This week, a flurry of documents were released by Ofqual and the Department for Education in response to the consultation over what is to replace GCSEs and A-Levels in 2021 I blogged about previously.

In this post, I examine these documents to draw out the main lessons and evaluate them against my own submission to the consultation, which was based on my earlier post. The sources of information I draw on for this post are:

1. A letter (‘Direction’) from the Secretary of State for Education to Ofqual sent to Ofqual on the 23rd February (and published on the 25th).
2. Guidance on awarding qualifications in Summer 2021 published on the 25th February.
3. Ofqual’s new Consultation on the general qualifications alternative awarding framework published on the 25th February, and to close on 11th March.

In my post on 16th January, I concluded that the initial proposals were complex and ill-defined, with scope to produce considerable workload for the education sector while still delivering a lack of comparability. The announcements this week from the Secretary of State and Ofqual have not helped allay my fears.

Curriculum Coverage

The decision has been made by Government that “teachers’ judgements this year should only be made on the content areas that have been taught.” However, the direction from the Secretary of State also insists that “teachers should assess as much course content as possible to ensure in the teachers’ judgement that there has been sufficient coverage of the curriculum to enable progression to further education, training, or employment, where relevant.”

Presumably, these two pieces of information are supposed to be combined to form a grade, or at least the latter modulates the decision over whether a grade is awardable. However, in what way this should happen is totally opaque. Let’s assume we have Student A who has only covered a small part of the GCSE maths curriculum, in the judgement of teachers ‘insufficient to enable progression to further education’ (In what? A-Level maths, or something else? Surely the judgement may depend on this.) However, Student A is ‘performing at’ a high grade (say Grade 8) in that small part of the curriculum. What do they get? A Grade 8? Lower than a Grade 8? No grade? How well will they do compared to Student B who has broad curriculum coverage, but little depth?

The issue of incomplete curriculum coverage has not nearly been addressed by these proposals.

The Return of Criterion Referencing

Several of us made the point in our submissions to the consultation that GCSE grades are norm-referenced, not criterion-referenced (with the exception of Grade 8, 5 and 2, as per the Grade Descriptors). As a result, if national comparability of exams is to be removed, then solid grade descriptors would need to be produced. Several of us suggested that the existence of so many GCSE grades, with such a low level of repeatability between assessors (see, e.g. Dennis Sherwood’s articles on this topic), suggests that grades should be thinned out this year. It seems that the Government agrees with this principle, as they have directed Ofqual to produce ‘grade descriptors for at least alternate grades’. This is good in as far as it goes, but if grade descriptors for only alternate grades are produced – quite rightly – then surely only alternate grades should be awarded!

In addition, if grade descriptors are to be useable no matter what narrow range of the curriculum has been covered, they will necessarily be very broad in nature, further narrowing the precision with which such judgements can be made. I await exemplar grade descriptors with some trepidation.

As I pointed out in my submission, calling 2021 and 2020 results GCSEs and A-Levels just misleadingly suggests comparability to previous years – better to wipe the slate clean and call them something else.

Fairness to Students: Lack of Comparability

One of my main concerns in the original proposal – not addressed in the final outcome – is that of fairness between centres and even between individual pupils in a centre. Centres will be allowed to use work conducted under a wide variety of circumstances, and while they are supposed to sign off that they are ‘confident’ that this work was that of the student without ‘inappropriate’ levels of support, I am not clear how they are supposed to gain that confidence for work conducted during lockdown, for example – which is explicitly allowed. There are many opportunities for unfairness here even within a centre.

Now if we bring in different centres having covered different parts of the curriculum and using different methodologies for quality assurance, the scope for unfairness is dramatic. The problem for students is that such unfairness will be much harder to identify come Summer compared to 2020, when ‘mutant algorithms’ could be blamed.

It seems odd to me that centres are asked to “use consistent sources of evidence for a class or cohort” yet there does not appear to be any reasonable attempt to maintain that consistency between cohorts at different centres. Exam boards will be asked to sample some subjects in some centres to check grades, but given the points I raise above over curriculum coverage it is very unclear how it will be possible to reach the conclusion that the incorrect grade has been awarded in all but the most extreme cases.

The guarantee of an Autumn exam series (as in 2020) is, however, to be welcomed.

Kicking the Can to Exam Boards

It is now the job of exam boards to come up with “a list of those sources of and approaches to collecting evidence that are considered most effective in determining grades” by the end of March. Good luck to them.

Exam boards must also undertake checks of all centres’ internal quality assurance processes before grades are submitted to them on the 18th of June. It is unclear what these checks will entail – I find this hard to imagine. Schools: please do share your experience of this process with me.

Teacher Workload

One of the big concerns I had in my original consultation response was over the increase in teacher workload. One aspect of this has been addressed: unlike in the draft proposals, teachers will no longer be responsible for appeals. However, there is still a very considerable additional workload involved in: getting to grips with the assessment materials released by the exam boards, developing an in-house quality assurance system, getting that agreed by the exam board, making an assessment of students, showing the students the evidence on which this assessment is based (this is a requirement), and submitting the grades, all over the window 1st April 2021 – 18th June 2021. I asked in my consultation response whether additional funding will be made available for schools, e.g. to provide cover for the release time required for this work. No answer has been forthcoming.

The development of an in-house quality assurance system is non trivial. The proposed GQAA framework imposes the requirements for such a system to have:

• ‘a set policy on its approach to making judgements in relation to each Teacher Assessed Grade, including how Additional Assessment Materials and any other evidence will be used,’
• ‘internal arrangements to standardise the judgements made in respect of the Centre’s Learners and a process for internal sign-off of each Teacher Assessed Grade,’
• ‘a comparison of the Teacher Assessed Grades to results for previous cohorts at the Centre taking the same qualification to provide a high-level cross-check to ensure that Teacher Assessed Grades overall are not overly lenient or harsh compared to results in previous years,’
• ‘specific support for newly qualified Teachers and Teachers less familiar with assessment, and
• ‘a declaration by the head of Centre.’

The third bullet point seems logically impossible to achieve. Results this year will not be comparable to previous years as they will be using a different system based on different evidence. So there appears to be no way to check whether TAGs (not CAGs this year!) are comparable to those in previous years.

Private Candidates

Private candidates got a really bad deal last year. This year we are told that private candidates “should be assessed in a similar way to other students”, but that this will be “using an adapted range of evidence”. I’m not completely convinced that these two statements are logically consistent. It will be interesting to hear the experience of private candidates this year.

What about 2022?

It is unfortunate that schools will be left with such a narrow window of time, so we must start to think about 2022 right now. However, I note that in the current Consultation on the General Qualifications Alternative Awarding Framework, there is scope for whatever is decided now to bleed into 2022: ”We have not proposed a specific end date for the framework because it is possible some measures will be required for longer than others. Instead we propose that the GQAA Framework will apply until we publish a notice setting an end date.”

All the more reason to get it right now.