5. Neither of these options is necessarily incompatible with the AS/A2 model recommended in paragraph 42. There is no prima facie reason why a modular curriculum requires separate assessment of each module and it may be that three curricular modules could be assessed in two assessment units. The burden of external examination could also be reduced by relying more on internal assessment and coursework, providing care is exercised to ensure that the total burden of internal assessment does not become excessive. There are issues that would first need resolving about coursework standards and how it is assessed, and about the training and professionalisation of examiners, some of which are explored in paragraphs 120 to 136. It has not, however, been possible in the time available for me to come to any firm conclusions about the amount and type of assessment appropriate to the curriculum and the maintenance of standards.

6 I recommend that, as part of the development of the 14-19 reforms, the Government and its partners examine carefully the scope for reducing the total burden of external assessment derived from GCSEs and A levels.

Relationship between the timetables for A level examinations and university admissions

7. The timetable for the marking and grading of A levels has been driven largely by the need to issue results in time to ensure that students may confirm their university places before the start of the academic year. Although there have been huge changes in the volume of A level entries, the time available for marking, grading and issuing results has hardly changed in 50 years.

8. The availability of technology has removed much of the burden of administration and data processing, but time pressure remains a significant factor and can still have a notable impact on the quality of the marking and awarding processes. For example, post examination meetings to standardise marking and determine grade boundaries sometimes have to take place with only a limited amount students' work available on which to make judgements.

9. The timing issue has also adversely affected some of my own recommendations. In particular, it is my view that considerable benefits could be gained in the judging and maintaining of standards from the presence at awarding meetings of a Chair of Examiners from another board. As set out in paragraph 70, however, given current time constraints and capacity issues I do not believe that this is possible in the short-term.

10. It would in my view be beneficial to create additional space in the academic calendar for awarding to reinforce arrangements for guaranteeing standards and to enhance public confidence that important procedures are not being rushed. This needs, however, to be balanced against other demands, not least the time available for teaching. Consideration of these issues is well beyond the scope of my remit, though I do believe there are steps that can be taken which will bring about immediate improvements.

11. As an interim measure, I believe that delaying the publication of AS and A level results by 1-2 weeks is possible if consequential adjustments are made to the timing of GCSE results - perhaps with GCSE results coming out later in the same week as those for A levels. The impact on university admissions procedures, including clearing, should be manageable and offset by the potential benefits. I recommend that this is done to take effect as soon as can realistically be managed without risk to the effective administration of the systems for examinations and for entry to higher education.

For the longer term, I recommend that consideration be given to structural reforms to the timetables for A levels and university admissions to extend the time available for examining and awarding, without reducing the teaching time for A levels. This should, in my opinion, include looking at the possibility of reform of the school year and the university admissions timetable with a view to moving to a post-qualifications admission (PQA) system.

12. Though there are practical issues that need to be addressed, I have been persuaded in the course of my inquiry that PQA has much to commend it. The movement to PQA would increase accuracy in the admissions process as well as removing much of the burden of clearing. Students would be relieved of the stress of applying for universities during year 13 and have more time to focus on gaining good results. I think therefore it is worth considering how a PQA system might be established. This might include looking at:

• delaying the start of the first year of university. Moving the start of the first year of undergraduate study back to, say, the end of October might provide the additional space necessary for robust quality assurance and PQA. The impact on first year teaching might, if universities wished, be offset by a narrower break between the first and second years. This is a matter for universities to resolve, and they may want to consider how it would relate to other changes, such as the trend in many universities towards the adoption of a semester system, and the balance between the potential costs and the benefits of PQA in simplifying university admissions. I urge UUK to continue their work in this area;

• the LGA recommendation for a six term year. If this model were adopted on a national basis, examinations could perhaps be taken in term five, giving awarding bodies substantially more time to carry out the awarding process. The knock-on effect for earlier years would need careful evaluation, as an earlier start to the school year would be necessary to ensure no reduction in the teaching time that teachers and students already feel is too compressed, especially for AS. The impact on the availability of markers and the present twice-yearly examination sessions would also need to assessed.

Relevance to Northern Ireland and Wales

6. Action to tackle burdens of assessment may be a matter of national policy and need not necessarily be common to all three countries. Nevertheless, any reforms which affect the design of national qualifications must be developed on a three country basis. Equally, reform of the A level and school and university timetables would need to apply across all three countries. The impact on Scotland, especially of changes to the university year, would require appropriate involvement by Scottish institutions in consideration of any changes.

