Reforming Key Stage 4 Qualifications

Consultation Response Form

The closing date is: 10 December 2012 Your comments must reach us by that date.

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the access to information regimes, primarily the Freedom of Information Act 2000 and the Data Protection Act 1998.

If you want all, or any part, of your response to be treated as confidential, please explain why you consider it to be confidential.

If a request for disclosure of the information you have provided is received, your explanation about why you consider it to be confidential will be taken into account, but no assurance can be given that confidentiality can be maintained. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department.

The Department will process your personal data (name and address and any other identifying material) in accordance with the Data Protection Act 1998, and in the majority of circumstances, this will mean that your personal data will not be disclosed to third parties.

Please tick if you want us to keep your response confidential.

Reason for confidentiality:

Name Bob Vesey

Organisation (if applicable) AMiE (The Association of Managers in Education)

Address: 35 The Point Market Harborough Leicestershire �LE16 7QU

If your enquiry is related to the policy content of the consultation you can contact The Department on:

Telephone: 0370 000 2288

e-mail: KS4QualReform.CONSULTATION@education.gsi.gov.uk

If your enquiry is related to the DfE e-consultation website or the consultation process in general, you can contact the Consultation Unit by e-mail:

consultation.unit@education.gsi.gov.uk or by telephone: 0370 000 2288 or via the Department's 'Contact Us' page.

Please mark the box that best describes you as a respondent.

School College

Academy

Higher Education Institute

Further Education Institute

Local Authority

Subject Association Parent

Student

X Union Employer-Business Sector

Governor

HT/Teacher

Awarding Organisations

Other

Please Specify:

Introduction AMiE (The Association of Mangers in Education) represents leaders and managers in schools and colleges. It is now the leadership section of ATL ATL, the education union, is an independent, registered trade union and professional association, representing approximately 160,000 teachers, head teachers, lecturers and support staff in maintained and independent nurseries, schools, sixth form, tertiary and further education colleges in the United Kingdom. AMiE is the trade union and professional association for leaders and managers in colleges and schools, and is a distinct section of ATL. We recognise the link between education policy and members' conditions of service.

ATL exists to help members, as their careers develop, through first rate research, advice, information and legal advice. Our evidence-based policy making enables us to campaign and negotiate locally and nationally.

ATL is affiliated to the Trades Union Congress (TUC), Irish Congress of Trade Unions (ICTU), European Trade Union Committee for Education (ETUCE) and Education International (EI). ATL is not affiliated to any political party and seeks to work constructively with all the main political parties.

AMiE Response

a) The focus in the consultation largely on matters of detail indicates that the government is determined to make the proposed changes even if there is no evidence to suggest that they will be effective in addressing the perceived weaknesses in the current key stage four qualification framework.

b) There are several obvious weaknesses in the proposal, including:

i) The proposals ignore the implications of the raising of the participation age that suggest that the need for an end test at 16 is no longer clear.

ii) The proposals focus on knowledge and largely ignore skills. As such they do not address some of the concerns that are raised in the introduction to the consultation e.g. about the skills gaps identified by employers.

iii) In dealing with academic and vocational qualifications separately, the proposals will perpetuate the academic and vocational divide that weakens the English education system at key stage 4 and beyond.

iv) There is a significant risk that some young people will be encouraged to repeat EBC qualifications with the prospect of repeated failure, rather than take a more appropriate route with greater prospects of success.

v) The new system will not address the disjunction between assessment at key stage 4 and the assessment that informs international comparisons.

vi) There is no evidence that the views of the profession have been considered in devising the proposals.

vii) The implementation timetable will lead to significant problems for the first few year groups and will therefore risk causing serious harm to the life chances of many young people.

viii) The implementation timetable is ambitious and there is a risk that schools and colleges will not be sufficiently well prepared by the time delivery of the new qualifications start.

ix) Issues of transition between GCSEs and EBCs have not been addressed.

x) Art & design, is likely to be marginalised by these proposals at a time when the UK needs to enhance its pool of creative skills in order to compete internationally,

Title

1 Do you agree that the new qualifications should not be called "GCSEs"?

Agree X Disagree Not sure

Comments: AMiE does not agree that there is is a need for a new qualification to be taken at the age of 16. Qualifications for the upper secondary phase of education need to be reformed but not in this way. AMiE believes that if there is to continue to be a qualification that is normally taken in schools at the age of 16, the GCSE qualification should be retained, with reforms.

