Summary of our response on the consultation for the Office of the Qualifications and Examinations Regulator - Ofqual

AQA has welcomed the opportunity to comment. We have taken the opportunity to raise a number of key issues which we are summarising in this statement because we believe that they are of broad public interest and concern. We welcome the reform of the regulatory structure which has been proposed by the Government and are completely supportive of changes which are designed to give greater public confidence that standards in qualifications are being maintained within and across awarding bodies. We do, however, have a number of significant concerns about the proposals and these are summarised below:

• The new regulator will be responsible for maintaining and enhancing public confidence in examination standards. We look for reassurance that there will be sufficient staff of the appropriate experience and expertise to support this work given the decision to relocate the new body. This expertise must be underpinned by a comprehensive knowledge and understanding of complex and sophisticated technical processes and the supporting literature.
• Awarding organisations such as AQA offer their qualifications in England, Wales and Northern Ireland. The consultation gives no commitment to the establishment of an integrated cross-country approach to regulation with the establishment of a new regulator in England. To avoid confusion, bureaucracy and to ensure clarity across the three countries, we believe that it is a political imperative that cross-country regulation is addressed as a matter of urgency.
• AQA believes that it is essential that the new regulator operates at a high strategic level. There is a real opportunity with the establishment of the new regulator to move away from the current approach where regulation is at the level of detail. It is important that any awarding organisation satisfies high expectations in terms of quality and AQA supports the proposals which will underpin these expectations. Regulation at the detailed operational level should, therefore, be unnecessary. If the present approach continues, the danger is that innovation will be stifled.
• The proposals suggest that there will be a greater level of regulation for high profile qualifications such as GCSE and GCE than for those offered by employers. This suggests that the latter are less important to holders and users than GCSEs and GCEs and runs the risk of devaluing them. This is inappropriate and risks a two-tier level of regulation.
• There are a number of areas, appeals being an important example, where the proposals promise further consultation on detail. The details are themselves extremely important for the effective implementation of the proposals. It is essential that the promised further consultations take place as soon as possible and, in particular, before the formal arrangements for the new body are put in place.
• The proposals suggest that the regulator might make ‘non-binding’ recommendations on awarding bodies to compensate candidates or their parents (presumably mainly in instances where there have been errors in the publication of results). This interference in the relationship between an awarding organisation and individual candidates and their parents seems to us entirely inappropriate. Awarding organisations deal directly with candidates and parents over the resolution of serious issues arising from errors made in, say, the publication of incorrect results. We do not believe that this is an appropriate role for the regulator and are unclear of the basis on which it would make recommendations to awarding organisations that were appropriate, consistent and evidence-based. We therefore call for further discussion to take place with awarding bodies before any proposals are taken forward.
• While the split in the functions between the two current functions of QCA is welcomed, it is important that the issues of principle as well as many matters of important detail are resolved before the new body is established. There needs to be complete clarity about the working relations between the new regulator and the proposed curriculum development agency and about the working relationships between that agency and awarding organisations. Further consultation and discussions on the way in which the principles will be applied in practice are important and should take place as soon as possible, being seen as an integral part of the process for the establishment of the new bodies.

Read the full copy of our response and the consultation document.