Tagged / Education Secretary

HE policy update for the w/e 10th September 2020

We thought it might be a quiet week, this week, but we were wrong.  The DfE has started the new academic year with a bang, and the Ofs are going to be busy.

So we are back properly to our weekly schedule although with a bit of flexibility on days of the week.

International student visas

The Home Office have made an announcement about student visas.  The new international student immigration route is opening early, from 5th October to allow the “best and brightest” to apply for a visa under the new points based system.  That includes EU students.  This will mean that “as a result of coronavirus, some overseas students are choosing to defer their entry onto courses in the UK until the spring semester of 2021. Introducing these new routes now means that students will be able to benefit from the new streamlined process whilst still giving sponsors time to adapt after their autumn intake”.

The Secretary of State and the Minister for Universities speak

Gavin Williamson has been speaking to UUK.  He starts with a bouquet of praise and thanks for the sector and almost an apology for the extra work on admissions this year, although not quite.  There was always going to be a “but…”.

First he wanted to “land three key messages” related to the pandemic:

  • Keep going – and he looks forward to working with us all as the situation evolves over the autumn term
  • The importance of collaboration – specifically with local authorities.
  • And to stay alert, which includes comms to students and keeping them at uni rather than sending them home if there are local restrictions

And then the “but”.  It starts nicely:

  • Too often, there can be an implicit narrative that every university needs to measure itself against Oxbridge. That if a university isn’t winning Nobel prizes and taking in triple A students it is somehow second rate.
  • In reality, it is the diversity of our sector which will drive the levelling up agenda that is central to everything this Government does.

But…

  • There are still pockets of low quality. One only has to look at the Guardian subject league tables to see there are too many courses where well under 50% of students proceed to graduate employment.
  • But more fundamentally, in order to create a fairer, more prosperous and more productive country, we need to reverse the generational decline in higher technical education.
  • We have already announced that, over the next few years, we will be establishing a system of higher technical education where learners and employers can have confidence in high-quality courses that provide the skills they need to succeed in the workplace, whether they are taught in a further education college, a university or an independent training provider.
  • Of course, a large proportion of this will be delivered in our great further education colleges, but what I also want to see is for universities to end their preoccupation with three-year bachelors’ degrees and offer far more higher technical qualifications and apprenticeships. These would be more occupation focused and provide a better targeted route for some students, and benefit employers and the economy.

Again, none of this is new, he has been completely consistent.  It will be interesting to see how the sector responds.

Michelle Donelan

There was a double act at UUK this morning, as the Universities Minister also spoke.

Again, lots of thanks and different examples too.  I want to say a special thank you. Thank you for bending over backwards to unlock the dreams and opportunities of this year’s cohort.

Her speech is mostly about the bureaucracy reduction announcements set out below.  But in return for this her speech also has a “but”.  Her but is also consistent with what we have heard before.  She wants:

  • readily accessible bitesized learning for people looking to upskill and reskill…. and also foster a culture of lifelong learning”.

And it comes with a carrot – or a stick – hard to tell which:

  • You will remember that the Augar review looked in detail at flexible learning and argued for widespread changes to the organisation and funding of higher education to enable that flexibility. And we will respond in parallel with the Spending Review. Rest assured, the global pandemic has not and will not throw us off course.”

Her last point was about mental health, and the need for on-going support.

Bonfire of the metrics (and general reduction of bureaucracy)

The OfS were due to review the NSS this year, and of course we are also waiting (and have been waiting for ever, it seems) for the government response to the Pearce review of the TEF.  But the DfE have gone early.  In a move which confirms what we and everyone else has been saying all summer, the DFE have confirmed that they only really care about outcomes (and continuation) and asked the OfS to do a serious review of the NSS by the end of the year.

The announcement is here.  It is much broader than just the NSS, and there are some really interesting developments, so we will set them all out by area.

Starting with the Office for Students

The measures outlined below are a combination of decisions taken by the OfS to help achieve those aims, and changes that DfE would like the OfS to implement. DfE will be following up this policy document with strategic guidance to the OfS,”

