Education Bill: consultation analysis

The independent analysis by Wellside of responses to the consultation on the Education (Scotland) Bill, commissioned by the Scottish Government.

2. Establishment of a New Qualifications Body

The consultation paper sought views and feedback in relation to four of the recommendations from the Muir Report related to the creation of a new qualifications body, as follows:

1. A new qualifications body should be established. This new body should be an executive Non-Departmental Public Body (NDPB).

2. It should take on board SQA’s current awarding functions, chiefly the responsibility for the design and delivering of qualifications, the operation and certification of examinations, and the awarding of certificates.

3. Income-generating contract services currently provided by SQA for organisations, governments and businesses, should be included in the remit of the new NDPB. SQA’s current international work should also be part of the NDPB’s remit.

4. The governance structure of the proposed qualifications body should be revised to include more representation from, and accountability to all learners, teachers, practitioners and the stakeholders with whom it engages.

A Diversity of High Quality Qualifications

Respondents were asked to comment on the second and third recommendation set out above, i.e. that the new qualifications body (NQB) should take on the SQAs current awarding functions, and income-generating and international work. The consultation paper set out the Scottish Government’s vision around the development and delivery of qualifications and proposed that the NQB would be responsible for ensuring all these activities were delivered effectively as part of its qualifications provision.

Q1: What changes should the Scottish Government consider in terms of how qualifications are developed and delivered that you think would improve outcomes for Scotland’s pupils and students?

A wide range of factors were discussed by respondents, often in combination, rather than one single change being suggested.

While the question focused on the development and delivery of qualifications, individuals often tended to discuss which specific elements and skills should be better accommodated/recognised within the assessment or qualification structure, the outcomes that future qualifications needed to deliver, or their preferred approaches to operational issues related to the curriculum, assessment process or class profile. A few stressed the interconnected nature of the curriculum and assessment/qualifications and felt that making changes to just one element would not bring the desired effects of raising standards/outcomes, but rather a holistic approach would be required.

Key Areas for Greater Recognition/Development

Respondents discussed the need for a range of pupil and student centred qualification pathways, and to increase emphasis, recognition and value placed on a range of aspects. Issues commonly discussed across both written responses and events included:

  • greater recognition of wider, more practical, less academic based learning/ experience/achievements, such as vocational qualifications, community based learning, volunteering and work experience, and schemes like Duke of Edinburgh Awards, John Muir Award, and Youth Achievement Awards;
  • greater focus on the four capacities (i.e. successful learners, confident individuals, effective contributors, and responsible citizens), as well as a wider range of skills, including resilience, self-motivation, communication, negotiation, collaborative/team working, interpersonal skills, enhanced people skills, budgeting/financial management, ethics, logic and critical thinking, problem solving, practical and work related skills, enterprise and leadership;
  • need to deliver parity of esteem and access between different qualifications (including but not limited to academic and vocational qualifications), as well as ensuring a wider range of vocational qualifications are available in schools;
  • requiring and evidencing real thinking and learning in assessments, as well as skills and knowledge, and move away from “rote learning” and exams being simply a “memory test” or recall exercise; and
  • move away from “teaching to the test” and having the exam lead the learning/ course structure and content:

“It is important that qualifications, therefore, reflect the curriculum, and approaches to learning, teaching, and assessment in the senior phase rather than driving them.” (Trade union/professional representative body)

It was argued that all schools needed to offer a wide, varied and rich curriculum (or establish partnerships, consortia and digital arrangements to do so), whilst also ensuring equity of access and delivery. It was felt that more needed to be done to deliver parity of esteem between different types of qualifications, and that systems needed to be developed to ensure those attending smaller and/or more rural establishments could access the same wide range of subjects/qualifications as their peers in other areas. It was felt important that qualifications were accessible for neurodivergent pupils and students, and those with additional support needs. Others suggested it would be important to ensure that course material and assessment methods were culturally sensitive and would not disadvantage certain pupils/students, e.g. those from disadvantaged areas/backgrounds, minority groups, etc. A few also stressed that the full range of qualifications should be available to home educated young people.

