Consultation outcome

Consultation analysis: ​Updating Qualification Level Conditions for T Level Technical Qualifications

Updated 10 August 2023

Background

Following receipt of evidence from providers delivering the first T Levels, the Department for Education (DfE) has decided to change the way in which students can take the Core Exam and Core Project at their first attempt. These form part of the Technical Qualification in a T Level. From September 2023, students’ first attempt at the Core Exam and the Core Project will no longer need to be in the same assessment series (this is already the case for students who retake assessments). This will offer more flexibility for schools and colleges, and for students, and means schools and colleges will be able to tailor the sequencing of assessments to their course.

To allow the revised approach, Ofqual consulted on amending its Qualification Level Conditions for Technical Qualifications. The first part of the consultation set out the changes needed to allow students to take the Core Exam and Core Project separately the first time they attempt them. These proposed changes were to:

• remove the requirement for students’ first attempt at the Core Exam and Core Project to be in the same assessment series
• amend the requirements specifying which assessments an awarding organisation must permit to be taken in different assessment series to one another
• amend the minimum required number of assessment series for the Core Assessments, to reflect that the revised policy will require 2 opportunities to take the Core Assessments in each academic year
• update the section on retakes to reflect that the position for retakes and first entries, which currently differs, will in future be the same

The second part of the consultation set out some minor changes, unrelated to those in part 1, which were needed to keep the Qualification Level Conditions up to date. These were changes such as updating references to the Institute for Apprenticeships, which is now known as the Institute for Apprenticeships and Technical Education (IfATE) and amending references to specific General Conditions that have been renumbered since the Qualification Level Conditions for Technical Qualifications were published.

Summary

The consultation ran from 20 March to 15 May and received 22 responses from awarding organisations, schools, colleges, teachers and representative groups. Respondents were supportive of the overall approach that students should be able to take the Core Exam and Core Project separately the first time they attempt them. Many felt that it would be fairer to students, allowing them to be entered only for those assessments for which they were ready. They said the proposed amendments to Ofqual’s Qualification Level Conditions were clear and would allow for this approach.

Some respondents, including awarding organisations, commented on the implementation of the proposals. They said there was limited time to update systems and processes, amend specifications and training materials, train staff and communicate changes to schools and colleges, ahead of September 2023. They also asked for confirmation of whether the changes would apply to students already on T Level courses, or only those starting from September 2023.

Respondents commented that the changes may lead to schools and colleges entering students for assessments in different ways. They could, for example, lead to schools and colleges entering students for some assessments earlier in the year, which, if students were less well prepared at that point, could lead to more students needing to retake assessments. This could increase costs for centres, and impact on the amount of teaching and learning time available.

A small number of awarding organisations commented on the impacts Ofqual had identified in relation to the setting and maintenance of standards in Technical Qualifications (TQs). One of these comments related to the possibility of changes to entry behaviours meaning the make-up of the cohorts sitting assessments in each series could change. It said this would need to be managed as part of the awarding process. Another related to the need to manage the approach to maintaining standards at the level of the Core overall, in light of the Core Exam and Core Project potentially being taken separately.

A small number of respondents commented on the specific wording used in the proposed requirements, while others commented on T Levels more generally, rather than the specific proposals on which Ofqual was consulting.

Approach to analysis

The consultation consisted of 9 questions. Respondents were asked to complete the consultation online or email their responses to Ofqual.

Respondents to this consultation were self-selecting, and therefore the sample of those who chose to participate cannot be considered as representative of any group.

The responses to the consultation questions are presented in the order in which they were asked. Respondents were asked to provide comments on the proposed Conditions, requirements and guidance. Respondents were not required to answer all questions.

In some instances, respondents commented on wider issues relating to T Levels, which were not the subject of this consultation and related to the underlying DfE policy rather than Ofqual’s regulatory approach. Additionally, some respondents answered a question with comments that did not relate to that question. Where this was the case, these comments have been reported against the question to which the response relates, rather than the question against which it was provided.

Who responded?

We received 22 responses to the consultation. All responses have been considered as part of this analysis.

There were 9 official responses from the following types of organisations:

• 3 awarding organisations
• 2 schools or colleges
• 2 other representative or interest groups
• 2 who indicated they were another type of organisation, without specifying further

There were 13 personal responses from:

• 6 staff working in schools or colleges
• 5 teachers (responding in a personal capacity)
• 1 student
• 1 senior leadership team member

All of the respondents were based in England.

