Ofquala Level Regulatory Requirements Consultation

Field Studies Council

Submission to:

OfqualA level Regulatory Requirements Consultation

January 2014

About FSC:

The Field Studies Council (FSC) is an education charity committed to bringing environmental understanding to all. It currently welcomes 145,000 visitors every year on courses to its national network of 17 Field Centres. These include groups from nearly 3,000 schools, colleges and universities. Established in 1943, FSC has become internationally respected for its national network of education centres and is the UK’s leading provider of curriculum focused field courses.

FSC provides informative and enjoyable opportunities for people of all ages and abilities to discover, explore, be inspired by, and understand the natural and built environment. We believe that the more we know about the environment, the more we can appreciate its needs and protect its diversity and beauty for future generations. We feel that fieldwork should be a vital element of an imaginative and contemporary education.

Section 2: Background - The objective of AS qualifications

To what extent do you agree with the proposed objective of the AS qualifications?
Do you have any further comments relating to this section?

FSC recommends that the introduction of the new A levels and AS qualifications is postponed from September 2015 until September 2016. This would synchronise the introduction of new GCSE and A level courses (a previous Ofqual aspiration), but would also allow for more substantive research into development of alternatives to current internal assessments of practicals and fieldwork, particularly in science. FSC questions whether there has been sufficient research and preparation to support the proposal that science practical assessments should be reported separately on a qualification certificate. There is very strong support from HE and employers to improve the level and quality of practical skills (including fieldwork) in science. The introduction of a speculative and unproven approach to reporting and authenticating of these skills, including a rewriting of the assessment objectives (AO3) to make them fit an exam-only approach, is a high risk and unnecessary strategy which could achieve the opposite of what is needed.

Section 3: Assessment

Biology, Chemistry, Physics

To what extent do you agree that exams in biology, chemistry and physics should include questions to access conceptual and theoretical understanding of experimental methods?

Agree

To what extent do you agree that practical skills in biology, chemistry and physics should continue to be assessed?

Strongly agree

To what extent do you agree that the results of practical skills assessments in biology, chemistry, and physics should be reported separately on the certificate and not count towards the final grade?

Strongly disagree

To what extent do you agree that the proposed assessment objectives are appropriate for A level and AS qualifications in biology, chemistry, and physics?

Disagree

To what extent do you agree that the proposed weightings are appropriate for A level?

Strongly disagree

To what extent do you agree that the proposed weightings are appropriate for AS?

Strongly disagree

Do you have any further comments relating to these subjects?

2.1-2.3. These sections state explicitly that the principal motivation originally was for A level reform to give universities more say in future direction. This culminated in the Independent Chair’s report (led by Professor Mark Smith). This report, and many others, has confirmed that HE and learned societies are calling for “A levels to increase students’ practical skills” and that “in science the debate was about direct hands-on competencies”.

In subjects such as biology “it is skills development rather than named subject content which is causing most concern” and “whilst there is widespread evidence from HE, SCORE, the Society of Biology and other Learned Societies citing the importance of practical skills, there is no consensus as to whether these need to be formally assessed”.

In short, the Smith report concluded that “further discussions need to take place, with input from Qfqual and “clarity is required from Ofqual regarding internal/external assessment”. Throughout all sciences, the report stated that subject groups needed to “resolve, working with Oqual, issues about assessment of practical skills”.

FSC proposes that much more clarity and evidence is needed before the present internal assessment approaches are rejected. We support the conclusion that practicals and fieldwork are critical but remain unconvinced that the proposed assessment solution – that the outcomes of practical assessment should be reported on using a certificate which does not contribute to the overall grade – is a sensible or adequate alternative.

3.30 FSC strongly recommends that Ofqual should issue ‘best practice’ guidelines based on available evidence and research (including sharing across subjects such as science and geography), and that this should inform both the i) creation of Assessment Strategies by Awarding Organisations, and ii) Ofqual’s decision whether the qualification has met the Condition of Recognition.

3.31 FSC welcomes any initiative which “creates opportunities for exam boards to be more innovative in their approach to practical assessments”. We recommend that this innovation should be driven by Ofqual. We propose that the Condition of Recognition and the Assessment Strategies that Ofqual will require from awarding organisations must set clear standards and requirements which will enable “A levels to increase students’ practical skills” and recognise that “in science the debate [is] about direct hands-on competencies”. FSC believes that only Ofqual can provide the statutory leadership and a level of thinking which is missing currently.

