Correspondence

Ofqual’s response to the Department for Education’s consultation on the approach for the Advanced British Standard (ABS)

Published 1 May 2024

Applies to England

Aims for the Advanced British Standard (ABS)   

1. Ofqual welcomes the aims of the ABS. These include maintaining greater breadth in post-16 studies, with increased teaching time and a clearer framework of options for students to choose from. At their heart, the ABS proposals are a curriculum reform – they set a new vision for what students should learn post-16, at what level and with what balance across subjects. Curriculum is rightly a matter for the Department for Education. It is in response to those curriculum changes that qualifications would be reformed.

2. The ABS proposals envisage a range of curriculum changes; given our role, Ofqual comments on these principally through the lens of assessment and qualifications. In so doing, we recognise that qualifications are only one part of successful curriculum reform. Other important dimensions include the availability and capability of the teacher workforce; the alignment of course-specific funding, accountability and inspection to the aims of the reform; the quality and availability of materials to support teaching; adequate levels of resourcing throughout the reform; and the recognition of qualification users such as higher education and employers.

3. In this response, we identify options for the Department for Education (the Department) in designing and delivering this curriculum and qualifications reform. We also suggest ways of managing risks, which inevitably come with ambitious reform, and signal alternative options, where these exist, for lower risk delivery of the ABS aims.

Ofqual’s statutory role 

4. Ofqual is the regulator for qualifications and national assessments in England. We have statutory objectives and duties that are relevant for the introduction of the Advanced British Standard qualification.

5. Ofqual would need to ensure that the ABS was designed and delivered in such a way that standards in new or reformed qualifications would be maintained effectively, so they would provide a reliable indication of students’ knowledge, skills and understanding. Ofqual would also need to ensure that the ABS could secure and maintain public confidence and that it could be delivered efficiently by awarding organisations.

6. Ofqual’s duties include considering that the range of qualifications available to students is appropriate. We must consider the reasonable requirements of qualification users, including students, employers and higher education. Statute also places a duty on Ofqual to take into account the benefits of innovation, and, by implication, the risks of innovation, in how qualifications are provided.

7. Ofqual must be confident that the speed and nature of any reform programme is manageable alongside delivering current qualifications, so that delivery of trustworthy qualifications, which are vital to young people’s future, is not put at risk.

Achieving the ambitions of the ABS  

The scope of the ambitions 

8. Achieving the ambitions of the ABS requires change on a scale unprecedented in England in recent decades. It envisages concurrent reform to curriculum, qualification content and structures, the qualifications market, and any associated technological reform.   

9. Ofqual has played a significant role in several recent qualifications reforms, for example the GCSE, AS and A level reforms announced in 2010 and the ongoing reform of Vocational and Technical Qualifications (VTQs).

10. Reform on this scale can be delivered successfully, but its scale and complexity require significant investment of resource across all parts of the education system.

11. In particular, given the breadth of change to curriculum, it will be important for the Department to secure sufficient expertise in good curriculum design. More broadly, strong programme management through the lifetime of the reform period and careful identification of the implications of change is important to expose and avoid unintended consequences. Failure in any one area could risk the success and reputation of the new qualification and impact the students taking it in the early years of implementation.

12. Lessons from previous reform programmes include allowing sufficient time for planning and trialling, providing effective professional development for teachers and disseminating high quality advice and guidance for stakeholders.

13. In this context, Ofqual welcomes the long-term reform timescale and the resourcing commitments set out in the consultation.

Sequencing the reform programme 

14. In a complex reform programme of this type, it is important to sequence changes carefully. Given the immediate benefits that the mathematics and English elements of the ABS proposals could deliver, the Department could consider a staged approach starting with these elements. The Department could introduce mandatory mathematics and English (appropriately tailored to the range of needs of students at this stage) at post-16, as a first step, initially focussing investment on the teacher workforce here, while contributing materially to the delivery of the longer-term vision of the ABS.

Public awareness and understanding of qualifications  

15. In essence, qualifications are a currency. Their value lies in the trustworthy evidence they provide that a student has mastered a particular body of content or set of skills to a well-understood level. Qualifications are ascribed value by higher education, employers and society as an indication that a student is suitable to progress in a particular strand of education or employment. That currency, like any monetary currency, requires public awareness, understanding and confidence.

16. The A level brand is especially well-regarded by qualification users. Over 80% of respondents to Ofqual’s perceptions survey agree that ‘A levels are trusted qualifications’ and 80% that they are good preparation for further study. This high level of confidence has been stable over recent years. This trust has been built over the 73 years that students have taken the qualification. In that time, the nature of the A level qualification has evolved significantly to meet changing educational and societal needs. However, the brand has accumulated public recognition and confidence at home and internationally.

