Consultation outcome

Analysis - regulating Level 2 and below Progression Qualifications

Updated 30 November 2023

Summary

Ofqual’s consultation on its draft conditions, requirements and guidance for Entry level, Level 1 and Level 2 Progression Qualifications ran from 20 July to 14 September 2023. The consultation covered:

• T Level Foundation Qualifications (Level 2)
• Level 2 Technical Progression Qualifications
• Level 2 Academic Progression Qualifications
• Level 1 Progression Qualifications
• Entry level Progression Qualifications

Ofqual previously consulted on its proposed approach to regulating the T Level Foundation Qualifications and the other 4 groups of Progression Qualifications in January and March 2023 respectively.

This document sets out Ofqual’s analysis of the responses received. 

Background

The Department for Education (DfE) is conducting a review of post-16 qualifications at level 2 and below (L2B). The aim of the review, as set out in DfE’s consultation response, is to: 

“…ensure that all qualifications available within the new landscape are high quality and have a clear purpose, giving students the knowledge and skills to achieve positive outcomes, whether they are progressing to further study, on to an apprenticeship, traineeship or supported internship, or into employment”. 

DfE has set out which qualifications will be funded in the new post-16 qualifications landscape. This includes Entry level, Level 1 and Level 2 Progression Qualifications.

These qualifications are expected to be primarily taken by young people as part of a one-year study programme, alongside other components including English and maths. They may also be taken by adults outside of a study programme.

Ofqual’s approach to regulating these qualifications has been designed to strengthen our oversight of them and to work in conjunction with the funding approvals process being put in place by DfE. Ofqual will provide feedback to DfE as part of that funding approval process and DfE will decide which qualifications are eligible for public funding.

Approach to analysis

The consultation included 20 questions (including equality and regulatory impact questions) and was published on Ofqual’s website. Respondents could complete the questions using the online consultation platform or email their responses to Ofqual.

Respondents to this consultation were self-selecting, therefore, the sample of those that chose to participate cannot be considered as representative of any group. Efforts were made to engage as many interested parties as possible by holding stakeholder events, as well as posting information on the Ofqual website and Portal for awarding organisations. 

The responses to the consultation questions set out in this document are presented in the order they were asked. For all the questions, Ofqual presented background contextual information followed by proposals. The questions asked respondents to indicate their level of agreement or disagreement with the proposal and presented an opportunity to provide additional comment. Respondents were not required to answer all the questions.

Who responded?

Ofqual received 15 written responses to the consultation. One response was in the form of a letter sent to Ofqual’s public enquiry mailbox. The rest of the responses were received via the Citizenspace consultation platform. Fourteen responses were official responses from the following organisations:

• 9 responses from awarding organisations
• 3 responses from other representative or interest groups
• 2 from other types of respondent

Ofqual also received one personal response.

Thirteen respondents were based in England, one was based in Northern Ireland and one was based in a country outside of the United Kingdom and the European Union but didn’t specify the country.

Respondents mostly provided comments which were relevant to the questions asked, although there were some comments which related to Ofqual’s or DfE previous policy decisions. 

One respondent repeated the same answer (which was not relevant to any of the questions) throughout the consultation. The respondent commented on DfE policy about the number of level 3 small alternative academic qualifications (AAQs) a student would be able to take in the future. Those responses have been counted but not summarised or analysed in the context of each question below.

Detailed analysis

Question 1
Do you have any comments on the drafting of proposed Condition PQ1 (interpretations and definitions)?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Eight respondents answered ‘yes’, while 6 answered ‘no’. Nine comments were received in total.

Two respondents provided comments that were supportive of the drafting of the proposed Condition. One said that the Condition was a positive step and the other said that the qualification definitions were logical and easy to follow.

Four respondents, all of them awarding organisations or their representative bodies, questioned why there was no reference to ‘technical’ content in the titles proposed for Entry Level and Level 1 qualifications. One respondent said the proposed Condition was too abstract to provide any useful information to centres or students when it is not yet clear which of the future qualifications will fit into which of the qualification groups. 