Collaborative Approach

Another key issue discussed by respondents was the need to ensure that course content and assessment were relevant and adaptable to real life, the future workplace, and/or further/higher education. It was largely felt that the best way to achieve this would be through collaborative working between the NQB and partners and stakeholders, with event attendees suggesting stakeholders needed to be involved at a more practical level in the design of qualifications.

Many respondents stressed the need for the NQB to develop and maintain consultation with/input from a wide range of stakeholders, including: teachers; subject specialists/advisors; colleges and universities; national bodies; learners and parents/carers; and employers. More specifically, it was suggested that there should be collaboration with and between awarding bodies, teachers/educators, colleges and universities, and employers to develop suitable processes and individual qualifications. Several organisations felt this should be done alongside the consideration of Local Market Intelligence (LMI) information:

“You need to take more input from the expert teachers on the ground, as well as employers and further and higher education providers on skills gaps.” (Individual)

“Involve key stakeholders, including young people, teachers and lecturers, employers, and industries, in the development and evaluation of qualifications. This ensures that qualifications meet the practical needs of all involved parties.” (Local Authority)

Widespread communication and awareness raising regarding any changes and new qualifications were also said to be needed (discussed in both written responses and the events), targeting all stakeholders and wider society to provide clarity and ensure that everyone would understand and value the range of qualifications on offer. This was considered particularly important for schools and the users of qualifications, including further and higher education and employers:

“Work must be done with post-school destinations such as industry and universities in particular to make sure there is a common and shared understanding of any new qualifications and their value.” (School/Early Years)

“Universities and colleges must be made part of the conversation - particularly in their response to the provision of more technical-based qualifications which are highly in demand - and encouraged to embrace a diverse range of qualifications that feed into a multitude of destinations. These changes must be embraced by not only by tertiary education and, importantly, by employers, but also by the general public.” (Trade Union/Professional Representative Body)

Holistic Approach Needed

It was stressed that any changes to qualifications (and assessment) needed to be seen alongside curriculum design and review and pedagogy. A holistic approach was said to be required if reforms were to be successful. Regular audits were also suggested of both the curriculum and assessments, with them being modernised where necessary, and updated to reflect societal, technological and workplace/ industry developments. Again, it was stressed that teachers needed to be involved in such updates. Further, the range of qualifications should be reviewed to remove outdated and less suitable courses and replace these with alternatives which are more suited to developing relevant skills and economic/industry needs.

Qualification Structure

Some (including a sizable proportion of organisations) expressed support for the recommendations set out in the Hayward Report, and the use of the Scottish Diploma of Achievement (SDA) in particular. It was argued that this should be used to develop reforms around qualifications, and that work needed to begin to implement the recommendations:

“The vision and recommendations of Louise Hayward's report should be robustly recognised and be used as the guiding principle of the development of qualification in the future. The views of the nation have already been gathered and presented in the report and its recommendations are strongly supported in terms of the qualifications reform we wish to see.” (Local Authority)

Others also noted support or recommended further consideration of the findings from the Stobart Report and Withers Report. There was also general support for the use of Scottish Credit and Qualifications Framework (SCQF) levels for mapping learner pathways and developing a linked and cohesive framework:

“Recognition of a wider range of qualifications, particularly those which do not rely on 'high stakes' assessments, should become more prevalent to accommodate the wide range of ways in which young people demonstrate their understanding of subjects and knowledge. I support the view of having the SCQF framework as the primary measure of attainment for all qualifications.” (Individual)