17. New qualifications can also succeed and gain widespread recognition. The GCSE, introduced in the 1980s, demonstrates this. However, it takes time and investment to build confidence and understanding. For example, public understanding of the 9 to 1 GCSE grading scale rose slowly from 16% in 2016 to 56% in 2020. Public awareness of the relatively new T Level qualification is beginning to grow as a result of sustained effort since its inception.

18. Given the high level of recognition that A levels have accumulated, it is likely that awarding organisations will continue to offer unregulated ‘international’ A levels, even if the ABS means that A levels cease to be regulated qualifications available in state schools. These A levels could be taken in UK independent schools and abroad. This could present a confidence or reputational challenge for the ABS.

19. The Department might consider whether the aims of the ABS could be successfully implemented, whilst retaining the identity and branding of well-established, and more recently introduced qualifications that are beginning to secure public awareness, as components within the new ABS framework.

Qualification content and design  

A new whole-cohort qualification type – the importance of clear purpose 

20. The consultation proposes that the ABS would replace the wide range of level 3 qualifications currently taken by 16 to 19-year-olds - A levels, T Levels and other qualifications taken alongside them and as alternatives. The purposes of the current range of qualifications differ significantly, for example in terms of the extent to which:

• the content has a direct relationship to a specific job role
• they are designed to support entry to higher education
• they signal ability to progress directly into employment
• they focus on covering a specific subject domain or applying knowledge in different contexts
• they are designed to secure student engagement in continuing their education as an end in itself
• they are accessible to the full breadth of the 16 to 19 cohort

21. It would be challenging to combine the wide range of purposes of the current full suite of 16 to 19 qualifications into a new, tightly defined set of purposes without accepting trade-offs. For example, a qualification would be designed differently if aimed primarily to support progression to further study at higher education versus primarily for entry into a specific employment role.

22. It is therefore important that the Department is clear on the purposes it wants the ABS (or its constituent components) to have and their relative priority. It will be important that the suite of options in the ABS framework reflects sufficiently the range of purposes for which students take qualifications and the different contexts and needs of the 16 to 19 cohort. We welcome the Department’s commitment to develop qualification purposes in further detail with Ofqual. Following this work, Ofqual would expect to consult on detailed purpose statements.

Academic and vocational options  

23. The ABS reform aims to simplify the qualifications landscape for 16 to 19-year-olds. A more tightly defined set of qualifications than is currently available would be beneficial in many respects, but it is also important that elements of choice and diversity are also retained. It is critical that a strong range of high quality vocational and technical options are available, within the ABS framework, alongside academic and other general options. These vocational and technical options are required to develop skills which meet the needs of employers and the nation’s economy, and to provide choice for young people as they seek to meet their aspirations and develop their interests.

Qualifications content  

24. Ofqual supports the proposal for nationally set content for all assessed elements of the ABS. This would be important to underpin consistent national standards in each subject area across academic and occupational options and across different organisations offering the qualification. This is not currently the case across all level 3 qualifications, where different approaches are taken to subject content.

25. Once the Department has publicly consulted on subject content, Ofqual’s role is to ensure that the content can support effective assessment that will reliably indicate students’ knowledge, understanding and skills.

Level 2 route 

26. Ofqual welcomes the focus on the level 2 route for post-16 students in the context of the ABS reform. There is opportunity to improve quality for students taking vocational qualifications at level 2 through the introduction of nationally set content, an improved set of relevant and appropriately rigorous qualifications and updated assessment arrangements.

27. It will be important for the Department to confirm its expectations for the likely size and nature of the level 2 cohort. An understanding of the cohort should inform the necessary decisions to design effective content, assessment and grading arrangements.

English and mathematics content 

28. In developing proposals for compulsory study of English and mathematics, the Department should consider the wide range of achievement recognised at age 16. For example, students achieving grade 4 in GCSE mathematics may not have studied much of the higher tier content that typically forms the basis for study at level 3, including in the existing core maths qualification. Likewise, the curriculum content for English would need to be broad enough to meet a range of needs at this level, building on prior attainment and preparing students effectively for their next stages.

29. In both areas, mathematics and English content would need to enhance and support other subjects being taken and not create unhelpful duplication. Assessment and qualifications would need to support this. Ofqual stands ready to support development work in this aspect of the reforms.

Digital assessment and innovation 

30. The ABS could present opportunities for targeted and careful digital innovation. Any digital reforms would need to be carefully planned and resourced, to ensure that they do not introduce unintended unfairness into assessment, and that delivery systems are sufficiently robust and secure to maintain the strong reputation of England’s qualifications. The full implementation period for the ABS affords the opportunity for this work to be done carefully and cautiously.