  • Enhanced monitoring – the OfS intends to report to the DfE within 3 months on how it is reducing its use of enhanced monitoring
  • Data futures – OfS has agreed to review the proposed termly data collection to make sure it is proportionate – also looking at making data collection more timely. Due by end October with final decisions alongside an OfS data strategy in April.
  • Random sampling – the OfS has suspended this
  • No further regulatory action on student transfers – this was a “big issue” in the original Jo Johnson Green/White Paper – students were being prevented or discouraged from transferring, apparently. The OfS has decided to review their current requirements for monitoring and consult on changes – but the headline suggests they won’t get more onerous.
  • The announcement welcomes the already announced decision to make estates and non-academic data collected by HESA optional.
  • Review of TRAC (T). The Transparent Approach to Costing for Teaching.  This data was used by Augar to attack fees and the announcement recognises that the government have used it to look at efficiency.  The OfS have been asked to review it because the sector have said that it is “disproportionately burdensome”.  This year’s return has been cancelled.  A “way forward” for the review is due by October alongside the UKRI review of the other stream of TRAC (see below).
  • Review of the transparency condition – this is the monitoring data provided to the OfS relating to offers and acceptable, completion and outcomes, including by gender, ethnicity and background. The OfS have said that they will explore if the amount of information requested can be reduced and replaced by other sources, and the DfE are “pleased” with that.  Due by end October.
  • Reduction in OfS fees – the OfS have to review their own efficiency with a view to reducing fees, and to help them along the government’s review of fees (which are set by the Secretary of State) will take place this Autumn instead of next year. The QAA and HESA are expected to reduce their fees too.

So, the NSS.  Hold on to your hats – these statements are bold!

  • We have asked the OfS to undertake a radical, root and branch review of the National Student Survey (NSS)…..Since its inception in 2005, the NSS has exerted a downwards pressure on standards within our higher education system, and there have been consistent calls for it to be reformed. There is valid concern from some in the sector that good scores can more easily be achieved through dumbing down and spoon-feeding students, rather than pursuing high standards and embedding the subject knowledge and intellectual skills needed to succeed in the modern workplace. These concerns have been driven by both the survey’s current structure and its usage in developing sector league tables and rankings. While government acknowledges that the NSS can be a helpful tool for providers and regulators, we believe its benefits are currently outweighed by these concerns. Further, its results do not correlate well with other, more robust, measures of quality, with some of the worst courses in the country, in terms of drop-out rates and progression to highly skilled employment, receiving high NSS scores. Accordingly, the extensive use of the NSS in league tables may cause some students to choose courses that are easy and entertaining, rather than robust and rigorous.
  • The government shares concerns raised by some in the sector that, in its current form, the NSS is open to gaming, with reports of some institutions deliberately encouraging their final year students to answer positively with incentives or messaging about their future career prospects. Academics have also criticised the cost and bureaucracy the NSS creates, arguing that the level of activity it generates can be a distraction from more important teaching and research activities. There is a sense that the level of activity it drives in universities and colleges has become excessive and inefficient. For example, we are aware that some providers employ analysts to drill down into NSS performance, in some cases at module level, and investigate any sub-par performance.
  • Student perspectives do play a valuable role in boosting quality and value across the sector, but there is concern that the benefits of this survey are currently outweighed by the negative behaviours and inefficiencies it drives. Universities must be empowered to have the confidence to educate their students to high standards rather than simply to seek ‘satisfaction’.

Now, many people will agree with at least some of that.  The sector blows hot and cold on the NSS – heavily critiquing its use in the TEF, then worrying that there was no voice for students when it was diluted in later iterations.  Many have criticised it for being subjective and unhelpful (so not so much a criticism of the survey as a tool for driving improvements, as a criticism of its inclusion in the TEF and league tables) – but that was a case of the TEF using the metrics that they had, because there wasn’t anything else.  Lots of people have criticised the methodology, despite the reviews that have been carried out before.  Some universities have had consistent boycotts (Oxbridge).

But don’t think that abolishing it will mean that we can stop worrying about the underlying issues.  The OfS have been asked (by the end of the calendar year!) to:

…undertake a radical, root and branch review of the NSS, which:

  • reduces the bureaucratic burden it places on providers
  • ensures it does not drive the lowering of standards or grade inflation
  • provides reliable data on the student perspective at an appropriate level, without depending on a universal annual sample
  • examines the extent to which data from the NSS should be made public
  • ensures the OfS has the data it needs to regulate quality effectively
  • will stand the test of time and can be adapted and refined periodically to prevent gaming

Expectations are high.  No annual survey and yet reliable data….that reduces the bureaucratic burden, and prevents gaming and avoids lowering standards and grade inflation.  Notably there are no positive suggestions about what a new approach actually will achieve other than “reliable data on the student perspective”.  You might ask perspective on what?  Not satisfaction, it seems, or even experience, but “quality and value”.   It sounds like getting rid of it completely is on the table, replacing it with something else that isn’t a survey at all.  But what?  So this is your moment.  What is the best way to get “reliable data on the student perspective”.  We look forward to engaging with staff across BU on the inevitable OfS call for evidence.

Obviously the OfS have responded to all this.  They seem to think that they will be keeping the survey.  Maybe the requirement to avoid an annual universal sample means just that – not annual, not everyone, just a sample?