Other suggestions, related to specific qualifications, were also outlined. This included that certain qualifications (particularly National 5s and Highers) should be conducted over two years (rather than one), or that course content should be adjusted to ensure that depth of learning is possible within the one year timeframe. A few also felt that National 4s and National 5s should be graded within the qualification (much like previous Standard Grades) to be motivational for pupils and more informative to employers regarding ability. It was also suggested (across both written responses and events) that pupils should be able to cover two levels to aid progression, provide challenge and allow pupils to strive for higher levels without risking achieving no qualification, and thereby reducing the risk/need to drop between qualifications (e.g. from National 5 to National 4), which was considered demoralising. Similarly, it was felt that National Qualifications (NQs) and National Progression Awards (NPAs) should be better aligned to allow movement between the two. Others suggested changing to alternative qualifications, such as returning to Standard Grades, adopting GCSEs or a baccalaureate-type qualification.

Practicalities of Reform

Funding for schools and education was noted as an issue (here and throughout the consultation), with respondents stressing that they needed to be funded and resourced appropriately, both to deliver the current curriculum and meet the needs of all learners, and to develop and action any changes.

It was also stressed that sufficient lead in time would be required for schools to familiarise themselves with any new approaches. As such, content and assessment criteria needed to be provided to schools in ample time and well ahead of courses launching. It was also suggested that additional support would be needed in the way of guidance documents and subject specialists producing materials, assessments and model answers. Investment in a range of professional development opportunities for teaching professionals would also be required, as well as updates to the Initial Teacher Education (ITE) programme. Further, any guidance and information sharing needed to happen ahead of the start of any new school year and not be delivered after courses had begun.

Other Comments

A minority of respondents also considered the international element of the current qualification provision. While several felt that the NQB should continue to provide qualifications to the rest of the UK and internationally, a few suggested that a breakdown of such commercial activities and income was required to inform whether this role should be retained by the NQB, with concerns expressed that this may undermine the public service side of the role.

A few respondents also raised concerns over the implications and possible conflicts of interest between the proposals for the NQB and other awarding bodies. It was suggested that it may be inappropriate for the NQB to drive and shape all qualifications in Scotland as many other awarding bodies also currently existed - it was felt that such an approach would create a monopoly, be cost prohibitive, and reduce the involvement of stakeholders.

There were also a few respondents who were concerned that the NQB proposals as presented represented little/no change from the functions of, and delivery by, the SQA. Therefore it was felt that this would not result in any real meaningful change:

“What you have described here is basically the legacy/status quo SQA.” (Individual)

Excellence in Learning and Teaching

In establishing a NQB, the Scottish Government agreed with Professor Muir’s recommendation: “The governance structure of the proposed Qualifications Scotland body should be revised to include more representation from, and accountability to all learners, teachers, practitioners and the stakeholders with whom it engages”.

In order to achieve this, the consultation set out three key proposals, as follows:

  • to introduce a requirement that the Board that oversees the qualifications body must have individuals on it with current practical experience of providing learning and teaching for a qualification. For example, to include at least one teacher and at least one college lecturer on the Board;
  • to create a dedicated Committee as part of the organisation’s decision-making structures to provide views on behalf of the teaching professions. This Committee could be made up of practising teaching professionals, representatives such as professional associations and teaching trade unions, and specialists in teaching practice and pedagogy; and
  • the qualifications body should develop a specific user “Charter” for the teaching professions in collaboration with them. This Charter would serve as a way to provide clarity on what the teaching profession should expect from the qualifications body when delivering qualifications and working with them.

Q2: How best can the Scottish Government ensure that the views of teaching professionals are taken into account appropriately within the new qualifications body, and do these proposals enable this?

There was strong support for teaching professionals to have an input to the make-up and delivery of the NQB. Generally, the proposals for the Board, an advisory Committee and the introduction of a Charter were welcomed, however, there were considered to be some limitations.