2 a) Do you agree that the new qualifications should be called English Baccalaureate Certificates?

Agree X Disagree Not sure

Comments: Using the term “baccalaureate” for a suite of narrow, academic, knowledge-based qualifications is not appropriate and will create confusion in terms of both national and international understanding of the UK qualification. During the transitional phase, we will have a series of qualifications; potentially, EBC subjects running alongside GCSE and the recently promised Technical or vocational baccalaureate. This will make the English qualification framework appear muddled and confused. It would be far more appropriate to develop a baccalaureate that met the needs of young people at the end of the secondary phase of education (i.e. at the age of 18/19) that covered the whole range of academic learning, practical and vocational learning and skills development that is required in an educated young person as they move from school to higher education or university. The proposed EBC is not likely to succeed in helping to develop the educated and skilled young workers that we need in an increasingly competitive global economy.

2 b) If not, what alternative title should be adopted?

Comments: Until there is a clearly developed qualification, designed for all school leavers at the age of 18, the GCSE, with modifications, should remain in place.

High expectation of performance and accurate grading

3 Do you agree with our expectations for grading structures, set out in paragraphs 5.4 to 5.5?

Agree Disagree Not sure

Comments: We are asked to comment on expectations for grading structure when no detail is provided in the consultation document. The absence of detail is an indication of the extent to which this is a poorly developed reform that is being rushed through with undue haste. The concern is raised in paragraph 5.5 about the ‘danger of confusion’ between GCSE and EBC grades unless there is a “clear break from the past in how grades are described…” This suggests that the primary characteristic that Awarding Organisations must consider when devising grade structures, is the need to differentiate the politically inspired EBC from other qualifications. This is not the best starting point for discussions about grading. The current grade range used in GCSEs is broadly fit for purpose. It allows schools, colleges, universities and employers to differentiate between candidates and is helpful to those involved in providing advice and guidance to support discussion about progression with young people and their parents.

AMiE is concerned that the reference to a ‘fall in standards’ that lies behind the proposed reform is not evidenced.

4 Do you believe that we should insist on a common grading structure for all English Baccalaureate Certificates or should we allow Awarding Organisations the freedom to innovate?

X Common Grading Structure

Freedom to innovate

Other

Comments: If the new qualification and its grading is to be understood by students, parents, employers and higher education admissions staff it is essential that a common grading structure is used by all awarding organisations.

No tiering

5 Do you agree that it will be possible to end tiering for the full range of subjects that we will be creating new qualifications for?

Yes X No Not Sure

Comments: The case against tiering is not made by the consultation paper. Differentiation is important and the idea that there is a on-size-fits-all assessment that will work for all students, whatever their ability will not work in practice. The strength of the case for tiering may vary between subjects. It is perhaps stronger in modern foreign languages and mathematics than in other subjects. This is one area where Awarding Organisations and teachers should be free to decide whether or not tiering is appropriate.

6 Are there particular approaches to examinations which might be needed to make this possible for some subjects?

Yes x No Not Sure

Comments: The Government should not be seeking to involve itself in this level of detail around qualifications and assessment. We have, as Ministers acknowledge, the best generation of teachers and leaders that we have ever had and it is time to trust the profession with this kind of detail.

Assessed 100% by examination, or minimising reliance on internal assessment

7 a) We intend that English Baccalaureate Certificates should be assessed 100% by externally marked examinations. Do you agree?

All English mathematics

sciences history geography

languages None

Comments: AMiE does not agree that EBCs should be assessed 100% by externally marked examinations. The method of assessment cannot be separated from what is being assessed and external examinations are more suited to some purposes than others. There is a place for internal or teacher assessment and ample evidence that teacher assessment works well where teachers are trained to undertake assessment tasks and clear moderation processes are in place.

7 b) If not, which aspects of English, mathematics, the sciences, history, geography or language do you believe absolutely require internal assessment to fully demonstrate the skills required, and why?

Comments: This is another area where Government should trust the profession to decide where a range of assessments of varying kinds should be deployed to enable students to demonstrate their achievement. Examples would include:

In science, the assessment of practical ability in laboratory experiments or the collection and analysis of data.

In languages, oral skills. In geography, fieldwork skills. In mathematics, problem solving in applied contexts.

The EBC is not currently to include such subjects as Art and Design, Physical Education and Performing Arts. Leaving aside the risk of impoverishing the upper secondary curriculum from this decision, if these subjects are added to the EBC it would be preposterous to rely on 100% externally marked examinations for the assessment of students in such subjects.