31. While well-executed digitised assessments may bring benefits to students and support effective delivery of examinations, the routes to technology reducing assessment burden are complex. Ofqual will be pleased to support the further work needed in this area.

Assessment 

Approaches to assessment  

32. The consultation proposes that ‘all level 3 double majors, majors and minors within the ABS will need to follow a single set of design and assessment criteria to ensure consistency between subjects and the maintenance of standards.’ Ofqual supports the intention that the ABS is designed from the outset to secure effective assessment and maintenance of standards.

33. We also support the proposal that non-exam assessment will be used only where it is most appropriate. Ofqual’s review of controlled assessment (2013) showed that such approaches do not always lead to accurate assessment, take time away from teaching and learning and are hard to deliver consistently.

34. That said, there are good reasons, rooted in well-established effective assessment practice, for the assessment approaches to differ between subjects, and areas, for example in some vocational, practical or creative domains. It will be important to select optimal approaches for each case. Ofqual would have responsibility for setting detailed rules to secure this.

 Assessment volume and burden 

35. Ofqual welcomes the Department’s aim to manage the assessment burden students will face in the ABS. However, it is important to note that increasing the volume of content students will study, while maintaining the current level of reliability of grades, will likely increase the volume of assessment. Ofqual will offer technical advice on the trade-offs between burden and reliability as the policy is developed.

36. Any increase in assessment also creates challenges to address relating to exam timetabling, exam delivery in schools and colleges, and timely marking and issuing of results. Accommodating more exams without increasing clashes for students would require a longer timetable. This would mean exams encroaching either on current teaching time, before the exams season, or the marking and grading period, already under pressure, after the exams season. The scale of the system (16 million exam scripts across GCSEs, AS and A levels each summer) means any increase in the volume of scripts to be marked would introduce additional risk to the delivery of results and could exacerbate existing pressures, such as examiner recruitment.

37. Ofqual has significant experience in regulating for the safe delivery of high stakes qualifications and is ready to advise the Department on options to address these risks.

GCSE  

38. Ofqual stands ready to work with the Department and stakeholders to evaluate potential routes to address assessment burden in GCSEs and consider the implications of any changes.

39. It is sensible that in confirming plans for post-16 reform the Department considers any implications for GCSE and equivalent qualifications. The Department should consider the sequencing of any review of GCSE and equivalent qualifications. If the Department was minded to make changes, they could consider whether to introduce these ahead of the full roll-out of the ABS so that students would have studied revised qualifications that best prepare them for the new expectations of the ABS.

Grading 

Individual grades for majors and minors 

40. Ofqual agrees with the proposal that students should be provided with individual grades, scores or marks for each major and minor element. This supports higher education admissions and employer selection. It also gives students recognition for their - often different - achievements in different subjects.

Grading the components of the ABS  

41. The consultation proposes a single grading scale for majors and minors for all vocational, technical and academic ABS routes. This contrasts with the current established variety of grading approaches.

42. Ofqual recognises the aim of supporting parity across vocational, technical and academic routes. However, this might be better achieved in ways other than a common grading scale. Specifically, the direct comparability that a common grading scale appears to offer would be misleading and is likely to lead to unintended consequences.

43. As the ABS is intended for a broader level 3 cohort than is the case for A levels, the existing six-grade A level scale would likely need to expand. This would require a change in public understanding of grades. It also risks unintended differences in grading profiles across the range, academic and occupational, of ABS components.

44. We also note that the greater the number of grades in a scale, the greater the volume of assessment (usually exams) needed to ensure reliability.

45. It may be that occupational components of the ABS are better assessed via a grading scale that conveys occupational competence (for example, pass, merit, distinction) rather than using a multipoint academic-style scale. This would have the benefit of recognising likely differences both in nature of content and achievement of students in those areas. Equally, a pass-merit-distinction grading scale for academic subjects would not offer the precision sought by, for example, selective universities.

46. Given the range of challenges and implications of a single grading scale, we would advise careful further consideration of this proposal.

Grading the overall ABS award 

47. The choices here are complex and the comments on each option set out in the consultation lead us to suggest that further work is needed to determine the right way to proceed. This work should be undertaken with a view to the intended uses of an overall ABS award. Ofqual is ready to support this work and provide evidence-based technical advice as options are considered.

Option 1 – a certificate or statement of achievement with minimum attainment conditions (the proposed lead option). 