  • ‘On the NSS, our review will seek to reduce any unnecessary bureaucracy, prevent any unintended consequences and gaming of the survey, whilst ensuring that the NSS stands the test of time as an important indicator of students’ opinions and experiences at every level.

UKRI and BEIS

UKRI are being asked to make a lot of changes

Selection

  • simplify eligibility criteria for bidding
  • streamline grant schemes
  • streamlined two stage application process for grants – only necessary information provided at each stage
  • single format for CVs
  • “brand new, fully digital, user-designed, applicant-focused and streamlined grants application system with the first pilot launched in August”
  • single information document for a call rather than lots

Assurance and outcomes

  • harmonising reporting
  • reducing the number of questions and making it “minimally demanding”
  • enhance risk based funding assurance approach to reduce the burden and assure an organisation not individual projects
  • review end of award reporting

Other things

  • provide additional independent challenge (on costs and bureaucracy)
  • Stop multiple asks for information that already exists
  • review TRAC (as mentioned above)

NIHR

The NIHR are congratulated for already taking a number of steps to reduce the burden on researchers.  Now there are a set of new commitments to take this further.

  • Will consider ways of making peer review more proportionate
  • “will immediately delete clauses which place obligations on research institutions which add limited value to the general research endeavour and end user from the standard NIHR contract”
  • “review eligibility criteria for all funding streams including requirements for compliance with charters and concordats”
  • Will drop the requirement for Silver Athena Swan – but instead “We will expect organisations that apply for any NIHR funding to be able to demonstrate their commitment to tackling disadvantage and discrimination in respect of the nine protected characteristics set out in the Equality Act (2010). These are: age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation” [that sounds like more not less bureaucracy….]
  • “NIHR currently obliges researchers, through a standard contractual provision, to notify DHSC of all publications associated with their research. ….This contractual clause will be deleted for almost all new contracts from 1st August 2020 “

Reductions in providers’ internal bureaucracy

What could this mean?  Well:

  • We …expect providers to ensure reductions in government or regulator imposed regulatory activity are not replaced with internal bureaucracy. In addition, we want them to go even further to enable academics to focus on front line teaching and research: stripping out their existing unnecessary internal bureaucracy, layers of management and management processes. [now that interesting, we flagged it a few weeks ago because it featured in the introduction to the financial restructuring document as an objective…but it is still unclear how this should be implemented – and one person’s internal bureaucracy is another person’s sensible internal control measure]
  • There are a wide variety of organisations which offer voluntary membership awards or other forms of recognition to support or validate an organisation’s performance in particular areas. …. Such schemes can be helpful but can also generate large volumes of bureaucracy and result in a high cumulative cost of subscriptions. Where a university believes that membership of such schemes are genuinely the best way of addressing a matter, it is of course free to do so, but in general universities should feel confident in their ability to address such matters themselves and not feel pressured to take part in such initiatives to demonstrate their support for the cause the scheme addresses. [from the points made above, that probably includes Athena Swan – what else?]
  • We will engage with the sector, and in partnership with research funding bodies across the UK, to tackle the broader issues that are often causes of unnecessary bureaucracy. [Like what?]
  • This is also an opportunity to shift the research sector to more modern methods of research, which will help cut red tape too. This means embracing modern methods of peer review and evaluation. It also means tackling the problematic uses of metrics in research and driving up the integrity and reproducibility of research. Crucially, we must embrace the potential of open research practices.

David Kernohan was quick to respond on Wonkhe.  One thing he points out is that the government are correct that the NSS does not correlate with highly skilled employment or outcomes.  But he points out that the government’s favourite two metrics don’t correlate with each other either  – and of course why would they.

Brexit

Have you missed it?

As you know, the trade deal with the EU has to be done by the end of the year because that is when the transitional period ends.  It could have been extended, but the deadline to request an extension was 30th June 2020 – and there was no way this government (with its large majority all signed up to a possible no deal Brexit) was going to ask for an extension.

The deadline for a deal has similarly been a bit flexible – of course, and despite all the talk of dates, the most real deadline is 31st December.  Originally it had been suggested that the deal needed to be done by July to allow for ratification – now both sides are saying that the EU leaders’ meeting on 15th October is the deadline.  But no-one will really be surprised if it carries on after that.  The withdrawal agreement was sorted in October last year, as you will remember and was then approved by Parliament in December 2020, receiving royal assent in January, just days before the UK left the EU on 31st January.  It was close.  The draft legislation wasn’t even published during all the backwards and forwards before the election, because it was such a hostage to fortune for the May government.  Then Boris negotiated changes to the withdrawal agreement and “got it done”, just in time.