Other issues relating to this year's concerns

16. In the context of phase 2 of my inquiry, I have looked carefully at the circumstances that gave rise to some of the individual cases which have been highlighted as a cause for concern this year, such as the appearance of results for individual units which appeared to be out of line with the relevant students' pattern of results in other units ("the AAU problem").

17. Most of the concerns raised by those cases related to the overall standard setting and grading processes, which I have addressed in my two reports. However, there are other cases which highlight issues related to the design and quality assurance of individual subject syllabuses and marking schemes; and the consistency and transparency of marking.

18. For instance in one coursework unit, the design of the syllabus and marking scheme made it inevitable that students' marks would be compressed into a very narrow range. The result was 9 marks (from a total of 50 available) separating the A and U grades. Where the grade boundaries are this close together it is difficult for the grading process to differentiate effectively between the performance of individual candidates. QCA and the awarding bodies are taking the necessary steps to correct such flaws for examinations in 2003.

19. Some continuing concerns have been expressed to me about the consistency of marking. Many of the case histories submitted to my inquiry, including some that have fuelled concern about "rogue" grades, appear to have affected only individual candidates or groups of students within a school. I am persuaded that such results cannot be the result of systematic manipulation of the grading process since that would downgrade all of the students taking the relevant units and in extreme cases would have led to up to 80% of them receiving a U grade. I have no evidence that this happened in any unit. I can therefore conclude that such cases are either a proper reflection of lower-than-expected performance by the candidate or inconsistent marking and/or coursework moderation. I have no clear evidence on which to judge a conclusion about the balance between these two explanations.

20. I am concerned also about the quality of communication and feedback to schools and colleges. For example, a number of case histories were submitted to me in which specific concerns about students' grades were based on significant misunderstanding of the A level marking and awarding process (e.g. about the translation from raw marks to UMS scores). Despite correspondence between the relevant school or college and the awarding body, these misunderstandings were often not corrected or explained, leaving teachers and students uncertain about whether their work has been treated fairly. It is essential that schools, colleges and students have access to high quality feedback and clear explanations of the processes which have applied to their entries.

21. I am clear that all these problems are separate from the allegations which I investigated in my first report that the grading process was systematically manipulated. Similar issues can, and have, arisen in previous years. They have nevertheless added weight to the current concerns about the credibility of the system.

22. I do not believe that changes are needed at the level of system-wide procedures and practices to prevent such problems occurring again: they can and should be detected and tackled on a case-by-case basis as they arise. I am content that the existing regulatory framework, if properly applied, offers the correct mechanism to achieve this. Nevertheless, it is necessary for the regulators and the awarding bodies to keep their quality assurance and communication procedures under review in the light of experience. This year's events offer a good deal of experience on which to draw.

Relevance for Northern Ireland and Wales

23. The Code of Practice and other key regulatory processes are common to all three countries. Changes to this framework should therefore be taken forward jointly. Any other arrangements for scrutiny of the awarding process are a matter for individual countries to consider in the light of their own circumstances and current practices.

25. The Quinquennial Review of QCA earlier this year reported in detail on QCA's work. I have not sought to reproduce the scope of this review. Moreover, I have not sought to investigate in detail the internal management and operation of QCA. I have every confidence that the new leadership at QCA will take whatever action is needed to ensure that the Authority can perform its functions effectively and credibly. In particular, they will need to ensure that the regulatory role is clearly delineated and that it functions separately from QCA's wider business.

26. In this inquiry I have focused on concerns highlighted by recent events about the role of QCA and its relationship with Ministers and the awarding bodies. This chapter examines those concerns and sets out my recommendations relating to the roles of, and relationships between, these key players in England.

Relationship between Ministers and the QCA Developing and implementing qualifications policy

27. It is self-evident that Ministers should be responsible for the key decisions which shape the qualifications system and its relationship with wider education and skills policy. In exercising that responsibility they should be able to look to the QCA for expert advice. I fully accept that the QCA should have a clear duty to respond to requests from Ministers for advice. In this context I note also that, whilst QCA is the Secretary of State's principal advisory body on qualifications, others have an interest in the development of qualifications policy and should be able to make their views known directly to Ministers if they so wish.

