WOO0008

 

Written evidence submitted by the NAHT

 

 

  1. NAHT welcomes the opportunity to submit its views on the work of Ofqual in regulating examinations, including reform of GCSEs and A levels. NAHT represents more than 29,000 school leaders in early years, primary, secondary and special schools, making us the largest association for school leaders in the UK. We represent, advise and train school leaders in England, Wales and Northern Ireland. We use our voice at the highest levels of government to influence policy for the benefit of leaders and learners everywhere. Our new section, NAHT Edge, supports, develops and represents middle leaders in schools. This puts us in an excellent position to provide an informed response which covers the viewpoint of leaders across all phases of education.

 

  1. NAHT supports the work of Ofqual in regulating examinations and believes that it is important to guarantee the organisation's total independence from political influences to ensure parity and fairness across the examination system. We would also encourage further transparency regarding Ofqual’s intervention with examination boards and any subsequent impact on student outcomes.

 

  1. We are particularly concerned that at the 1st October 2015, only the Latin specification has been accredited of all the new GCSE, AS and A level subjects to be taught in September 2016. Without these accredited specifications, examination boards cannot offer training and resources to support delivery, nor can teachers and schools start to prepare fully to deliver these new courses. Best practice would be to provide a full academic year to prepare for such significant curriculum changes and this will not now be possible with this phase. We would highlight the need to consider the impact of this reduced timescale for implementation on schools and teachers and to avoid its reoccurrence with the introduction of specifications for first teaching in September 2017.

 

  1. What is already clear about the new qualifications is that they will require a significant increase in excellent exam markers, especially as there will be more open ended questions that require expert marking. This is a concern at a time when examination boards are already reporting shortages, with some evidence suggesting this is due to the prevalence of online marking, and more examiners being needed in the Summer series of linear qualifications. The sector needs assurances that Ofqual is taking action to ensure that there will be enough suitably qualified examiners, trained in marking the new specifications.

 

  1. NAHT supports as a principle the use of performance descriptors for the allocation of grades in examinations, allowing students and their teachers to establish the standard required to attain each grade. We therefore favour the development by Ofqual of performance descriptors for both grade 9 at GCSE and A* at A level rather than the proposed use of norm referencing and comparable outcomes.

 

  1. 2015 saw a significant rise in the number of entries for iGCSE with many NAHT members expressing concerns over outcomes and grading, particularly in English. The view from members is that these queries have not all been resolved efficiently, with some still awaiting clarification of results.  With similar volumes of entries in 2016, we have concerns that these experiences could be repeated. As part of its role Ofqual must ensure that all examining bodies fulfil their remit properly, however, its regulatory activity of CIE in not in line with other examination boards and we would suggest this should be the case.

 

  1. NAHT members also have ongoing concerns regarding the National Reference test and how it will succeed as an effective means of judging improvements in the quality of teaching and students' learning. Concerns have been raised by members over how the purpose of the test will be explained to students in order to ensure their full engagement and how a truly representative sample of the cohort can be achieved. Depending on the design of the test, teaching to the test could also distort the value of any results. Further consideration of these issues and clarification of how the results of such a test would be used in practice are needed.

 

  1. NAHT members are concerned at the stripping away of examination courses at pre GCSE level thereby disenfranchising students with learning disabilities and raising a significant equalities issue. In addition the increased use of 'high order language' and demands of comprehension have similarly put some GCSEs out of such students reach. We would highlight the need for a revision of accessibility arrangements for such students to ensure equality of opportunity and to enable their educational attainment to be accredited.

 

  1. Finally, in terms of primary assessment, NAHT is keen to seek clarification of the extent of the role that Ofqual will play in monitoring delivery of both KS2 tests and reception baseline assessments.

 

 

 

 

 

 

 

October 2015