So, the government are getting ahead.  Hence all the fuss about the new draft bill. Press coverage has been very excitable, especially as the NI Secretary confirmed in Parliament before it was published that the new law will “breach international law in a specific and limited way”.  As many are saying, that is not usually a defence (“sorry officer, but I only [insert criminal offence of choice here] in a specific and limited way”).  You can read the Hansard extracts here.

The Internal Markets Bill was published yesterday.  If you want to read it, it is here, which is where you will also find all the amendments etc. as it goes through.

The Institute for Government have a short blog here:

  • The bill would give ministers powers to make regulations about state aid and customs procedures for trade from Northern Ireland to Great Britain, and would allow ministers to make regulations inconsistent with the UK’s obligations under the Withdrawal Agreement.
  • The existence of those powers is a breach of Article 4 of the Withdrawal Agreement, which provides that the UK must use primary legislation to give full effect to the Withdrawal Agreement in domestic law.
  • However, unless the powers were actually used, the UK would not be in breach of the state aid and customs provisions of the Northern Ireland protocol.

So that answers that question.

And also:

  • Perhaps more extraordinary than the bill’s provisions on international law are those on domestic law. Under s45(4)(g) of the bill, regulations made by the minister on state aid or customs declarations would have legal effect notwithstanding their incompatibility with “any rule of international or domestic law whatsoever”.
  • This appears to be an attempt to oust the jurisdiction of the courts to review the legality of ministerial decisions under these powers at all.
  • Such clauses are rare, and they rarely work. The courts have repeatedly found ways of reviewing government decisions even where similar clauses have tried to keep them out of the picture.
  • That is because the judges consider them an affront both to the rule of law and to parliamentary sovereignty. “It is a necessary corollary of the sovereignty of Parliament,” the Supreme Court said in a case on this issue last year, “that there should exist an authoritative and independent body which can interpret and mediate legislation made by Parliament.”
  • Section 45 of this bill will make uncomfortable reading for anyone who believes in the principle that governments are subject to the law, at home and abroad. It requires careful scrutiny in parliament.

The other concerns are about timing.  We can look forward to the arguments being aired in full over the next two weeks.

So what is the issue?

From the BBC:

  • The UK and EU settled on the Northern Ireland Protocol. This would see Northern Ireland continue to follow some EU customs rules after the transition period – meaning customs declarations would be needed for goods moving from Northern Ireland to Great Britain, as well as some new checks on goods going from Great Britain into Northern Ireland.
  • It was unpopular with some sections of the Tory backbenches and Northern Ireland’s Democratic Unionist Party – which had been supporting the government until that point. But the agreement was passed through Parliament and the Northern Ireland Protocol became part of the international treaty.

You will remember all this, because the PM said there would be no checks, and then the government said well actually there would, etc…..

From the BBC again:

  • Downing Street said one thing it would do is allow ministers to unilaterally decide what particular goods were “at risk” of entering the EU when passing between Great Britain and Northern Ireland, and therefore subject to EU tariffs.
  • The law would also give ministers the powers to scrap export declarations on goods moving from Northern Ireland to Great Britain and would make it clear that EU state aid requirements – where governments give financial support to homegrown businesses – would only apply in Northern Ireland.
  • But the government insists the bill only introduces “limited and reasonable steps” to “remove ambiguity” – not “overriding” the withdrawal agreement, as government sources had suggested on Sunday.

We will see.  Maybe they are just making sure that there is time for proper Parliamentary scrutiny this time, by publishing something technical in good time rather than waiting for October when the deal is finalised and there is no time to discuss it properly.  Or maybe it is sabre rattling.  And why might they need to sabre-rattle?  Because, apart from the NI border issue, there are also a couple of (unsurprising) issues outstanding in the main trade deal negotiations with the EU.

One is fishing rights, which was always going to be tricky.  You will recall that at one point it nearly derailed the discussions last year when France and Spain demanded extra concessions at the last minute.  There is an Institute for Government article from March and a  Guardian article (from June).

And the other issue is state aid – the rules about supporting domestic businesses, which are seen as anti-competitive.  There is an FT article on that.

We can expect a lot more rhetoric, bitterness, and positioning over the next few weeks.  It is clear that the deal won’t be done until it is done, and also that all the other bits, like research collaboration and participation in Erasmus, are dependent on there being a deal at all.  So we’ll just have to wait and see.

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HE policy update for the w/e 3rd September 2020

So it’s back to school for pupils and teachers, and Parliament is back (although still mostly virtually). What’s in the news?