One respondent suggested that they disagreed with the drafting of the proposed Conditions on the basis that they disagreed with the underlying DfE policy. They also felt that the way that the regulatory framework had been divided into T Level Foundation Qualifications and felt Progression Qualifications (Other) suggested that the other Progression Qualifications were not being valued in their own right. 

Question 2
Do you have any comments on the drafting of proposed Condition PQ7 (Progression Qualification purposes)?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Seven respondents answered ‘yes’, while 7 answered ‘no’. Seven comments were received in total.

Two respondents provided comments that were supportive of the drafting of the proposed Condition. One noted the similarity with previous Conditions developed through the Post-16 Qualifications Review, while the other suggested that the Condition would ensure that Progression Qualifications were developed with a clear purpose and were aligned with the needs of students and employers.

One respondent suggested that the proposed Condition PQ7.3 could be split into 2 points: one point covering how the general purposes are prioritised and one covering compliance of the general purposes. This is to make it easier for awarding organisations to read and comply with.

Another respondent commented on the drafting of the proposed purpose statements and this comment has been included in the analysis for Question 3.

One respondent commented on DfE policy, questioning the viability of colleges delivering both T Level Foundation Qualifications and Level 2 Technical Qualifications. They suggested that all Level 2 qualifications should be able to lead to a variety of higher-level qualifications. Another respondent said they did not know enough about progression from T Level Foundation Qualifications to T Levels to be able to give a view on the proposed Condition.

Question 3
Do you have any comments on the drafting of the general purposes for the Progression Qualifications?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Seven respondents answered ‘yes’, while 7 answered ‘no’. 

T Level Foundation Qualifications

There were 7 comments related to the drafting of the general purposes for the T Level Foundation Qualifications.

Three respondents provided comments that were supportive of the proposed general purposes. One of these respondents noted that the minor drafting changes that Ofqual has made since the policy consultation stage had brought the general purposes in line with those for other qualifications. The other 2 respondents indicated general support for the drafting of the general purposes, but one didn’t provide any explanation. The other noted that it was difficult to comment without knowing which qualifications would be included in which groups.

One respondent expressed concerns that the general purposes would not provide students with flexible progression opportunities nor provide centres with flexible and manageable qualifications to deliver.

Two respondents commented on specific purpose statements. One respondent suggested Purpose A should be reworded to include reference to National Technical Outcomes. The other respondent suggested in relation to Purpose E that differentiating attainment is a qualification characteristic rather than a qualification purpose. In addition, in their response to Question 2, one respondent said that Purpose B should be reworded to reflect the fact that the T Level Foundation Year provides opportunities for skills to be both developed and demonstrated.

Level 2 Technical Progression Qualifications

There were 6 comments related to the drafting of the general purposes for the Level 2 Technical Progression Qualifications.

Three respondents provided comments that were supportive of the proposed general purposes. One respondent said that the general purposes seemed reasonable as they had a better understanding of the qualifications likely to fall into this group. Another indicated general support of the drafting of the general purposes but didn’t provide any further explanation. The other respondent commented that the drafting changes that Ofqual has made since the policy consultation stage had brought the general purposes in closer alignment to those for other qualifications that Ofqual regulates.

One respondent repeated an earlier comment that the general purposes would not provide students with flexible progression opportunities nor provide centres with flexible and manageable delivery of qualifications.

Two respondents commented on Purpose E. One of these respondents questioned what grading scale was expected in light of this general purpose and thought that it was mandating a particular grading approach, which they did not support. Another respondent suggested, in relation to Purpose E, that differentiating attainment is a qualification characteristic rather than a qualification purpose.

Level 2 Academic Progression Qualifications

There were 5 comments related to the drafting of the general purposes for the Level 2 Academic Progression Qualifications. 

Three respondents provided comments that were supportive of the proposed general purposes. One respondent repeated points made in answers to the question about the purposes for the Level 2 Technical Progression Qualifications – that the general purposes seemed reasonable as the qualifications clearer and better understood, and that the drafting changes that Ofqual has made since the policy consultation stage had brought the general purposes in closer alignment to those for other qualifications that Ofqual regulates. One respondent indicated general support but did not provide an explanation.