Size requirement for syllabus

8 Should our expectation be that English Baccalaureate Certificates take the same amount of curriculum time as the current GCSEs? Or should schools

be expected to place greater curriculum emphasis on teaching the core subjects?

X Same amount of curriculum time

Greater curriculum emphasis

Other

Comments: This is not something the Government should be interested in specifying. For Ministers to specify the amount of curriculum time that should be allocated to each subject suggests that Ministers are interested in micro-managing the school and college curriculum in a way that is impractical. Schools vary the amount of time allocated to particular subjects based on an assessment of need in a given context. For example, second language learners will normally be allocated a greater time in core subjects and those with relatively low attainment at the start of key stage four may similarly have a differentiated timetable. However, if Ministers wish to produce a guideline in relation to the time allocation, there should broadly be parity between EBC and GCSE subjects.

Examination aids

9 Which examinations aids do you consider necessary to allow students to fully demonstrate the knowledge and skills required?

Comments: The consultation outlines examples of the kinds of aids that are currently permitted in examinations (5.14) and suggests in the next paragraph that these should be restricted wherever possible, to allow students to demonstrate their true abilities and competence.’ No reason is given for suggesting the restriction and no evidence is presented to suggest that the aids mentioned inhibit students’ potential to demonstrate their ability and competence. It might be inferred from this that Ministers believe that rote learning and memory testing provides a better insight into students’ ability and competence and that the removal of aids would somehow raise the bar.

However, no evidence is mentioned to support the proposal. Once again, it is reasonable to suggest that the aids to be permitted in an examination or during a practical assessment should be for the Awarding Organisations and the profession to determine.

Subject suites

10 Do you agree that these are appropriate subject suites? If not, what would you change?

X Yes No Not Sure

Comments:

11 Is there also a need for a combined science option covering elements of all three sciences?

X Yes No Not Sure

Comments: The document notes ‘that the current combined science GCSEs are currently a popular option.’ We know that students who study combined science do go on to further study in sciences, including at Russell group universities. It is important that as many students as possible continue to study sciences, at least until the age of 16 and the best way to maintain a high level of participation is to continue to offer a combined sciences option through key stage four.

Track Record

12 What qualities should we look for in English Baccalaureate Certificates that will provide evidence that they will support students to be able to compete internationally?

Comments: Student performance in an examination that is designed primarily as a test of knowledge in a limited range of subjects is unlikely to enable students to compete internationally. As currently envisaged the EBC will not serve the majority of students well and will not meet the needs of the minority of students who excel in the proposed set of qualifications. It is difficult to envisage how students will cope with the transition to EBC during a period in which GCSEs continue to operate. It is to be expected that there will be performance differences between the two sets of qualifications and students who are awarded significantly different grades between the two qualifications, and their parents, will doubt the validity, reliability and consistency of the whole examination system as a result. Successful students will need to be able to demonstrate an ability to master a range of subjects and the knowledge component of the EBC subjects will support that. In addition students will need to be able to demonstrate a range of skills and qualities that are valued by employers in the national and international market for jobs. These include outstanding communication skills, both oral and written, presentation skills, and the ability to work with others as part of a team in diverse settings and with sensitivity to cultural differences. In addition, students need to demonstrate creativity and analytical skills. It is not clear that the EBC will enable students to develop this range of skills and

Assurance of literacy and numeracy

13 Do you agree that we should place a particular emphasis on the successful English language and mathematics qualifications providing the best assurance of literacy and numeracy?

X Agree Disagree Not sure

Comments: AMiE agrees that there needs to be an emphasis on English and mathematics and would further argue that students should have opportunities to continue to develop their skills in these subjects up to the age of 18. The EBC should not be seen as an end qualification, which, if not achieved at the age of 16, should be repeated until it is achieved. Such an approach will not serve the interests of those who do not reach the required standard by the age of 16. There needs to be alternative qualifications for those who do not reach the pass threshold by 16 so that they are not repeating the same programme of study for one or two further years. Whilst AMiE supports an emphasis on English and mathematics, it is important that all qualifications, whether subject-based academic qualifications or vocational qualifications are designed to enable students develop appropriate skills in English and mathematics in the context of the subject or vocational area in which the student is operating.

School and Post-16 institution Support

14 In order to allow effective teaching and administration of examinations, what support do you think Awarding Organisations should be:

a) Required to offer?

