Laying foundations for the future

It seems appropriate for a regulator to look well beyond the immediate, fairly predictable future. The assessment system we are devising now must be able to take account of – or at least provide a firm basis for – the changes that are bound to take place over that time, many of which we cannot predict. We must build in flexibility, enabling learners to update their skills and reaffirm their competences with qualifications that keep up to date.

In doing so we must also recognise that constant change destabilises the system and discourages investment. Why should awarding organisations be expected to invest in the development of new forms of assessment if the likelihood exists that, even before the changes have had a chance to settle down, the whole system will be re-organised and their investment wasted?

Modernising the system has been on the agenda for many years. Both the awarding organisations and QCA have invested considerable resources into increasing the use of technology, which is now available for on-screen marking, to capture the data and to speed up processes. But I wonder whether sufficient resource has been put into supporting and training examiners so that they are able to keep abreast of new assessment techniques and devise new challenging questions and tasks that test the knowledge, understanding and skills of the learners? Or has so much effort been put into keeping the assessment ship afloat that we have paid insufficient attention to developing the personnel whose skills are essential to good quality examinations and tests?

In the short time Ofqual has been in existence our activities have tended to be focused at the output end of the process rather than looking at the quality of the input. Many of the problems identified in the GCSE sciences, for example, might have been tackled at an early stage if more time and resources had been expended on ensuring that the quality of the provision had been thoroughly tested before the vast majority of candidates moved to the new approach. The piloting principles I proposed in my May report have received considerable support from all quarters and will be incorporated into the consultation document seeking feedback.

The speed of change has brought with it increased complexity which, unchecked and unregulated, could add to the management burden without necessarily improving the system. The increase in the number of providers, unitised assessment (such as the Diploma and the QCF), a greater number of assessment windows and moves towards assessment on demand all require greater and more frequent input from awarding organisations and their personnel. The regulator must keep under close review the effect of change and complexity on quality. However demanding it might be, Ofqual’s expectation must be that a high and consistent quality will be maintained across providers, subjects, specifications, units or assessment windows. We will also need to be assured that quality and standards are maintain as we move to a greater use of technology as the mode of response of candidates.

At this embryonic stage in Ofqual’s development it seems appropriate to reflect on the philosophy that should underlie our approach to regulation. It is first important to establish what it means to have an independent regulator and then to consider what benefit regulation brings to the system: it is by no means proven that more regulation means better qualifications.

By passing the Apprenticeships, Skills, Children and Learning Act, and with the creation of a post of Chief Regulator, the government has indicated the need for a body at a distance from the government to safeguard standards and to promote confidence in qualifications, tests and assessments. Just as it does in health, security and financial affairs, the government will set policy in relation to education and qualifications. Under the terms of the Act Ofqual must keep various aspects ‘under review’ and identify issues that cause concern.

Within that policy, however, it is the regulator that carries responsibility for:

• determining what constitutes quality
• setting standards that awarding organisations and assessment agencies must meet
• monitoring the quality, efficiency and effectiveness of the qualifications, tests and assessments
• issuing warnings to those who fall short of requirements
• taking the necessary steps to ensure compliance with its demands.

Although we carry forward the regulatory work of QCA, Ofqual is not just ‘more of the same’; it is a new body with different duties and powers. We have to work with and through those we regulate, so a collaborative approach is essential. Our goals and those of the awarding organisations are primarily the same – to provide rigorous, fair and reliable assessments that are valued by the learners and other users of the certificates – so there is basically no conflict of interest. We must be conscious of the needs of those organisations. We must listen to their concerns to ensure that our regulatory mechanisms do not have unintended and undesirable consequences.

Our approach should lead to a reduction in centralisation, devolving more responsibility to the organisations we have recognised and thereby capitalising on the professionalism of their staff. It is not Ofqual’s responsibility to produce high-quality syllabuses, to determine the standards that are relevant to a particular job, to carry out valid and reliable assessments in appropriate contexts. The expertise for all these lies elsewhere and we must respect it. But we must also be vigilant in checking that what is promised is actually delivered. By looking at those aspects that present the greatest risk we aim to target our resources where we will be most effective.

We must also be aware of the views of the learners, whose future is determined by the qualifications and tests that we regulate. Our principle here is that the focus should be on learning. Qualifications, tests and assessment must facilitate good learning, not dominate or distort it. Good assessment enables and encourages good teaching by providing the teacher and learner with feedback that enables them to plan and progress. But too often assessment has been used to control the curriculum, leading to a narrowing of provision and the tendency to teach what is important for the assessment rather than what is intrinsically important.

With this focus on learning, one aspect that we will need to consider is the degree to which it is appropriate to spell out in detail the requirements that must be met. We require valid assessments but do we need to prescribe how validity should be attained. Or can we leave that to those responsible for preparing the assessments in the knowledge that we will be checking to ensure that they are valid? We may find that if more effort is put into devising methods to ensure validity we get a better result than that obtained by centrally-determined procedures.

Many regulated bodies in the public sector set performance standards, which prescribe the outcomes to be achieved. It may be that this approach would be helpful in the field of qualifications. Were we to go down that road, following consultation, we would expect those standards to be tailored to the specific qualifications. For example while it may be appropriate to require a minimum number of assessment opportunities, it may be more appropriate for more assessment windows for functional skills tests than, say, for A2 units. Similarly if we were to have a target for the turnaround of results, some forms of testing might better lend themselves to a speedier turnaround than others. A central question would be what can be achieved while retaining the necessary quality assurance to ensure the accuracy of the results? Other targets might encourage more awarding organisations to start to experiment with innovative approaches such as e-assessment and on-demand testing.

And as a regulator responsible for safeguarding a qualifications and testing system that has stood us in good stead over many decades, we must also step back from the immediate concerns of ensuring that the current system is as good as it can be and plan carefully to make it even better for the future.