One respondent repeated their point that the general purposes would not provide students with flexible progression opportunities nor provide centres with flexible and manageable delivery of qualifications.

Level 1 Progression Qualifications

There were 6 comments related to the drafting of the general purposes for the Level 1 Progression Qualifications.

One respondent repeated an earlier comment that indicated support for the proposed general purposes but didn’t provide any further explanation.

Two respondents suggested that the proposed general purposes for these qualifications could limit the ability of students to progress to qualifications other than Level 2 technical qualifications. One of these respondents suggested that the general purposes for the qualifications should include employability skills, and personal and social development, alongside opportunities to progress to further study.

Another respondent said that the regulation of these qualifications should be as clear and straightforward as possible so that teachers and students know what is required of them.

One respondent noted that the general purposes for the Level 1 and Entry level groups of qualifications refer to ‘students’, whereas the general purposes at Level 2 refer to ‘learners’.

Entry level Progression Qualifications 

There were 5 comments related to the drafting of the general purposes for the Entry level Progression Qualifications.

Respondents repeated points made earlier about the Level 1 Progression Qualifications. One respondent indicated support for the proposed general purposes but didn’t provide an explanation. One respondent suggested that the proposed general purposes for these qualifications could limit the ability of students to progress to qualifications other than Level 2 technical qualifications. Another said that the regulation of these qualifications should be as clear and straightforward as possible so that teachers and students know what is required of them.

One respondent noted again that the general purposes for the Level 1 and Entry level groups of qualifications refer to ‘students’, whereas the general purposes at Level 2 refer to ‘learners’.

Question 4
Do you have any comments on the drafting of proposed Condition PQ2 (assessment strategies)?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Six respondents answered ‘yes’, while 8 answered ‘no’. Six comments were received in total.

Two respondents provided comments suggesting they agreed with the drafting of the Condition. Of these, one respondent said the requirement should help to ensure greater consistency of approach between awarding organisations. Another respondent suggested that the assessment strategy requirements would enable Ofqual to identify where awarding organisations’ approaches to qualification design are flawed.

One respondent said the drafting set out clear expectations for awarding organisations, but questioned how it would be monitored to ensure compliance. 

One respondent said the Condition seemed reasonable. They also commented that the assessments should not be too burdensome for the level of study, which was not in scope of this question. 

Another respondent agreed that it made sense for Ofqual to complete qualification checks upfront and to have all of the information on a qualification together in a single document. This respondent said that it would be important to ensure that the process is efficient and noted the additional burden that the requirement could place on an awarding organisation. They also said it would be helpful for Ofqual to include links to the relevant Conditions in the assessment strategy requirements.

Question 5
Do you have any comments on the drafting of the proposed requirements relating to assessment strategies?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Five respondents answered ‘yes’, while 9 answered ‘no’. Six comments were received in total.

One respondent welcomed the similarity of the requirements to those implemented for other qualifications and suggested this would minimise the burden on awarding organisations.

Three respondents referred to the burden the requirements would place on awarding organisations. One of these respondents suggested the requirements were too prescriptive, while another suggested the requirements would place a disproportionate burden on smaller awarding organisations and asked whether a more streamlined approach could be developed. The third respondent suggested that assessment strategy requirements should be proportionate to the level of the qualifications and said that assessment strategies should take into account the characteristics of the students taking a qualification.

Another respondent answered ‘no’ but provided a comment suggesting the proposed requirements were reasonable and similar to those in place for other qualifications. They also welcomed that awarding organisations would be able to provide one assessment strategy document that covers multiple qualifications.

Question 6
Do you have any comments on the drafting of proposed Condition PQ4 (assessments)?

This question applied to the T Level Foundation Qualifications only.

There were 14 responses to this question. Five respondents answered ‘yes’, while 9 answered ‘no’. Five comments were received in total.

Two respondents provided comments that were supportive of the proposed Condition and said that it was clearly drafted. One of these respondents, however, suggested that Ofqual should specify in the Condition that the assessments for T Level Foundation Qualifications must be taken under controlled conditions, in addition to the guidance.

One respondent said they had no comments on the drafting of the proposed Condition but that they would like to understand the exemptions referred to in PQ4.2.