Comments: The consultation document suggests that the kinds of support that Awarding Organisations are able to provide needs to be restricted to avoid teaching to the test and a competitive race to the bottom. It is noted at the same time, that the kinds of support offered by awarding organisations is not the only factor that has led to failure in relation to GCSE and that the school accountability system has a key part to play in undermining key stage 4 qualifications. Against that background, it is inappropriate to consult on the kinds of support that that awarding organisations may offer without at the same time considering other changes that will be made to reduce the risk of failure in future. Feedback is important and is as important for teachers as it is for students. Restricting access to materials such as examiners reports will deny to teachers the kind of detailed feedback they need to enable them to improve their teaching and the potential performance of their students. It is not about enabling teaching to the test but about supporting improvements in teaching and learning. Such restrictions could not be effective as some teachers will be likely to work as examiners and will therefore, have access to the kinds of information not made available to others. The arrangement would be inequitable and would disadvantage some students at the expense of others. Rather than to think about the kinds of support that awarding organisations should not be allowed to offer, there should be an agreed specification of information, advice and support that should be offered to schools, colleges and teachers as part of the service that is provided for the examination entry fee. It might be appropriate to consult further on whether awarding organisations could offer services beyond that agreed specification. However, restricting the development of other support services may prove to be impractical in a market system. For example, what would prevent a person who had recently left a subject team in an awarding organisation, from selling consultancy to subject teachers in those schools and colleges that could afford to buy such services?

14 b) Prevented from offering?

Comments: Dealt with in 14 a) above

15 How can Awarding Organisations eliminate any unnecessary burdens on schools and post-16 institutions relating to the administration of English Baccalaureate Certificates?

Comments: AMiE is aware that the costs to schools and colleges of examination services have risen considerably in the recent past. This is partly due to an increase in the number of examination entries or registrations but is also because awarding body costs and prices have risen disproportionately in comparison with other costs and with school or college income. A move to a single awarding organisation for each EBC subject runs the risk of making things worse as each provider will have a monopoly for the 5-year period for which they are the authorised provider. Ministers need to consider how they will limit the potential abuse of monopoly power in these new arrangements. Ministers could reduce the costs of the examinations function and at the same time free up resources to spend on teaching and learning by interfering less in assessment arrangements.

Qualification supports progression of lower achievers

16 Which groups of students do you think would benefit from a "Statement of Achievement" provided by their school?

Comments: AMiE does not accept that there is a clear case for Awarding Organisations offering ‘more detail in the information that is made available about students’ achievement’ (5.4). There is a need to see the detail about what this additional information might include. There is a risk that investment is made in developing bureaucratic data gathering processes that do not produce information valued by students, parents or others to whom the data is made available. It would also be of interest to see what evidence there is, from employers, colleges or higher education institutions, to suggest that this further information might be valued. If statements of achievement are to be developed, they should be provided for all students. If statements are only provided for those students who do not complete a full EBC they will risk being seen as unwelcome statements of failure.

17 How should we ensure that all students who would benefit from a "Statement of Achievement" are provided with one?

Comments: There is little purpose in considering this until the purpose, content and data gathering processes have been considered in more detail. The proposal has the potential to become another centrally-imposed expensive burden that will not help to improve teaching and learning and will not raise standards.

Equalities

18 a) Do you believe any of the proposals in this document have the potential to have a disproportionate impact, adverse or positive, on specific pupil groups?

X Adverse impact Positive impact Both

No impact

Comments: The EBC will have an adverse impact on all students who will find that they are having to spend a significant amount of time being trained in examination techniques. In addition the following groups of students are at risk of being disadvantaged.

Those with English as a second language Those with learning difficulties and disabilities Female students, who perform less well than boys in examination

assessments Those who are unwell on the day of a test (who will not be able to

demonstrate the strength of their achievement from other elements of assessed work)

Students from poor families Students from some ethnic minority background Students who spend one or two years re-sitting elements of the EBC

after the age of 16, and who continue to fail.

18 b) If they have potential for an adverse impact, how can we reduce this?

Comments: Consult parents, employers, teachers and lecturers, educational leaders and academics on the design of an appropriate upper secondary school curriculum that is suitable for the vast majority of students.

Implementation

19 Should we introduce reformed qualifications in all six English Baccalaureate subjects for first teaching in secondary schools in 2015, or should we have a phased approach, with English, mathematics and sciences introduced first?

In all six subjects from 2015 Phased approach x Other

Comments: The timetable is ambitious and the planned arrangements for support are unclear. The start should be delayed and there should be pilots before the EBC is used across the whole of England.

