Grades based on a range of evidence
Schools will be asked to determine grades for students based on “…a range of evidence completed as part of the course, including evidence produced in the coming months, which demonstrates the student’s performance on the subject content they have been taught.” The judgements need to be “objective and fair”. This is a different test compared to last year and should be an easier process for teachers as there is no requirement to rank students. It has also been well documented that there will be no algorithm this year. At least 2 teachers must sign off on the grade for each subject, one of whom should be the head of department or subject lead. The head of centre must also submit a declaration when the grades are submitted.
Comparison with previous results
The Ofqual and JCQ guidance recommends that schools compare the grades students are given by teachers this year with the performance of previous cohorts who sat exams between 2017 – 2019. We anticipate that this exercise may pose challenges for some centres. The JCQ guidance states the following,
“….centres are advised to consider the profile of their results in previous years in which exams have taken place, as outlined in Ofqual’s Information for heads of centre, heads of department and teachers on the submission of teacher assessed grades: summer 2021. Centres can use this to undertake a high-level check once grades have been assigned to students, to ensure that they have applied a consistent standard in their assessment of the 2021 cohort compared to previous years in which exams took place…. However, grading judgements should not be driven by this data. Historical grade data should only be considered after grading judgements have been made.”
If the outcomes this year are much higher or lower compared to the results in 2017 – 2019, the JCQ guidance suggests that the school may need to reflect on the grading standards applied by teachers for the relevant subject / qualification, although it emphasises that TAGs must be based on the evidence of students’ work i.e. grades should not be altered artificially to correspond with a centre’s previous results.
There may be contextual reasons to explain changes to a school’s grading profile but if there is a significant divergence between this year’s grades and the results from previous years, it is more likely that the school will be picked for targeted sampling by the exam boards following submission of the TAGs. It is therefore important that schools keep detailed records to explain the rationale for any variations in grades compared to previous years if the school is satisfied that the TAGs are appropriate, so that this evidence can be shared with the exam boards if required.
Communications with students
The Ofqual and JCQ guidance state that centres should inform students about the range of evidence that teachers will be relying on in order to determine the TAG, although students must not be told their actual grades before results day. The JCQ guidance states that “…the range of evidence used to determine a grade is not negotiable” which we take to mean that staff will be required to tell students what evidence has been used as opposed to seeking approval from the student. The purpose of this dialogue is to help to show transparency which will, “…enable students to raise any errors or circumstances relating to particular pieces of evidence to be taken into account in advance of the grade submission” with the aim of reducing the risk of appeal later on.
By comparison, the section in the JCQ guidance relating to malpractice encourages centres to be alert to students, parents and guardians who may try to put pressure on teachers to influence grades. The guidance suggests that schools should be able to handle most of these discussions internally (though records should be kept) but states that some cases may need to be reported to the exam boards as potential malpractice if the student or parent continues to act inappropriately.
This is going to be a difficult tightrope for schools to walk. On one hand, schools need to follow the Ofqual and JCQ guidance and ensure that teachers are not placed under undue pressure to award certain grades. However, it is also important that teachers carefully consider any communications received by or on behalf of students in case legitimate issues are being raised which should be considered before the TAGs are submitted to the exam boards. In particular, schools should be alert to any concerns about access arrangements not being applied for assessments and concerns about a student’s performance being affected by physical or mental health conditions. This is because such communications could be the pre-cursor for a subsequent appeal to the exam boards or even a disability discrimination claim.
Each individual case will turn on its facts, but it is important that teachers are asked to share any such communications with senior leaders so that the school can decide on an appropriate response and take advice if necessary.
Access arrangements / reasonable adjustments
Both the Ofqual and JCQ guidance state that reasonable adjustments for disabled students and access arrangements should have been in place when the evidence was generated. Where access arrangements have not been applied properly (which in our experience is a relatively common occurrence for some school based assessments and may well have been the case for some assessments that took place during the periods of remote learning), the JCQ guidance needs careful consideration. This is because one section states, “It is better not to use evidence if access arrangements were not in place when they were meant to be”.
However, another part of the guidance states the following,
“Where such adjustments/arrangements weren’t in place, teachers must consider whether to either:
- use the evidence when assigning a grade on the basis that it is the most appropriate evidence available, and disregarding it would disadvantage the student – if this is the case, the impact must be accounted for at stage 5 (see below), and the rationale recorded; or
- use alternative evidence to replace assessments that are not appropriately representative of individual students’ performance and if so, document decisions appropriately.”