Part 1 – Allowing students to be entered for the Core Exam and Core Project in separate assessment series

Question 1
Do you have any comments on the wording of the proposed amendments to the assessment requirements set out?

A total of 17 comments were received for this question. Most of the respondents, including senior leadership team members and other staff working in a school or college, awarding organisations, representative bodies, and schools or colleges, considered that the proposed amendments to the assessment requirements were clear. Many went on to say that the changes in the way the Core Exam and Core Project can be taken would help students by giving schools and colleges greater flexibility in how assessments are sequenced.

An awarding organisation provided the only detailed comment in relation to this question. They wanted to know if the change in wording from ‘scheduling of assessments’ to ‘availability of assessments’ within the assessment strategy indicated a change in meaning in the proposed new requirements. An awarding organisation wanted to know whether students who registered in September 2022, but who may not yet have taken their Core Assessments would benefit from the revised arrangements, in addition to those starting courses in September 2023.

Two respondents, an awarding organisation and a school or college, requested consistency in language between Ofqual, IfATE and awarding organisations when referring to the Core Project, which is also referred to by some users as the Employer Set Project.

Other respondents made comments that did not relate directly to the wording of the proposed amendments. These included a request for more time to allow the current changes to be fully embedded before introducing any further changes to the T Level model.

Question 2
Are there any impacts caused by the changes proposed to Ofqual’s Qualification Level Conditions, which have not been identified? Please explain what these are and how any negative impacts might be mitigated?

Options	Number of respondents
Yes	7
No	15

A total of 22 responses were received for this question, with 9 of the respondents providing comments. This included 2 who had responded to indicate there were no further impacts, but who still provided comments.

The majority of respondents, who were representative bodies and staff working in schools or colleges, felt there were no further impacts caused by the proposed changes and did not leave a comment.

Two respondents, a teacher and a member of staff working in a school or college, did not identify any negative impacts but nonetheless provided comments. One suggested that the changes were unlikely to impact on their delivery approach.

Seven respondents, including teachers, staff working in schools or colleges, awarding organisations, schools and colleges and representative bodies, identified impacts that would be caused by the proposed changes. These included:

• two staff working in schools or colleges who commented that offering part of an assessment in the first year went against the holistic ethos of T Levels, as students would not have the benefit of the work experience and teaching to develop their knowledge and skills, prior to taking their assessment
• one respondent who commented that the timing of assessment series for the Core Exam and Core Project would need to take account of any other assessments which students may also be taking
• two respondents who raised concerns that teaching staff needed time to familiarise themselves with the changes and noted that awarding organisations would need time to change specifications and paperwork before teaching in September 2023. Additionally, the training materials for teaching in 2023 may have already been accessed by schools and colleges

Two awarding organisations made comments relating to the maintenance of standards, which was highlighted in the consultation as an area that Ofqual had identified and considered. One suggestion from these comments included that the revised approach could lead to changes in entry patterns, with students entered earlier for assessments than currently. This could lead to earlier series being made up of a greater number of less well-prepared students, and later series including more retake students, which would need to be considered when setting and maintaining standards.

The second comment questioned how the concept of the standard being set or maintained for the Core as a whole could be maintained, alongside the consideration this is given at the level of the individual Core Exam and Core Project.

Part 2 – Other updates to the Qualification Level Conditions, requirements and guidance for Technical Qualifications within T Levels

Question 3
Do you have any comments on the changes proposed to ensure the Qualification Level Conditions for Technical Qualifications remain up to date?

A total of 8 responses were received for this question. Five of the respondents, an awarding organisation, representative bodies and staff working in schools or colleges, commented that the proposed changes to ensure the Qualification Level Conditions remained up to date were clear.

There were 3 more detailed comments. The first from an awarding organisation noted that the consultation referred to an update being made in relation to General Condition H2 (Centre Assessment Standards Scrutiny where an assessment is marked by a Centre), to correct some incorrect references in the Qualification Level Conditions. They wanted to know what the correct references included in the updated versions would be.

Two comments were unrelated to the proposal. One member of staff working in a school or college commented that T Level students benefited from the work placement element of their programme of study as they could potentially apply current sector knowledge gained from the workplace in their assessments. Another member of staff working in a school or college wanted more flexibility to access either Core Exam papers or Core Project assessments in a January series in the first year of study.

Equality impact

Question 4
Are there other potential equality impacts that have not been identified? If yes, what are they?

Options	Total Respondents
Yes	2
No	19
Not Answered	1

A total of 21 responses were received for this question. Of these, 5 included a comment, 1 of which was unrelated to the question.