20 How best can we prepare schools for the transition to these reformed, more rigorous qualifications?

Comments: There is a need to consult subject specialists in the design of the specifications for each subject. During the consultation process, teachers should be involved in the development of appropriate training programmes to give the new qualification a chance of succeeding. There needs to be considerable investment in training and development and the regulator and awarding organisations must provide the detailed information that teacher need about the new qualifications at least 12 to 18 months in advance of the introduction of the EBCs. Ministers need to learn from past mistakes that resulted in a chaotic introduction of hurried qualification reform (e.g. Curriculum 2000) and ensure that the same mistakes are not repeated.

21 How long will schools need to prepare to teach these reformed qualifications?

Up to 12 months X 12 - 18 months More than 18 months

Other

Comments:

Languages

22 Should all languages in which there is currently a GCSE be included in our competition?

Yes X No Not Sure

Comments: Languages teaching in England has been damaged by political interference in the past and AMiE is concerned that adding languages to the EBC will have a further detrimental impact on the teaching of languages and on the numbers of students taking languages in schools and colleges. There is a need to consult further on how students can be encouraged to take up languages in schools so that English students are better able to compete in the global economy. A new qualification that looks more like those offered in the 1950s may not be the best way to stimulate the take up of languages in schools. Students should have the freedom to study as many languages as they are capable of undertaking but there is a need to encourage the vast majority of students to study at least one language, a related need to develop capacity in the teaching workforce to facilitate that.

23 Should the number of languages for which English Baccalaureate Certificates are identified be limited? If so, which languages should be included?

Yes X No Not Sure

Comments: See above

24 Given the potential number of new languages qualifications to be developed, should they be introduced to a later timescale than history and geography English Baccalaureate Certificates?

Yes

No Not Sure

Comments: See above

Post-16

25 Should we expect post-16 institutions to be ready to provide English Baccalaureate Certificates at the same time as secondary schools?

Yes

No X Not Sure

Comments: The answer depends, in part, on whether the EBC is seen as an appropriate qualification for students who have not reached the required standard in GCSE subjects by the time the new qualification is introduced. Students entering post 16 institutions in 2015 who have not successfully completed a GCSE qualification in particular subjects may be better advised to repeat GCSE or to take an alternative qualification. Post-16 institutions are expected be able to recruit students at the age of 14 so they need to be as ready as other institutions to offer the EBC from the date on which they are introduced.

26 How best can we support post-16 institutions to prepare to provide English Baccalaureate Certificates?

Comments: Post-16 institutions should be provided with the same access to training and development opportunities as schools.

Choosing the best qualification in each subject

27 Do you agree that five years is an appropriate period for the new qualifications to feature in the performance tables before the competition is rerun?

Agree Disagree Not sure

Comments: AMiE shares the concern that has been made by awarding bodies that it will be difficult for them to retain the expertise needed to enable them to bid in future rounds if they are not offering and working on a subject. The model proposed is unlikely to work.

28 Please let us have your views on responding to this call for evidence (e.g. the number and type of questions, whether it was easy to find, understand, complete etc.).

Comments:

Thank you for taking the time to let us have your views. We do not intend to acknowledge individual responses unless you place an 'X' in the box below.

Please acknowledge this reply X

Here at the Department for Education we carry out our research on many different topics and consultations. As your views are valuable to us, would it be alright if we were to contact you again from time to time either for research or to send through consultation documents?

Yes No

All DfE public consultations are required to meet the Cabinet Office Principles on Consultation

The key Consultation Principles are:

departments will follow a range of timescales rather than defaulting to a 12-week period, particularly where extensive engagement has occurred before

departments will need to give more thought to how they engage with and consult with those who are affected

consultation should be ‘digital by default', but other forms should be used where these are needed to reach the groups affected by a policy; and

the principles of the Compact between government and the voluntary and community sector will continue to be respected.

Responses should be completed and emailed to the relevant consultation email box. However, if you have any comments on how DfE consultations are conducted, please contact Carole Edge, DfE Consultation Coordinator, Tel: 0370 000 2288 / email: carole.edge@education.gsi.gov.uk

Thank you for taking time to respond to this consultation.

Completed questionnaires and other responses should be sent to the address shown below by 10 December 2012

Send by post to: Public Communications Unit Level 1 Area C Castle View House East Lane Runcorn WA7 2GJ

Send by e-mail to: KS4QualReform.CONSULTATION@education.gsi.gov.uk