Ofqual fight back

The House of Commons Education Committee grilled Ofqual this week in a fascinating session – the transcript is here. Before the session, Roger Taylor, the Chair of Ofqual, submitted a written statement, which you can read here.   We thought we would summarise the good bits for you.

Before you skip, though, the obvious question is “does it matter” – or is it all just a witch-hunt?  Clearly it does matter, because some of the same issues that led the government to cancel exams this year still apply – missed school time, uneven opportunities to learn, the implications of a second wave.  In our next segment, we look at the hints about next summer.

If you want to skip the next bit, the conclusion seems to be: Ofqual were handed an impossible brief by the Minister, who made it harder by changing policy on the hoof without asking them, they had a solution to it all in the form of a better appeals process to address outlying results (like high performing students in schools with poor previous performance) but never got a chance to roll it out because of the mocks fiasco, that they always thought exams should have gone ahead, and that the algorithm was fair and has been unfairly criticised by people who don’t understand the data!  Gavin Williamson is giving evidence soon, so that will be worth reading.  And Ofqual are going to publish correspondence so everyone can see that it wasn’t their fault….

David Kernohan has written about it for Wonkhe here.

The written statement  starts with an apology to students, teachers, and HE and FE providers.  As widely reported on the news channels yesterday, it confirms that Ofqual didn’t want the exams to be cancelled – they wanted them held in a socially distanced way.  Gavin Williamson decided to cancel them because of concerns about lost schooling and the risks with getting students back into schools.  So the well known solution and the well known moderation process was adopted. 

You will recall this decision was announced on 18th March – which was very early – and might be said to have shown decisiveness and the desire to provide certainty in a complex situation.  But of course that assumes that the alternative was going to be a good and not a mutant one, which we all hoped it would be…..

In the evidence session, Roger Taylor said that after Ofqual offered advice on options:

  • It was the Secretary of State who then subsequently took the decision and announced, without further consultation with Ofqual, that exams were to be cancelled and a system of calculated grades was to be implemented. We then received a direction from the Secretary of State setting out what he wished Ofqual to implement.

In the statement, Ofqual say:

  • The principle of moderating teacher grades was accepted as a sound one, and indeed the relevant regulatory and examination bodies across the four nations of the United Kingdom separately put in place plans to do this. All the evidence shows that teachers vary considerably in the generosity of their grading – as every school pupil knows. Also, using teacher assessment alone might exacerbate socio-economic disadvantage. Using statistics to iron out these differences and ensure consistency Written submission from Roger Taylor, Chair of Ofqual looked, in principle, to be a good idea. That is why in our consultations and stakeholder discussions all the teaching unions supported the approach we adopted. Indeed, when we consulted on it, 89% of respondents agreed or strongly agreed with our proposed aims for the statistical standardisation approach.

And they knew there were risks but on the whole the averaged out effect was correct:

  • We knew, however, that there would be specific issues associated with this approach. In particular, statistical standardisation of this kind will inevitably result in a very small proportion of quite anomalous results that would need to be corrected by applying human judgment through an appeals process.
  • For example, we were concerned about bright students in historically low attaining schools. We identified that approximately 0.2% of young peoples’ grades were affected by this but that it was not possible to determine in advance which cases warranted a change to grades. That is why the appeals process we designed and refined was so important. But we recognise that young people receiving these results experienced significant distress and that this caused people to question the process.

In the evidence session, Roger Taylor was asked about this and he said:

  • It was clear that to make a valid judgment would require a degree of human judgment and therefore a form of appeal would be necessary to make this work, but we were also exploring with the exam boards how we could implement a system of outreach to those students through the exam boards to let them know on the day, “Look, we think you’ve probably got a very good case for appeal.” That was the direction we were moving in. When the mock appeals route came in, that question became less relevant.

And they are still defending it:

  • The statistical standardisation process was not biased – we did the analyses to check and found there was no widening of the attainment gap. We have published this analysis. Indeed, ‘A’ and ‘A*’ grade students in more disadvantaged areas did relatively better with standardised results than when results were not standardised.

They were challenged on this in the evidence session.

  • Robert Halfon, the chair, asked about it: The Department for Education confirmed on 14 August that pupils from lower socioeconomic groups were more likely than their peers to have their centre assessed grades downgraded by Ofqual’s algorithm at grades C and above. The difference between Ofqual’s moderated grades and teacher centre assessed grades for lower socioeconomic groups was 10.42%. In contrast, the difference between Ofqual’s moderated grades and teacher centre assessed grades for higher socioeconomic groups was 8.34%.
  • Michelle Meadows, Executive Director for Strategy and Research, replied: We had done a full equalities analysis, looking at the grades not just by socioeconomic status but by other protected characteristics such as ethnicity, gender and so on, and what we were able to see and we were very confident about was that any fluctuation in outcomes seen for these various groups this year was extremely similar to the small changes in outcomes we had seen in previous years. In other words, there was nothing about the process that was biased.

