Education CommitteeWritten evidence submitted by the Department for Education (DfE)


1. We welcome the Committee’s Inquiry, which is timely in two key respects:

There is a danger that confidence of candidates in the qualifications they are taking is falling. Too many serious errors were made in GCSE and A Level exam papers this summer. The awarding bodies—overseen by Ofqual—must put in place better systems to ensure no repetition of such problems.

Confidence among universities and employers in the rigour of key qualifications has fallen. In recent years market incentives have failed to ensure that developments in some key qualifications meet the needs of end users.

2. A high quality qualifications system must meet two criteria:

The qualifications concerned have the confidence of end users in how they assess students’ knowledge, skills and understanding following the study of an appropriate curriculum: in other words, qualifications with the right content and rigorous assessment;

and these are underpinned by efficient and effective delivery mechanisms that have the confidence of candidates, characterised by students receiving the right papers at the right time with the results accurately reflecting their achievements.

Importance of the qualifications system

3. A key role for qualifications is in supporting progression to further education or training and work. Results allow judgements to be made as to how well candidates have performed in their studies and how well prepared they are to move on: both in absolute terms and relative to their peers; and in this country and overseas.

4. Qualifications should not necessarily be seen as a key driver for the quality of teaching in the classroom. But their importance to pupils means that they run the risk of putting barriers in the way of good teaching, by placing a de facto cap on ambition if they do not recognise the most rigorous aspects of a subject.

5. Qualification results are also an important proxy measure for the effectiveness of schools and colleges. If qualifications lack the necessary rigour or are testing the wrong things, results will give misleading signals about where educational performance needs to improve. And parents, pupils and communities will be less able to hold schools and colleges to account for how well they perform. Professor Wolf laid bare in her report1 on vocational education just how significant a problem this has been. There are some good quality vocational qualifications which are respected and have currency in the labour market. But the number of vocational qualifications taken in schools up to age 16 has grown dramatically in recent years, from 15,000 in 2004 to 575,000 in 2010, and far too many of these are either of poor quality or are not appropriate for young people. Young people have therefore been studying courses which are not of real worth and do not enable them to progress. This is why we are implementing Professor Wolf’s recommendations for change as a matter of urgency.

6. Given the importance of the qualifications system, it is imperative that we have excellent, internationally renowned qualifications that are delivered efficiently and effectively. We will be securing significant changes to the content of GCSEs and A levels to ensure they are appropriately geared to this country’s needs and so that they stand up better in comparison with other countries. We are also—in the light of the Wolf Report—making major changes to the performance regime relating to the use of vocational qualifications, so that the qualifications used most widely in schools and colleges are those that are best for young people. Drawing heavily on evidence from the world’s best education systems, we will be reforming:

the National Curriculum, so that it sets out only the essential knowledge and understanding that all children should acquire and leaves teachers to decide how to teach most effectively;

GCSEs, so that they reflect where relevant the new National Curriculum and focus on essential knowledge in key subjects;

A Levels, so that universities and learned bodies are more fully involved in their development, ensuring that they measure up against the most rigorous qualifications systems and meet the needs of Higher Education; and

school and college performance measurement systems, so that these set out our high expectations—every pupil should have a broad education, for example through the English Baccalaureate—and only the highest quality vocational qualifications should be recognised in performance tables.

7. We are also concerned that increases in the numbers getting higher grades in GCSEs and A Levels have undermined the confidence of employers and Higher Education in the rigour of those qualifications. For example over the last 15 years, the proportion of pupils achieving at least one A at A level has risen by approximately 11 percentage points. In 2010, more than 34,000 candidates achieved three As at A level or equivalent. Research by Robert Coe and Peter Tymms at Durham University2 concluded 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. These findings raise important questions about grading.

8. We are therefore complementing the reforms to the content of qualifications with changes to required assessment approaches, so that standards are measured more rigorously: through structural change to qualifications (for example, limiting GCSE exams to the end of a course); and through changing Ofqual’s statutory objectives so that they have to seek to secure consistency with qualification standards overseas, not just standards over time. We also welcome the initiative that Ofqual is taking to acknowledge and tackle the issues around standards and public confidence in exams; including through using its new powers to regulate more strategically under its founding legislation (see paragraph 17 below).

9. We will need to reassure ourselves, however, that these changes are indeed enough to deliver qualifications with the content and rigour necessary.

10. In parallel with these changes to the content and assessment methodology, we need to understand how the delivery mechanism can best support these reforms and make changes accordingly. High quality qualification specifications must be matched by efficient machinery for the actual delivery of qualifications. The challenges are significant, for this is a complex, high volume, high stakes system involving schools and colleges throughout the country. To take A Levels and GCSEs3 for example, during last summer’s exam series:

over 2.5 million GCE AS and A level awards were made;

over 5.5 million GCSE qualifications were awarded; and

c 15.1 million scripts were marked.

