Ofqual Consultation: Final Entries to legacy GCSEs, AS and A levels Response from Sixth Form Colleges Association (SFCA) February 2016

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Ofqual Consultation: Final Entries to legacy GCSEs, AS and A levels Response from Sixth Form Colleges Association (SFCA) February 2016 The Sixth Form Colleges Association (SFCA) is the representative body of the 93 official or designated Sixth Form Colleges across England. Collectively, they educate approximately 150,000 16-18 year olds each year. They offer an extensive range of courses, both academic and vocational. Question 1 To what extent do you agree or disagree that students taking AS and A levels should have at least one opportunity to re-sit their exams in the specification for which they studied? A student s opportunity to achieve their qualification successfully should not be hindered by the Government s ongoing curriculum reforms. Students should be given the opportunity to re-sit their exams in the specification for which they studied. Question 2 To what extent do you agree or disagree that students re-sitting their AS and A levels in qualifications that have ceased to be accredited should be able to resit any of the AS or A level units they have previously taken (including controlled assessment units)? Question 3 To what extent do you agree or disagree that there should be an additional resit opportunity for legacy GCSEs in English, English language and mathematics (including the linked pair) in summer 2017? In September 2014, the Government made it a condition of funding for all post-16 institutions to deliver English and maths GCSE to those students that did not achieve a grade A*-C in these subjects at Key Stage 4. Since this time, we have seen a large increase in the number of students retaking these qualifications in Sixth Form Colleges and we expect this trend to continue in future years with the introduction of new and tougher specifications in these subjects. 1

The Department for Education released data in October 2015 on Level 1 and Level 2 attainment in English and maths by students aged 16-18 (2013/14 academic year) 1. It showed that Sixth Form Colleges outperform schools/academies and FE colleges on this measure 44.6% of Sixth Form College students achieved an A*-C in English in 2013/14 compared to 37.1% in schools and 7.1% in FE colleges. In maths, the figure was 30.8% compared to 22.3% in schools and 4.2% in FE colleges. Therefore Sixth Form Colleges have a proven track record in ensuring students pass these qualifications. We welcome the re-sit opportunity being made available in vember 2016 in legacy maths and English GCSE qualifications. We strongly advise Ofqual to provide an opportunity for students to re-sit in these qualifications in May/June 2017 for the following reasons: I. Two types of students requiring different support: There are two types of students entering Sixth Form Colleges each September - students that are on the borderline of a C/D and those that are borderline E or below in these 2 subjects. Both types of students require different support structures to enable them to pass. Students that are borderline C/D require general organisational support and extra support in particular topics. They are usually entered in the vember re-sit which allows them to focus their efforts on their main learning programme from January. Students that are borderline E or below require much more support and would benefit from a further 5-7 months preparation to achieve a grade C or above in the May/June exams. II. III. IV. 5-7 months progress plan: During those extra 5-7 months Sixth Form Colleges will be able to develop a progress plan that provides extensive support to students. This is something Sixth Form Colleges do already. For example, they provide one-to-one support, deliver workshops and arrange drop in sessions - all of which will enhance student chances to achieve a grade C or above in maths and English in the May/June 2017 exams. Vulnerable students: t offering re-sits in May/June 2017 will affect the most vulnerable students in the education system. The 2016/17 cohort may have failed their GCSEs in these qualifications at school and may do so again in the vember re-sit resulting to loss of confidence. These students will require the extensive support programme available in Sixth Form Colleges which will help students build their confidence and give them a higher chance of passing the qualifications in May/June 2017. New unseen specifications: If students fail the vember re-sit, they will be required to undertake the new reformed subject specifications. It is highly unlikely for these students to undertake a qualification with a new specification from January which is new, unseen, has more challenging content and requires them to develop new skills within a few months and to achieve a grade C or above. Furthermore, the new specifications have been designed to be taught over a period of 2 years which will be likely for all future cohorts except the 2016/17 cohort, further reinforcing the requirement for a May/June re-sit 2017 opportunity to be provided for these students. 1 Department for Education Statistical First Release: Level 1 and 2 attainment in English and Maths by students aged 16-18: academic year 2013/14, October 2015 https://www.gov.uk/government/statistics/level-1-and-2-english-and-maths-16-to-18-students-2013-to- 2014 2

V. Providing a better chance to progress onto Level 3 programmes and HE: Students that pass the qualifications in May/June 2017 will have a better chance to access Level 3 programmes the following year - September 2017 and therefore open up opportunities to study HE courses that may not have previously been accessible had they not passed their GCSE maths and English. VI. It is the fair thing to do: Removing the May/June 2017 re-sit opportunities will disadvantage a whole cohort of students from achieving their best possible grade. It is only fair to offer this cohort a final chance to succeed in the legacy GCSE qualifications. If students are not successful in the May/June 2017 re-sits, they can start the new specification in September 2017 focusing on new content. Question 4 To what extent do you agree or disagree that, with the exception of English, English language and mathematics (including the linked pair), there should not be a re-sit opportunity available for legacy GCSEs? Disagree A re-sit opportunity in GCSE Science will help those students wishing to progress onto HE courses with a minimum grade C or above entry requirement in Science GCSE. Question 5 Do you have any comments on our draft General Condition D9? Question 6 Do you have any comments on our draft saving and transitional provisions for legacy AS and A level qualifications in the first phase of reform? Question 7 To what extent do you agree or disagree that we adopt the same saving and transitional provisions, amended as necessary, in respect of all further legacy AS and A level qualifications, without further consultation? 3

Question 8 Do you have any comments on our draft saving and transitional provisions for legacy GCSEs in English, English language and mathematics (including the linked pair)? For the reasons explained in answer 3, the 2016/17 cohort should be given the opportunity to re-sit their maths and English GCSEs in May/June 2017. Question 9 We have not identified any ways in which our proposals on re-sits would impact (positively or negatively) on persons who share a protected characteristic. Are there any potential impacts we have not identified? Increasingly, Sixth Form Colleges have seen a rise in students with mental health difficulties. In a survey carried out by the Association of Colleges in June 2015 2, it reported that 66% of respondents (colleges) said that the number of students with mental health difficulties had significantly increased in the past three years. Moreover, colleges reported that exam pressures (60%) attributed to mental health conditions. By allowing only a re-sit opportunity in vember for legacy Maths and English GCSE, it will put undue pressure on these students. Removing the opportunity for legacy GCSE, AS and A level re-sits will also impact negatively on students on maternity or paternity leave. Question 10 Are there any additional steps we could take to mitigate any negative impact resulting from these proposals on persons who share a protected characteristic? For the reasons explained in answer 3, the 2016/17 cohort should be given the opportunity to re-sit their maths and English GCSEs in May/June 2017. This opportunity will support and enhance their future success and life chances. 2 Association of Colleges (AoC) survey on students with mental health conditions in Future Education, June 2015 https://www.aoc.co.uk/sites/default/files/aoc%20survey%20on%20students%20with%20mental%20h ealth%20conditions%20in%20further%20education%20-%20summary%20report%202015%20- %20FINAL.pdf 4

Question 11 Have you any other comments on the impacts of the proposals on students who share a protected characteristic? Question 12 Do you have any comments on the impacts of our proposals on students, schools/colleges and/or exam boards? The removal of the May/June 2017 resit opportunity will put undue pressure on college resources with the requirement to deliver new qualifications designed to be delivered over 2 years in a very short period of time. Deepa Jethwa Policy Officer 2 nd February 2016 5