Sunday, September 2nd, 2012

OK, hands up: I haven’t been updating this blog in the last few months. This is for a couple of reasons: the demands of childcare and work pressure during the time I am not looking after our daughter.

Anyway, enough excuses. I still do hope to be posting on here from time to time in the coming months. And, given the importance of the current controversy over GCSE English results, I wanted to post a blog offering some observations not already put down elsewhere. What follows below is a mixture of some facts I’ve come across over recent days about Ofqual and the regulatory system and some very brief observations about some implications of the regulator’s current actions on grade inflation and how they interact with school accountability.

The below was actually written last week, before the publication of Ofqual’s report following its short investigation into the issue. It could almost be read as a postscript to my blog, published on Friday morning, on the NAHT’s website.

So much for the preamble. Some observations:

– First, we know, from Ofqual board meeting papers, that the regulator raised the potential of problems with the new GCSEs being launched in 2011 and 2012 in December 2010, when a minute from a board meeting paper (at point 10 of paper 13 here ) says: “Achieving comparable outcomes [ ie holding grade proportions roughly constant overall] while at the same time ensuring consistent unit level standards will be challenging for GCSE”. The TES reported on Friday, of course, that fears were also raised by Isabel Nisbet, Ofqual’s former chief executive, in 2009.

– Second, we also know that, as of earlier this summer, Ofqual did not seem to think, officially at least, that a big problem was brewing this year. A minute of an Ofqual board meeting on Monday, June 25th this year (see here and scroll down to near the bottom to a document slightly confusingly titled “24-12: minutes of meeting held on 16th May”) says: “The board received a short update on the progress of the 2012 summer [exam] series which had gone well and more smoothly than previous years”.

Moving more into comment now:

– Third, the whole business of Ofqual seeking to curb grade inflation raises huge questions about the pressure being placed on many individual schools to improve their results or risk closure. If results for the country as a whole effectively cannot rise (as discussed in another recent blog for the NAHT) one has to ask what the purpose of this policy now is.

– Fourth, the technicalities of the way Ofqual is seeking to curb grade inflation – with pupils’ Key Stage 2 results now a central aspect in the judgement as to whether the regulator should move away in any one year from what is effectively coming close to resembling norm referencing system – mean that a collective effort by secondary schools across the country to raise grades seems unlikely now to find any reward in overall national average results.

-Fifth, returning to try to look in detail at exam rules for the first time in a while, I have been staggered by the complexity around new modular specifications such as the GCSE English/English language/English literature suite. It seems to me that the boards have not really helped their cause in the current controversy over grading by offering, with approval from the regulator at the time they were developed, GCSEs which now seem to me, as an outsider to this system, incredibly complicated. Perhaps this is in response to demand from schools for assessments over which they hope to gain more control. I have not space to go into detail on this here; it may be the subject of a future blog.

– Sixth, these politicians do have to be watched carefully, don’t they? Michael Gove has said he wants to break with the recent past and not be a minister who seeks to claim credit for incremental annual rises in higher grade pass rates. These he has likened to “tractor production figures“. He is likely to have got credit for this stance with political commentators and many members of the public, I guess. Yet Mr Gove has also repeatedly been happy to highlight the results of some of his favoured academies, achieved under exactly the system which, at a national level, he currently criticises. He thus wants to use these particular improving results, but only in certain schools, to claim credit for the academies policy. Some will no doubt shrug their shoulders and say this is to be expected from a minister, but for me, the dishonesty and duplicity is staggering.

Finally, and on related matters…I wanted to look into the issue of whose responsibility this saga is. In his interview 10 days ago with the BBC , Mr Gove said both that the setting of grade boundaries was a matter for the boards and that the boards, in conversation with Ofqual, were ensuring that new exams – sat in English and other subjects – were comparable in standard with those in previous years. This was billed as Mr Gove denying political interference in GCSEs.

He said: “The decision about where to set grade boundaries is made by exam boards.

“If you take English, then yes the number of As and A*s has fallen but the number of Bs has increased. The number of Cs has fallen and the number of Ds has increased.

“And that is the result of the independent judgements made by exam boards entirely free from any political pressure.”

Reading this, and listening to the interview, I couldn’t resist a feeling of…well, ”scepticism” would be a polite way of putting it. While I don’t believe the Secretary of State played any direct role in ordering grade boundary changes, I think Mr Gove was being disingenuous in suggesting things are quite as simple as he implied.

First, it is not the case that exam boards make these decisions entirely “independently”. Although he did mention that they ensure the new exams are comparable in standard to previous years after “conversations” with Ofqual, in fact the influence of the regulator appears to be quite substantial.

We know, for example, that Ofqual wrote to the boards in late June to remind them about need to ensure “comparable outcomes” in new GCSE qualifications including English. I’ve also seen evidence, from a paper presented by an Ofqual director to the Ofqual board last month, that Ofqual held teleconferences with the boards every week as the publication of national results neared, to discuss “standards issues”.

The paper says “provisional award outcome data” – ie provisional national results – would be provided to Ofqual and its counterparts in Wales and Northern Ireland in late July or early August, ie well before their publication towards the end of August.

The paper adds: “Through this procedure, which includes weekly teleconferences with all of the exam boards, we will have an early sight of awards [national grade statistics] and be able to identify and challenge any standards issues.