28. The normal mechanism for seeking QCA advice is a remit from the Secretary of State or other education Minister to the Chairman of QCA, asking for advice on specific aspects of qualifications policy, and setting out any parameters - such as timescale or wider policy constraints - which the QCA should take into account in preparing its advice. QCA officers will normally then prepare a response for approval by the QCA board, consulting other relevant interests, such as the awarding bodies or teachers. It is usual practice for QCA's advice to be published. There is no fixed timing for such publication, but the pattern is often for publication to take place alongside announcement of any decisions by Ministers resulting from the advice which QCA has offered. In general, QCA will have a responsibility to manage the implementation of those decisions in collaboration with the other regulators and the awarding bodies.

Regulating qualifications

29. The QCA's regulatory function is further removed from the Secretary of State's direct responsibilities than its role in advising Ministers on qualifications policy. In its regulatory role, QCA's responsibilities include:

• putting in place the framework of rules and processes to ensure that standards are maintained - for instance the Code of Practice governing A levels, GCSEs and GNVQs;

• monitoring the application of this framework by the awarding bodies;

• approving individual qualifications, including all A level courses, proposed by awarding bodies;

  reviewing, and taking whatever steps are necessary to maintain, standards over time between individual qualifications and across awarding bodies

• monitoring and taking steps to maintain the overall health and effectiveness of the qualifications system.

30. Ongoing responsibility for maintaining and operating the regulatory system rests with QCA and the other regulatory bodies. From my inquiry it is clear that there is a wide consensus that Ministers have a legitimate interest in assuring themselves through contact with the QCA that these functions are being carried out effectively. Nevertheless, they should not intervene in the ongoing operation of the regulatory framework nor in the details of the QCA's relationship with the awarding bodies.

Does the relationship between Ministers and the QCA work?

31. I have received a range of views on the relationship between Ministers and the QCA. Many of these turn on whether QCA is, and is seen to be, sufficiently independent of Ministers. In particular, there is concern:

• that QCA's advice may be informally constrained in order to produce an outcome that is acceptable to Ministers;

• that lines of accountability are unclear. Even among some of those most closely involved in the delivery of qualifications, the decision-making processes can be unclear, and they are unsure where responsibility for some key decisions lies;
• that the DfES may become involved too closely in monitoring and influencing implementation and regulation activity which should properly be the responsibility of QCA.

32. The perception that the relationship might function in these ways damages the reputations both of Ministers and of QCA and affects the credibility of the decisions and actions which both take legitimately to maintain and develop the qualifications system.

QCA and the awarding bodies

33. Some similar issues arise in perceptions of the QCA's relationship with the awarding bodies. In particular there is a significant lack of clarity about the boundaries between QCA's role in overseeing and ensuring the health of the qualifications system and the awarding bodies' responsibility for operational management of that system and the qualifications outcomes to which it leads. In my earlier report, I highlighted a specific difference in perceptions between the Authority and the awarding bodies about the way in which QCA was carrying out its functions as regulator. That difference was indicative, at least in part, of a blurring of the boundaries between the respective roles of regulator and awarding bodies.

34. It is essential that the QCA acts as a regulator, and is rigorous and consistent in its actions. But it should not become involved in managing the detail of the awarding bodies' responsibilities in relation to the setting, marking and grading of A levels and other qualifications.

35. There is one aspect of the relationship between QCA and the awarding bodies which requires particular attention. QCA acts, in effect, as the awarding body for key skills qualifications and the national curriculum Key Stage tests in schools. Both of these activities fall outside my remit. Nonetheless, they involve a different relationship between QCA and the awarding bodies, because the delivery of significant parts of the key skills and key stage assessment process is carried out by the awarding bodies under contract to the QCA. The Quinquennial Review of the QCA published earlier this year expresses concern about this additional dimension to the relationship. Those concerns should be given significant weight. It appears to me that there is potentially a conflict of interest between the contractual and the regulatory relationships; QCA's management of contracts with the awarding bodies to deliver the tests is not compatible with the Authority's role in regulating those same awarding bodies' own qualifications.

Conclusions

36. Some have argued the case for giving QCA a greater measure of statutory independence. The QCA's status as a non-departmental public body gives greater formal powers for the Secretary of State to steer its work than would be the case if, for instance, the Authority were to become a non-ministerial government department like OFSTED. However, whilst a change of status might reduce some of the formal powers which Ministers have to influence and direct QCA's operations, I am not persuaded that it would address effectively the concerns which have been highlighted this year; and there is a risk that the necessary legislation and disruption arising from major institutional change would be a distraction from the immediate priority of managing the delivery and standards of A levels.

