Consultation outcome

Analysis of consultation responses: Arrangements for the assessment and awarding of Vocational and Technical Qualifications and Other General Qualifications in 2021 to 2022

Updated 6 August 2021

Summary

The government’s intention is that exams and other assessments including for vocational and technical qualifications (VTQs) and other general qualifications^{[footnote 1]} will go ahead in the academic year 2021 to 2022.

The government recognises, however, that students who will be taking exams and other assessments have experienced significant disruption to their education and that these students may also need continued support in the face of any further disruption.

The Department for Education (the Department) and Ofqual published a joint consultation on the arrangements for the assessment and awarding of vocational, technical and other general qualifications:2021 to 2022 on 12 July 2021. It set out the Department’s policy position that exams and other assessments should go ahead but that adaptations to assessments and qualifications may be necessary and appropriate to address the ongoing impact of the coronavirus (COVID-19) pandemic. Results will therefore be based on evidence from exams and other assessments. It also set out the small number of changes necessary to Ofqual’s regulatory arrangements so that exams and assessments could no longer be replaced with teacher judgement (Teacher Assessed Grades or TAGs) and to continue to permit awarding organisations to make adaptations to their assessments and qualifications.

The consultation ran between 12 July 2021 and 26 July 2021 and received 259 responses, submitted either through an online form or by email. This document provides a summary of the responses received.

Background

As previously set out, the government’s intention is that exams and other assessments will take place in the academic year 2021 to 2022. This is because exams and other assessments continue to be the fairest way for students to evidence what they know, all other things being equal.

On 12 July 2021, the Department for Education (the Department) and Ofqual published a joint consultation. The Department was the author of Part A (policy position and equalities considerations) and Ofqual was the author of Part B (changes to Ofqual’s regulatory arrangements, equalities impact assessment, regulatory impact assessment); this division reflected the key roles and responsibilities of the 2 organisations. The 2 parts of the consultation were necessarily linked as the policy position set out in Part A informs the approach taken in Part B.

In Part A of the consultation, the Department set out its policy position and scope of adaptations to assessments and qualifications for VTQs approved for inclusion in performance tables, Functional Skills qualifications (FSQs) and T Levels that may be necessary to address the ongoing impact of the coronavirus (COVID-19) pandemic in the academic year 2021 to 2022. The Department consulted on the equalities impacts of this policy. In Part B of the consultation, Ofqual set out the changes to its regulatory arrangements to implement the Department’s policy position, as set out in Part A of the consultation. Ofqual consulted on the impact of changing the categorisation of qualifications in its regulatory framework so that qualifications could not be awarded based on teacher judgement (Teacher Assessed Grades or TAGs) and would only be awarded based on evidence from exams and other assessments.  Awarding organisations would be permitted to make adaptations to their qualifications and assessments, and to carry forward any adaptations from academic year 2020 to 2021 where they were still necessary and appropriate. Ofqual also consulted on minor updates to the drafting of the framework to reflect the context of academic year 2021 to 2022. 

Approach to analysis

The consultation included 13 questions and was published on the Ofqual and Department for Education websites with an online form for responses.

Reflecting the approach to the consultation, this analysis document follows the same format. The Department analysed the responses to the questions contained in Part A and Ofqual analysed the responses to the questions contained in Part B.

This was a consultation on the views of those who wished to participate and, while we tried to ensure that as many respondents as possible had the opportunity to reply, it cannot be considered as a truly representative sample of any specific group.

We present here summaries of the responses to the consultation questions in the order in which they were asked. For each of the questions, we presented our proposals and then asked respondents whether they had any comments on what we had proposed. Respondents did not have to answer all the questions. Some respondents chose to provide general comments instead of responding to the specific proposals. During the analysis, we reviewed every response to each question. In some instances, respondents answered a question with comments that did not relate to that question. Where this is the case, we have reported those responses against the question to which the response related rather than the question against which it was provided. In several places we noticed that respondents used almost identical phraseology in their comments. These responses were analysed no differently from other responses, although it has been highlighted where they may have influenced a central theme.

Who responded?

We received 259 responses to our consultation. 256 respondents completed the survey online – these are recorded in the figures shown against each question. We also received 3 free text responses. These are not included in the quantitative data we provide below but relevant comments have been considered as part of the appropriate question analysis. We list the organisations that responded to the consultation in Annex A.

In addition to the formal consultation, we also held engagement events with a wide range of stakeholders including awarding organisations and colleges. The purpose of these events was to support awarding organisations in developing their approaches, and to identify and understand potential issues, and how these might be addressed.

The views expressed at these events were not formal consultation responses (although some of those attending may have separately responded to the consultation) and as such are not reported in this analysis document. We have considered both the responses to this consultation and the views expressed at consultation events when developing our final position.

Table 1: Breakdown of consultation responses where the respondent has indicated it is an official response from their organisation ^{[footnote 2]}

Official Responses	Count
Awarding body or exam board	19
School or college	10
Other representative or interest group	10
SLT (Senior leadership team)	10
Awarding organisation employee	3
Other	3
Local authority	2
Private training provider	1
Academy chain	1
Teacher (responding in a personal capacity)	1
Student	1
University or higher education institution	1
Total	62

Table 2: Breakdown consultation responses where the respondent has indicated it is their own personal response ^{[footnote 3]}

Personal Responses	Count
Teacher (responding in a personal capacity)	94
Parent or carer	24
Student	18
School or college	16
Academy chain	13
SLT (Senior leadership team)	9
Exams officer or manager	7
Consultant	3
Awarding organisation employee	2
Local authority	2
Other representative or interest group	2
Awarding body or exam board	1
Student – private, home-educated of any age	1
University or higher education institution	1
Governor	1
Total	194

The vast majority of respondents indicated that they were based in England. We received a small number of responses from Wales (2), Northern Ireland (2) and other non-EU countries (2).

This was a public consultation on the views of those who wished to participate. We were pleased to receive a large number of responses, although we recognise that the responses are not necessarily representative of the general public or any specific group.

Detailed analysis

Part A - Arrangements for academic year 2021 to 2022

Question 1

Are there any other equalities impacts that we have not identified and should consider?

Of the 259 responses received for this consultation, a total of 74 comments were submitted. Approximately two thirds of respondents agreed there were no other equalities impacts that they had identified for the Department to consider. The comments received were largely related to assessments that were already in scope of this consultation, although 15 responses were focused on GCSEs and A levels, which are out of scope. Many respondents used this question to highlight the ongoing impact of lost learning which is explained in more detail below. There was a consensus among respondents that the Department’s consideration of equality impacts had been thorough and was welcomed.   

The majority of responses from awarding organisations and some students and teachers requested that any decisions on adaptations should be made as soon as possible and communicated by awarding organisations before the start of the academic year 2021 to 2022, this would alleviate many of the concerns for students, teachers and centres.  

The majority of responses recognised that COVID-19 had disrupted learning in multiple ways. This included the lack of exam preparation, face-to-face learning, time for practice of practical skills and for work placements. It was also highlighted, largely by teachers, who were the largest stakeholder group to submit comments on question 1, that the impacts have differed depending on where students and centres were geographically in the country, for example some regions had more public health restrictions in comparison to others. 

A significant proportion of the comments from awarding organisations and an equalities organisation expressed that due consideration should be given to students or learners who have SEND (special educational needs and disabilities) or are from a disadvantaged background or have protected characteristics, given that these are students/learners who will have been affected the most.  