Two respondents made general comments about the need for the assessment approach for the T Level Foundation Qualifications to be manageable, without commenting on the proposed Condition. 

Question 7
Do you have any comments on the drafting of the proposed guidance relating to assessments for the T Level Foundation Qualifications (Level 2)?

This question applied to the T Level Foundation Qualifications only.

There were 14 responses to this question. Nine respondents answered ‘yes’, while 5 answered ‘no’. Ten comments were received in total, including one from the respondent that sent a response to Ofqual’s public enquiries inbox. Most respondents suggested some minor changes to the drafting of the guidance to improve clarity.

One respondent said they agreed with the proposed guidance but suggested that the paragraphs of text under “use of context” and “emphasis on overall performance” could be broken up to aid readability.

Three respondents said that the consideration that assessment contexts should ‘vary over time so that they are not predictable’ was too vague and would be open to interpretation. They also said that changing contexts too often would create an administrative burden on awarding organisations, and they requested guidance from Ofqual on good practice in this area.

Two respondents said that the suggestion that ‘a case study approach’ could be used was too vague and risked being misinterpreted by awarding organisations. They said that Ofqual should make it explicit if a case study approach was preferred, and that, if a case study approach was not preferred, then Ofqual should develop further criteria to ensure standardisation across the sector.

One respondent suggested a minor drafting amendment to the guidance to replace ‘ensure’ with ‘secure’. This respondent also said that they would welcome further clarity on whether compensation would be permitted provided a learner demonstrates broad coverage of the knowledge, skills and understanding. 

One respondent said that the guidance was too prescriptive and did not give awarding organisations enough flexibility to design appropriate assessments. The same respondent also said that it didn’t provide enough detail on how to assess the National Technical Outcomes (NTOs) or address the challenges of assessing students with disabilities or learning difficulties.

One respondent noted that although the grading guidance stated the expectation that a pass grade is intended to demonstrate the outcomes in the NTOs through broad coverage of the relevant knowledge and skills, there was no further guidance on grading the T Level Foundation Qualification assessments. Another respondent suggested the draft guidance did not clarify whether students would be required to pass all assessments to achieve pass grades or whether compensatory approaches would be permitted.

Question 8
Do you have any comments on the drafting of the proposed Condition PQ5 (specified levels of attainment)?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Five respondents answered ‘yes’, while 9 answered ‘no’. Five comments were received in total.

One respondent said they agreed with the drafting of the proposed Condition. They also said the principles set out in the guidance were appropriate for the levels of study.

One respondent said it would be useful to understand the exemptions Ofqual would accept as stated in proposed Condition PQ5.2.

One respondent said the proposed Condition set out clear expectations for awarding organisations but did not state how specified levels of attainment should be set. They said that this could lead to inconsistencies between different awarding organisations. They also said the proposed Condition did not say how specified levels of attainment should be aligned with the National Curriculum or other qualifications. They said this could make it difficult for students to progress between different qualifications. Finally, this respondent said that the proposed Condition did not specify how specified levels of attainment should be communicated to students and other stakeholders. They said this could lead to confusion and misunderstanding.

One respondent suggested consistent approaches to grading would make qualifications easier to understand for key stakeholders but did not set out what this meant in the context of the proposed Condition. Another respondent suggested it was important for common grading structures and titles to reflect a common standard.

Question 9
Do you have any comments on the drafting of the proposed requirements related to specified levels of attainment for T Level Foundation Qualifications (Level 2)?

This question applied to the T Level Foundation Qualifications only.

There were 14 responses to this question. Six respondents answered ‘yes’, while 8 answered ‘no’. However, one respondent that answered ‘no’ also provided a comment. Seven comments were received in total.

One respondent supported the proposed requirements and welcomed the fact that awarding organisations will be able to use their own term when students do not reach a specified level of attainment.

One respondent repeated a comment they made earlier, about how the specified levels of attainment should be set, how they should be aligned with the National Curriculum or other qualifications and how they should be communicated to students and other stakeholders. 

Another respondent also referred to the need for alignment with the National Curriculum and to another qualifications. They said that the requirements did not address the challenges of assessing students with disabilities or learning difficulties.