37. Nor am I persuaded that the relationship of necessarily close co-operation between the DfES and QCA across a wide range of curriculum and qualifications matters would be enhanced by a greater degree of separation.

38. I have also considered whether the QCA's regulatory functions should be separated from its other roles and accorded a separate independent status. I agree that there is a clear need to ensure that the regulatory function is effectively ring-fenced from QCA's wider activities. But the evidence presented to me suggests that the benefits of separating QCA's regulatory role would be largely presentational, and would not outweigh the risks inherent in organisational change, and in dividing the qualifications expertise currently available within QCA.

39. On this basis, I am persuaded that a change in the status of QCA or some if its component parts is not justified. There is nonetheless an early need to tackle the perceptions which appear to have grown up about the ways in which the DfES (Ministers and officials), QCA and the awarding bodies actually behave in practice. The key to this is to inject a greater degree of clarity and transparency into the roles and responsibilities of each, and into the ways in which they work together. I note that the Quinquennial Review recommended a memorandum of understanding setting out the guiding principles which should underpin the relationship. I support that approach.

40. I recommend that the DfES, QCA and the awarding bodies jointly draw up an agreement which describes their roles and relationship and establishes clear lines of responsibility and accountability. This agreement should also, wherever appropriate, set out ways of working to ensure that the relationship is transparent. In particular, the agreement should ensure that:

• requests to QCA from Ministers for fresh advice or new work should set out the matters which the advice should cover or the action required, who will have responsibility for subsequent decisions and follow up action, and which organisations or individuals should contribute to that work, including where appropriate DfES Ministers or officials;
• such remits and QCA advice to Ministers should be published at or near the time when they are issued - unless there are strong reasons why they need to remain confidential;
• implementation timetables for new policies and initiatives are established and published as early as possible in the development process, and fully reflect the need, amply illustrated by this year's experience, to allow realistic time for development and testing. In my view, major changes to the qualifications system should have a lead time of at least five years;
• as clear a distinction as possible is maintained between (a) QCA's responsibility for monitoring and coordinating delivery, and for overseeing and guaranteeing standards and the general health of the qualifications system and (b) the awarding bodies' individual responsibility for managing effective delivery of their own qualifications to students, schools and colleges;
• the awarding bodies and others with an interest can make representations directly to DfES on matters of qualifications policy;
• that application of the agreement is monitored, and that mechanisms exist for resolving inconsistencies or uncertainty about its application in specific cases.

I share the misgivings expressed in the Quinquennial Review about QCA's responsibilities for delivery of the key and basic skills qualifications and Key Stage tests, and recommend that these should be separated from QCA's other responsibilities and placed in the hands of a separate body. QCA should retain its regulatory oversight of these activities.

41. In making these recommendations, I am conscious of the extent to which these bodies work together formally and informally across a wide range of policy and delivery issues. This is a proper dimension to their relationship and plays a crucial part in helping to foster effective collaboration. A clearer delineation of roles and responsibilities should take care not to cut across the day-to-day working partnerships which are necessary to the smooth operation of the qualifications system.

Relevance for Northern Ireland and Wales

42. I have focused on the QCA and relationships within the English qualifications system. These recommendations apply only in that context. The institutions and their roles within the Wales and Northern Ireland systems are different. It is necessary that there should be a common understanding, and thus a joint approach across all three countries, about the regulators' roles and responsibilities in relation to those of the awarding bodies. My recommendations should be taken forward on that basis.

Fee structures

48. Standard unit entry fees currently range from £9.20 to £10, while late entries are charged at the standard rate plus £4.60, £9.40 or £10, depending on the board. For very late entries the additional charge ranges from £9.20 to £20, meaning that costs range from £18.40 to £30. There is in schools' and colleges' view no obvious correlation between the charges made and the service they receive. Competition regulation outlaws the possibility of the awarding bodies collaborating to standardise the level of fees they charge. The prices charged are a matter for the awarding bodies, although I note that the QCA has some statutory powers to cap entry fee levels. More significantly, differences in the types of service for which the awarding bodies charge and the pricing structure for those services make direct price comparisons very difficult, and complicate the administration for schools and colleges. Consideration should be given to ensuring greater consistency and transparency in pricing structures.

Administration

49. Progress has been made by the awarding bodies since the Guaranteeing Standards consultation in improving the commonality of their systems, but significant differences remain, particularly in the administrative process through which they communicate with centres. These differences often appear to have no clear justification and seem to be the result of custom and practice within the individual awarding bodies rather than of overriding operational need. I offer some examples of these below.