A number of respondents argued that insufficient support had been given to students. A key area highlighted was technology support, recognising that there are several factors that can affect digital inclusion and literacy, including region, background and language.  It was also noted, by an awarding organisation, that students are often extremely adept at using leisure devices such as mobile phones but less able to use business devices such as laptops. Additionally, it was reported, by some awarding organisations, that digital inequality has affected some Functional Skills qualification (FSQ) students being assessed via remote invigilation, for example, where there are limited devices or specialist equipment or software, and/or disrupted access to the internet. 

Several responses from teachers, parents and some awarding organisations, expressed concern for the mental health of students, including anxiety that could be caused by having to take exams and assessment under public health restrictions, or when they felt they had not been sufficiently prepared for them. 

One representative body argued that FSQs are as demanding as GCSEs therefore any contingences considered should apply equally to FSQs as they would GCSEs.  

Question 2

Do you have any views on how any potential negative impacts on particular groups of students could be mitigated? 

Of the 259 responses to the consultation, a total of 141 submitted a comment for question two. 27 of the 141 were out of scope of the consultation, referring mainly to GCSE, AS and A level assessments.

The majority of responses set out different types of adaptations and where they would be useful, for example reducing content of qualifications or assessments, adding optionality to exams or assessments, or having fewer internal or external assessments in a qualification. Some responses from teachers, students and parents, suggested that grading boundaries should be reviewed and lowered.  

Many respondents, across all stakeholder groups, argued that any such adaptations should be communicated as early as possible and preferably in advance of the academic year 2021 to 2022 starting.  

A significant number of responses from parents and teachers were about teacher assessed grades, where the majority said they should either continue or a hybrid of exams or assessments and teacher assessed grades should be put in place, due to the impacts of lost learning and pressures on students.  

Many respondents argued for improved support mechanisms, including technology support, pastoral support, mental health care, additional funding and education recovery support, particularly for SEND, those with English as an additional language and students from lower socio-economic backgrounds. Some argued that additional support should be for all students and learners, whilst others argued that those who had been most affected by COVID-19 should receive the greatest amount of support. 

Some respondents thought that remote assessment for FSQs worked well in some circumstances. Others highlighted challenges in delivering FSQ assessments via remote invigilation, including the cost to set up, ability to deliver at scale in colleges, and a requirement to have the necessary equipment. One representative body stated that adaptations for FSQs need to be comparable with those for GCSEs because FSQ Level 2 can be just as demanding as GCSEs, therefore if GCSEs make formulae sheets available then they should also be available for FSQs.

For T Levels, some respondents suggested further adaptations to the autumn core assessments are needed. Others have pointed out that because the delivery of Industry Placements was disrupted last academic year, for many learners, this means all the Industry Placement hours must now be delivered in the second year. As such, a number of respondents suggested the need for greater flexibility in the delivery of Occupational Specialism assessments to maximise students’ opportunity to prepare for these assessments whilst completing their Industry Placements. This may include, for example, pushing the set time for Occupational Specialism assessments back further in the academic year so learners have more time to develop required skills. 

Part B - Regulatory arrangements for academic year 2021 to 2022

Changes to the categorisation of qualifications

Question 3

Do you have any comments on the impact of our decision to withdraw the designation of Category B qualifications at this time and to move all qualifications under Category A?

Of the 259 responses received for this consultation, a total of 99 respondents provided comments in response to this question.

Nine out of those 99 responses were out of scope for this consultation, with the majority of these referring to GCSE, AS and A level assessment.

The largest single group of responses, just over a third, did not mention whether they agreed or disagreed with our decision to withdraw the designation of Category B qualifications at this time. This group tended to comment on individual and organisational experiences of VTQ teaching and assessment in the context of the COVID-19 pandemic, and how this had impacted student learning.

Slightly fewer than a third of respondents said that they agreed, or agreed in principle, with our decision to withdraw the Category B designation at this time. A similar proportion of respondents either said that they disagreed with our decision to withdraw the designation of Category B qualifications at this time, or thought the withdrawal of TAGs was premature because of the ongoing pandemic.

Teachers responding in a personal capacity were the single, largest stakeholder group responding to Question 3. More than half did not mention whether they agreed or disagreed with our decision to remove the Category B designation. Although numbers were small, twice as many said that they disagreed with our decision to remove Category B at this time, or thought it premature to remove TAGs, than agreed.

Of those that thought it either premature to remove TAGs or said that they disagreed with our decision to remove the Category B designation at this time, students, parents or carers, and teachers accounted for around half of such responses.

Of the 19 official awarding organisation responses to this consultation from awarding organisations, 14 responded to Question 3.

Most awarding organisations understood our decision to withdraw Category B designation, and welcomed that they could be re-introduced, should the COVID-19 pandemic worsen. Awarding organisations also welcomed that they had permission to review the requirement for any additional adaptations to assessment to ensure that candidates are not disadvantaged. A couple thought it premature to remove TAGs at this time because of the ongoing impact of the pandemic.

Some awarding organisations thought that the decision to withdraw the Category B designation, could create confusion with qualification users should a return to Category B become necessary. One thought it might be more appropriate to introduce a new category altogether.

There was a general consensus amongst awarding organisations, that there was insufficient clarity around who and what would mandate a return to the Category B designation.

Some awarding organisations thought the timelines were challenging to implement changes required under the new regulatory framework, whereas others thought any changes would be minimal.

The challenge of communicating changing regulatory frameworks was also raised by some awarding organisations, and the time and resources this took when explaining it to schools, colleges and training providers. It was argued that support with communicating these changes would be welcomed to avoid undermining the trust of training providers, students and the broader public towards VTQs. One respondent also highlighted that due to the wide diversity in the arrangements for VTQs, it was important these were clearly communicated and understood by the sector.

One awarding organisation observed that because of the different approach to awarding this academic year for FSQs as compared with GCSEs (where TAGs were permitted for all learners), some of their centres are already considering making the switch to GCSEs for the coming academic year. It stressed the importance of parity in approaches required across the qualifications, otherwise training providers will switch qualification types.

Of the 4 representative or interest groups that responded, 2 thought it premature to remove Category B at this time because of the ongoing pandemic. Two agreed with our decision to do so. The continuation of adaptations was welcomed. However, there was some concern about the impact on mid-flight learners who started their qualification journey under one regulatory framework, and who would finish under another. The need for timely and decisive decisions in the future, was stressed.

A response from an equality organisation that represents people working with SEND students felt that TAGs were a useful tool in helping to address disparities between the least and most disadvantaged. It asserted that all adaptations should, as their starting point, focus on levelling out inequity. Another organisation that aims to overcome exclusion through language education thought that withdrawingthe Category B designation might adversely affect ESOL (English for speakers of other languages) Skills for Life students.

Of those other respondents that stated they in principle supported for the changes or didn’t make a judgement on whether they agreed or disagreed with our decision to withdraw the designation of Category B, key themes and concerns centred around:

• insufficient and inconsistent adaptations made by awarding organisations
• the impact of arrangements on ‘mid-flight’ students (students who were not completing their qualifications in summer 2021)
• awarded results based on TAGs prior to August 2021
• examination and assessment practicalities

Adaptations

Many teachers said that both course content and internal assessment should be reduced in academic year 2021 to 2022. Reasons given were that students were already behind with their coursework, this having been brought about, for example, by ‘bubble closures’, needing to self-isolate, and having limited access to other teaching arrangements, thereby leading to learning loss.

