Conclusions and recommendations
1.We welcome Ofqual’s commitment to publish a full programme of evaluation in the autumn. Until it does so, we will not have answers about the fairness of the system. (Paragraph 19)
2.Ofqual’s evaluation must include comprehensive data on attainment, by characteristics including gender, ethnicity, SEND, children looked after, and FSM eligibility, providing full transparency on whether there are statistically significant differences between attainment this year compared with previous years. (Paragraph 20)
3.Given the potential risks of bias in calculated grades, it is clear that standardisation will be a crucial part of ensuring fairness. We are extremely concerned that Ofqual’s standardisation model does not appear to include any mechanism to identify whether groups such as BAME pupils, FSM eligible pupils, children looked after, and pupils with SEND have been systematically disadvantaged by calculated grades. (Paragraph 26)
4.Ofqual must identify whether there is evidence that groups such as BAME pupils, FSM eligible pupils, children looked after, and pupils with SEND have been systematically disadvantaged by calculated grades. If this is the case, Ofqual’s standardisation model must adjust the grades of the pupils affected upwards. (Paragraph 27)
5.Ofqual must be completely transparent about its standardisation model and publish the model immediately to allow time for scrutiny. In addition, Ofqual must publish an explanatory memorandum on decisions and assumptions made during the model’s development. This should include clearly setting out how it has ensured fairness for schools without 3 years of historic data, and for settings with small, variable cohorts. (Paragraph 28)
6.Ofqual must collect and publish anonymised data at the conclusion of the appeals process on where it received appeals from, including, as a minimum, type of school attended, region, gender, ethnicity, SEND status, children looked after (including children supported by virtual schools), and FSM eligibility. (Paragraph 29)
7.As part of its evaluation Ofqual must publish comprehensive data on vocational and technical qualifications, by characteristics including gender, ethnicity, SEND, children looked after, and FSM eligibility, providing full transparency on whether there are statistically significant differences between attainment this year compared with previous years. (Paragraph 33)
8.Where calculated grades are used to award vocational and technical qualifications this year, Ofqual must identify whether there is evidence that groups such as BAME pupils, FSM eligible pupils, children looked after, and pupils with SEND have been systematically disadvantaged by calculated grades. If this is the case, Ofqual’s standardisation model must adjust the grades of the pupils affected upwards. (Paragraph 34)
9.We are extremely concerned that pupils will require evidence of bias or discrimination to raise a complaint about their grades. It is unrealistic and unfair to put the onus on pupils to have, or to be able to gather, evidence of bias or discrimination. Such a system also favours more affluent pupils and families with resources and knowledge of the system. (Paragraph 41)
10.Ofqual must urgently publish the evidence thresholds for proving bias or discrimination, clearly setting out what evidence will be required, including example case studies. This must be communicated to parents and pupils in advance of results day. (Paragraph 42)
11.Where pupils with SEND, or their families, have concerns about their grade, they must be allowed to see the evidence, such as past work or mock exams, used by teachers to arrive at their calculated grade. If appropriate access arrangements were not in place for the work used, or if their school did not use evidence from SEND specialists if this was appropriate, the pupil must be allowed to appeal on the basis of malpractice or maladministration. (Paragraph 43)
12.Both Ofqual and the National Careers Service will be offering helplines to provide support and advice on and after results day. Two helplines must not mean a two-tier system. It is imperative that whichever number pupils ring, they will be provided with the same gold-standard, professional advice. (Paragraph 44)
13.Ofqual must ensure advice and support is easily accessible for all pupils unhappy with their grades. Both the helplines provided by Ofqual and the National Careers Service must be freephone lines. These must both be staffed by dedicated professionals with the training to provide sound and impartial step-by-step advice and support on appeals. (Paragraph 45)
14.Ofqual must issue guidance to schools and colleges about the options available for pupils unhappy with their results. Letters to pupils should be sent out by schools and colleges, to ensure they are aware of their options, including the standard of evidence required to bring an appeal on the basis of bias or discrimination. Schools and colleges should clearly communicate to pupils and families which staff member will be their point of contact for discussions about next steps. (Paragraph 46)
15.Fairness and accessibility must be the guiding principles of an autumn exam series. Having directed Ofqual to provide pupils with “an opportunity to sit an exam at the earliest reasonable opportunity”, the Department must not now wash its hands of further responsibility. (Paragraph 49)
16.The Department must provide guidance for schools and colleges, outlining minimum requirements for provision of teaching support for pupils opting for an autumn exam. The Department must support schools and colleges to manage the logistics of this series, providing concrete solutions on how the burden of an additional series can be minimised. (Paragraph 50)
17.As at 30 June 2020, Ofqual has merely stated it will “confirm the exact timing of the exams in due course”. We believe that given the potential disruption for schools and colleges, and the need for pupils and teachers to know, now, when their exams will take place, this is not good enough. (Paragraph 52)
18.Ofqual must urgently publish dates for the autumn exam series and end uncertainty for pupils, teachers, schools and colleges. (Paragraph 53)
19.We believe that modifications to assessments will lead to erosion of standards, and that the 2021 cohort of exam-takers could be disadvantaged by a perception that their exams were not as rigorous as those taken by other cohorts. (Paragraph 55)
20.We support a short delay for exams in summer 2021 as preferable to modifications to exam content. Any delay must be a matter of weeks, not months. Ofqual must publish details of the 2021 exam series as soon as possible, and before the end of the summer term. (Paragraph 56)
21.The pandemic’s impact on learning loss does not stop when pupils turn 16. Post-16 learners, whether they are resitting key English and Maths GCSEs, or preparing to sit final exams before entering higher education or the workplace, deserve proper catch-up support. (Paragraph 58)
22.The Government must extend catch-up funding to include disadvantaged post-16 pupils to ensure this is not a lost generation. This should be done by doubling the disadvantage element in the 16–19 funding formula for pupils in Year 12, for at least the next year. (Paragraph 59)
23.Any post-16 pupils attending Alternative Provision and Pupil Referral Units, and those training for basic skills, must also be eligible for catch-up funding. (Paragraph 60)
Published: 11 July 2020