Education CommitteeWritten evidence submitted by the National Association of Headteachers (NAHT)

(i) The current arrangement of having several awarding bodies is often referred to as a “market” but the arrangements have characteristics that render the use of this term problematic. In a conventional market competitors can base their marketing on absolute outcomes but, clearly, an awarding body cannot make a comparable claim by, for example, pledging more C grades.

(ii) Players in the market must therefore compete by developing a reputation for quality of service and by product differentiation. The former includes such elements as speed of response to queries, quality and availability of guidance and support materials, perceived accuracy of marking and appropriately targeted and effective in-service training.

(iii) The argument in retaining the present structure is that this competition is a driver for ensuring and maintaining the quality of service and provision. The radical policy of having one national body could, arguably, only incorporate one of the elements listed above: product differentiation. By word of explanation, this refers to offering a range of specifications for a given subject.

(iv) A counter-argument might run along the lines that quality assurance measures would be built into new structures. However, this raises the key question of whether regulation can compensate for, match or emulate the responsible operation of market forces.

(v) Extending the market metaphor, it could be argued that the dominance of a few providers, certainly in meeting the needs of schools, runs the risk of a cartel emerging. NAHT members do not appear to believe that this is the case and there appears to be confidence that the current regulatory arrangements provide the necessary framework for precluding this from occurring.

(vi) However, there are concerns expressed by some members that there are some barriers to competition within the current system. The ability to choose what is perceived to be the most appropriate specification for a particular group of learners can be constrained by the costs of switching from one specification to another if this would require purchasing text books specifically written for a given specification.

(vii) The issue of text books is one that is a matter of concern for some NAHT members. There is a perception that examiners and chief examiners are able to benefit from writing texts. NAHT believes that there may be something of the “urban myth” surrounding this perception. The Association is aware of, for example, the strict guidelines operated by one awarding body that prohibits those in such positions from publishing texts that include references to their status as examiners. NAHT believes that there is a strong case for greater transparency in this matter.

(viii) However, the possibly erroneous perception regarding a “droit de seigneur” for examiners to publish text books does not lessen the concern felt about the tie up between some specifications and texts.

(ix) Further to this matter, the point should be made that schools do not tend to change specifications on a frequent basis. There is an interesting tension between continuing with a specification that teachers, using their professional judgment, believe to be the best-suited to meet the needs of pupils in their school and the dissatisfaction, inconvenience and irritation experienced when the service aspects of provision do not meet expectations. It is suggested that the tipping point comes when a perception emerges that the quality issues are compromising the integrity and quality of assessment.

(x) To the best of NAHT’s knowledge there is not a body of evidence that seeks to explain how schools arrive at the judgment that a particular specification is right for a particular cohort of pupils. The Association is prepared to stand corrected if wrong in this view. If such research exists it could usefully shed light on the focus of this inquiry. If it doesn’t, NAHT would venture that research of this nature would be beneficial in developing a fuller understanding of how consumer decisions are made.

(xi) To summarise, NAHT members do have some concerns about the current structure. However, the Association remains unconvinced that radical solutions such as having one national body or a franchise system would provide a solution. The production of examination papers and associated materials is a complex and organic process. Awarding organisations have well-established and sophisticated research and development operations informing provision. It is difficult to envisage how this could be replicated under the alternative arrangements suggested. This is particularly the case with a franchise system.

(xii) A further potential problem with a franchise system is envisaging how potential participants would be attracted. The examinations “business” is one that requires an established corpus of expertise. Perhaps the reality would be that the existing players would specialise in given areas. However, franchises have – in theory – a limited shelf life and it could be the case that this uncertainty would act as a disincentive to entry.

November 2011

Prepared 2nd July 2012