One respondent suggested these requirements should apply to all 5 groups of Progression Qualifications for consistency.

One respondent felt that more guidance on grading approaches for the Level 2 Technical and Academic Progression Qualifications was needed to ensure alignment in grading approaches and to enable comparability between qualifications.

One respondent welcomed opportunities to work with Ofqual and other awarding organisations to ensure that if common grading scales and titles are used, there is also a common standard. 

One respondent referred to previous comments they had made regarding the purpose statements set out for these qualifications. They suggested that a pass, merit, distinction grading scale may not be the best option for the National Technical Outcomes in all T Level routes.

Question 10
Do you have any comments on the drafting of the proposed guidance relating to specified levels of attainment for Other Progression Qualifications.

This question related to Level 2 Technical Progression Qualifications, Level 2 Academic Progression Qualifications, Level 1 Progression Qualifications, Entry level Progression Qualifications.

There were 14 responses to this question. Six respondents answered ‘yes’, while 8 answered ‘no’. Six comments were received in total.

One respondent, commenting specifically on the Level 1 and Entry Level Progression Qualifications, said that they welcomed the proposed guidance on specified levels of attainment.

One respondent said that the guidance was clear and suggested that it could also apply to the T Level Foundation Qualifications.

Another respondent agreed with the proposed principles and considerations but suggested that all of the Level 2 Progression Qualifications should have the same approach to grading to ensure greater comparability. 

Another respondent thought (incorrectly) that the guidance was prescribing a grading scale for these groups of Progression Qualifications. This respondent suggested that Level 1 and Entry Level qualifications should not have grading scales beyond pass or fail.

One respondent repeated comments made earlier, about how the specified levels of attainment should be set, how they should be aligned with the national curriculum or other qualifications and how they should be communicated to students and other stakeholders. 

Another respondent also repeated comments made earlier in which they suggested it was important to ensure that if common grading scales and titles are used, there is also a common standard. 

Question 11
Do you have any comments on the drafting of proposed Condition PQ8 (standard setting)?

This question applied to the T Level Foundation Qualifications only.

There were 14 responses to this question. Six respondents answered ‘yes’, while 8 answered ‘no’. Six comments were received in total.

Three respondents provided comments that were supportive of the drafting of the Condition. One said that the proposed Condition seemed reasonable, whilst the second said that the Condition was clear and concise and set out clear expectations for awarding organisations. The third respondent noted that the drafting of the Condition was consistent with Conditions that are in place for other regulated qualifications.

One respondent said that the Condition was prescriptive and did not give awarding organisations enough flexibility to set appropriate specified levels of attainment. 

Another respondent commented that it was not clear whether the Condition would apply in cases where grading is separate from the marking process. They said that it should be made clear if this Condition will not apply if there isn’t a standard setting process.

One respondent repeated their earlier comment where they suggested that it was important for common grading structures and titles to reflect a common standard.

Question 12
Do you have any comments on the drafting of the proposed requirements relating to standard setting?

This question related to the T Level Foundation Qualifications only. 

There were 14 responses to this question. Six respondents answered ‘yes’, while 8 answered ‘no’. Seven comments were received in total.

Three respondents wanted to understand what information they would need to submit to Ofqual to show that they were complying with the standard setting requirements.

Two respondents said that it could be challenging and not always appropriate to measure levels of attainment for these qualifications using the same methods as those used with general qualifications. One of these respondents questioned whether Ofqual would want some comparability across similar qualifications of the types of evidence used to inform standard setting. 

One respondent said that the proposed requirements did not specify the weighting that awarding organisations should give to different types of evidence. It was suggested that this could lead to inconsistencies in the ways that specified levels of attainment were set. 

Some respondents seemed to have misunderstood that these requirements were only being proposed in relation to the T Level Foundation Qualifications.

Question 13
Do you have any comments on the drafting of proposed Condition PQ3 (Ofqual reviews of qualifications)?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Three respondents answered ‘yes’, while 11 answered ‘no’. Three comments were received in total.