Concerns were also raised that students could not catch up on their outstanding coursework for this current academic year whilst studying the course content in the coming academic year. This same argument was also used to justify why it would be impractical to make students, who should have taken internal assessments relating to coursework in theacademic year 2020 to 2021, (but for some reason, like bubble closures, couldn’t), to take them in the academic year 2021 to 2022.

There was also a concern that the risk of further learning disruption over the academic year 2021 to 2022 was significant, be that local, regional or national disruption.

‘Mid-flight’ students

There was some confusion across many respondent groups as to whether it was permissible for students to carry forward results based on TAGs awarded prior to 31 August 2021 into academic year 2021 to 2022 (or later for longer study programmes).

Similar arguments were also made by respondents who thought it premature to remove TAGs at this time. For example, it was stated that some students who did not have enough evidence, due to the restrictions, to be awarded a grade in their coursework in the academic year 2020 to 2021, would end up being disadvantaged if they were not permitted to receive a TAG.

Assessment practicalities

Respondents cited burdens placed on schools, colleges and other places of learning, in maintaining safe examination and assessment environments, like enhanced cleaning regimes, for example.

A sector specific issue was also raised. The example given concerned the care sector, for both children and adults. It was stated there have been instances of employers both limiting access to their work settings to carry out assessment, whilst also limiting access for their employees to visit external venues. The work settings were also deemed incompatible for remote invigilation. Some training providers and assessors have been told they will not be able to access some workplace settings “until 2022 at the earliest”. In this specific instance, it was argued, an issue has been created by the withdrawal of Category B and the use of TAGs at this point in time.

As stated earlier, a majority of responses who said that they disagreed with our decision to withdraw Category B at this time, or thought it premature to remove TAGs, came from teachers, students, and parents or carers. Key themes that emerged were that:

• there is a differential learning loss within and across places of learning teaching VTQs, and that TAGs can help mitigate this
• an insurance policy is required due to the uncertainty over the direction of the COVID-19 pandemic, especially with the emergence of a ‘third wave’

Many respondents mentioned the need that comprehensive contingency plans are in place, should the changes to the public health situation require a rethink. Many respondents also stressed that should a change of approach become necessary, then decisions must be decisive and timely to allow for effective implementation.

The importance of fairness to students was emphasised by many respondents. This was regardless of whether respondents said that they agreed with our decision to withdraw the Category B qualification designation, or not.

Some respondents commented on a perception of ‘unfairness’ for those students taking more practical courses who have been significantly impacted by differential learning loss, especially in comparison to those students taking GCSE, AS and A level subjects. Others felt that re-classifying all qualifications under Category A wouldn’t accurately reflect the differential learning loss that might be suffered by students in the future where, it was argued, retaining TAGs would have gone some way to mitigating these impacts, thereby creating a fairer outcome.

Requirements and guidance in relation to adaptations

Question 4

Do you have any comments on the proposed changes to the drafting of the statutory guidance on adaptation in the revised VCRF?

Of the 259 responses received for this consultation, a total of 50 respondents provided comments in response to this question.

Eight of those 50 responses were out of scope for this consultation, with the majority of these referring to GCSE, AS and A level assessment.

Overall, over half of respondents did not say whether they agreed or disagreed with the proposed changes to the drafting of the statutory guidance on adaptation in the revised VCRF. A third stated they were broadly in agreement with the proposed changes, and a very small proportion stated that they disagreed with the proposed changes. Of the few that disagreed, TAGs were often seen as a fairer option.

Of the 19 official awarding organisation responses to this consultation from awarding organisations, 11 responded to Question 4. This was the single, largest stakeholder group that commented on this question.

A small number of awarding organisations had concerns over the wording of some of the Principles outlined in the consultation document. This was regardless of whether they said that they broadly agreed or disagreed with the proposed changes to the drafting of the statutory guidance on adaptation.

Comments on the Principles

A response from a representative body challenged the appropriateness of Principle A3 in the context of a pandemic.

Principle A3 – An awarding organisation must seek to maintain standards, as far as possible, within the same qualification in line with previous years, and across similar qualifications made available by the awarding organisation and by other awarding organisations.

Although it agreed that maintaining standards across similar qualifications is essential for fairness for students, it reasoned that the reference to previous years does not adequately account for the variable educational experience students have had compared to previous cohorts.

This argument was echoed by an awarding organisation, which also wondered whether there were specific previous years that Principle A3 was intended to refer to.

Some awarding organisations gave almost identical responses as to the appropriateness of Principle A3. They drew attention to the challenge of ensuring comparability across previous years.

Separately, one awarding organisation expressed concern that should the public health situation improve, the withdrawal of adaptations could lead to inconsistency in approach across awarding organisations. It was worried that those that started to remove adaptations first, could experience resistance from training providers and colleges, who have become used to adaptation to assessments and qualifications for a significant period of time.

Some awarding organisations gave almost identical responses as to the appropriateness of Principle A4.

Principle A4 – An awarding organisation must seek to ensure, as far as possible, that the Adaptations which it makes to a qualification do not serve to advantage or disadvantage Learners taking that qualification against their peers taking similar VTQs or, where relevant, general qualifications not covered by the VCR Conditions.

They contended that as they have an obligation not to advantage or disadvantage students against those taking the qualification in previous years, then this is a complex task when different arrangements such as Centre Assessed Grades^{[footnote 4]} and TAGs have been used for awarding in previous years.

They also thought that the obligation on awarding organisations to share their approach to adaptation with others working on similar qualifications raised issues of how this will be monitored, and wondered what Ofqual’s expectations are around this.

A response from a college proposed the introduction of an additional principle - that awarding organisations communicate all adaptations to their centres by a common deadline, agreed with Ofqual.

One awarding organisation suggested that it would be helpful to include the words ‘reasonable steps’ in each principle to recognise the challenges of meeting each principle. 

Adaptations

Other respondents did not comment on the wording of the guidance or the principles but commented on their experience of, or the impact of, adaptations.

Some respondents felt that there had been an inconsistent approach to adaptations across awarding organisations and some therefore believed that course content and/or assessment should be reduced. This was in line with responses received for Question 3.

Responses from organisations that worked with more disadvantaged students, such as ESOL Skills for Life and SEND students, thought that awarding organisations needed to receive more guidance on the types of adaptations that could best mitigate against such students becoming further disadvantaged. It was argued that, especially during a pandemic, it is critically important that students who normally suffer more disadvantage than most, have barriers removed that prevent them from being able to demonstrate skills and knowledge. Barriers that were cited as particularly affecting such students were digital poverty and difficulties engaging with remote learning.

Again, as for Question 3, many respondents emphasised the need for fairness for students. Many respondents stressed that the principles underpinning Ofqual’s approach to examination and assessment in the academic year 2021 to 2022, should be based on adaptations that offer:

• fairness for the student
• a flexible, but consistent approach that provides for comparability
• a sense of certainty for students, training providers and awarding organisations, which is timely and decisive

Arrangements for appeals

Question 5

Do you have any comments on the proposed changes to arrangements for appeals in the revised VCRF?

Of the 259 responses received for this consultation, a total of 24 respondents provided comments in response to this question. Almost a quarter of the responses received were out of scope of this question (the reasons for this are set out below).