Entry procedures

50. The system for administering entries varies between boards. Advances have been made in recent years in standardising the terminology used, but there are still considerable differences in the codes used to identify candidates, series and syllabuses.

51. Not all of these differences are easily diminished, nor are they necessarily issues that the awarding bodies themselves can resolve. Some of the problems around the use of unique identification numbers for candidates, for example, arise from provision in the 1998 Data Protection Act, which also has a major bearing on the way educational data can be captured, stored, reported and exchanged. Efforts must continue to resolve these issues, though the process of doing so may not be quick.

52. Short-term progress does, however, seem possible in areas like the awarding bodies codes for units and examination sessions. It is unclear, for instance, why the GCE January 2003 examinations are given the code E IE03 by AQA, 1C by Edexcel and 1B by OCR. This complicates and extends the entry administration process. Similar inconsistencies are evident throughout, including in the format and provision of envelopes and labels and in the use of forms.

53. Over the longer term, important opportunities to simplify administration are presented by ICT. These are explored in paragraphs 145 to 164. The need is not to impose uniform systems on awarding bodies, but to simplify their interface with users. Standardising how centres input and amend their entry data would bring significant efficiency gains.

Issuing results

54. At present awarding bodies deliver results to centres in different formats. For example, one supplies results in alphabetical order, and another in candidate number order. Centres must then spend time cross-referencing information in disparate formats to collate results for candidates. Certificates for students also differ in the supplementary information they show. One awarding body, for instance, issues grades at unit level, whilst others do not.

Appeals procedures

55. Although the processes for making inquiries upon results for individuals or groups of candidates are common between A level awarding bodies, the awarding bodies' own appeals processes, which may be followed where the school or college remains dissatisfied, appear to differ significantly in the demands they make on schools and colleges.

56. I recommend that the awarding bodies work together and with QCA to undertake a systematic review of such differences in administration and take urgent action to eliminate unjustified differences.

The Joint Council

56. The Joint Council for General Qualifications (JCGQ) could do much to enhance commonality between the awarding bodies. It has already produced a wide range of common documentation and identified common procedures and guidance covering many aspects of the examination process. I have already referred above to the need to carry this work further, to standardise any aspect of awarding bodies' work and requirements where there is no good reason for differences to be maintained.

57. JCGQ has the potential to act as a self-regulatory body, defining and encouraging minimum standards of service and defining the way in which award standards are to be set, judged and maintained. Mechanisms already exist for this, though so far groups like the Compliance Committee have limited their activity to sharing common practice. I believe that standards of both service and awards could be greatly enhanced if work was extended into actively seeking to define and enforce common standards, in areas such as monitoring examiners, dealing with enquiries about results, reviewing awarding arrangements and, in consultation with QCA, placing strict limits on the late notification of changes to syllabus and assessment requirements. The latter is a particular problem for teachers and lecturers at present, adding significantly to the complications of delivering A level courses to students.

58. JCGQ might also provide a forum for enhanced co-operation between the awarding bodies - for instance in examiner training and the sharing of data more effectively during the awarding process - with potential benefits for the overall consistency and quality of the system.

59. I recommend that awarding bodies strengthen the self-regulatory role of JCGQ, and review the council's structure, to: " take forward the work recommended in paragraph 112 to improve commonality of administrative requirements between boards; " identify and take forward further areas where it might usefully self-regulate, such as defining minimum service standards; enhance co-operation between the awarding bodies in the awarding process.

60. Whilst I recommend that the JCGQ should be the vehicle for enhanced collaboration and commonality between the awarding bodies, I should make it clear that I consider that the work itself must be taken forward urgently. If the JCGQ cannot be strengthened in the way I envisage then its purpose must be seriously questioned. In these circumstances I recommend that the QCA and the other regulators should step in to progress this necessary work.

Implications for Wales and Northern Ireland

61. Students in Wales and Northern Ireland sit qualifications offered by English awarding bodies, while students in England and Northern Ireland take qualifications offered by WJEC. In 2002, for example, English awarding bodies received over 30,000 A and AS subject entries from students at Welsh centres, while WJEC had around 27,500 subject entries from students at English centres. This cross-border traffic of qualifications means that it is important that any approach to standardisation across boards is common to all three countries. My recommendations should be taken forward jointly.

The JCGQ represents the awarding bodies in all three countries. Any development of its role would need to be taken forward on a three country basis.