Minutes of Access Consultation Forum meeting ACF(15)M1
Date and Time: Thursday 22nd January 2015 – 11:00-16:00 Venue: Meeting Room 4, Spring Place, Coventry, CV5 6UB Attendees: Julie Swan (JS), Ofqual (Chair)
Abi James (AJ), BDA By telephone: Amanda Hipkiss (AH), former Carolyn Presland (CP), CIE SENCO & PhD student Jenny Trotman Blake (JTB), researcher Pearson Andrea Baker (AB), BATOD Julia Pace (JC), CIE Clare Beesley (CB), C&G Paula Hannah (PH), CCEA Kala Parasuram (Kala P), IBO Peter Edwards (PE), CCEA Kenn Palmer (Kenn P), Welsh Sharon Williams (SW), UKAAF Government (item 6) Nick Lait (NL), JCQ Bronagh Campbell (BC),CCEA Niki Polydorou (NP), OCR Rory Cobb (RC),RNIB Sian Bewick (Sian B), FAB Karen Wells (KW), Ofqual Sue Barnbrook (Sue B), AQA Steve Hickmott (SH), Ofqual Sue Flohr (SF), BDA Tudor Thomas (TT), WJEC
Apologies: Lisa McMahon, CCEA
Item 1: Preliminaries Item 2: Minutes of the meeting of 10 October 2014 – approval and matters arising – ACF(14)M3 1. The minutes of the previous meeting were drafted as action points only. Matters arising 2. All previous actions were closed, except for those set out below:
Actions carried forward from previous meeting - DfE meeting on 19 November 2014 to discuss issues faced by autistic candidates when taking General Qualifications. ACTION 1: Kala P to send past papers to Mark Snow, Ofqual.
Previous Action 1: Sue B confirmed that the report about use of BSL has been drafted and she is waiting for Ofqual to provide details of where to send it. ACTION 2: Sue B to send draft report to [email protected]. Sue B explained that requests for the use of BSL in answering assessments at GCSE and A Level should be considered by awarding organisations rather than ‘approved’ by access arrangements on line because of the associated risks. NL confirmed that requests should be considered on a case by case basis as much depends on the subjects being taken. As it only affects a small number of candidates such an approach is manageable.
Previous Action 3: NL informed the Forum that JCQ was not planning on producing further guidance, and noted that the JCQ booklet is reviewed each year anyway. Previous Action 5: Await response from Patricia McDonald re: sharing details of the information made available to candidates through specifications etc. about justifiable limitations on accessibility resulting from qualifications design.
Previous Action 6: Ofqual to centrally hold electronic copies of agendas, minutes and papers relating to ACF meetings that will be available to the forum, on request.
Previous Action 8: Update found under item 6 below.
Previous Action 12: terms of reference & membership. ACTION 3: Forum to advise if there are any proposed changes to representatives attending ACF or whether other organisations should be invited.
Previous Action 13: Lisa McMahon liaised with the forum (Lina Read & others) over details of a query about the qualifications needed for specialist assessors. Item 3: Update on qualifications reform (a) GCSEs and A Levels regulated in England 3. JS briefed the Forum that Ofqual was moving ahead with reform of GCSEs and A Levels and publishing various consultations, and expanded on the following two areas that were most relevant to the Forum:
The exam boards are continuing to trial different approaches with schools for the new GCSE English Language spoken language assessment that will be separately reported, as it is for current GCSEs (A*-G). NP explained that there has been some support for audio visual recording, although not all parents were comfortable with this due to cultural issues.