We look to Ofqual to monitor closely whether the system is delivering the standards that the public would rightly expect; to be quick to intervene where (as was the case last summer) it is not; and to alert us when we too need to take action (as we have for example over legislating to give Ofqual extra sanction powers—see paragraph 17 below).

The benefits and drawbacks of having several awarding bodies

11. The qualifications system has a long history, with roots in the university sector, industry and trade associations. 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. The Government believes in the effectiveness of the market in delivering the right quality products and services efficiently, with appropriate regulation where necessary to address market failure. However, qualifications play such an important role for individuals and for society that it is right to ask whether the current delivery mechanism is as effective as it needs to be and whether other options would result in a more secure system that delivers the best educational outcomes. The overriding priority has to be the effectiveness and integrity of the qualifications system in practice, because so much else depends upon it.

12. In principle, the current market approach to the development and delivery of qualifications provides a range of potential benefits, notably the following:

There are incentives for awarding bodies to offer choice for students, schools and colleges (so that for example a range of syllabuses can meet the diverse needs of students, employers, universities, etc); to deliver qualifications that meet the needs of end users—employers, colleges and universities; to have syllabuses that keep pace with subject change; to innovate, for example over the use of technology in assessment; to provide excellence in the quality of the service provided to schools and colleges; and to provide efficiency, in particular through competition over price.

There is resilience in the case of delivery failure—the risk is spread between a number of providers. (We have seen in recent years examples overseas where a single State supplier has been involved in delivery failures, with an impact on very large numbers of students.)

The risks of qualification reform are shared between the State and the awarding bodies.

GCSEs and A levels are independently regulated and developed and therefore they have credibility outside the State sector, with independent schools and universities: they are typically the qualification of choice even when there are other options available.

There are also some particular advantages associated with the current system. Many such qualifications are widely used and respected around the world; and the awarding bodies concerned—often (as we have noted above) with their origins in universities—have a long-established reputation.

13. Where market failure may be creating tensions over achieving the outcomes that are in the public interest, regulation may be needed. The qualifications market presents some very real risks of this kind. The errors in exam papers this summer (see paragraphs 19–20 below) are a good example, but there are also long-term trends which are just as worrying.

14. The chief such risk of market failure with qualifications is in relation to standards—the so called “race to the bottom”. Central to our concern is that the nature of competition seems to present significant risks of awarding bodies producing more “accessible” specifications, with content which is less intrinsically challenging, in order to capture market share. To understand whether this is happening one must look not just at the qualifications themselves but also at the context in which they are purchased and taught. Perverse incentives in the performance tables, the structure of examinations, modularisation and re-sits, and support materials for teachers, all influence the level of demand in a qualification. That is why, for example, the Government and Ofqual have acted to reform performance tables and end modularisation in GCSEs.

15. We also need to ensure that the qualifications market is working efficiently. Competition should deliver some upward pressure on service quality and downward pressure on price; but it is costly for a school or college to switch between awarding bodies, and entry to the market for new organisations requires substantial investment in delivery infrastructure.

16. We have the benefit of a new regulator in Ofqual, with a key role in regulating the market, particularly for GCSEs and A levels. It is charged with ensuring that awarding bodies operate in ways that best serve the public interest.

17. Ofqual is a relatively new body, enjoying full independence only since April last year. It has made a very significant impact over a short period, notably in its timely and robust response to the exam paper errors in the summer. As we noted in paragraph eight above, Ofqual has also begun to show a real willingness to tackle awarding bodies on the key issue of standards. We are looking to Ofqual to help deliver the kind of improvements to the qualifications system—to both the standards of the qualifications, and to the systems for delivery—that need to be made. We have full confidence in Ofqual and its leadership to transform the system and restore confidence. To support Ofqual, we are legislating to give it extra powers to sanction those awarding bodies that fall short of the required standards, to deter poor practice and to punish if it does occur. Ofqual itself has recently put in place a robust new regime of strategic regulation, using the powers given to it by its founding legislation; and it is working on a better understanding of the “health” of the market in targeting its regulatory interventions. Some very significant changes are being made towards a more efficient and effective regulatory regime that will help ensure outcomes that are in the public interest.

18. Our overriding interest in considering the qualifications market and its regulation is securing the credibility of and confidence in the qualifications system; and that is the criterion we will apply in deciding what changes are appropriate.

Ensuring accuracy in setting papers, marking scripts and awarding grades

19. The scale and nature of last summer’s awarding body errors over GCSE, AS and A level papers were unacceptable. Twelve question papers contained significant errors that made it very difficult or impossible for candidates to answer certain questions. 138,000 papers were affected. Were it not for Ofqual’s intervention, with our full support, the impact on students would have been even worse; with inevitable implications for confidence in the system. The awarding bodies concerned need to ensure that errors of this seriousness do not happen again. We must have a highly reliable system: a low error rate overall is no comfort to the thousands of young people who are caused great and justified anxiety about their futures when mistakes are made.