One respondent said that the proposed Condition would provide clarity to awarding organisations about the outcome of an Ofqual review and would help to maintain the quality of Progression Qualifications. This respondent also suggested that it would be important to ensure there was no additional administrative burden on awarding organisations.

Another respondent said that it was important for awarding organisations to meet Ofqual’s requirements. This respondent also suggested that they would like more information about how Ofqual’s review would be undertaken. 

Question 14
Do you have any comments on the drafting of proposed Condition PQ6 (withdrawal of approval for public funding)?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Seven respondents answered ‘yes’, while 7 answered ‘no’. Eight comments were received in total, including one from the respondent that sent a response to Ofqual’s public enquiries inbox.

Three respondents commented on the policy underpinning the proposed Condition, suggesting Ofqual should receive the information directly from DfE. Another respondent suggested that the proposed Condition was unnecessary as such a notification would already be required under General Conditions B3.1 and B3.5.

One respondent said that it was unclear whether notification would need to be provided as soon as an awarding organisation is alerted to potential withdrawal of public funding from a qualification, or once funding withdrawal had been confirmed. They also said that they would like guidance on how much detail an awarding organisation would need to supply to explain why funding is being removed. 

One respondent said that as notification of funding withdrawal to an awarding organisation can be variable in timescale, it could impact the ability to ‘promptly notify’ Ofqual as specified under the proposed Condition.

Another respondent said that PQ6.3 was vague and did not set out under what circumstances Ofqual would decide that the additional Progression Qualifications conditions, requirements and guidance would continue to apply to a given qualification where public funding had been withdrawn.

Equality impact

Question 15
Are there any further equality impacts (positive or negative) on students arising from our regulatory approach for Progression Qualifications that Ofqual should consider? Where possible, please separate your answer by protected characteristic.

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Six respondents answered ‘yes’, while 8 answered ‘no’. Seven comments were received in total, including one from the respondent that sent a response to Ofqual’s public enquiries inbox.

One respondent suggested that the proposed Conditions and requirements relating to assessment strategies, Ofqual reviews of qualifications, together with the general conditions related to the application of reasonable adjustments and special considerations, could have positive equality impacts but did not specify which groups of students would benefit. 

Four respondents commented on DfE policy rather than Ofqual’s proposed conditions, requirements and guidance. One respondent commented on the proposed size of the qualifications, which is set by DfE. Three respondents raised concerns about the lack of academic pathways below Level 1. One of these respondents also questioned the ability of vulnerable students to navigate the reformed qualifications landscape. The other 2 respondents also referred to the potential impact of the withdrawal of public funding from current qualifications at Level 2 and below. 

Question 16
Other than those identified above, are there any ways in which Ofqual could mitigate potential negative impacts on particular groups of students?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Four respondents answered ‘yes’, while 10 answered ‘no’. Four comments were received in total.

One respondent agreed that the proposed requirements relating to assessment strategies, Ofqual reviews of qualifications, and reasonable adjustments and special considerations could have positive equalities impact.

One respondent said they would expect Ofqual to provide a full equalities impact on its requirements, which they felt should include the impact on students from disadvantaged socio-economic backgrounds. This respondent also suggested that DfE’s policy might reduce the number of qualifications available at Level 2 and below which would have a negative impact on students with special educational needs and disabilities.

One respondent recognised that DfE determined the levels of the different groups of Progression Qualifications but suggested that Level 2 Academic Progression Qualifications should be awarded at Level 1 or 2, as is currently the case for Technical Awards. This respondent suggested that this would enable students who are not quite able to achieve at Level 2 to be awarded a qualification that is appropriate to their level of achievement, and that it would enable greater comparability with GCSE outcomes.

One respondent made a general comment that any changes to qualifications should not place an additional burden on schools and teachers.

Regulatory impact

Question 17
Are there any additional regulatory impacts arising from the proposed regulatory approach to Progression Qualifications? If yes, what are the impacts and are there any additional steps that could be taken to minimise the regulatory impact?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Eight respondents answered ‘yes’, while 6 answered ‘no’. Nine comments were received in total.

One respondent said that there was still a degree of uncertainty about how Ofqual’s requirements would be interpreted and implemented. This respondent suggested that Ofqual should provide guidance to awarding organisations on compliance with the new requirements, such as the concept of specified levels of attainment.

