Regulating level 3 qualifications: NCFE’s response to Ofqual’s consultation

Ofqual has launched a consultation into regulating academic and technical qualifications at level 3, which closes on 20 April at 11:45pm. This consultation sets out how Ofqual proposes to regulate academic and technical qualifications in the new landscape, including those which will serve as alternatives to A Levels and T Levels.

The impact of this review will be one of the most significant reforms to the qualifications landscape in the last decade, and we encourage you to submit a response.

We recently hosted a webinar with our Policy team to support with responses to the consultation, which you can catch up on here. We also wanted to share with you the key points  and issues that we’ll be raising in our response:

• There’s a risk that the level 3 qualifications reforms will add more complexity to, rather than simplify, the qualification landscape. There are too many qualification categories, particularly around additional technical qualifications, risking a widening of the divide between academic and technical routes, and creating confusion for learners. 
• The impact of the changes could be greater on adult learners – especially those with protected characteristics. It’s vital to understand and mitigate this impact before the reforms are taken forward.
• We strongly support the continuation of nested qualification suites which, by acting as stepping stones, help to facilitate learner achievement.
• Ofqual doesn’t need to put additional controls in place for assessors, as we now have Centre Assessment Standards Scrutiny (CASS) in operation. This allows centres flexibility in marking non-exam assessments backed up by awarding organisation monitoring.
• Assessment by examination (ABE) restrictions could hinder validity, reliability and innovation. Good practice on qualification design is to develop the content, and then decide on the best way to assess. Starting with the principle of end assessment is not appropriate and could impact on quality of delivery.
• We agree with non-exam assessment (NEA) but disagree with the proposal to limit submissions to twice per year. Many programmes rely on flexible delivery and we should not seek to restrict access based on exam windows. The restrictions could also cause exam management problems if they conflict with general examination (GCSE and A Level) timetables.
• The pandemic has shown that we can still assess reliably and robustly despite concerns about flexibilities, and we believe that continuing flexibility and innovation could bring additional benefits to learners, colleges, and providers.
• Much greater clarity is needed on titling, size, content and funding – this is key to the ‘currency’ of qualifications. Employers will understand and value a qualification based on its title and learners will understand what it is they’ve achieved.

If you’d like to discuss our response to the consultation in more detail, please contact [email protected].