Exam boards will be expected to investigate claims from students that schools and colleges have not shown “care or integrity” in stamping out “bias” in teacher-assessed grades.

In updated draft guidance on appeals for exam boards, Ofqual said while they expect such allegations to be rare, it is an “important safeguard” for pupils in this year’s grading arrangements.

A consultation has been launched on new guidance today which sets out the information exam boards must provide schools considering an appeal, and the circumstances an appeal may be allowed because the “wrong data” was used.


1. Allegations of ‘bias’ in teacher-assessed grades to be investigated

Ofqual has, again, ruled out allowing individual students to challenge their teacher-assessed grades, as an appeal would have to be undertaken by “someone better placed than the student’s teachers to judge their likely grade if exams had taken place”.

“In the unique circumstances of this summer, we do not believe there is any such person,” Ofqual said.

However, the regulator said students who have concerns about “bias, discrimination or any other factor that suggests that a centre did not behave with care or integrity” when issuing teacher-assessed grades can complain to the school or college.

Where there is “evidence of serious malpractice”, Ofqual says it “may be appropriate to bring those concerns directly to the exam board in the first instance”.

“Where there is evidence, we require exam boards to investigate allegations as potential malpractice or maladministration. We expect such allegations to be rare, but this is an important safeguard for students and their overall confidence in this year’s grading arrangements.”


2. Student appeals guide to be published, and helpline set up

As part of the above, Ofqual has also committed to publishing a guide for students that sets out how their grades were calculated this year and the options available if they believe their result was not properly produced.

This will include “expectations about who can support students in understanding both the options available to them if they wish to query their result and how to access those routes”.

Ofqual has said this will be published by the end of July, before results days in August.

Sally Collier, chief regulator for Ofqual, said they are “committed to helping students and their families understand how to access an appeal or make a complaint about bias, discrimination, or another concern.

“We will provide accessible information and have a helpline available to students and their parents or carers to talk about the appeals process and any other questions they may have about their results this summer.”


3. No specific appeal route because of ‘significant demographical change’

Ofqual had promised to look into whether allowing an appeal where a school or college could show “significant demographical changes in its cohort to justify changes in how the standardisation process was applied to its students”.

The regulator justified this by analysis that found such circumstances were “exceptional” cases, as the “magnitude of change that would be required to affect calculation of results would need to be great”.

The guidance said such circumstances may include a school or college becoming single-sex, or having put in place an “accelerated learning programme for very able learners other than in year 11 or 13” who are for the first time entering qualifications.

Another case could be where teaching and learning for 2018 or 2019 was “significantly disrupted” due to “one or more extraordinary or momentous incidents or events”.

However – and importantly – Ofqual has said should this be the case, schools and colleges can use the “wrong data” grounds to appeal.

But Ofqual said appeals should not be made on the basis of inspection reports, curriculum choices or mock exams – it must relate to evidence that “something happened” to either the 2020, or an earlier, cohort that “may not be comparable with previous years”.


4. So what grounds can schools and colleges appeal on?

Ofqual has already said schools and colleges can appeal only on procedural grounds: the basis that the “wrong date was used to calculate results”, or where there was an administrative error.

The wrong data includes where a school or college has provided incorrected teacher-assessed grades or rank order information, where the exam board has used the incorrect data for its standardisation process, or where the exam board has “introduced an error” into the data.

For appeals based on the school or college making a mistake when submitting information, it will be on the school or college to evidence this.

Ofqual said: “We expect that any mistakes will be quickly found and corrected.”


5. Exam boards can provide further info to help centres decide on appeals

Ofqual said that, in “appropriate” cases, exam boards can disclose further information to schools and colleges to help them decide whether to appeal a grade.

The regulator said “sufficient information” would include the centre-assessment grades and rank order, the school’s or college’s historical results and the relevant prior attainment data used by the exam boards for its standardisation.

Exam boards must have arrangements in place to provide this information if requested by schools and colleges.

It’s also up to schools and colleges whether to disclose this information to the student whose grade may be appealed.

Information about teacher-assessed grades and rank orders are not allowed to be shared with pupils or parents amid concerns they “may try to exploit” the system. But the draft guidance states disclosure of such information from exam boards “at this stage will not represent a breach of confidentiality … because it will take place after results have been issued”.

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