Four respondents referred to the timescales for implementation, which they felt were too short, and to the impact of the changes on awarding organisation resources. However, it is unclear whether these respondents were referring to Ofqual’s requirements or to DfE policy. 

Other respondents commented on DfE’s post-16 policy. For example, one respondent commented on the impact of the requirements on colleges, including the cumulative burden of scheduling assessments across multiple levels and subjects. This respondent suggested that to reduce the burden, Level 1 and 2 Progression Qualification assessments should not be held on the same days as GCSE English and maths assessments. They also said that qualifications should prepare students for multiple potential destinations as colleges will not be unable to run multiple qualifications with different purposes in the same subject.

One respondent commented on the potential impact of different approaches across the United Kingdom. They suggested that qualifications which are titled and given a purpose for progression to T Levels could still have value outside of England.

Question 18
Are there any costs, savings or other benefits associated with the proposed regulatory approach which have not been identified? Please provide estimated figures where possible.

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Five respondents answered ‘yes’, while 9 answered ‘no’. Five comments were received in total.

Four respondents said that there would be additional costs for awarding organisations and schools and colleges. It was not clear whether these costs related to Ofqual’s proposed conditions, requirements and guidance or to DfE’s post-16 policy. 

One of these respondents, a large awarding organisation, suggested that the qualification development work was likely to be costly. This is in addition to internal costs, plus the cost and time associated with supporting providers, teaching staff and students. This respondent did not specify whether this was as a result of the conditions, requirements and guidance that Ofqual is putting in place or as a result of the DfE’s reform programme overall.

Another of the respondents also said that awarding organisations would face additional costs but did not specify what these were. They said that it would be important that these additional costs are not passed on to providers. The third respondent said that if additional assessments were required, this would generate additional costs for providers and for awarding organisations.

The fourth respondent suggested that a more prescribed approach to developing the qualifications could increase costs for some awarding organisations. They also suggested that awarding organisations may need to increase course fees to cover the costs of complying with the new requirements, and that there was a risk that these costs may be passed on to students. 

Question 19
Is there any additional information that Ofqual should consider when evaluating the costs and benefits of the proposed regulatory approach?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Four respondents answered ‘yes’, while 10 answered ‘no’. Four comments were received in total.

One respondent said that the proposed regulatory approach may have a different impact on different sized awarding organisations. This respondent also said that there could be an overall impact on the cost of education, although they did not say how much and who would face them.

Another respondent suggested that Ofqual should understand the cost implications of any requirements it proposes. This respondent repeated a comment they previously made about the potential for awarding organisations to pass costs on to students in the form of increased fees.

One respondent said that as much should be retained from existing qualifications as possible where those qualifications are performing well and enabling students to achieve positive outcomes. This respondent also suggested that student progression could be put at risk if schools and colleges were not able to offer all groups of Level 2 Progression qualifications.

Question 20
Do you have any comments on the impact of the requirements on innovation by awarding organisations?

This question applied to all 5 groups of Progression Qualifications.

There were 14 responses to this question. Eight respondents answered ‘yes’, while 6 answered ‘no’. Eight comments were received in total.

Five respondents suggested that the cost of meeting Ofqual’s requirements would limit awarding organisations capacity and resources to innovative. Two of these respondents suggested that this would be the case if Ofqual were to be overly prescriptive in the types of assessment that it accepted. One of these respondents suggested that this would be because of the minimum number of guided learning hours specified by DfE, particularly for Level 2 subjects in public services and creative industries and at Level 1 and Entry Level. 

One respondent questioned whether smaller awarding organisations would have the capacity to innovate within the proposed regulatory framework but did not provide further details. Another respondent suggested that awarding organisations should work together to share innovative approaches.

Annex A: List of organisational respondents

• The Federation of Awarding Bodies
• Association of Colleges
• UAL Awarding Body
• ECITB
• The Independent Schools Association
• Open College Network NI (OCN NI)
• ASCL
• OCN London
• Gateway Qualifications Ltd
• City & Guilds
• NCFE
• Pearson Education
• OCR