And when challenged about the impact on individual students, Roger Taylor said in the evidence session:

  • I disagree with the notion that this algorithm was not fit for purpose or that a better algorithm would have produced a different result; but I strongly agree with your statement that to say this was fair just fails to recognise what happens to students—just the level of accuracy that was fundamentally possible with the information that was available was too low to be acceptable to individuals, and we recognised this right at the outset. We identified this as a risk.

And on small class sizes etc

  • However, the impossibility of standardising very small classes meant that some subjects and some centres could not be standardised, and so saw higher grades on average than would have been expected if it had been possible to standardise their results. This benefitted smaller schools and disadvantaged larger schools and colleges. It affected private schools in particular, as well as some smaller maintained schools and colleges, special schools, pupil referral units, hospital schools and similar institutions. We knew about this, but were unable to find a solution to this problem. However, we still regarded standardisation as preferable because overall it reduced the relative advantage of private schools compared to others.
  • Ultimately, however, the approach failed to win public confidence, even in circumstances where it was operating exactly as we had intended it to. While sound in principle, candidates who had reasonable expectations of achieving a grade were not willing to accept that they had been selected on the basis of teacher rankings and statistical predictions to receive a lower grade. To be told that you cannot progress as you wanted because you have been awarded a lower grade in this way was unacceptable and so the approach had to be withdrawn. We apologise for this.

And here is the killer statement:

  • With hindsight it appears unlikely that we could ever have delivered this policy successfully.

And whose fault is it?

  • Understandably, there is now a desire to attribute blame. The decision to use a system of statistical standardised teacher assessments was taken by the Secretary of State and issued as a direction to Ofqual. Ofqual could have rejected this, but we decided that this was in the best interests of students, so that they could progress to their next stage of education, training or work.
  • The implementation of that approach was entirely down to Ofqual. However, given the exceptional nature of this year, we worked in a much more collaborative way than we would in a normal year, sharing detailed information with partners.
  • We kept the Department for Education fully informed about the work we were doing and the approach we intended to take to qualifications, the risks and impact on results as they emerged. However, we are ultimately responsible for the decisions that fall to us as the regulator.
  • …. The blame lies with us collectively – all of us who failed to design a mechanism for awarding grades that was acceptable to the public and met the Secretary of State’s policy intent of ensuing grades were awarded in a way consistent with the previous year.

Autumn exams:   It was clear to everyone that autumn exams would be a problem for those intending to start university this year.  No plan or proposal was made for this, apart from ministerial exhortations that universities should be flexible, and vague references to a January start.  Put on top of an absolute prohibition on unconditional offers, it was hard to see what universities were meant to do. Ofqual say:

  • “the original policy was adopted on the basis that the autumn series would give young people who were disappointed with their results, the opportunity to sit an examination. However, the extended lockdown of schools and the failure to ensure that such candidates could still take their places at university meant that this option was, for many, effectively removed. This significantly shifted the public acceptability of awarding standardised grades”

I have no idea what that means….but it looks like blaming the context for the problems.  Roger Taylor clarified it in the evidence session:

  • When the decision was originally made, there was a strong belief that the autumn series would be the compensation for that—that people would be given a chance and that university places could be held open for them that they could take in January, and that that would limit that damage. At the time, it was felt that it was a fair offer, but of course, over time, schools did not reopen; there were no arrangements for late entry to university; and by July, it was clear that the autumn series did not represent any sort of reasonable alternative that candidates felt would make up for being given an inaccurate calculated grade. At that point, we were in a situation where it was difficult to see how people would accept it as a fair way to have their grades awarded.

Autonomy and influence

  • Roger Taylor: The relationship is one in which the Secretary of State, as the democratically accountable politician, decides policy. Ofqual’s role is to have regard to policy and to implement policy, but within the constraints laid down by the statute that established Ofqual. Those constraints are that the awarding of grades must be valid, it must maintain standards year on year, and it must command public confidence. We can decide not to implement a direction from the Secretary of State if we feel that it would directly contradict those statutory duties, but if the policy does not directly contradict those statutory duties, our obligation is to implement policy as directed by the Secretary of State.

There was a bit more about this in the evidence session when Roger Taylor was asked about the mock appeals policy (see below) and he said:

  • It is important, in trying to manage public confidence, that we do not have a Secretary of State stating one policy and Ofqual stating a different policy. It also struck us that the way to resolve this was to move at pace and it needed to be negotiated and managed in an orderly fashion. But we were acting with full independence.

