Sally Collier's Speech to the Federation of Awarding Bodies Conference in Leicester.
It’s a pleasure and privilege to be here.
My first 6 months as Ofqual’s Chief Regulator has been something of a mental workout. Learning about the education system, qualifications landscape and our regulatory rules has sometimes felt like learning the intricacies of all 64 Olympic and Paralympic disciplines – some things are more straightforward than others. I was quite reassured when Olympic commentators were debating whether dressage was more challenging than taekwondo this summer, similar to the way we consider how subjects compare to one another - a problem shared, apparently.
Actually I have been out and about a lot, listening to members of this audience and many others on the front line, teachers and heads in schools and colleges and apprenticeship providers. That feedback has been invaluable in shaping what we do at Ofqual for the next period.
And I have got a superb team to support me. Assessment experts, researchers, economists, lawyers, psychologists and communicators.
It has been an immensely stimulating and enjoyable 6 months.
Much of our most high profile work over the past 6 months has been on the reform of GCSEs, AS and A levels. Reformed qualifications, a new GCSE 9 to 1 grading system – starting with maths and English next summer – new rules for marking reviews and appeals, as well as accrediting new subjects for teaching from September 2017.
However, a key priority during my tenure will be to ensure equal priority for other qualifications. That will include establishing a new regulatory landscape that brings clarity and robustness to the new world of technical and professional qualifications, and apprenticeships. Achieving that requires us all in this room to work together. From our end we have a new head of vocational qualifications, Phil Beach, and we are recruiting additional members for his senior leadership team.
Today I would like to focus on our work in 3 areas. Technical education, functional skills, and apprenticeships. I would also like to talk later about other qualifications, as part of business as usual.
The recent report by Lord Sainsbury and the government’s plan to implement it in full will see wide-reaching change to raise standards and simplify the system; 15 routes with a small number of qualifications in each. We will fully support its implementation to create a qualification system that is clear, navigable and gives the greatest opportunity for success to everybody who uses it. We will give advice where we have experience of how qualifications markets function, including on what the optimum commercial routes are. We will highlight risks and issues where we see them. A clear pathway then for our children to choose technical and professional education as a first choice to fulfill their dreams and with it contribute to our country’s skills gaps and its economic prosperity.
In order to lay the foundations to support these changes we have begun housekeeping of our Register. This has led to you withdrawing over a thousand qualifications. Navigation will be easier for all concerned. We are looking at how we continue this work.
Functional Skills qualifications
These qualifications often underpin further technical study. 1 million functional skills qualifications were awarded in 2014/15 – the most recent period for which we have data – and around 50% of these were used in apprenticeships.
Our experience of general qualifications reform is being put to use with our work to reform maths and English qualifications in this space. Government has made it very clear that these qualifications need greater relevance to and currency with employers. They should also support the raising of maths and English standards across the board.
We are working closely with the Education and Training Foundation, which is tasked with developing the national standards in literacy and numeracy and the content for the reformed qualifications. Quite clearly, if the qualifications are to serve employers’ needs, the content has to reflect their requirements. But if they are to serve their needs well, they need to have appropriate assessment too. This is where we are providing support now; advising on aspects of assessment methodology.
We expect to be consulting next year on the new qualifications. We are also considering, as with technical education, what role up-front evaluation can play. The timeline here is tight, but where an up-front review adds value, then we believe an approach to it should be considered.
Some of you may have seen the evidence session from the sub-committee on Education, Skills and the Economy yesterday (19 October) in its enquiry into the new apprenticeships arrangements. I am sure the audience rivaled that of Bake-Off. It was an evidence session for the Institute for Apprenticeships, Ofsted and ourselves.
We are delighted to play our role in ensuring high quality end-point assessments. They are of course new and different and require a flexible approach, particularly in up-front evaluation. Regulating these new apprenticeships is an area where we are currently developing an approach, rather than reviewing an existing one.
Here we have begun to look at trailblazer group assessment plans and advising them as to whether they would enable an apprentice assessment organisation to develop an end-point assessment that is both valid and able to be regulated.
We’re offering this ‘service’ as 1 of 4 potential providers of external quality assurance for apprenticeship end-point assessments.
So far we’ve engaged with around 2 dozen trailblazer groups. To date, we’ve agreed to regulate 12 assessment plans from 24 we have looked at. While these are relatively small numbers, we’re looking at what are historically some of the biggest industries for apprenticeships – such as healthcare and customer services.
But irrespective of whether they cover large or small sectors, it’s important that these assessment plans are well established. Employers understand what good looks like and what an apprentice needs to know and do to undertake a job. But many don’t (and why would they?) have on-tap access to assessment experts. That has been apparent in some of the plans we have been asked to review.
For example, we’ve seen issues with grading criteria. We’ve also seen the use of complex calculations to reach final grades, with over-reliance on some aspects of assessment, meaning outcomes can be skewed by performing well in just one, small task. And in some cases there has been a lack of detail around grade differentiation or forms of assessment.
The proposed use of on-demand testing and multiple choice tests has proved quite popular, but there has often been little detail on the use of things like item banks, and there have been issues of predictability and a lack of recognition of the resource this sort of approach requires.
None of these issues alone are show-stoppers, and we’ve provided feedback to the trailblazers we’re working with and to the Department for Education. The better the assessment plan, and the related end-point assessment, the more likely it will be that the full range of knowledge, skills and behaviours identified by employers is tested fairly and consistently.
All of that combines, as you will recognise, to give increased confidence that an assessment does what it is meant to do, and that it has value.
There is a further challenge here, one for us as regulator to be mostly concerned about, and that is being 1 of 4 external quality assurance organisations – the others being the new Institute for Apprenticeships, professional bodies, or employers themselves.
Where we are the chosen option, we require that the apprentice assessment organisation is regulated by us, and we will treat the end-point assessment as a qualification. The obvious challenge is how the bar is set between the 4 options to ensure that a level playing field is achieved. If the reforms to apprenticeships are to truly succeed, employers must see their value, in terms of the occupation-specific skills developed but also in other skills, those that are transferable. It means that those providing external quality assurance must set the bar together, and not allow an ‘easier’ option to emerge.
We’re working closely with the Institute for Apprenticeships on this. We have expertise and some resource already available. We will also hold conferences for any trailblazer on how to create an excellent quality end-point assessment.
Business as usual
Change is all well and good but of course there are many qualifications, including licences to practise, that don’t fit into any of the above and of course a lengthy transition period. We will continue to develop our ways of working, including our risk based approach with the aim of reducing any potential harm for students and improving practice. Of course, where poor practice results in harm to students, qualifications where assessments aren’t delivered, where marking or grading is compromised, or wrong marks issued then we will take strong action as the regulator.
Being able to design valid assessments, reflecting the more applied nature of vocational qualifications, and striking the ‘right’ balance between the development of knowledge and skills is not easy. It is essential that the delivery of assessments is manageable, that they are fair for students and deliver outcomes which can be relied upon. Regulation is just one component of the landscape.
I know many of you are thinking about how you will respond to the changing landscape, designing qualifications that are needed, to the quality that’s required and valued, and managing your centres so that standards are maintained.
In order that we are fit for the challenge, we’ve reviewed some of our internal structures raising the prominence of our vocational qualifications directorate.
I’ve asked Phil Beach to look at whether we’ve got in place an approach that will deliver us an appropriate system for vocational qualifications – with the bigger picture of system coherence in mind.
It is vitally important in times of change that we work together. I’ve been encouraged by the conversations I’ve had so far with FAB and I want them to continue. I am interested in learning much more about you all and to understand first-hand the impact of reforms as they are made.
So exciting times.