A subsequent part of the guidance states the following in relation to access arrangements / reasonable adjustments that have not been applied,
“….centres should consider using other evidence or take it into account when coming to their judgement. Where appropriate, this should include input from relevant specialist teachers and other professionals and it must be appropriately recorded/documented.”
In any event, the failure to apply an access arrangement / reasonable adjustment to an assessment should be taken into account when teachers are making their final judgement and a record made to reflect that this has happened.
If reasonable adjustments or access arrangements have not been applied for some or all of a student’s assessments for any reason, our recommendation is that teachers should notify their head of year and the examinations officer so that the school has an accurate picture of the assessments, subjects and students that are affected. The school should ensure that it has a clear, written policy on the approach to be taken by teachers in such circumstances.
Aside from ensuring that the issue is addressed appropriately for the purposes of deciding on TAGs for pupils with SEND, the school should consider the reasons why access arrangements have not been applied properly, for example, does it reveal any issues relating to communications or training that ought to be addressed?
The above point assumes that schools have a list of students with agreed access arrangements. However, some students may have disabilities which are protected by the Equality Act 2010 which might not have been picked up by the school previously and / or which may have developed or become exacerbated during the Covid-19 pandemic. In addition, some students may have a disability, such as a medical condition, which might not normally require formal access arrangements to be implemented but which might still have a detrimental impact on their performance during an assessment or their attendance at school which should be taken into account. As above, we recommend that schools are alert to any communications from students or their parents which indicate that there are issues that the school need to consider and that such communication is passed on to a senior member of staff for further consideration and advice if necessary. Schools may also wish to provide refresher training to staff on the Equality Act 2010; we can deliver online training sessions to schools on request.
Retaining records
There is much more emphasis in this year’s guidance on retaining records of decisions and evidence about TAGs and the head of centre’s declaration includes a reference to the retention of evidence (the JCQ guidance refers to “excellent” record keeping throughout the assessment process!). Our experience from last year’s process was that there was quite a lot of variation across different subject areas within the same school and that many teachers did not create formal records of decisions that were made. This is understandable given the short notice that schools were given last year for deciding on centre assessed grades, but staff should be informed about the importance of keeping records and evidence this year. The JCQ website includes a template ‘Assessment Record’ for recording such decisions which schools might find helpful.
Appeals
The JCQ guidance explains the process for students to challenge their grades. This will involve a two-stage process where schools will initially need to carry out a ‘centre review’ to check if there has been an administrative or procedural error. If not and if the student remains unhappy, the student can ask the school to submit an appeal to the relevant exam board(s).
Unlike last year, schools will not have to decide whether the grounds for lodging an appeal with the exam boards have been met and, in fact, a failure to lodge an appeal if asked to do so by a student could constitute malpractice. However, the timescales for dealing with the two-stage appeals process, especially for priority appeals, are very tight and we recommend that schools plan how the process will be managed and resourced, bearing in mind that it will be the middle of the summer holidays.
Our experience from last year’s process was that some of the conversations that took place with students after they received their results were fragmented and students were not always signposted to follow the official channel for raising their concerns. In addition, not all schools had a clear process for managing concerns which related specifically to exam grades. Although it is understandable that students may reach out to staff members who they trust after they receive their grades and schools should provide emotional support and reassurance to students after grades are released, it is also important that all staff inform students that they should follow the correct published route to request a centre review and then an appeal to the exam board if it is apparent that a student is unhappy with their grades.
In relation to the procedure for dealing with appeals, the template centre policy on the JCQ website refers to the centre’s separate ‘internal arrangements’ for dealing with appeals and we advise schools to ensure that these arrangements are set out in writing as this will provide invaluable guidance and clarity on the process for both staff and students at a time when requests for centre reviews and appeals will need to be handled quickly.
We have drafted a template appeals policy which includes guidance and template forms for students to submit which will be available after the JCQ has published its guidance relating to the appeals process. To register your interest and request a fee quote for the policy, please email schoolsupport@wslaw.co.uk
Conclusion
There is no doubt that the summer term promises to be another challenging period for schools and our School Support team are here to answer your questions and give support on any issues relating to the process for determining TAGs or dealing with Covid-19 more generally.
This blog is intended to provide some general observations on the guidance relating to TAGs and is not a comprehensive analysis of all the points that schools need to be aware of.