The majority of responses were organisational responses, including from awarding organisations, schools or colleges and other representative or interest groups. Of those comments received:

• over one third said they supported the changes
• three respondents said that there would be no impact as they or their members did not make use of the provisions under VCR7.1 which took account of the particular situation which applies to Technical Qualifications (TQs) within T levels^{[footnote 5]} because:
  • there were few appeals received
  • successful adaptation meant that external assessments could continue
• just over one sixth said that consistency of approach to appeals between qualifications and across awarding organisations was important

The comments that were out of scope dealt with a range of subjects from dissatisfaction with the outcome of the recent DfE consultation on qualifications at Level 3, to a suggestion that vulnerable students such as those suffering from anxiety or those that are LGBTQ+ should be awarded additional credit in acknowledgement of the additional personal challenges they have faced and the support and intervention they have missed out on as a result of the pandemic. Other out of scope responses discussed the arrangements for general qualifications in 2021 to 2022 and 2 responses dealt with the subject of appeals but did not specifically address the question posed. One considered that appeals should be dealt with by awarding organisations and they should charge a fee for this service and one thought that learners, colleges, teachers and parents should be more involved in the appeals process.

The majority of those that supported the proposals did not give a rationale for this. Although one respondent did comment that there being an appeals process was important.

A couple of respondents said that whilst they agreed with the proposals, they had some concerns. One awarding organisation commented that whilst they supported the approach, it was possible that appeals based on TAGs could continue after September and they thought it was important that VCR7.3 was applied to these appeals. They were also concerned that if contingency arrangements meant that TAGs were permitted for some learners in the academic year 2021 to 2022 then these learners would be able to appeal directly to their awarding organisation once their centre appeals process had been exhausted and that this could prove logistically challenging. One respondent commented that they agreed with the approach to appeals but if there were further restrictions then the arrangements for Category B qualifications should be reinstated.

Respondents who thought parity of approach was important stated that:

• if contingency arrangements are required in the 2021 to 2022 academic year then the appeals procedures for GCSEs, AS and A levels and vocational qualifications should be as closely aligned as possible
• any changes made to appeal arrangements must be flexible enough to cope with contingency plans that may need to be introduced in response to the public health situation
• the appeals system must be fair for everyone, with as little need for appeal as possible

One respondent commented that the Category B qualification designation should be retained with the wording in the VCRF altered to make it clear that the Category B designation was a contingency reserved for a worsening public health situation. This would mean that the provisions for appeals could be retained as they are at this time.

An equality organisation commented that it is important to ensure that arrangements for appeals are clearly communicated to ensure that ESOL Skills for Life learners aren’t disadvantaged either because they do not understand the process or because they don’t understand that it is possible and acceptable to appeal following a stated procedure. The respondent felt that some learners may not feel comfortable questioning authority in this way.

Changes to the statutory guidance on remote invigilation

Question 6

Do you have any comments on the proposed changes to the guidance on remote invigilation and the introduction of guidance on remote assessment in the revised VCRF?

Of the 259 responses received for this consultation, 36 respondents provided comments in response to this question. Of those who commented, the majority of responses were organisational responses, from awarding organisations, representative groups and schools and colleges. There were no significant differences between respondent groups.

The majority of respondents did not comment on the proposed changes to the statutory guidance. Instead, they provided their views on remote invigilation and remote assessment.

Those in favour of remote invigilation and remote assessment emphasised that removing these measures would disadvantage some students, including those isolating due to COVID-19. They said that these adaptations provided a very positive experience and much needed flexibility to meet individual circumstances.

Those not in favour of remote invigilation and remote assessment raised concerns around the increased ability to cheat or plagiarise work, due to the lack of live invigilation. Two or more respondents also raised their concerns around student engagement following periods of isolation and absence and believed students should be assessed on their knowledge and ability, not their completion of work.

Other respondents raised concerns that these adaptations disadvantage students from low-income backgrounds, students without access to the necessary equipment and students that suffer from illnesses, included those suffering from long COVID-19. One respondent mentioned how difficult it was to implement these adaptations, partly because of the lack of information received from the awarding organisation. Some respondents also commented on the cost of implementing these measures, and said that they were not cost effective.

A number of respondents also raised concerns about how Ofqual could ensure consistency in the implementation of remote assessment and remote invigilation across awarding organisations.

A number of respondents commented on the need for further guidance and clarity for all parties, including awarding organisations and students. This included one respondent who reported that some awarding organisations had different views on what ‘remote’ meant and so felt additional clarification would be helpful.

Where respondents did address the question, the majority agreed with the changes to the statutory guidance, with one respondent welcoming the increased clarity and consistency in the guidance.

One awarding organisation asked for more specific guidance to be provided by Ofqual, rather than just the addition of the definitions.

Some awarding organisations also requested further guidance related to the specific way they carry out their assessments. They felt the definitions used within the guidance may exclude certain assessment styles, such as assessments that are not timed. Other awarding organisations requested specific guidance relating to the type of centre, for example, prisons.

One respondent stated they felt awarding organisations would benefit from guidance being embedded into the General Conditions of Recognition after the end of the pandemic.

One awarding organisation requested a review of the use on non-specialised systems, and for further guidance to be provided on the use of general tools for remote invigilation to ensure the systems used by awarding organisations were suitable.

A few respondents noted that whilst they do not use remote invigilation or remote assessment, they still welcomed additional guidance.

Some respondents had misunderstood the question and thought the guidance applied to the delivery of GCSEs, AS and A Levels.

Monitoring the public health situation and contingency planning

Question 7

What factors do you think we may need to consider in developing any contingency plans?

Of the 259 responses received for this consultation, 181 respondents provided comments in response to this question. Responses to this question were from across a range of respondent types. The majority of responses were personal responses from teachers or other college staff and students, parents or carers

A small number of the responses were out of scope for this consultation, with responses referring to arrangements for GCSE, AS and A levels.

Respondents to this question commented on a range of factors that they felt we should consider when developing any contingency plans, these included:

• early communication
• flexibility
• use of TAGs
• regional issues
• awarding organisation consistency and support
• mental health
• isolation and disruption to teaching and learning
• grading standards
• fairness to students
• access to ICT
• content coverage
• practical assessments/ work placements
• Functional Skills qualifications
• implementing contingency arrangements

Early communication

The majority of respondents who commented said that the most important factor in developing any contingency plans was the need for early communication. A large number of personal responses centred around the need for:

• decision making to be done as soon as possible and the timelines for the decision making to be communicated clearly
• as much advance notice of any contingency arrangements as possible to promptly to prepare teacher, staff, and students of any disruptions to avoid burden
• if applicable, as much notice as possible on the reintroduction of TAGs and the processes involved to allow for workload planning

The majority of organisational responses, including awarding organisation, school and college responses focused on the need for:

• alignment of processes and procedures across awarding organisations in order to maintain public confidence
• lessons learnt from 2020 and 2021 to be fully realised into the next stages of contingency planning for academic year 2021 to 2022
• communications to centres to ensure evidence is being collected in case TAGs are implemented later in the academic year
• clear written guidance on what would trigger the need for contingency plans alongside adaptations for academic year 2021 to 2022
• schools, colleges and training providers to receive transparent, equitable and timely guidance to avoid adding to the logistical challenges they already face and the preparation required to prepare for the new accountability and funding regimes. It was felt that the timelines to implement TAGs this summer led to stakeholders not feeling confident with the arrangements.