For new GCSE science there is a proposal for students to undertake practical work and for exam papers to have some marks allocated to show that students have drawn on their experience of this practical work. However, it is not proposed to directly assess a student’s ability to do practical assessments. JS encouraged ACF members to look at Ofqual’s open consultation on the future assessment of practical work in GCSE science. 4. JS reminded the Forum that Ofqual has moved to the GOV.UK website and that current consultations are now found here rather than on Ofqual’s old website. Search GOV.UK website for ‘consultations’ then filter the search to ‘Ofqual’ under the ‘organisations’ heading to find the full list of open Ofqual consultations. ACTION 4: Link to where archive documents from Ofqual’s old website can now be found is at: http://webarchive.nationalarchives.gov.uk/20140813095715/http ://ofqual.gov.uk/ (b) Reform in Wales 5. Kenn P briefed the Forum on the key features of qualification reform in Wales:
Kenn P thanked those ACF members who contributed to the ‘Fair Access by Design’ revisions. A response will be circulated to those who contributed to check for errors etc, and then it is intended to publish ASAP.
Kenn P told the Forum that an informative newsletter is available, ‘DYSG’ (meaning ‘learn’ in Welsh) that anyone can sign up to receive.
Qualifications Wales (who will be the new independent regulator of qualifications in Wales) is due to be functional by September 2015. Exact timing will depend on the passage of the Bill through the Welsh Assembly (the first stage of the Bill was being read in the Welsh Assembly on 22 January 2015). Kenn P explained that A and AS will remain coupled and GCSEs may be unitised if there is a strong rationale. Content is likely to be similar although, for example, English Literature will have approximately 80% same content but will include Welsh poets rather than American poets. 6. In discussion, the following points were made:
Qualifications Wales will be responsible for regulating all qualifications (other than higher education). There are still some grey areas, such as licences to practice.
Whether qualifications are modular or linear should not require changes to the Terracotta Book as there shouldn’t be any impact on access arrangements.
WJEC will be the sole provider to maintained schools in Wales, unless it doesn’t offer qualifications in a particular subject. Item 4: JCQ/FAB update 7. NL confirmed that JCQ are planning to make some changes to the way its members receive and consider requests for Reasonable Adjustments to reduce administration and bureaucracy for centres, and another change relating to risk. JCQ aims to publish its requirements by July/August 2015, and confirmed that no changes will relate to this academic year 2014/15. 8. Sian B confirmed that FAB continues to consider how it can promote good practice by its members. Item 5: Update on review of specifications under s96 of the Equality Act 2010 - (ACF(15)1): 9. SH briefed the Forum on Ofqual’s proposals to review its Section 96 specifications: Ofqual’s specifications set out the circumstances when awarding organisations are not subject to a requirement to make reasonable adjustments. It also lists the qualifications, prescribed by DfE, to which these specifications apply.
The paper sets out: Ofqual’s proposals for reviewing the existing specifications; an alternative approach to making specifications and proposals for asking DfE to update the list of qualifications. 10. In discussion, the following points were made:
Despite differences between qualifications in England and Wales, it is desirable to have consistency between the two where possible, whilst noting that the specifications may not be identical in the two countries. ACTION 5: Welsh Government to provide contact details for Section 96 to Steve Hickmott, Ofqual.
Members queried the list of qualifications in the paper, in particular the proposal to include all qualifications from the ‘other general’ RITS category. It was felt that this category was too broad and it would be preferable to list individual qualifications. It was also noted that it would be helpful to have additional clarity in some of the current categories, for example which Entry Level subjects are included.
ACF members believe the current approach to setting specifications, whereby specific adjustments are listed, is preferable to the criteria approach outlined as an alternative in the paper. The current approach provides clarity for awarding organisations and centres; a less prescriptive approach could lead to inconsistency between awarding organisations. It was noted, however, that the criteria are helpful in understanding why specifications are made and could be included alongside the specifications.
Members believe that the existing specifications are effective. There may be some minor changes needed, for example, to take account of changes to qualification structure, but members do not believe major changes are needed.