48. A student would be awarded the ABS if they reach a minimum attainment threshold in all ABS components. This is a ‘hurdles-based’ approach to certification. It suggests that the overall ABS could be a pass-fail: students who meet the minimum attainment threshold across the required components pass, whereas those who do not fail. This would lead to a lower number of students achieving the overall ABS than currently achieve level 3 qualifications, potentially impacting on, for example, progression opportunities post-18.

49. Furthermore, the combination of subjects that students choose will have an effect on pass rates. This is because the correlation between pass rates in different subjects will differ. For example, students’ marks across subjects such as maths, physics and chemistry are typically more similar to each other than across the social science subjects. Such variation in pass rates based on subject choice would not be desirable. It could also have the unintended consequence of distorting students’ subject choices to maximise their chances of an achieving an overall pass.

50. Finally, the hurdles-based approach leading to a binary pass-fail outcome places very significant pressure on a small number of critical grade boundaries. To make grading at these boundaries sufficiently reliable could lead to an increase in assessment burden.

Option 2 – a certificate or statement of achievement without any minimum attainment conditions.

51. A student would be awarded the ABS if they enter all relevant components, without attainment requirements. This presents few technical grading challenges. Decisions would still need to be taken about the delivery of this option, including deciding which body would be responsible for awarding a qualification.

Option 3 – an aggregate ABS score or grade.  

52. Ofqual agrees that this should not be the preferred option for the ABS. It is unclear what value this would add, as the aggregation of results from individual subjects into a single score or grade would inevitably reduce the amount of information conveyed by that overall result compared with that conveyed by results for each major and minor. Combining results in this way would suggest an implicit assumption of direct equivalence between grades in different subjects. Ofqual’s work in this area demonstrates the complexity of intersubject comparability. Ofqual has not explored the full consequences of this option, as it is not the Department’s preferred option, but could do so, if necessary.

Delivery implications 

53. The delivery model for ABS-level awarding would need to be carefully considered. If a number of awarding organisations (AOs) are recognised as providers of ABS components, which is desirable for system resilience and capacity, an individual student’s ABS is likely to comprise elements from more than one AO. The additional steps required, including transfer of information, quality assurance, and impact on reviews of marking, as well as the dependence of the ABS-awarding body on all other awarding organisations, are organisationally complex. They may also require additional time prior to the release of results, with potential implications for when this could safely take place. The Department should take cognisance of the risks associated with this and allow for the detailed planning needed.

The qualifications market 

Awarding organisation capacity 

54. Sufficient awarding organisation capacity to deliver reforms, in parallel with safe delivery of existing provision, would be vital to successful implementation of the ABS. High stakes qualifications are essential to the nation’s economic and social infrastructure and must therefore be delivered by organisations with appropriate levels of capability and resilience. Awarding organisations would need to demonstrate their ability to deliver high volume sessional, exam-based assessments with accurate awarding over time.

55. To achieve this, Ofqual would expect awarding organisations to demonstrate proven expertise in delivering such high stakes qualifications if they were to offer the ABS. It is possible, and perhaps likely, that this would result in a consolidation of the number of awarding organisations offering the ABS when compared with those currently offering post-16 regulated level 3 qualifications. This could helpfully lead to a stronger market. It is unlikely that a single provider model would ensure sufficient capacity and resilience to deliver a high stakes qualification in the volumes that the ABS would involve.

56. Ofqual would be pleased to continue discussions with the Department on the optimal approach to securing an effective awarding organisation market for the ABS.

Potential qualifications market impact

57. There are several current reform programmes in train. These include the post-16 qualification review, T Levels and Higher Technical Qualifications reform. These follow recent reforms including new apprenticeship standards and reformed functional skills qualifications. Some awarding organisations are developing qualifications that might exist only relatively briefly before the ABS is introduced.

58. The Department should aim to provide as much clarity as possible about the implications of ABS for existing reform programmes to allow awarding organisations to plan the work required to ensure quality and provision for students in the interim. It is critical that the ABS reform programme does not lead some awarding organisations to exit the market hastily, for example due to reducing demand for their qualifications or because they do not plan to offer ABS qualifications. This would leave students in the short term with a reduced choice of courses and qualifications.

Concluding comments 

59. In summary, Ofqual welcomes the policy aims of the ABS. At its heart, the ABS is a curriculum reform, in which qualifications play a critical role, alongside other levers for change.

60. Given the scale of ambition, Ofqual’s response centres on the choices and options available to the Department to maximise the success of the proposals.  Ofqual will continue to provide expert advice and use its regulatory powers to help the next stage of ABS development.

61. We look forward to working with the Department to ensure that regulated qualifications continue to function in the best interests of the students that take them, and that they maintain the confidence of those that use them across the economy and society.