The need for timely communications was also mentioned by awarding organisations so that they could make the necessary arrangements.

Two awarding organisations and their representative body said that that they would benefit from service level agreements with Ofqual and the Department for responses to questions from awarding organisations.

Flexibility

Another key theme expressed by teachers was the need to build in flexibility into any contingency arrangements. This covered a range of factors including:

• a ‘one size fits all’ approach is not appropriate for VTQs
• there has been an uneven impact of Covid-19 on individual schools therefore there must be flexibility in the arrangements to allow an element of local discretion by individual schools
• the ability for teachers to adopt online, hybrid and face to face learning models should they feel it was necessary
• consensus that the flexibility provided in the regulatory framework which would allow Category B requirements to be reintroduced easily and in a timely fashion is helpful

Use of TAGs

Several responses mainly from teachers and school and college staff were in support of retaining TAGs for students who have to isolate, or if there are any future school closures. The need to communicate a move back to TAGs in a timely manner was also emphasised. Other points raised about TAGs included:

• the expectation that TAGs would be introduced at some point during the academic year, motivated learners to engage and seek support throughout the year
• that in the interest of fairness to students, the same mitigation of TAGs should be in place if the situation remains the same in 2022

A couple of respondents said that awarding organisations should be allowed to make their own decisions on the contingency arrangements for their qualifications, with one awarding organisation stating that they felt TAGs may not be the most reliable method for determining results in 2022.

Regional issues

Many respondents commented on regional differences in the impact of the pandemic. Respondents highlighted that any contingency plans must:

• be flexible and responsive in approach in case the situation changes locally, regionally or nationally
• take into consideration the larger infection spikes experienced during the summer holidays, especially in tourist towns and cities as restrictions have eased
• allow teacher judgements to be used if there is a local lockdown in a single area to enable learners to complete their qualification

One representative body stated that if regional contingency arrangements are put in place, these should be dealt with separately to the current requirements for Special Consideration to avoid confusion. Arrangements for Special Consideration apply when students have temporarily experienced an illness or injury or some other event outside their control which means that they cannot access assessments as normal.

One awarding organisation stated that the only way that an awarding organisation could attempt to effectively apply any additional contingency arrangements that would compensate students for lost learning, would be to use an algorithm to give additional marks based on the number of weeks’ disruption.

In addition, one awarding organisation had continued to develop its international contingency plans with the intention that they could apply at regional, area, school and potentially individual student level. They also stated they would welcome a similar flexibility in Ofqual’s regulatory approach for England, and reflected that both Category A and Category B rules might be needed.

Awarding organisation consistency and support

A concern that was raised primarily by teachers and schools or colleges was around awarding organisation consistency and support. Respondents stated that:

• more guidance was needed from awarding organisations as to what assessments need to take place
• learners might be disadvantaged if awarding organisations take different approaches to implementing any contingency arrangements
• it is important for the arrangements put in place by awarding organisations to free up consistent amounts for teaching time, as was felt to not be the case with the adaptations which are already in place
• earlier guidance and support on the collecting of evidence for TAGs is needed
• awarding organisation processes and procedures should be as aligned as far possible, for example, there should be a national summary document outlining key processes used by awarding organisations
• Ofqual should facilitate alignment of awarding organisation procedures and processes
• it is important to test adaptations ahead of implementing any contingency plans as this would save time further down the line

Mental health

Many respondents highlighted the need to consider the impact on student mental health, particularly around:

• impact of ‘long Covid’ on students’ learning
• disruption of the last 2 years causing stress for students and teachers
• vulnerable students with anxiety or who are LGBTQ+ or SEND
• workload and stress levels for all staff, students and parents

Respondents also shared the factors they felt might particularly impact students with serious mental health issues. This included social anxiety caused by being back in large groups, increases in the infection rates, and the effects of being given additional time as a reasonable adjustment on already long exams and assessments. One respondent also highlighted the importance of ensuring there was available funding to address the impact on mental health caused by the pandemic.

One response from an exams officer highlighted the additional stress upon teachers arising from the decision to cancel exams. The respondent said that the decision to cancel exams in 2021 was made too early, and that it is not the role of teachers to teach and support and also carry out the role of an awarding organisation. The respondent felt that any plans going forward needed to ensure that teachers did not lead to this additional stress and burden upon them for the third year in a row.

A response from an awarding organisation suggested it should be within their discretion to award a qualification where all assessments haven’t been completed. They felt that individual students with protected characteristics, or those who have suffered extreme loss of learning should qualify under such circumstances.

Isolation and disruption to teaching and learning

Many respondents also referred to the impact of isolation on learners. The majority of these comments were from teachers, staff and academy chains. The points highlighted were the impact:

• on learners’ ability to generate evidence for TAGs
• of changes to isolation rules and isolating due to other family members
• on teaching and learning time, the completion of coursework and access to assessments
• of the quality of teaching where staff are absent due to isolation and are replaced by cover staff
• of teacher and student absence due to ‘long Covid’
• of disruption on the stages of learning for different cohorts
• of the reduced exposure to English for ESOL Skills for Life learners due to a lack of social contact with other speakers

Respondents also suggested that the average number of student and staff in-person days that have been lost due to isolation could be used to determine whether additional contingency measures were necessary. In addition, it was suggested that Special Consideration^{[footnote 6]} should be given for students who miss exams and assessments due to isolation.

In relation to this, a couple of respondents commented that indicators such as the rising rate of infection, vaccination rates and hospitalisation rates must be factored into developing contingency plans.

Respondents also suggested that young people should be vaccinated ahead of any potential rises in infection rates to help avoid additional lost teaching and learning time.

Grading standards

The risks and concerns around maintaining grading standards were flagged by several respondents. These included:

• that grading standards need to be consistent and fair across all students
• concerns around grade inflation and the impression that GCSEs, AS and A levels had more grade inflation than VTQs
• that some form of adjustment to students’ grades should be permitted where there is evidence of significant disruption
• that teacher grading should be trusted and teacher should be able to provide a rationale for grades that are borderline
• that if a regional contingency plan is implemented, it is important to ensure that student outcomes are comparable to those sitting assessments as normal
• that it is important to maintain the grading standards used in previous years regardless of the levels of disruption caused by the pandemic

Fairness to students

A small number of respondents commented on the need for fairness to learners, including the need to:

• apply contingency plans at the national level, avoiding regional measures to prevent unfairness between student groups
• ensure that students are not unfairly advantaged or disadvantaged dependent on when they complete their assessments.
• avoid late decisions, which can lead to unfairness

Access to ICT

The issue of access to ICT because of digital inequality and variable funding for ICT equipment was raised by several respondents, mainly teachers, parent or carers and students. This unequal access to ICT would impact students’ ability to access online learning. One teacher commented that there had been a lack of engagement from students with online learning.

Content coverage

A number of respondents suggested that awarding organisations should reduce the volume of content to be taught, and that they should state from the onset what content is essential. Two respondents also suggested that advance notice of topics should be provided. However, in contrast, one respondent from a senior leadership team commented that reducing the curriculum would not help with learner transition to the next stage of studying.

In addition, awarding organisations sought clarification on the Department’s position around coverage of content and whether the Department’s expectation was that all content must be taught unless there is further disruption and new contingencies are put into place. They also stated that if a reduction in the teaching of content was allowed it would need to be reflected in the Department’s technical guidance on VTQs included in performance tables.