3.32 FSC welcomes the intention to use prior modelling to ensure that any introduction of assessments based on certificates does not disadvantage the early cohorts of science A level students, but we are concerned that there will be insufficient time between the results of this modelling and the creation and implementation of a ‘certificate-led’ approach. As stated above, we recommend a postponement in the introduction of new A levels to enable this preparatory research and modelling to provide a sufficient lead in time for exam boards and schools.

3.33 FSC is unaware of any evidence that supports the argument that differential performance in practical and written exam skills is masked if both are assessed separately but reported together towards an overall grade. This statement conflates two quite separate issues: the reliability and validity of the separate assessment of practicals (which is a methodological challenge); and the reporting of assessment objectives in final scores (which is a reporting challenge). Although the FSC agrees that both could be improved, it disagrees with the solution proposed by Ofqual.

FSC strongly recommends that Ofqual tackles separately the two challenges of creating a reliable and valid assessment for practical science, and that of producing reports which enable the separation of practical skills and theoretical knowledge in the award of final grades.

3.35 FSC is unaware of any substantive evidence to support Ofqual’s statement (in 3.31) that separating practicals from the overall grade will mean that “students will be taught a wider range of skills [because] teachers will not feel under pressure”. On the contrary, we share the [widespread] concern that “unless the outcome of the assessment contributes to the overall grade, practical skills will not be taught, or taught well” and believe that the weight of current evidence supports our interpretation. Furthermore, we are concerned that a decline in high-quality teaching of practicals (including fieldwork) will occur most strongly in those schools which already fail to provide adequate resources and support for science practicals (and fieldwork). The disparity in existing provision has been highlighted in recent SCORE and Ofsted reports and FSC is concerned that Ofqual’s proposal will increase this. There is an unnecessary risk that this will work against science students from underperforming State schools in particular.

FSC strongly recommends that the proposal to separate practicals (and fieldwork) from final grades is only implemented if:

Ofqual has carried out a review of all available evidence, including in other subjects such as geography which has a high fieldwork component
AND this review shows that such a move is unlikely to risk a decline in the level and quality of current provision of practicals (and fieldwork).

3.37 Proposed Assessment Objectives. The FSC recommends that the following assessment objectives (AO3) which are applied currently, but have been deleted from the proposed assessment objectives (AO3), are re-instated. They are linked closely to practical skills in science and their omission will risk a decline in the teaching of practicals (and fieldwork) because Awarding Organisations, schools and teachers may/will attribute less importance to these skills in their assessment strategies and the teaching of practical skills.

FSC recommends that the following AO3 objectives are reinstated in proposed courses:

Demonstrate and describe ethical, safe and skilful practical; techniques and processes, selecting appropriate qualitative and quantitative methods;
Make, record and communicate reliable and valid observations and measurements with appropriate precision and accuracy.

3.55 Whilst FSC strongly endorses the proposal that the outcome of the geography fieldwork assessment should be included in the final grade we disagree strongly with its conclusion that the range of practical skills in science are so different that they are unable to assessed similarly through student-led non-exam assignments which take place over a period of time. For example, Science and Geography share similar needs for high-quality practical skills in data gathering and choice and use of appropriate equipment. We can see no justification for excluding such assessments from the final science grade. This is particularly true for biology fieldwork.

FSC recommends that Ofqual reconsider its decision to exclude non-exam and student-led practical assessments from the final grade.

Geography

To what extent do you agree that for the geography Alevel 20 per cent of the available marks should be allocated to non-exam assessments?

Agree

To what extent do you agree that the proposed assessment objectives are appropriate for A level and AS qualifications in geography?

Disagree

To what extent do you agree that the proposed weightings are appropriate for A level?

Agree

To what extent do you agree that the proposed weightings are appropriate for AS level?

Strongly disagree

Do you have any further comments relating to this subject?

3.51& 3.52 FSC welcomes the recognition that fieldwork: is integral to the subject at this level of study; skills are hard to demonstrate in a written exam.

3.53 We endorse the view that fieldwork should be assessed in a non-exam assessment at A level. We also support the proposal the marks should be allocated to this assessment, that this mark should count towards the final grade and assessment approaches should be subjected to regular review. However, FSC believes that an allocation of 20% of final marks to fieldwork skills is too large a fall from the current range of 25-45%.

FSC supports the proposal to include non-exam assessment of fieldwork, with marks allocated counting towards the final grade, and that marking and moderation should be reviewed regularly.

