It didn't come as much surprise to me last night to hear that Ofqual is now expressing serious concerns about the Coalition government's planned EBC qualifications in English, mathematics, science, history, geography and languages ( consultation on those here
). In a letter
to the Secretary of State, sent several weeks ago but released yesterday after its existence was revealed at the Education Select Committee, the exam regulator sets out in some detail what is wrong with the current proposals.
There now appears to be a formidable coalition questioning the very existence of exams at 16 and also challenging the nature of the EBCs. Headteachers from maintained, academy
and fee paying schools
have aired their concerns, the CBI
has weighed in, as have representatives of the creative industries
and performing arts
. All of these groups have legitimate worries - some of which I outlined here
. The over riding fears are that the proposals will inevitably narrow the post 14 curriculum, but also have a knock on effect on KS3 and KS5 if schools choose, or are forced, to wind down their art, music, technology and drama departments. There is some evidence that this is already happening. Without a clearer idea of what accountability measures will run alongside the EBCs - and this is as yet very vague - it is hard to know what perverse incentives might result over the longer term. But there is clearly a risk that pupils will be offered less choice, and fewer opportunities to pursue pathways that meet their individual needs.
There are also fears that young people with SEN will get excluded from the new qualifications - at the moment those who aren't able to take the new exams will be fobbed off with something called a "Statement of Achievement" - and that the proposals are being rushed through in a way which could lead to chaos. Developing new robust, well tested qualifications is a lengthy business - often taking 6-8 years. However the EBCs are scheduled to be in schools by September 2014. In the intervening period there needs to be a response to the current consultation, publication of the KS4 curriculum and a consultation on that, decisions about the EBCs content with a possible consultation on this as well ( remember the statutory consultation period is 12 weeks).
Then the awarding bodies will need to develop the qualifications - I recently met a senior figure at one exam board who explained that they are already trying to do this but as he put it "in the dark". Ofqual will need to accredit the qualifications and a competition will need to be carried out to determine which will be made available to schools. The consultation states that there should only be one qualification in each subject and exam boards will need to slug it out to win the right to offer the chosen one.The Ofqual letter released yesterday reveals serious concerns about this latter point. If competition between exam boards is to be eliminated, some providers may lose subject specialists and then be unable to develop A levels in the subjects for which they had not secured the EBC. "The system would lose a large amount of subject expertise" state Glenys Stacey, Chief Ofqual regulator. She recommends that this competitive process be put to one side for now.
But this is not the most worrying aspect of her letter, which questions whether it is realistic for one single assessment, without tiers, coursework, modules, and reliant on a terminal exam, to do all the things that the government states it should, and whether the new system can successfully hold schools to account.
The consultation on KS4 reform states that the new qualifications should be of high quality, be internationally respected and able to meet the needs of the whole ability range, stretching the top end, engaging those of lower ability. They should also develop the skills and knowledge needed for employment and further study, encourage better teaching , provide a signal of achievement to employers, colleges and universities and hold schools to account.
But Ms Stacey says: "Our first concern is that the aims for EBCs may exceed what is realistically achievable through a single assessment...our advice is that there are not precedents that show that a single assessment could successfully fulfil all of these purposes."
And ther is more! She goes on "In the short term ( and following every subsequent EBC competition) the new qualifications will not provide a good basis for school accountability in the year they are introduced, because there will be predictable variability in outcomes at school level; some teachers will adapt and prepare better than others for the new qualifications. The GCSE English experience this year shows starkly how school acceptance of outcomes can be damaged when unexpected variations occur. We believe that parallel strands of accountability testing are needed, at least in English and mathematics, that can run across the transition period and provide evidence of changes in the underlying quality of teaching".
Finally she points out that "first class qualifications with the characteristics you are looking for in EBCs will be significantly less reliable in the technical sense (ie the consistency of repeatability of results from one assessment to the next). Good marking of structured essay questions is quite subjective and can never be entirely captured in structure mark schemes. This variability will make EBCs less suitable for accountability measurement, which requires highly reliable tests with minimal susceptibility to marking challenge. We therefore advise that consideration be given to broadening the base of secondary school accountability measurement."
It is a pretty damning indictment. No wonder Mr Gove didn't want to volunteer this information himself yesterday
. No -one seems to want these new exams, they are being rushed ( probably to suit the political timetable and the date of the next general election) they aren't fit for purpose and there may be a negative repercussions throughout the education system.
But let's not forget the most important point - strangely not included in Ms Stacey's letter. This isn't just a debate about the technical merits of one type of assessment method vs another, or a vehicle for political point-scoring ( always Mr Gove's default position). This is about changes that will impact on the lives of tens, possibly hundreds, of thousands of young people.
Ms Stacey's last paragraph explains that she is copying the letter to Sir Michael Wilshaw, Chief Inspector at Ofsted.
I suggest he applies the same same rigorous standards to this shambolic process that he does to schools and give us his own judgement. As far as I can see at the very best it has serious weaknesses, but a more realistic assessment is that it is failing the pupils whose lives are most likely to be affected.
NB For anyone who is concerned about EBC and the future of the 14-19 phase, please read this consultation
which has been prepared by the Heads Roundtable
Group that I wrote about in the Guardian in October. Deadline is on December 10th - same day as the government consultation closes. Please respond to open up the debate to alternatives to current organisation of curriculum and assessment.