JCQ’s existing reasonable adjustment requirements are based on Ofqual’s specifications. The timelines for updating JCQ’s requirements and the need for Ofqual to consult mean it would not be possible for awarding organisations to implement changes for the 2015/16 academic year. Any changes would need to take effect from 2016/17, meaning changes being agreed by late- 2015. It was noted that any changes will need to reflect both existing and reformed qualifications being available at the same time. ACTION 6: ACF members to provide feedback on the existing specifications and the list of qualifications to [email protected]. Item 6: Update on electronic papers, e-assessments and assistive software issues - ACF(15)2 11. Two papers were introduced by SW under this item. The first was the UK Association for Accessible Formats (UKAAF) minimum standards: Accessible PDFs for Assessment that aims to set minimum standards where PDFs are used to ensure that they include certain features. The second was UKAAF: Consultation Summary of Minimum Standard for Accessible PDFs for Assessment:
The documents set out the standards that awarding organisations should meet when producing accessible PDFs and the responses to the consultation UKAAF ran when developing these standards. These are published on the UKAAF website. 12. In discussion, the following points were made:
There was a discussion about what was technically possible for accessible PDFs in practice. Awarding organisations reported that they had raised concerns as part of the consultation process that the standards set out were not technically possible. SW reported that UKAAF was aware of these concerns, but believed all standards were deliverable.
Awarding organisations were also concerned about the document being referred to as minimum standards, when it was felt that best practice may be a more accurate description of what the document contains.
Awarding organisations agreed in principle with having minimum standards for accessibility of PDFs and reported that they worked to ensure all materials are accessible. However, the nature of some subjects and differences in the technology used in schools mean it is unrealistic for all PDFs to meet these standards. SW confirmed that the standards in the document may be possible for some subjects, but not all subjects. Awarding organisations felt it would be helpful for this to be made clearer in the introduction to the document.
The awarding organisations stated that even where minimum standards were met, it was difficult for them to guarantee that the accessibility features of the PDF documents will work in all instances. This may depend on the technology that each school uses, and awarding organisations suggested that schools need to work with past papers to see if the PDFs work with their technology in practice. It was noted by SW that SQA thought it was close to achieving the standards at level 1, and some awarding organisations go beyond these standards so consider these standards to be watered down. However, it was observed by the awarding organisations that SQA’s processes for handling accessible PDFs were different from those used by awarding organisations in England. SQA processes requests for accessible PDFs as modified papers, which is made manageable by the size and nature of the market it operates in.
Awarding organisations reported that due to the volumes (of students and papers) involved, the complexity of meeting these standards for all papers would require fundamental changes to assessment production processes at significant cost. It was discussed that this was a Responsible Officer issue and the representatives from awarding organisations who were present did not have the level of authority to sign up here.
UKAAF intends to produce additional guidance to accompany these minimum standards. In the next couple of months, further drafts of guidance will be circulated. SW requested feedback from awarding organisations on specific parts of the standards that they may find difficult to achieve. 13. The final paper considered was a proposal for standards for reading aloud maths notation by BDA. The October 2014 ACF meeting had discussed the need for guidance on how notation in maths should be read aloud. There were concerns that reading mathematical symbols aloud (with or without technology) is not always appropriate, as in some cases, decoding the symbol itself is part of the assessment. Not allowing symbols to be read aloud however means that some candidates with reading difficulties could be penalised, where this is not part of the assessment criteria. 14. In discussion, the following points were made:
Existing JCQ guidance does not allow symbols to be read aloud. In maths, the JCQ arrangements allow a reader to point to the symbol, but not decode it. These requirements are designed to maintain the integrity of the exam where decoding the symbol forms part of the assessment.
It was noted that some groups believe the existing JCQ requirements are not sufficiently clear. There may also be instances where a student with a visual impairment cannot see the symbol being pointed at.
In cases where a centre is not clear about the use of a reader in maths, they should contact the relevant awarding organisation. It was noted that without common guidance, it may not be possible to ensure centres are given consistent advice in all cases and across all awarding organisations.
The data awarding organisations collect cannot identify cases where a reader is used in maths, or where reading aloud of symbols has been queried by centres. Awarding organisations do not believe this is an issue they are contacted about regularly.
