4.48 There are concerns regarding the extent and quality of current modifications to examination papers. On this basis, if OLMs were to be specified as a reasonable adjustment that should not be made under section 96, this could disadvantage some disabled candidates. The potential disadvantage that may be suffered by disabled candidates could also undermine public confidence in general qualifications.

4.49 We therefore propose that no specifications be made under section 96 in relation to OLMs. This would allow awarding organisations to continue to allow the use of OLMs as a reasonable adjustment and minimise the disadvantage to disabled candidates. As there are quality concerns both in relation to OLMs and to modified papers this approach would appear neutral in relation to the need to secure that qualifications provide a reliable indication of the knowledge, skills and understanding of a candidate. Awarding organisations should take steps to make sure modified papers are of sufficient quality that OLMs are not needed. In addition, or alternatively, they should take steps to enhance the quality of the interventions made by OLMs.

4.50 This issue highlights the importance of designing accessibility into qualifications from the start of the development process, as outlined in Fair Access by Design.³³