Several related themes were also raised by a small number of respondents mainly teachers, schools and colleges. Respondents highlighted the need to consider the burden placed on teachers, school and college staff, and awarding organisations from any arrangements that are put in place.

Practical assessments and work placements

In addition, a small minority of respondent’s commented on issues related to practical assessments and work experience, including that it is important to:

• consider alternative ways to complete practical assessments safely so that students’ have the expertise and confidence in taking up a future job
• acknowledge placement opportunities may not be as readily available in some sectors, for example Health and Social care, especially if there is further disruption as a result of the pandemic
• consider the impact on pandemic on courses that carry a vital work experience components
• provide additional funding to provide ‘catch-up sessions’ for practical skills before an assessment

Functional Skills qualifications (FSQs)

Some respondents provided comments which related to the arrangements for FSQs, these included that:

• contingency plans should consider that students should not be treated differently because of the type of qualification they are taking. For example, English and maths should take into consideration both GCSE and FSQs
• remote assessment or remote invigilation should not be suggested as an option for FSQ assessments unless they can be demonstrated to work at scale

Implementing contingency arrangements

Awarding organisations asked that the burden on awarding organisations was taken into account, including the regulatory burden placed on them by Ofqual.

One awarding organisation referred to the time it may take for them to develop and implement a new ICT solution at a large scale if there was a significant deviation away from the use TAGs as a contingency arrangement.

Other respondents commented on the need to take into account the burden on teachers and other staff, in particular around quality assurance processes.

One respondent also reflected that some types of assessment were more resilient to disruption than others, for example on demand assessments, and so would require minimal contingency arrangements.

Equality impact

Question 8

Are there any potential positive or negative equality impacts arising from our decision to withdraw the Category B qualification classification at this time and our proposed changes to the drafting of the VCRF, apart from those we have explored? If yes, what are they and how might they be mitigated?

Of the 259 responses received for this consultation, 40 respondents provided comments for this question. Responses came from teachers responding in a personal capacity, schools, representative bodies, students and parents or carers. There were no significant differences between respondent groups.

Several responses were out of scope. Some respondents had misunderstood the question and thought we were asking whether or not to retain TAGs or were talking about the GCSE, AS and A Level consultation. Other respondents were unaware of proposed changes to GCSEs, AS and A Levels, and so were concerned that changing only the VTQ approach to assessment next year would put VTQ students at a disadvantage by comparison. Two representative bodies called upon awarding organisations to provide advance notice about their plans for the academic year 2021 to 2022 and to work with specialist organisations when deciding on their approaches to adaptations. Another organisation stated that they were unopposed to the changes, as long as adaptations were maintained and any further discussions on adaptations include the end users of qualifications. An awarding organisation stated that they had not had time to consider the equalities impact of the proposals and decisions, given the time pressures on their organisation. A representative body commented that it would welcome the evaluation of the awards made under previous regulatory frameworks to help inform future arrangements. Many of the responses supported issues we had identified as part of the equalities impact assessment in our consultation, while others highlighted additional issues that they did not feel had been considered.

The key themes across responses included:

• differential learning loss
• physical and mental health issues
• the impact on students with special educational needs and protected characteristics
• increasing disadvantage
• mid-flight students

Differential learning loss

A number of respondents, including teachers, raised concerns about differential learning loss experienced by students in different parts of the country, those from ethnic minorities, those forced to isolate for longer, and students shielding due to health conditions. An awarding organisation made the case for maintaining TAGs on the basis that teachers were well-placed to make assessment judgements which could take into account their particular circumstances. They felt that although the contingency arrangements being considered by Ofqual and the Department could mitigate for national and local disruption, there needed to be alternative arrangements beyond Special Consideration to take account of the impact on individual learners. Special Consideration only applies when students have temporarily experienced an illness or injury or some other event outside their control which means that they cannot access assessments as normal, it does not apply the disruption to teaching and learning.

Physical and mental health issues

Six respondents commented on the mental health issues some students experienced. They suggested that these issues might be exacerbated by the domestic and financial pressures that had arisen because of the pandemic, and that the impact of withdrawing Category B qualifications (and thereby the use of TAGs) on these students had been underestimated. They also suggested that the impact on students with mental health issues could be mitigated significantly by planning contingencies earlier and communicating the different options. Other respondents noted that students with mental health issues might need greater flexibility in the types of evidence required by awarding organisations when applying for access arrangements, as it might take time for these students to obtain a diagnosis. One respondent observed that clinically extremely vulnerable students (including those with mental health conditions) were likely to be disproportionally affected if they had to self-isolate during the next academic year. To mitigate the effects of further lockdowns and these students missing school, the contingency plan of reintroducing the Category B designation (and thereby reintroducing TAGs) should come into effect.

A teacher also expressed concern that if there were any delays to the decision to reintroduce the Category B qualification designation, it would create bureaucracy and therefore increase pressure on their workload, which would impact their mental health.

Impact on students with special educational needs and protected characteristics

Three respondents commented on the experiences of students with special educational needs, including that access arrangements may come too late for some students who were newly diagnosed. It was also suggested that the decision to withdraw the Category B qualification designation at this time might be positive for students taking Functional Skills qualifications, as it would lead to a level playing field and consistent application of reasonable adjustments.

Increasing disadvantage

Some respondents commented that the withdrawal of TAGs would compound the challenges disadvantaged students already experienced. They suggested that this might be mitigated by a significant reduction in assessment to allow all learners to be assessed fairly but with sufficient time to cover all content. Two respondents expressed concern over the lack of parity between cohorts from different years, given the different approaches to assessment in 2020, 2021 and 2022, and that some students might be disadvantaged because of awarding organisations taking different approaches to reducing coursework.

One respondent observed that students without access to specialist materials, media, equipment and specialist teaching rooms or teachers would be less likely to achieve higher grades on their coursework, and having to sit externally-set assessments would further reduce the time available for the completion of their coursework.

One awarding organisation thought that the removal of TAGs might be challenged on equalities grounds, as they potentially mitigated the impact of learning loss to a greater extent than adapted assessments, as teachers had more flexibility to choose evidence.

Two organisations pointed out that not all centres were open and able to deliver teaching and run assessments, such as prisons and community learning centres, whilst some employers were restricting access to the workplace. They stated that both FSQ and ESOL Skills for Life students were less likely to have access to the equipment required for remote invigilation or assessment.

A student commented that the effects on those with caring responsibilities should also be considered.

Mid-flight students

Some respondents commented on the potential impacts on mid-flight students, querying the impact of decision to withdraw the Category B qualification designation at this time, on these learners. A respondent also expressed concern about those students on modular courses who might need to make decisions about resits before finding out the grades that they had ‘banked’ in the TAGs process and so might be at a disadvantage.

Regulatory impact

Question 9

Are there any regulatory impacts arising from our decision to withdraw the Category B qualification classification at this time and move all qualifications into Category A, apart from those we have explored? If yes, what are they and how might they be mitigated?

Twenty-six respondents provided comments in response to this question. Responses were from a range of respondent types. The majority were organisational responses, with most of these from awarding organisations. We also received organisational responses from schools, colleges and training providers, higher education institutions and representative groups. We received 9 personal responses from teachers and students.