“We will meet with the exam boards to review these data and resolve any issues on Tuesday 31st July for A-level and Monday 6th August for GCSE.”

It is clear, then, that exam boards have not been taking these decisions entirely “independently”, and that the notion of “conversations” the boards may have with Ofqual seems to underplay the detailed nature of these interactions. Ofqual itself seems to have had, to judge from the above, an opportunity to learn of any problems with GCSE English several weeks ago, if this were being flagged up by the boards.

In terms of political influence, the question then turns to what influence the Government, and the Secretary of State, have over Ofqual. While, again, there is no evidence of any direct ministerial involvement in either exam boards’ decisions over grade boundaries or over individual moves by Ofqual to scrutinise and “challenge” any such decisions, it would be very misleading to view the regulator as operating outside of general influence by ministers.

I should say, first, that Ofqual is, in one sense, more independent than its predecessor body the Qualifications and Curriculum Authority, in that it is not given a formal annual remit by the Department for Education, as used to happen throughout most of the Labour government for the QCA. Also, formally Ofqual reports to Parliament, rather than to Mr Gove.

On the other hand, Ofqual is largely funded by the Department for Education. Its chair and the rest of its board were appointed by the Secretary of State, subject in the former’s case to approval from the Queen and in the case of the other board members, in consultation with the chair. In the case of the chair, Amanda Spielman, she was appointed by Mr Gove as Secretary of State. Half of the other 12 board members were appointed by Mr Gove’s predecessor, Ed Balls, and the other half by Mr Gove. Although the chief executive, Glenys Stacey, was not directly appointed by Mr Gove, she went through an application process in which he clearly could have serious influence.

A memo by the Department for Education to the House of Commons Education Select Committee (published here ) makes this very clear. It says: “The position of Ofqual chief executive is an Ofqual appointment, on conditions of service determined by Ofqual, although both the approval and conditions are subject to approval by the Secretary of State.”

Although the minister cannot interview the candidates or express a preference for any of them, the memo continues, “extensive discussions took place among the parties involved, including the Civil Service Commissioner and the Secretary of State to decide the requirements [in the prospective candidates for chief executive] seen as important for the role.”

Among these were a “robust stance on standards issues….” although, to be scrupulously fair, this was quoted with reference to comparing our qualifications against those available in other countries, rather than in relation to guarding against drops in standards over time. The first line of the job advert by which Ms Stacey was recruited, by the way, begins “Could you guarantee the rigour of examinations and qualifications…?”

The memo lists the final requirement of the role as the ability to “maintain Ofqual’s independence” though adding, interestingly – and, perhaps, confusingly – that this should be done “in partnership with ministers”.

Jon Coles, then a very senior civil servant working for Mr Gove at the Department for Education, was one of a four-person selection panel for the chief executive post which appointed Ms Stacey. At one stage, the memo says, the chair of the panel sought “additional input” from Mr Gove and representatives of other government departments. After the selection panel had reached its decision, it made Mr Gove aware of this and he met Glenys Stacey and then approved the decision.

In the same document, a letter sent on January 5th this year from Mr Gove to the select committee chairman, Graham Stuart, is published. It begins: “As you know, the Education Act 2011 [to state the obvious, this is a government document] will strengthen Ofqual in enforcing rigorous standards and ensuring that our exams system stands comparison to the best in the world.”

Ofqual’s latest annual accounts show that the Secretary of State determines the pay, allowances and expenses of board members; that the chief executive’s remuneration is determined by the Secretary of State; and that the Department for Education determined that Ofqual should not be awarding bonuses to staff members in 2011-12.

All of this shows, then, that while Mr Gove may not have intervened directly in individual grade boundary decisions, his potential or likely influence over the overall direction of travel for standards-setting should be clear. Would it be possible, for example, for Ms Stacey or anyone in her position to have put a greater emphasis on treating pupils equally within a particular set of examinations – the key issue in the current row – even if this on occasion conflicted with attempts to tackle grade inflation?

It has to be said that not only does the potential influence over the regulator of the Department for Education seem to limit that room for manoeuvre, but legislation originally passed by Labour which established Ofqual and set its priorities in law also set out its objective as holding “standards” constant over time.

But the DfE’s influence outlined above must also be borne in mind. Grade boundary decisions, then, are clearly not taken by the boards independently. And, from what I have learned over the last few days reading these background documents, a description of Ofqual as simply acting “independently” of ministers is very simplistic indeed, if not downright misleading.


  1. Thank you for your work on this and the talent you bring to it. Please don’t stop. There are probably many other teachers like myself who have been ground down by this and cannot believe that the work they had done, striving for high standards with our pupils, or just survival for our schools, and be wiped outta the whimof authority. Where an we go? Please continue the fight for truth and justice.

  2. We found it very difficult to reconcile the tracking required in school with a new spec with no boundaries. I’m insulted by Stacey reference to overmarking of controlled coursework. We were begging for examples of work in different bands, and to know what the standard would be for coursework. It seems like they changed rules around cwk as we went along, and we began to hear of other schools doing the tasks in sections, ‘teach a bit, write a bit’, whilst we were abiding by the original guidance. And then she says we overmarking! If so moderate down the schools, don’t change the boundary.

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