The comings and goings about the use of mock results in appeals were discussed at length:

  • Roger Taylor:the Secretary of State informed us that, effectively, they were going to change policy. Until that point, the policy had been calculated grades plus an appeals process. The Secretary of State informed me that they were planning to change this policy in a significant way by allowing an entirely new mechanism by which a grade could be awarded through a mock exams appeal. Our advice to the Secretary of State at this point was that we could not be confident that this could be delivered within the statutory duties of Ofqual, to ensure that valid and trustworthy grades were being issued. The Secretary of State, as he is entitled to do, none the less announced that that was the policy of the Government.
  • That having been announced as the policy of the Government, the Ofqual board felt—I think correctly—that we should therefore attempt to find a way to implement this in a way that was consistent with our statutory duties. We consulted very rapidly with exam boards and other key stakeholders. We were very concerned that this idea of a valid mock exam had no real credible meaning, but we consulted very rapidly and developed an approach that we felt would be consistent with awarding valid qualifications. We then agreed that with the Department for Education and, to our understanding, with the Secretary of State’s office. We then published this on the Saturday. We were subsequently contacted by the Secretary of State later that evening and were informed that this was in fact not, to his mind, in line with Government policy.
  • ….It was published about 3 o’clock on the Saturday. I think the call from the Secretary of State was probably at around 7 o’clock, 8 o’clock that evening. The Secretary of State first phoned the chief regulator. …
  • The Secretary of State telephoned me and said that he would like the board to reconsider. ….given the Secretary of State’s views, it felt appropriate to call the board together very late that evening. The board convened at, I think, around 10 o’clock that evening. I think at this stage we realised that we were in a situation which was rapidly getting out of control—that there were policies being recommended and strongly advocated by the Secretary of State that we felt would not be consistent with our legal duties, and that there was, additionally, a growing risk around delivering any form of mock appeals results in a way that would be acceptable as a reasonable way to award grades….

Grade inflation

  • Ian Mearns asked: This is the problem: Ministers are regularly telling us that we have more good and outstanding schools, with the most highly professional teaching profession that we have ever had. Given that process, that improvement and that continuing improvement, should there not be some increase in the levels of achievement by youngsters year on year that cannot be put down as grade inflation?
  • Roger Taylor replied: On your point about grade inflation, we were very aware that being very strict about grade inflation would only make this situation worse. That is why, in the design of the model, at every point where we could reasonably do this, we erred in the direction of making decisions that allowed grades to rise. Consequently, the final result of the moderated grades did allow for between 2% and 3% inflation in grades which, in assessment terms, is very significant and larger than would represent the sorts of effects that you talked about resulting from improvements in teaching, but we felt that that was appropriate in these extremely unusual circumstances, given the disruption happening in people’s lives as a result of the pandemic.

Issues with CAGs:

  • David Simmonds MP said that he has had more complaints about the u-turn and the fairness of the CAGs than the original grades. There is concern about the lack of opportunity for students to appeal these grades.
  • Roger Taylor said: It goes to the nature of the problem: there is not an independent piece of information that can be used to determine between these two competing claims. That is why the lack of any form of standardised test or examination makes this a situation that people find very hard to tolerate.

On private students (who have to take exams in the autumn):

  • Roger Taylor: I have huge sympathy with these people. Clearly, they have been some of the people who have lost out most as a result of the decision to cancel exams. I will hand over to Julie to say a little bit more about this, but once the decision had been taken to cancel exams, it was very hard to find a solution. We explored extensive solutions, but ultimately the situation was one in which, once exams had been cancelled, these people had lost the opportunity to demonstrate their skills and knowledge in a way that would enable them to move forward with their lives. That was the situation we were in.

On the tiering problem (students getting a higher grade than permitted by the exam, i.e. foundation students at GCSE who can’t get higher than a 5, who got a 6, for example):

  • Michelle Meadows: In the absence of papers this year, we felt that the fairest thing to do was to remove those limits on students’ performance. So there were a very small number of cases where, for the tiered qualifications, less than 1% of foundation tier students received higher grades and, for the higher tier, less than 0.5% received lower grades than they would normally achieve. We felt that it was a decision in favour of students—that they would not be constrained in the normal way.

And on BTECs:

  • Roger Taylor: It was not inevitable that there would be a domino effect, because the use of calculated grades inside the BTEC system was completely different from what had gone on with general qualifications. They were two completely separate pieces: one Ofqual was closely involved with and where we had the authority to make a decision; and the second was one that Pearson were responsible for and where we had no authority to determine how they were going to respond to the situation. That was their call.

And did the algorithm mutate?

  • Ian Mearns: At what point did the algorithm mutate?
  • Dr Meadows: I don’t believe that the algorithm ever mutated.