20. We warmly welcomed the action taken by Ofqual during the exam season to minimise the impact of the errors; and the work that it and its fellow regulators in Wales and Northern Ireland have done to identify the lessons that must be learnt. We support both the action that Ofqual and its fellow regulators set out in the interim report on their investigation4 published on 31 October and the areas for further enquiry that they have identified.

21. The qualifications system must ensure that assessments are marked consistently and accurately. It falls to Ofqual to lay down the requirements of the marking system and to ensure that awarding bodies discharge their responsibilities over marking accordingly. We recognise that no large-scale marking system of this kind can be entirely error-free, but with so much at stake we look to the awarding bodies to ensure that students are awarded the marks their achievements deserve, first time (ie without recourse to the appeals system). We strongly support Ofqual in its work to ensure that the system is indeed robust and fair.

The commercial activities of awarding bodies, including examination fees and textbooks, and their impact on schools and pupils

22. The qualifications market is large and has grown significantly in recent years. In Ofqual’s 2010 Annual Qualifications Market Report,5 it gave an indicative figure of at least £933 million for the total annual revenue of the qualifications sector (pre- and post-19) that it regulates: with £281 million spent by schools and £173 million spent by colleges. This includes £219 million spent on procuring GCSEs and A levels and £614 million spent on other regulated qualifications.

23. Given this context, we welcome the Committee’s interest in the commercial aspects of awarding body behaviour. We have seen a shift in awarding body behaviour in recent years towards a more commercial approach and diversification into areas like publishing and training. In all their activities awarding bodies need to strike the right balance between what is in their commercial interest and what is in the public interest. We would expect this to be evident in every aspect of their business decisions. We would for example expect them to continue to recognise the educational importance of qualifications in certain subjects even if the take up (and therefore profit to be generated) is relatively low.

24. Expenditure on exams including exam fees is one of the most significant calls on school and college budgets; and for a range of reasons the sums have been growing in real terms, as has the percentage of budgets that this represents. Expenditure on examinations and assessments in secondary schools for example accounted for nearly eight per cent of running expenses (non-staff costs) in 2009–10 compared with around six per cent in 2002–03. This makes such expenditure the second largest non-staff cost for secondary schools.


















25. Exam fees are met from the public purse and represent money that could otherwise be spent on teaching. We must therefore reassure ourselves that fees are at an appropriate level. Awarding bodies should be setting fees that give a reasonable return on their investment, given the risks they face, but do not generate excessive profit. We must also eliminate any waste in spending on qualifications, for example by schools and colleges minimising the fees associated with late entries. Key to ensuring the right outcomes is Ofqual’s ability to regulate the market effectively, and one of its statutory objectives relates to ensuring that qualifications are provided efficiently and that exam fees represent value for money.

26. The links between awarding bodies and textbooks is an area where there can be a tension between what is in the public interest and what would be in an organisation’s commercial interest. On the one hand, teachers and students require high quality textbooks and related material and awarding bodies are well placed to help meet this need. On the other, certain types of textbook can promote risk-averse teaching focused on what may be assessed, rather than the fuller picture and the promotion of a real love and understanding of a subject. Textbooks associated with awarding bodies are likely to be particularly attractive to schools and colleges, so such material must be of high quality educational value rather than a product that incentivises “teaching to the test”. It is essential that the barriers to entry to the market are not unduly high, and that potential new entrants compete on equal terms with existing awarding bodies when it comes to the production of textbooks and similar material. Links between awarding bodies and textbooks also raise issues about whether there are inappropriate conflicts of interest because of the risk that these make (or may be perceived to make) questions in exams more predictable. The same issue arises in relation to other activities including training, for example chief examiners offering exams training to teachers.

27. To protect public confidence in the system, we need the highest possible ethical standards combined with a fully transparent system. Ofqual has a remit to keep under review activities by awarding bodies such as involvement in the publication of text books, and has in place a regime for managing conflicts of interest. It also takes a very close interest in the quality and security of assessments. Ofqual has acknowledged that more work is needed in this area.


28. The Committee’s Inquiry will be addressing a range of key issues over the qualifications system. We look forward to the Committee’s findings as a contribution to policy development.

November 2011

1 Review of Vocational Education—The Wolf Report; March 2011

2 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, p 97.

3 The figures relate to England, Wales and Northern Ireland.

4 Inquiry into Examination Errors Summer 2011 Interim Report; October 2011; Ofqual/11/5073

5 Annual Qualifications Market Report, Version Two; August 2011; Ofqual/11/4854

6 Taken from Department for Education England outturn summary tables at
nding/section251/archive/b0068383/section-251-data-archive/summary-level-la-outturndata- reports

Prepared 2nd July 2012