FSC recommends that the proportion of marks for fieldwork skills should fall within the range 25-35%, rather than the fixed 20% as proposed for new exams.

3.54 FSC does not support Ofqual’s suggested contrasting approaches to assessing fieldwork in GCSE and A level. Fieldwork is integral to the subject at levels of study and the full complement of skills (including collecting primary data and the handling of equipment) are impossible to demonstrate in a written exam.

FSC recommends that the assessment approaches proposed for A level should be adapted and applied to GCSE.

General questions on A level assessment

To what extent do you agree that our proposals for A level assessment will support our aim of more secure and valid assessment?

Disagree

To what extent do you agree that our proposals for A level assessment will support our aim of reducing incidents of malpractice in A level assessment?

Disagree

We will be working with the exam boards to consider how greater assurances about the authenticity of students’ work can be secured and the moderation of teachers’ assessments enhanced. Do you have proposals to contribute to this work?

As previously stated, FSC does not support Ofqual’s suggested contrasting approaches to assessing fieldwork in GCSE and A level. Fieldwork is integral to the subject at both levels of study and the full complement of skills (including collecting primary data and the handling of equipment) are impossible to demonstrate in a written exam.

FSC recommends that the assessment approaches proposed for A level should be adapted and applied to GCSE.

Furthermore, FSC is unaware of any evidence that supports the argument that differential performance in practical and written exam skills is masked if both are assessed separately but reported together towards an overall grade. This statement conflates two quite separate issues: the reliability and validity of the separate assessment of practicals (which is a methodological challenge); and the reporting of assessment objectives in final scores (which is a reporting challenge). Although FSC agrees that both could be improved, it disagrees with the solution proposed by Ofqual.

Section 4: Assessment strategies

To what extent do you agree that exam boards should be required to develop and apply assessment strategies for A levels and AS qualifications?

Agree

To what extent do you agree that our proposed requirements for an assessment strategy are appropriate?

Agree

Question types

To what extent do you agree that we should require exam boards to include in their exams questions that provide opportunities for students to gain marks by demonstrating their ability to:
Integrate and apply their knowledge, understanding and skills across different aspects of the subjects;
Construct a response which develops a sustained line of reason, is coherent, relevant, comprehensive and logically structured?

Agree

Do you have any further comments relating to this section?

As previously stated, FSC welcomes any initiative which “creates opportunities for exam boards to be more innovative in their approach to practical assessments”. We recommend that this innovation should be driven by Ofqual. We propose that the Condition of Recognition and the Assessment Strategies that Ofqual will require from awarding organisations must set clear standards and requirements which will enable “A levels to increase students’ practical skills” and recognise that “in science the debate [is] about direct hands-on competencies”. FSC believes that only Ofqual can provide the statutory leadership and a level of thinking which is missing currently.

Section 5: AS qualifications

To what extent do you agree that where AS content is identified within the A level content it should be used as the basis for developing the new AS qualification in the same subject?

Agree

To what extent do you agree that where no AS content is prescribed, we should require the content to be drawn from the A level content in the same subject?

Agree

To what extent do you agree that AS Qualifications should be assessed at a level of demand appropriate to the knowledge, skills and understanding to be reasonably expected of someone who had completed the first half of the A level course of study?

Agree

Teaching AS students with A level Students

To what extent do you agree that our regulations should not prevent qualifications from being designed so that AS and A level can be co-taught, providing the design of a good quality, linear A level is not compromised as a result?

Agree

Assessment of AS qualifications

To what extent do you agree that for the subjects on which we are consulting (with the exception of art and design) all AS assessment should be by exam only?

Strongly disagree

Do you have any further comments relating to this section?

FSC strongly disagrees with the proposal that AS assessments in science and geography should be by exam only. Both are practical subjects and the AS equivalent to AO3 should recognise that fact, including the need to ‘select and use a variety of methods, skills, techniques and equipment’ to carry out investigations. This could only be assessed through non-exam assignments (see 3.37, Science, and 3.56, Geography, above).

FSC recommends that AS geography fieldwork and science practicals (including fieldwork) are assessed using non-exam assignments.

Removing a practical skills assessment from AS could compromise the co-teachability of A and AS levels, undermining the ability of schools and colleges to provide AS courses.

Furthermore, it is erroneous to suggest that practical skills are only required by higher institutions for further study. Knowledge, experience and confidence in practical skills is highly valued by employers and extend to a range of careers and apprenticeships that are available independent of further study at higher education institutions.

Dr Steve Tilling, Director of Communications, Field Studies Council