Appendix 1
Government Response
Government's response to 2012 GCSE English results
—Education Select Committee
Introduction
We would like to thank the Committee for its thoughtful
investigation into the events surrounding the awarding of GCSE
English in summer 2012. Those events have been subject to great
scrutiny, by pupils and parents, by schools and by the courts,
as well as the investigations carried out by Ofqual and the exam
boards. The Committee's report is a further helpful contribution
on the factors that resulted in the events of last year, which
caused distress to many pupils, parents and teachers.
We agree with the Committee that we must learn lessons
from last summer's events. We have already taken action to end
modular GCSEs: all pupils completing their GCSEs in summer 2014
will take all their assessments at the end of the course. We have
made clear our wish to see internal assessment reduced to a minimum,
and that is reflected in our consultation on subject content and
assessment objectives for reformed GCSEs. These changes will mean
that the reformed GCSEs will not be so easy to 'bend out of shape',
and will be qualifications in which the public, teachers, further
and higher education, and employers can once again have confidence.
We recognise the pressure that qualifications can
come under from the way in which they are used for accountability,
the consequences of which can be significant for schools. Our
recent consultation on secondary accountability recognised this,
and we will set out our conclusions shortly, before we and Ofqual
finalise the requirements for reformed GCSEs.
We have recently conducted our own analysis of the
extent of multiple entry (where pupils enter more than one GCSE
in the same subject) and its impact on attainment, building on
earlier analysis by the Department and Ofsted of early entry.
This analysis, which has been published by the Committee, suggests
that, for some schools, entry strategies such as early and multiple
entry are common, with the focus often being on how to maximise
the school's 'pass rate' (and therefore its standing in performance
tables) rather than on what is best for pupils' education and
progression. We are very concerned about this and will continue
to consider—with Ofqual and Ofsted—how to safeguard
the integrity of the exams system.
Many of the Committee's recommendations are for Ofqual,
the independent regulator. Like the Committee, we welcome the
actions Ofqual has taken to ensure the standard and integrity
of GCSE examinations—particularly in English—until
our reforms to GCSE can be implemented. We also welcome the steps
that are being taken both by Ofqual and by the exam boards to
improve understanding of and confidence in the system. We agree
with the Committee that the events of last summer—and what
has happened subsequently—demonstrate the importance of
having a strong regulator that is independent of Government and
directly accountable to Parliament.
Conclusions and recommendations
We have confined our response to the recommendations
addressed specifically to the Government.
Impact of change
1. Under the previous Government, GCSEs changed
from mostly linear to modular, which, combined with other changes,
brought turbulence to the system and contributed to the problems
experienced with GCSE English in 2012. We recommend that, when
considering their reforms of GCSEs and A levels, current Ministers
think carefully about the cumulative impact and risks of change.
(Paragraph 30)
Our reforms will lead to much less complexity in
the system so that schools can focus on teaching rather than searching
for an optimum route through the qualification or preparing students
for examinations.
In our response to the Committee's report From
EBCs to GCSEs we acknowledged concerns about the scale and
pace of our proposed reforms. We believe the case for reform is
compelling; young people should have access to qualifications
that give the right recognition for their achievements. We have
shown that we are willing to listen to the advice of others, particularly
the regulator, regarding the impact of change. We have made clear
our intention to phase reforms to both GCSEs and A levels, in
order to balance the compelling case for change against the potential
risks.
On 6 September, Ofqual published an exchange of letters
with the Secretary of State about the next steps for A level and
GCSE reform. The letters set out a revised timetable for the reforms.
Ofqual also published the report by Professor Mark Smith on the
exam boards' subject-by-subject review of A level content requirements.
Professor Mark Smith's report gives a firm foundation
on which to build our A Level reforms and we welcome Ofqual's
commitment to produce new A Levels in September 2015.
Ofqual has advised that the introduction of Mathematics
and Further Mathematics should be re-phased for delivery in 2016.
We agree with their advice given the fundamental importance of
these subjects and the need to learn from Professor Hyland's 16-18
project at Cambridge University.
We have also accepted Ofqual's advice that the development
of reformed GCSEs should be re-phased, with English and Mathematics
brought in for first teaching from 2015 and other subjects introduced
in 2016. English and Mathematics provide the foundation for students'
progression to further study and employment and it is right that
we prioritise the availability of world class qualifications in
these two important subjects.
The re-phasing will enable schools to focus on preparing
for teaching of new English and Mathematics examinations and provide
schools with more preparation time for GCSEs in other subjects.
We will continue to keep schools' readiness to teach new qualifications
under review.
Qualifications design
This section addresses the Committee's recommendations
12 and 25, as listed below.
12. It is clear that warning voices regarding
potential problems were raised but not acted upon during the development
and accreditation phases of the current English GCSEs. While innovation
and change is healthy and essential in any examination system,
one of the crucial lessons that must be learned from this episode
is that Ofqual and Ministers should listen when concerns are raised,
especially when they come from specialists in the field. Balancing
innovation and change with sound, specialist advice is the hallmark
of a robust and high quality examination system (Paragraph 79)
25. The Secretary of State has shown that he is
prepared to act on the advice of the Chief Regulator regarding
changes to the exam system and qualifications. We recommend that
the Government continues to have serious regard to Ofqual's advice
on qualifications design in the forthcoming GCSE and A level reforms.
