Sector leaders have urged Ofqual to reconsider its proposal to only allow T-level exams in the summer, as it means pupils would have to wait a whole year for retakes.
One representative body warned the plan represents a “significant capacity risk for the whole exam system” while also being “overly burdensome” on pupils.
Ofqual received the feedback in its consultation about how it will regulate the new post-16 technical qualifications – which launched on July 10 with just a four-week turnaround.
This represents a significant capacity risk for the whole exam system
Despite the short deadline, over 50 awarding organisations offered formal responses after 100 people attended its consultation events and 40 joined its webinar on the topic.
Schools Week has seen a number of the responses, in which the proposed grading system and monetary and capacity issues were high on the list of concerns.
But Ofqual’s plan to only allow assessments to be taken in the summer, thus forcing students who need to re-sit their exams to wait a whole year to do so, was most alarming.
“If a learner fails an assessment at the end of year one they may well need to undertake further learning [in year two] to support the development of their skills and knowledge,” said the Federation of Awarding Bodies, which represents over 125 AOs.
“It is important to consider whether it would be overly burdensome on a learner to undertake this volume of learning, how it might impact on the time the learner needs outside of their studying for wider responsibilities (e.g. part time working).”
The federation added that only having exams in the summer is “not appropriate for the more vocational-style assessment that will be required for the occupational specialisms” and “smaller chunks” of assessments throughout the year would be better.
It also said that the May/June exam period is “already a busy and resource intensive time for providers and we are concerned that on a very practical level, there is not the capacity in the system to support additional assessment”.
Exam halls, invigilators, and examination staff will “already be under immense pressure at that time”.
The FAB added: “If T-levels are intended to scale up then this represents a significant capacity risk for the whole exam system.”
The Association of Colleges backed up the fears expressed by awarding organisations.
“Lessons need to be learnt from the roll out of previous qualifications which have in many cases required additional assessment windows and a safety net approach to grading,” said David Corke, the association’s director of policy.
“There must be additional assessment opportunities other than just the summer. It is important not to impede learners progressing to employment or further study, it is equally important that these reforms are in line with accountability reporting time frames for providers.”
He added that government must also “cost the impact of these changes” in monetary terms, “including exam fees, resit fees, invigilator costs, exam hall hire and extra exam staff salaries”.
In Ofqual’s webinar about the T-level consultation, held on August 1, the watchdog’s regulatory development manager, Steve Hickmott, explained why it only wants exams and retakes to happen in the summer.
“We’ve proposed this because we think this is the most robust approach in terms of maintaining standards and it saves the qualification being broken down,” he said.
“But we do fully appreciate this is likely to have implications with both the centres and students themselves that wish to retake sooner, and for employers who may be looking not just to recruit students each summer.”
He added that Ofqual has “flagged this as one of the key issues” and is “keen to hear what alternatives may be preferred”.
The NCFE, an awarding organisation, suggested that an exams system similar to A-levels, in which assessment periods also take place in January, would be better.
This would “reduce the time lag between assessments, support learners in their achievement and keep them motivated throughout”.
The responses to the consultation also highlighted concerns with the proposed triple grading system.
If a pupil passes, the regulator wants to give an overall “pass”, followed by the core component of the qualification graded A* to E, while using Pass, Merit and Distinction for occupational specialisms.
Awarding organisations disagreed with this approach and said the grades should all be standardised for “ease of clarity, understanding and aggregation of final pass or fail”.
Mr Corke said the grading structure is “definitely more complex”, but “we do recognise the usefulness of separate grading scales for what are essentially the theory and practical components of the qualification”.
Ofqual is expected to formally respond to its T-level consultation in the next few weeks.