Ofqual should not have double standards

One thing an assessment regulator should definitely not have is double standards; it undermines the core of their existence.

We’ve just emerged from a lively FE week Annual Apprenticeship Conference with much debate and concern about the disruption that the current process will cause without providing any significant benefit to the employer, learner, quality or apprenticeship numbers.

The thing that rocked me the most at AAC was the attitude of Ofqual. If the statements made by the Chief Regulator are the genuine views of the Ofqual, then I am very disappointed.

The thing that rocked me the most at AAC was the attitude of Ofqual

I am hoping it was just a misunderstanding of the issues. However I started to doubt it when reading an interview with the Chief Regulator on Friday in which there was no mention of anything other than academic qualifications. She talks about not really knowing about the 2012 English GCSE crisis until being in the role. Having lived through it and sat in front of four select committees, I have the scars of the assessment sector being challenged. 

There are two areas of concern I have and when I reflect on my experience at OCR during the development of GCSE and A-Levels, I start to wonder whether we are witnessing yet another shocking example, and possibly the worst, of “it won’t matter about those kids – they are just doing vocational qualifications”.

Most shockingly, was the Chief Regulator’s statement at the FE Week conference that the lack of an assessor in place to carry out the final apprenticeship exams wasn’t an issue. She said, “No, I don’t think the DfE is irresponsible”. I am stunned. At what point has the qualifications regulator decided that it is fine to start teaching and training against a curriculum without any idea what the assessment is going to be? While I can list one hundred reasons why this is wrong for an assessment viewpoint, let’s just think about the trainers, teachers and students.

I cannot begin to describe the hoops the exam boards were made to jump through when developing the new A-Level assessments. As well as input into the curriculum and the related assessment – assessment is needed that actually does validly and reliably assess the curriculum – there was a requirement to submit Sample Assessment Material.

These were the most scrutinised of all the documentation before regulatory approval was granted. The SAMs demonstrated how the assessment would appropriately test skills, knowledge and behaviour as defined in all apprenticeship standards. The regulator wanted to ensure that the assessment didn’t narrow the curriculum, be in anyway predictable and avoid teaching to the test. But most importantly the SAMs helped the teacher and the pupil understand the expectations of the assessment and what the learning needed to enable the student to do.

In addition there was an absolute requirement, not always met, that approved curriculum, assessment and SAMs were available ideally a year in advance of first teaching so that the teacher could properly prepare before delivering the new curriculum. Look at the current outcry that the Maths A-Level assessment is not ready six months before first teaching!

But where are we with the new apprenticeship standards? They are actually being taught, many without an end-point assessment organisation and the majority without a completed end-point assessment, let alone sample materials. No wonder 50% of the population feels forgotten, neglected, and second-class when it comes to education and training.

Where’s the government’s parity of treatment?

Secondly, take technical and professional education and the idea of a single exam board for each of the 15 routes. While I accept this issue does divide opinion across all exams, let’s at least reflect on the Regulator’s advice to the Secretary of State when this was proposed for academic qualifications. The very clear advice was that the redevelopment of the curriculum and the assessment – as well as changing the market to a single board per subject – posed too much risk to the system and could seriously damage the education and assessment of our young people. This is without changing the funding and the provider base. Even Michael Gove accepted this advice.

Indeed what it also led to was the government’s ability to draw on the expertise of all the exam boards and to benefit from robust and valuable discussions about the curriculum and content with all parties agreeing on a final single curriculum and assessment. This led to tight common standards for all the exams no matter which exam board chose to deliver them.

A few years down the line, and the exact same thing is being proposed, but this time for technical and vocational education. The government is in danger of losing access to a depth of expertise as it drags the exam boards into a competitive tendering situation – expertise which is sorely needed across the board.  The only conclusion I can draw is that either Ofqual forgot to look at their previous advice or they think it is okay to experiment on the vocational kids. It won’t matter if it is messed up, but where’s the government’s parity of treatment when it comes to these decisions?

At the AELP conference last year Susan Pember described the situation as diabolical – she repeated it again last week. I will add: disgraceful double standards.

Mark Dawe is CEO of the Association of Employment and Learning Providers