We also recommend that Ofqual ensures it has systems and procedures
in place for qualifications design which are sufficiently resourced
and appropriately robust to enable it to meet the significant
challenges ahead and to secure high quality qualifications for
young people. (Paragraph 147)
As the Committee notes, the Government has shown
itself willing to heed—and act upon—the advice of
the Chief Regulator regarding changes to qualifications and the
exams system. In developing and implementing reforms to GCSEs
and A levels we will continue to work closely with Ofqual, providing
clear policy steers where it is appropriate to do so and respecting
the statutory responsibilities of the regulator.
Prior to consulting on subject content and assessment
objectives for reformed GCSEs the Government sought confirmation
from Ofqual that its proposals could be regulated effectively.
We will review this following consultation, to ensure that the
qualifications are robust.
Following a process to seek the views of higher education
and learned bodies, chaired independently by Professor Mark Smith,
Ofqual has advised on the changes that can be made to A levels
for first teaching in 2015 (and subsequently). We have agreed
with Ofqual that Mathematics and Further Mathematics requires
more work given the fundamental importance of these subjects.
Both Ofqual and the Government agree that existing
GCSEs are inadequate and that reformed qualifications should be
introduced at the earliest opportunity. However, we accept that
much more rigorous regulatory demands should be put in place and
that Ofqual needs more time to develop them. This has resulted
in our agreed re-phasing of GCSE reforms.
Our programme of examination reform, alongside changes
to the National Curriculum and accountability system, will ensure
that all students are undertaking fulfilling and demanding courses
of study. We recognise that these reforms are ambitious and the
Secretary of State has agreed to make additional resources available
to Ofqual to support the extra work we need to do to complete
the reforms of GCSEs and A levels.
Roles and responsibilities
13. The Government is embarking upon the most
significant and wide-ranging reforms to GCSEs and A levels since
Ofqual was established as an independent regulator and has set
a challenging timetable. We recommend that the DfE and Ofqual
set out in detail their respective roles and responsibilities
in qualifications development, particularly regarding how subject
content will be developed, and publish this information before
their respective consultations on the proposed GCSE reforms have
ended. (Paragraph 87)
We agree with the Committee that it is important
to be clear about the respective roles of the Department for Education
and Ofqual in qualifications reform, bearing in mind the benefits
of the current regulatory model. We set out in our respective
consultation documentation the role of the Government in determining
the subject content of GCSEs and that of the regulator in determining
how that subject content is to be assessed. We will do the same
in relation to future qualifications reform.
Three country regulation
20. Relations between Ministers in England and
Wales are clearly under strain, as the era of three-country qualifications
and regulation appears to be coming to an end. We believe that
such an outcome would be regrettable and hope that even at this
stage the joint ownership of GCSEs and A levels will continue.
We urge Ministers to do everything possible to bring this about,
(Paragraph 125)
We believe that divergence in qualifications policy
between England, Wales and Northern Ireland is a natural consequence
of devolution. It is for each government to decide on the qualifications
it believes are right for its young people. The Welsh Government
has set out its plans for changes to GCSEs in Wales, which will
result in qualifications that are very different from those in
England, with different subject content, structure and assessments.
The Northern Irish Assembly is also considering the future of
qualifications there.
As qualifications policy diverges, there will be
consequences for regulation. Where the differences between the
qualifications in each country are significant, they cannot be
regulated on the same basis without the regulators being forced
to compromise on the setting of standards, which would undermine
confidence in the qualifications. We believe that it is right,
in these circumstances, to be open and honest about the differences,
while continuing to make sure that the qualifications available
in each jurisdiction are recognised by employers and higher education
institutions across the UK and further afield.
Ofqual has advised that it is timely to acknowledge
that three-country regulation of GCSEs and A levels is no longer
tenable. We take this advice seriously. Matters relating to the
effective regulation of qualifications in England, Wales and Northern
Ireland in these circumstances, including the consequences for
ownership and titling of qualifications, are for the regulators
to consider, and we look forward to receiving further advice from
Ofqual.[2]
The investigatory process
24. Ofqual is accountable to Parliament, predominantly
through this Committee. We scrutinise the actions of both the
regulator and the regulated, taking the advice of independent
experts where appropriate. We also make any necessary recommendations
for reform. In the exceptional event that a more wide-ranging
and in-depth inquiry is required, the Government and House of
Commons must ensure that the Committee is adequately resourced
to enable it to investigate the technical processes and procedures
in question. The Government should also commit to a presumption
that any subsequent recommendations made by the Committee will
be implemented. (Paragraph 141)
We appreciate that the Committee may need in exceptional
circumstances to seek expert advice to enable it to conduct an
inquiry of a similarly technical nature in future. We agree that
it is in the public interest that it should be adequately resourced
by the House of Commons; these are matters entirely for the House
and not for Government.
We agree that the recommendations of the Committee
must always be given full and careful consideration. We accept
the general principle that the Committee's recommendations should
be implemented unless there are sound reasons not to do so.
2 Ofqual: Corporate Plan 2013-16 (August 2013) Back
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