Ofqual consultation sees disagreement on ensuring grade fairness

Responses to an Ofqual consultation on teacher-assessed grades for GCSEs and A Levels have revealed differences of opinion on how, if at all, potential biases should be tackled.

Following the cancellation of exams, Ofqual has been consulting on proposals which would see pupils receive calculated grades. These would be based on both the mark teachers believe students would have achieved had exams gone ahead, and a rank order of pupils by performance for each subject and grade. For the rank order pupils would be ranked from those who are considered most secure in their attainment of a particular grade, down to those who are least secure. These rankings could then be used by exam boards to assist in moderating grades.

Publishing its proposed guidance at the launch of the consultation, (which closed on 29 April), the exam regulator said that it didn’t plan to intervene to attempt to prevent bias by looking at schools’ grades and statistically adjusting ‘the standard being applied to different groups of students (for example by SES [socio-economic status] SEND, ethnicity and gender’. It also said that headteachers should ‘emphasise the need for judgements to be objective and fair’.

However, responses from various organisations have argued that greater intervention is required to avoid groups of students being disadvantaged. In their response, equalities watchdog the Equality and Human Rights Commission (EHRC) argued that Ofqual’s proposed guidance ‘in itself will not address the risk of unconscious or conscious bias by exam centres predicting grades for students.’ They argued for further government guidance to be issued on the approach teachers should take to predicting grades and ranking pupils, and also proposed schools be required to provide Ofqual with ‘sufficient data on socioeconomic background and the protected characteristics of assessed pupils, including by ethnic group, to support analysis to check for systemic advantages or disadvantages’. Ofqual could use this information to publish a report evaluating the predicted grades process and outcomes, which could then form the basis for further intervention if required, the EHRC suggested.

Chair of the EHRC David Isaac said: ‘We know this is a difficult time for people working in education. It is also difficult for pupils. After years of hard work, control of their grades will be taken out of their hands. If we don’t get this right the future of some disadvantaged young people is severely at risk’.

Meanwhile the Sutton Trust charity used its response to call for Ofqual to intervene if there was evidence of bias against disadvantaged students, including making changes to schools’ ranking of pupils. ‘It is critical that socioeconomic attainment gaps are monitored throughout the stages of the adjustment process, so it’s important that Ofqual have access to data on the free school meal/pupil premium eligibility of pupils,’ the charity said. ‘If systematic bias is evident, statistical adjustments should be considered, which may include changes to centre rankings.’

Both the EHRC and the Sutton Trust also highlighted the importance of pupils having the ability appeal their results. The EHRC said pupils would need a ‘meaningful and timely route of appeal’. The Sutton Trust pointed out that there may be greater ‘barriers’ to disadvantaged pupils being able to appeal. ‘If these barriers are not removed, particularly at a time of upheaval such as this, they may prevent disadvantaged students from making an appeal and widen inequalities within the system between students. Students from poorer homes may also be less likely to be in a position to resit exams. The overarching principle should be to ensure that there are no inequalities in access to such remedies,’ their response stated.

However, a school leaders union took a different perspective in their response to Ofqual. The Association of School and College Leaders (ASCL) argued that rank orders submitted by schools to exam boards should not be modified to account for bias towards disadvantaged pupils or specific ethnic groups. ‘We have emphasised to ASCL members that, whilst perpetuating existing gaps is deeply uncomfortable, this is neither the method or moment to attempt to narrow them, and they should focus on the task of assigning the most plausible grade.’ their response said.

Responding to the points raised by the EHRC, ASCL general secretary Geoff Barton, said: ‘We will study the proposals of the EHRC with interest, and it is obviously important to guard against unconscious bias. But we do need to be careful not to layer on additional complexity to what is an already extremely complex process. The overriding principle of centre-assessed grades is that they must be an accurate and fair assessment of the student’s work, regardless of background.’

The ASCL’s response also took a different view to the EHRC and Sutton Trust on appeals, arguing that only schools – rather than students as individuals – should have the right to appeal grades. They also called for schools to be exempt from freedom of information requests from students after grades are released.

Ofqual will publish a summary of all the responses received to the consultation, and its decisions, in due course. The exams regulator is also now consulting on arrangements for awarding vocational and technical qualifications, with a closing date of Friday 8 May 2020. Details of that consultation can be found here: https://tinyurl.com/y9yem9x6

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