So what about next year

There are already discussions about delaying the exams, some elements have been changed, there are discussions about having an online option with open book exams, etc.  Ofqual have now made it extremely clear in the evidence session referred to above that they didn’t want to cancel exams this summer and they certainly don’t want to next summer, but also that they don’t want to rely on moderated CAGs again.  So some form of formal assessment seems likely.  But this one has some way to run.

For what was announced in August, Schoolsweek have a nice round up of the changes to A levels and for GCSEs here.  The Ofqual statement about A levels, AS levels and GCSEs is here.

In their statement referred to above, Ofqual confirm that amongst the lessons learned from this year are some things that will influence next year:

  • any awarding process that does not give the individual the ability to affect their fate by demonstrating their skills and knowledge in a fair test will not command and retain public confidence
  • a ‘better’ algorithm would not have made the outcomes significantly more acceptable. The inherent limitations of the data and the nature of the process were what made it unacceptable

And there should have been better comms and not just by them.

In the evidence session, Roger Taylor said:

  • I think we have been very clear that we think that some form of examination or standardised test, or something that gives the student an ability to demonstrate their skills and knowledge, will be essential for any awarding system that the students regard as fair. We have done some consultation, and have published the results of that consultation, but it is obviously a fast-moving environment, and the impact of the pandemic remains uncertain over the future, so it is something that we are keeping under constant review……I want to be really clear that, absolutely, we raised it in our initial consultation, and we are very conscious of the enormous benefit that would come from delay. We recognise the value in trying to find a way of making this work.

And Julie Swan said:

  • Content for GCSEs, AS and A-levels is of course determined by Ministers, and Ministers, as I am sure you will know, have agreed some changes to content for a couple of GCSE subjects—history, ancient history and English literature. We have published information about changes to assessment arrangements in other subjects that will free up teaching time, such as making the assessment of spoken language in modern foreign languages much less formal. …..as well as allowing, for example, GCSE science students to observe practical science, rather than to undertake it themselves….We are working with the DFE to get to conclusions within weeks, rather than months.

Gavin Williamson’s position

Gavin Williamson gave a statement to the House of Tuesday, on the first day back.  He said very, very little, really.  He apologised and then moved on quickly to talk about schools going back.  David Kernohan has written about this for Wonkhe too.

  • The problem with having a Prime Minister who will only sack officials is that we are forced to watch senior politicians descent into near-Grayling levels of farcical inadequacy without hope of respite. Williamson’s haunted soul screams for release, but still he has to field questions about next summer while struggling to get through the next five minutes.

Research Professional cover it here.

Meanwhile in HE

The Office for Students have today launched a call for evidence into Digital teaching and learning in English Higher Education during the pandemic.  It closes on 14th October 2020.

The review will consider:

  1. The use of digital technology to deliver remote teaching and learning since the start of the pandemic and understand what has and has not worked.
  2. How high-quality digital teaching and learning can be continued and delivered at scale in the future.
  3. The opportunities that digital teaching and learning present for English higher education in the medium to longer-term.
  4. The relationship between ‘digital poverty’ and students’ digital teaching and learning experience

If you are interested in contributing to a BU institutional response please contact policy@bournemouth.ac.uk as soon as possible.

Inquiries and Consultations

Have you contributed to a Parliamentary Inquiry?  Many colleagues from across BU have done so over the last year, and inquiries can be relevant for both academic and professional services colleagues.  Your policy team (policy@bournemouth.ac.uk) can help you prepare and submit a response – there are some important rules to follow about content and presentation, but a good submission might result in a call to give oral evidence (by video, these days) or get people talking about your submission.

You can find the list of open Parliamentary inquires here.  They include (just a few examples):

  • Police conduct and complaints (accepting written evidence until 14th September 2020)
  • Digital transformation in the NHS {(until 9th September)
  • Reforming public transport after the pandemic ?(until 24th September)
  • Biodiversity and ecosystems (until 11th September)
  • Black people, racism and human rights {(until 11th September)

And you can also find Secre – a small selection (these have longer dates):

  • A call for evidence on a future international regulation strategy
  • Pavement parking
  • Marine energy projects
  • Distributing Covid and flu vaccines
  • Recognition of professional qualifications
  • Marine monitoring
  • Deforestation in UK supply chains
  • Waste management plan for England
  • Front of pack nutrition labelling
  • Review of the Highway Code to improve road safety for cyclist, pedestrians and horse riders

Let us know if you are interested in responding to these or any others.MinisSecre

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JANE FORSTER                                            |                       SARAH CARTER

Policy Advisor                                                                     Policy & Public Affairs Officer

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