It was agreed that it may be helpful to provide further guidance in this area. Any guidance would be owned by JCQ and would be a stand-alone document; it would not be incorporated into the JCQ Access Arrangements and Reasonable Adjustments document. Guidance would need to be agreed with awarding organisations’ maths subject specialists.
The paper provided examples of how the use of a reader could work in maths. It was agreed that awarding organisations would review draft guidance, which would need to include more complex symbols and formulas than are in the paper tabled. If agreed, it could be adopted by the JCQ awarding organisations. The guidance should be based on the new maths specifications, meaning any guidance would be for the 2016/17 academic year. ACTION 7: AJ to draft and share proposed guidance with awarding organisations for comment. Item 7: 'Statistical Release - Access Arrangements for GCSE and A Level: 2013/14 academic year' 15. JS introduced Ofqual’s recently published report on access arrangements statistics and invited comments. The following points were made during the discussion:
It was noted that in table 3 (page 21) the category of ‘other’ access arrangements had a poor approval rate. Examples given were a request from a student with autism who asked for their dog to be present to provide a calming presence and a request for classical music to be played. One application that was not allowed was a mother requesting for her baby to be in the exam room so that she could carry out feeding.
Ofqual wrote to awarding organisations to seek their views on the statistics when they were published. Awarding organisations noted that although they had written back to Ofqual, they haven’t received a response and would be keen to know Ofqual’s view of the figures. It was suggested that if Ofqual wanted information about why applications for access arrangements were being requested then Ofqual should talk to schools, Ofsted, local authorities etc. It was discussed that one of the reasons for an increase in applications could be due to the new ‘whole school approach’ whereby senior leaders in schools become involved. Or perhaps there is now increased awareness of access arrangements being available and this means that students are now better able to get the help that they need. It was requested that any feedback to awarding organisations about Ofqual’s view of the figures could be shared with other ACF members. ACTION 8: Ofqual to provide feedback re: statistical release Access Arrangements for GCSE and A Level: 2013/14 academic year. Item 8: Oral Language Modifiers 16. JS introduced AB from BATOD who shared details about a Grammar school where deaf students are taught orally and where 20 students are proposing to take GCSE exams. The OLM requirements mean that the school will need to provide 20 OLMs overseen by 20 invigilators (1 per OLM) in 20 rooms, and this is practically impossible for the school to provide. 17. The awarding organisations explained their concerns about the high degree of risk associated with OLMs, and the scope for malpractice. 18. It was discussed that the school could propose some alternative options for consideration by the awarding organisations:
Is there scope for agreement on the school providing more than 1 but less than 20 OLMs.
Could the school stagger the conduct of exams and hold students in isolation; whether this is practical depends on the length of the exams and the number of students taking each subject. Item 9: Burning issues from members 19. RC requested that awarding organisations consider making modified print papers in PDF format available to centres. Awarding organisations reported that some already do this as standard and that this is being considered by JCQ for 2015/16. 20. RC had contacted Ofqual to report that RNIB had been told by a centre that an awarding organisation offering an online assessment had refused to provide a hard-copy of the assessment as a reasonable adjustment. Awarding organisations reported that generally, provision of hard- copies is likely to be a reasonable adjustment, unless the online element formed part of the assessment objectives. These requests are considered on a case by case basis by awarding organisations, so the issue would need to be taken up with the relevant awarding organisation. ACTION 9: Ofqual to respond to RNIB query. 21. It was noted that given the likelihood of access arrangements and reasonable adjustments required in National Assessments also being required for GCSE and A levels, it would be helpful to establish links with the ACF. Analysis of data from National Assessments may help to identify and explain trends in the statistics for GCSEs and A levels. ACTION 10: Link to information on Standards and Testing Agency website about access arrangements in Key Stage 2 tests below: https://www.gov.uk/key-stage-2-tests-how-to-use- access-arrangements Item 10: Any other business 22. There were no items of AOB.
Circulated to Forum members in draft, June 2015