A large number of respondents, including awarding organisations, representative groups, schools, colleges and training providers commented on the removal of the Category B qualification designation or classification. Many felt there was uncertainty about whether assessments may again need to be cancelled, and thought the option to revert back to Category B and award TAGs should be retained in case it is needed in future. Some respondents said that they intended to continue to collect information in case TAGs were reinstated, which they said would impose additional burdens. A representative group commented that if it were necessary to revert to Category B in future, this would have resource implications for schools, colleges and training providers. An awarding organisation commented that it would be important that where references to Category B remained in the guidance, it should be clear that these applied in exceptional circumstances, in order to prevent the guidance appearing complex.

A representative group commented that the impact on teaching staff needed to be considered. They said that while teachers would not be required to produce TAGs, they would have to deliver adapted assessments, and the conditions under which they would be working would vary depending on the school, college or training provider.

Respondents, including teachers, schools, colleges and training providers, commented on the need for clarity about the arrangements that will be in place next year. These included that:

• schools, colleges and training providers need to know what the arrangements will be as soon as possible, in order to plan and support staff
• it will be important to be clear about which units need to be completed and what supporting paperwork and evidence is necessary, so that schools, colleges and training providers can prepare accordingly
• there should be a consistent approach across awarding organisations, in terms of when and how they communicate with centres, and the systems and processes they use
• any adaptations will have an impact, including for those qualifications moving from TAGs to adaptation approaches

Some respondents made comments relating to the impact of arrangements that were previously in place, rather than those that will be in place next year. These included that:

• teachers would require additional support, training and other resources from awarding organisations
• the arrangements previously in place have caused an increased workload for teachers
• there has been a time cost for teachers of having to plan, administer, mark and standardise assessments

Awarding organisation respondents commented that while they agreed with the proposals, there were burdens on awarding organisations caused by having to participate in the consultation, attend meetings with Ofqual, and familiarise themselves with new requirements. These have happened alongside other regulatory activities, such as requests for information and data, and the implementation of Centre Assessment Standards Scrutiny requirements. They highlighted the impact on awarding organisations where the same staff are often involved in many of these activities. Awarding organisations also commented on the challenges, having communicated arrangements for Category B qualifications with centres, of having to now communicate alternative requirements, following the removal of Category B.

Some awarding organisations commented that changes to Ofqual’s regulatory framework should only be made where absolutely necessary. They commented that it would be helpful for contingency plans to be developed in advance in case assessments were again postponed.

Question 10

What new activities do you expect to carry out as a result of your proposed approach to adaptations and what additional costs will you incur across the range of qualifications you offer?

One hundred and one respondents provided comments in response to this question. Responses to this question were from across a range of respondent types. The majority of responses were personal responses. These were from teachers or other school and college staff, students, parents or carers and awarding organisation staff. We also received 37 organisational responses. These were from awarding organisations, schools and colleges, local authorities, and other representative groups.

A number of respondents commented that it would not be possible to estimate what new activities and associated costs would be incurred, until they knew what adaptations would be put in place by awarding organisations. Respondents commented on the need for information to be provided as soon as is possible. Respondents felt there would be a lack of time to implement any arrangements. They commented that any changes would have to be planned for over the summer, and they would have preferred to have information shared earlier

The majority of respondents who commented suggested additional activities that would incur costs, but were unable to provide breakdowns of what these costs might be. Where costs were provided, we have considered these as part of our analysis, but have not repeated them here. The additional activities identified are listed below. A small number of respondents made comments against this question that related to other questions in this impact assessment. Where this is the case, we have reported these responses against the questions to which they relate.

Direct delivery costs

A large number of respondents commented on additional technology, equipment and resources, which would be required to deliver assessments. These included:

• the need to spend more on technology, including:
  • to accommodate remote invigilation requirements
  • the cost of providing equipment such as laptops for students
  • the cost of providing web-based rather than machine-based software for students to access remotely
• equipment required to deliver alternative arrangements and additional rooms, which are needed to accommodate a greater number of smaller cohorts
• additional resources, such as revision guides and course materials, which may have changed due to the alternative arrangements, and in some cases may be different for on-site and off-site students

A number of respondents commented on administrative costs, including:

• the cost to schools, colleges and training providers who choose to digitise records to create a potential evidence bank, in case they it is needed in future
• the cost to schools, colleges and training providers of familiarising themselves with any new requirements, communicating these and responding to queries
• printing exams for SEND students
• scheduling and planning changes to make sure qualifications are deliverable in the time available
• additional development, quality assurance and standardisation costs
• the cost of running assessments in alternative ways, for example with smaller cohorts, in larger rooms with increased ventilation, and having to follow any public health guidelines such as cleaning and sanitising

Respondents, including awarding organisations, commented on:

• the cost associated with communicating changes to centres, relating to the re-categorisation of qualifications and the need to consider how to communicate changes, including explaining differences between the arrangements in place this year and last year
• the cost of running additional assessment sessions if needed to accommodate all students
• the impact of needing to gather information from centres about which units they anticipated being able to assess as part of any reduction in assessment
• a potential increase in applications for special consideration
• the impact of potential regional disruptions

People and staff costs

Respondents commented on a number of staff and people costs (both financially and in terms of time) associated with the proposals. These included:

• additional staff, such as teaching assistants, to support assessments and social distancing requirements
• additional time to process students under alternative arrangements
• additional training for staff to enable them to deliver assessments under alternative arrangements
• training staff and students on how to use technology
• delivering additional teaching, support and coaching to prepare students for assessments
• rewriting schemes of learning to reflect any changes made to qualifications and assessments
• additional invigilators to oversee assessments for smaller cohorts of learners
• the cost of additional teacher support for students to take account of the impact on mental health caused by disruption to their learning
• the effect on the morale and energy of teachers having to work to implement any changes
• additional teacher support needed by students to catch up on missed learning, where it has not been possible to continue learning at home due to the nature of the resources and equipment needed
• additional teacher support for students from disadvantaged backgrounds who have been less able to access home learning
• familiarisation with new requirements, especially where centres work with multiple awarding organisations
• managing an increased number of enquiries about the arrangements

Awarding organisation respondents commented that:

• there is a cost associated with understanding, applying, communicating and complying with Ofqual’s regulatory framework and the adaptations which fall out of it
• there are costs associated with working with other awarding organisations, sector and representative bodies to seek to ensure consistency of approaches
• the nature of the adaptations means that some qualifications are requiring greater oversight and resources than would normally be the case for these qualifications, both in terms of number and seniority of staff

Opportunity costs

A number of respondents from schools, colleges and training providers said that they intended to put in place contingency plans to mitigate the effects of further disruption. Typically, these included:

• continuing to collate evidence that may inform TAGs if they were reintroduced
• banking assessments at the earliest opportunity, typically through the use of additional moderation visits, which would incur additional fees

Question 11

What savings do you expect to make as a result of your proposed approach to adaptations?

Fifty-two respondents provided comments in response to this question. Responses to this question were from across a range of respondent types. There were fairly evenly split between organisational responses (27) and personal responses (25). Of those organisations who responded, we received responses from 13 awarding organisations, as well as representative groups, schools, colleges and local authorities. Of the individuals who responded, we received responses from 15 teachers or other school and college staff, 5 students, as well as awarding organisation staff.