The majority of respondents felt that there were no additional equality impacts, with two of these providing a comment. These respondents, an awarding organisation and a member of staff working in a school or college, felt that the revised approach increased flexibility for the students. One respondent commented that students would only have one attempt within an academic year if they chose to take either the Core Exam or Core Project for the first time in the second series in which it was available.

Two respondents considered there was an additional equality impact. One respondent, a school or college, felt there was a risk that students who had a poor educational experience would be disproportionately impacted if they were entered for an exam during the first series in which they were available, when they may not necessarily be ready. It was stated that these students may include those from disadvantaged backgrounds.

The other respondent, a teacher, commented more generally on the students who may take T Levels. They commented that students with special educational needs or disabilities (SEND) may choose not to take a T Level course because of the depth and breadth of learning, and the nature of the assessments.

Question 5
Do you have any suggestions for how any potential negative impacts on particular groups of students could be mitigated?

A total of 4 respondents provided a comment to this question. A representative body made a more general comment that the proposals to enable the Core Exam and the Core Project to be taken in separate assessment series would have positive impacts on particular groups of students. A member of staff working in a school or college commented that adjusting grade boundaries to take into consideration those students who had taken both assessments together could be a way of mitigating any potential negative impact on particular groups of students.

Other respondents’ comments included views on how multiple entries during the course could be discouraged, and that some students with SEND may choose not to take T Levels.

Regulatory impact

Question 6
Are there any regulatory impacts that have not been identified arising from the proposals? If yes, what are they?

Options	Total Respondents
Yes	4
No	16
Not Answered	2

A total of 20 responses were received, 4 answered yes to indicate that there were additional impacts. Three respondents suggested some unidentified regulatory impacts. One respondent, who did not indicate whether they considered there were additional impacts, did choose to provide a comment.

Two awarding organisations and a representative group felt processes and system changes would have to be made to incorporate the changes. Awarding organisations went on to say that although the changes were as a result of DfE policy, the regulatory impact would largely be around the additional work that needed to be undertaken. This work includes updating materials that have already been published and communication to schools, colleges, training providers and students about qualifications that have already been made available to them. While they were clear about the benefits of this policy change, they wanted the cumulative impact of policy changes on awarding organisations, in a relatively short timeframe, to be noted.

A representative group reiterated that the proposed September 2023 implementation date meant the time to implement these changes was tight.

One school or college felt that to make synoptic assessment possible, students would need to take all the assessments at the end of the second year, and suggested an additional assessment series would need to be made available.

Question 7
Are there any additional steps that could be taken to reduce the costs or burdens of the proposals?

Options	Total Respondents
Yes	7
No	12
Not Answered	3

There were 19 responses to this question, of which 10 provided comments. Some respondents that did not answer the question or selected no in response to the question, nevertheless provided a comment.

Responses from awarding organisations, representative bodies and members of staff working in schools or colleges suggested various steps to reduce the cost or burden of the proposals. These included:

• Core Exams in year 2 would reduce the cost of retakes as students would have developed the skills and knowledge to attempt the assessments so would be less likely to require a retake, while teaching staff would not have to prepare students for assessments in year 1, which would also preserve teaching time
• a request for free retakes for 3 years following the introduction of a T Level
• clear, prompt and detailed information and resources for delivery from awarding organisations

Others who responded provided comments that were unrelated to the question.

Question 8
Are there any costs, savings or other benefits associated with the proposals which have not been identified? Please provide estimated figures where possible.

Options	Total Respondents
Yes	3
No	17
Not Answered	2

A total of 20 responses were received for this question, of which 3 included comments.

Two awarding organisations commented on previously identified costs associated with the proposals, which included:

• changes to IT systems to accommodate the changes
• amending materials and resources (for example specifications) to reflect the changes
• up-skilling internal teams to provide customer support and monitor implementation of the changes

One senior leader repeated the idea, which they had raised under previous questions, that entering students for Core Exams in the second series available in each year would reduce the number of retakes and therefore costs.

Question 9
Do you have any comments on the impact of the proposals on innovation by awarding organisations?

There were 5 respondents who provided comments on the impact of the proposals on innovation by awarding organisations.

One representative body stated that they felt the proposal would not result in any negative impacts on innovation. Three other respondents commented that they welcomed the additional flexibility provided by the approach, and would like further flexibility and innovation in T Levels.

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:

• Association of Colleges
• Association of School and College Leaders (ASCL)
• Cirencester College
• City & Guilds
• Independent Schools Association
• NCFE
• Oaklands College
• Pearson Education
• UK Fashion and Textile Association