Correspondence

Qualifications at level 2 and below consultation response

Published 3 May 2022

Applies to England

Overview

The government’s proposed reforms to qualifications at level 2 and below, taken by students aged 16 and over, aim to simplify the landscape and improve the quality of provision. Ofqual supports these aims, as the interests of students and apprentices of all ages underpin our regulation. The aims align with our statutory objectives, which include securing qualification standards and promoting public confidence in regulated qualifications.

Owing to the scale and diversity of the landscape at level 2 and below, Ofqual advises that the government considers further the phases proposed for the implementation of the reforms. The benefits of this in relation to delivering the government’s ambition are threefold:

• providing better continuity of provision for those already studying;
• avoiding capacity risks within those awarding organisations who will need to effect change at a time when they are already undertaking level 3 reform activity; and
• staggering the practice changes required by providers, so as not to overwhelm educators at a time of recovery from the COVID-19 pandemic. Ensuring schools and colleges have appropriate time and capacity to adapt to the reformed requirements, and are able to do so coherently, will be critical to realising the intended benefits for students.

Sequencing the implementation of the reforms

The qualifications in scope of this review are numerous and diverse. They span academic and technical provision of a range of forms and at multiple levels – entry levels, level 1 and level 2 – as well as including a number of specific qualification types. At present, there is a risk that the large number of proposed groupings are not sufficiently clear or straightforward for students and others to differentiate between.

To address this, Ofqual’s expert opinion is that it would be helpful further to segment, and define, the provision based on aspects such as qualification purpose – in effect, combining those of the 17 proposed groupings that have common features. As well as aiding navigability for students, this clarity with respect to purpose is critical to supporting good assessment design by awarding organisations. This will help ensure that students are tested on the right things, in the right way, to support them in taking their next step, whether this is into work, an apprenticeship, or further academic or technical study. School and college leaders will, in turn, have a clearer basis on which to design the associated programmes of study.

This type of segmentation also has the benefit of enabling even more effective regulation of the resulting qualifications, by providing a sound basis for Ofqual to develop its regulatory approach. It would enable regulations to be put in place tailored effectively to the wide range of purposes and contexts that relate to the qualifications in scope.

The proposed timeline for implementation

At level 3, implementation of the Department’s proposals has been delayed by a year. This means that the proposals at level 2 and below – which were originally intended to follow those at level 3 – will now largely be implemented at the same time. This poses significant risks in terms of system capacity, which may impact on students’ ability to engage with the new provision. It will also entail challenges for qualification design as, based on the present timeline, some level 2 qualifications are expected to be developed and approved before the corresponding level 3 qualifications – to which in some cases they are intended to progress – are available.

The further segmentation that Ofqual proposes would provide the scope to increase the coherence of the phased implementation between level 3, and level 2 and below. This would help secure the quality of the provision and the ability of students, and school and college leaders, to engage with it. It would support the central aims of an easily navigable landscape with clear and high quality progression routes. There are multiple ways in which this segmentation could be applied. By way of illustration, it might be possible initially to focus on level 2 qualifications that are intended to progress to employment, given the significant work to date on the policy around their level 3 equivalents and the review activity that will be underway in relation to those. Introduction of further segments of the provision could then be phased over subsequent years.

This approach would also mean that due time and consideration could be given to those qualifications in scope of the review that will need particular consideration, owing to there being specific intentions, set by the Department, regarding their content and curriculums. ESOL qualifications are one such group, where they may be linked to new National Standards for Adult Literacy. There is also the proposal of new national standards for Personal, Social and Employability qualifications. In contexts such as these, and the T Level transition programme, Ofqual will work closely with the Department, advising on matters relating to assessment and regulation, and ensuring that the regulatory approach is coherent with the curriculum intentions.

The impact on students, awarding organisations, and schools and colleges

More so than at level 3, qualifications at level 2 and below, aimed at those aged 16 and over, serve a wide range of students, with a breadth of needs, prior achievements and aspirations. The Department’s impact assessment estimates that about a third of those aged 16-19 who enrol on the qualifications in scope of these reforms are in the most socioeconomically disadvantaged group. Ofqual welcomes the drive to ensure that these students, like all students, can choose effectively from a range of high quality provision. It is important that aspects of the proposals, such as certain sizes of qualification being available only to certain age groups, do not remove legitimate choices and opportunities for the students who depend on these qualifications.

Segmentation of the proposals, in a phased way, could help to mitigate this by ensuring that there is an appropriate range of provision for these students, as well as clarity about that provision, and that schools and colleges have sufficient time to familiarise themselves with the associated requirements. This would also increase the ability of awarding organisations to develop high quality qualifications aligned to clearly defined purposes. The Department’s indication that it will provide further analysis of the potential impact of these proposals on awarding organisations is welcome. It would be particularly useful to explore the cumulative impact on awarding organisations that offer qualifications in scope of both the proposals at level 3 and those at level 2 and below. In that regard, Ofqual has a responsibility to identify where there are risks to students if, for example, market instability affects the availability of qualifications. Ofqual would also welcome further analysis of the impact of the proposals on schools and colleges.

Conclusion

Ofqual fully supports the aims that underpin the proposals at level 2 and below, and will work closely with the Department, the Institute, and other stakeholders, in their implementation. By further segmenting the qualifications in scope at level 2 and below, as well as adjusting their phasing so that it coheres more with that at level 3, the policy intent of improving quality and increasing navigability would more readily be delivered.