A large number of respondents said they would make no savings as a result of the proposals. The majority of these responses were from teachers responding in a personal capacity, or organisational responses from schools, colleges, training providers or awarding organisations. In some instances, where respondents could identify savings, they thought that these would be offset by other costs, so the net effect would be neutral, or a cost increase.

Some respondents commented to say they could not determine whether or not there would be savings at this stage.

Of those who were able to identify potential savings, these included:

• savings on administrative costs, such as reductions in the amount of materials needing to be printed
• potential refunds on exam fees
• savings on equipment normally required for field activities if these no longer went ahead
• potential savings on invigilation costs if some assessments were conducted remotely
• reductions in examiner travel expenses, particularly for international assessments, due to the move towards remote approaches
• that there would be no additional costs as students would be able to use their own equipment
• savings on the production of paper-based assessments, where these were adapted to take place remotely
• time savings for teachers and awarding organisations if they no longer had to produce and quality assure TAGs

Some respondents commented that they may make savings compared to last year, as costs had already been incurred, so would not be incurred again, but these were still increased costs compared to a normal year. Some awarding organisations said that they intended to only make adaptations where required and to continue with the approach to adaptations already had in place, so did not anticipate additional costs. A representative group said that approaches to remote assessment had been implemented, so costs had already been incurred and were unlikely to increase further.

Question 12

Are there any other regulatory impacts, costs or benefits associated with the implementation of your proposed approach to adaptations? If yes, what are they?

Twenty-six respondents provided comments in response to this question. Responses to this question were from across a range of respondent types. Sixteen of these were organisational responses, from awarding organisations (10), as well as schools and colleges, representative groups and higher education institutions. Ten responses were from individuals, including teachers, students and parents and carers.

A small number of respondents provided comments to identify other impacts which they did not think had been covered. These additional impacts included the costs of:

• providing additional student support
• providing IT equipment for students where assessments have moved online
• visualisers required for some students for online lessons
• additional planning
• alterations required to resources
• having to operate with reduced room capacities, work with students in smaller groups and additional sanitising between students
• awarding organisations needing to maintain records of decisions made relating to adaptations
• new guidance, policies and communications to staff, students and parents
• communicating changes to schools, colleges and training providers, particularly if the approaches taken by awarding organisations last year changed as a result of the proposals

Respondents, including awarding organisations commented that no longer having to produce TAGs would result in additional time for their staff to support schools, colleges and training providers. They also commented that a reduction in the number of regulatory meetings and activities, and the need to respond to changing government policy would reduce burden. Awarding organisations also commented on the potential impact on their compliance of General Condition of Recognition G4 (ensuring the confidentiality of assessment materials), as they may have to make decisions about 2022 assessments relatively soon in order to allow time for any necessary adaptations to be made.

A small number of awarding organisations commented on the impact of implementing any changes, when combined with other regulatory activities, such as data collections and the implementation of new Centre Assessment Standards Scrutiny arrangements.

Respondents, including schools, colleges and training providers commented that it would not be possible to identify additional impacts until they knew the approaches that awarding organisations intended to take to adapting assessments.

Question 13

Do you anticipate any overall impact on qualification fees as a result of your proposed approach to adaptation? - If so, what do you expect these might be?

Forty respondents provided comments in response to this question. Responses were fairly evenly split between organisations and individuals Organisations who responded included awarding organisations, as well as schools and colleges, local authorities and representative groups. The individuals who responded included teachers or members of school and college staff, as well as students and awarding organisation employees. Responses were split between those who anticipated increased fees, those who thought there would be no change, and those who thought fees should be reduced.

Reduction in fees

Respondents, in particular schools, colleges, training providers and teachers said that fees should be reduced where the onus for delivery, organisation and implementation of adaptations rests with them. A number of other respondents, made similar comments, saying that fees should be reduced since awarding organisations are not carrying out many of the activities they normally would.

Increased fees

Some respondents felt that fees may have to increase if more expensive remote invigilation systems were needed.

No impact

A large number of respondents, including schools, colleges, training providers and teachers, did not anticipate any overall impact on qualification fees as a result of the approach to adaptation. Some felt that overall, costs and savings would balance out as any savings would be offset by other costs.

Respondents, including some awarding organisations commented that they did not anticipate any impact on fees.

Other comments

Some respondents commented that this would need to be kept under review once the cost of implementing adaptations was clear. They also commented that any further changes to whether assessments go ahead in 2022 could impact on fees.

Some respondents, including teachers, schools, colleges and training providers did not comment on fees for 2022, but queried why fees for 2021 had been charged and not yet refunded, where they had done much of the work for determining results. Respondents felt fees should be reduced given the savings awarding organisations will have made in the last 2 years.

Annex A: List of organisational respondents

When completing the consultation questionnaire, respondents were asked to indicate whether they were responding as an individual or on behalf of an organisation. These are the organisations that submitted a non-confidential response:

• ABRSM
• ACCA
• Active IQ
• AIM Qualifications and Assessment
• Alleyne’s Academy
• AQA
• ASCL
• Association of Colleges
• Association of Employment and Learning Providers (AELP)
• Baker Dearing Educational Trust
• BATOD, British Association of Teachers of the Deaf
• Birmingham Metropolitan College
• Buckinghamshire Adult Learning
• Cambridge Assessment International Education
• CCG
• Christleton High School
• City & Guilds
• Council for Dance, Drama and Musical Theatre
• Counselling and Psychotherapy Central Awarding Body (CPCAB)
• Engineering Construction Industry Training Board
• Fakenham Academy
• Federation of Awarding Bodies
• Furness college
• Havant & South Downs College
• HCUC: Harrow College & Uxbridge College
• Highfield
• IB Schools and Colleges Association
• IBO
• ICM
• Ifield community college
• Learning Resource Network
• MKLC
• nasen
• National Association of Schoolmasters and Union of Women Teachers (NASUWT)
• National Education Union
• NCFE
• New City College
• New Forest Academy
• NOCN Group
• North Kesteven Academy
• OCN London
• OCR
• Ofsted
• Open College Network NI
• Pearson Education
• Prisoners’ Education Trust
• Roding Valley High School
• RSL Awards
• St Edward’s, Cheltenham
• St Wilfrid’s CE Academy
• The Bell Foundation
• The Billericay School
• The Blackpool Sixth Form College
• The Bourne Academy
• The Cowplain School
• The Sheffield College
• Training Qualifications UK
• UAL
• UCAS
• University and College Union
• WJEC

1. Other General qualifications are academic in nature and are often taken in schools and colleges as part of secondary and tertiary education. Often the aim of these qualifications is to secure a body of knowledge and progress learners through to higher levels of academic study. Examples are baccalaureates, the Cambridge Pre-U, core and free-standing mathematics and entry level qualifications in academic subjects. ↩

2. The respondent categories listed reflect the categories chosen by the respondents in the consultation survey. ↩

3. The respondent categories listed reflect the categories chosen by the respondents in the consultation survey. ↩

4. Centre assessment grades (CAGs) were provided by teachers based on their professional judgements of the grade their students would most likely have achieved if they had sat exams in summer 2020 and completed any non-exam assessment. ↩

5. VCR7.1: Condition TQ1.1(c) does not apply to a Technical Qualification which an awarding organisation makes available (and Condition I1 therefore applies to such a qualification). ↩

6. Arrangements for Special Consideration apply when students have temporarily experienced an illness or injury or some other event outside their control which means that they cannot access assessments as normal. ↩