) with the consequent added costs. Given that the contractor could not rely on regaining the contract when it was next issued, they would need to recoup any investment within the life of the contract and not over a longer time period as awarding bodies do now;

(iii)the significant amount of work and associated cost for awarding bodies that is inherent in operating within a contract market and whether this would prove cost effective especially if there was a possibility of major change during the life of the contract (eg in the event of a General Election or if a major review into education was underway at the time of tendering. Similarly in relation to minority subject areas the costs may outstrip the potential income; and

(iv)if the contracts were to be let for particular subjects eg History, it would not be possible for each awarding body to maintain the necessary experts over the period when they do not hold the contract for this subject. Therefore these experts would be either subject to TUPE or lost to the system at the point at which the contract moved to another awarding body.

Ensuring Accuracy in Setting Papers, Marking Scripts and Awarding Grades

15. FAB notes the Ofqual’s Interim report of their Inquiry into the Examinations Errors – summer 2011, states that they have found awarding bodies “already working hard to implement measures to improve the quality of examination papers both in the shorter and longer term. These measures include: further checks of papers; the recruitment of additional expertise in proof reading; the audit of external suppliers quality assurance processes and additional training for staff and examiners.” We are sure that Ofqual will do whatever is possible to ensure accuracy in the setting of examination papers in the future.

16. The Federation does question the extent to which the production of examination papers can be 100% error free. We agree that this should always be the aspiration but the sheer number of questions developed across the system (over 60,000 in General Qualifications alone) and the fact that these are developed by people rather than machines, would suggest that some errors are inevitable. It may be that we can collectively draw on some of the techniques that are used in other industries around this aspect, such as Human Error Rate Prediction, and link this to the use of appropriate quality systems to ensure that the error rate is as low as humanly possible. It would then be critical to have streamlined appropriate processes in place to a) identify any errors as early as possible, b) mitigate the effect of these c) communicate this clearly to centres and candidates and d) ensure that lessons are learnt and carried through to the processes in the future.

17. In relation to marking scripts and awarding grades in GCEs and GCSEs, Ofqual’s regulation currently operates in a number of ways to oversee these processes. This includes the recent introduction of recognition of the awarding body as an organisation and the requirement for on-going compliance with detailed Conditions, which is in line with regulation in other regulated industries.

18. Additionally Ofqual is responsible for the standards as set out in the qualification and subject criteria, and they then approve (accredit) each awarding body to offer each qualification/examination which includes seeing sample examination papers and mark schemes and the full detail of their processes and systems. Ofqual staff will also attend a large number of the meetings that determine the awarding of the qualifications including the grades. Our colleagues who offer these qualifications will no doubt supply the Select Committee with more detail in this regard.

The Commercial Activities of Awarding Bodies, including Examination Fees and Textbooks, and their Impact on Schools and Pupils

19. As General Qualifications have substantially larger learner numbers on each qualification than we see on vocational qualifications, the Federation is not in a position to comment about the commercial activities in relation to these qualifications or the business models that underpin them.

20. It is relevant to note that awarding bodies are all private organisations with the vast majority also being charities and, apart from a very few, those that are not charities operate as “not-for-profit” businesses. Awarding bodies make their decisions about providing material and textbooks that support teachers and learners following their specifications within this context. In the case of qualifications with smaller numbers of learners, commercial publishers do not usually have an interest in producing textbooks or other material, whereas the awarding bodies will see it as part of their total offer to the schools and colleges.

21. In relation to examination fees, Ofqual has a statutory responsibility to ensure that these represent value for money and have various regulatory powers in this regard. Through the criteria for recognition as an awarding body and the Conditions of Recognition, Ofqual has set out a number of requirements on awarding bodies that relate to the fees and the related interaction with schools and colleges, such as invoicing. The Federation believes that this regulation is more than adequate to protect providers and learners.

November 2011