Greater Teaching Professional Representation Needed

It was widely felt (across written responses and in events) that more than one teacher and one lecturer would be needed on the Board and that frontline teachers/ lecturers should be allocated to the Committee in sufficient numbers in order to be effective. Indeed, several respondents suggested that the majority of the Board and Committee members should have recent pupil/student facing teaching experience. Respondents were particularly concerned that having just one teacher and one lecturer voice on the Board would mean it would be easy to override or ignore their views, and/or that it would be impossible for them to adequately represent all teaching professionals:

“Both the teacher advisory body and the inclusion of more teachers on the board of any future qualifications body will be a great step forward. However, to propose that the board only has one member of the teaching profession is ludicrous... The board should, ideally, have a majority of teacher members from all levels including senior management. Only then will it have legitimacy and reflect the views of the people who have the expert knowledge in assessment matters.” (Individual)

It was stressed that a larger number of teachers and lecturers were needed on the Board to ensure representation of a wide set of experiences/perspectives. Similarly, it was argued that the profile of Committee members needed to be structured to provide wide representation. In both cases, it was felt that teaching professionals admitted to the NQB’s governance structures needed to represent a variety of subject area; geographic and SIMD locations; demographic backgrounds; pupil ages, stages and needs; from within Gaelic Medium Education (GME); denominational and non-denominational settings; at different career stages; etc. It was also argued that those with current/recent classroom/teaching experience needed to be involved, with concerns expressed that those who had not been in a classroom for some time could be “out of touch” and create unrealistic expectations. Some suggested that teachers/lecturers should only be involved on a fixed term (maximum of five years) or rotational basis in order to keep input fresh and frontline teaching experience up to date and relevant:

“The profile of any new Board and Advisory Committee must have representation from various educational establishments and various levels, disciplines and geographical regions. Membership of any such groups must be regularly reviewed to allow different voices to be heard in order that these groups remain relevant and credible. The Board must have members that are actively teaching and not solely those with practical experience as outlined in the consultation paper.” (Local Authority)

Further, it was felt that “new members” were needed as part of the NQB, and not just the same people in a “rebadged” organisation:

“Simply re-employing the same staff under a shiny new name won't fix the problem. You need new people with new ideas.” (Individual)

All engagement with teaching professionals, including them sitting on the Board or as Committee members, or via the use of additional/alternative engagement methods (as outlined in Chapter 4), were said to require dedicated and protected time and resources to be made available. This would be required to free up teachers and lecturers from teaching (without having a detrimental impact on classroom delivery) and/or to allow them to contribute to consultation and engagement activities during the working day.

Committee Should Have Influence

There was a widespread sense among respondents that, in the past, the profession had often been asked to contribute their opinions, but were left with a perception that their feedback had been ignored, not acted upon, or overridden by other views. As such, concerns were expressed over the nature and level of influence of the proposed Committee, with respondents worried this could simply pay lip-service to the profession’s views rather than providing real influence in the decision making process. It was felt that teaching professionals must be listened to, their feedback acted upon, and importantly, they should be informed of any actions or outcomes resulting from consultation. Indeed, several responses focused on communication between the NQB and the profession, stressing the need for practitioners to be kept up to date with developments, and informed well in advance of any changes:

“The workforce need to be able to see that views expressed have been taken into account.” (Trade Union/Professional Representative Body)

Further, several respondents (including those attending events) suggested that the current proposals outlined the mechanisms by which teaching professionals could provide feedback to the NQB, but did not provide detail or reassurance about how effective their voice would be, or what structures, if any, would exist to ensure advice was taken on board/implemented. The proposals were also said to lack detail about how the teaching profession could meaningfully input to the development of new syllabuses, and what could be done should the NQB fail to deliver on the requirements of the Charter:

“The proposals include reference to the creation of a Charter which would set out what teaching professionals could expect from any new agency; the proposals, however, say little or nothing about what a teacher, department, school or local authority could do if the provisions of the proposed Charter were not met. In effect, the proposals do not seem to offer a convincing way in which the views of teaching professionals can be taken into account by any new agency… A commitment to operate in such a way, recognising the expertise and experience of teachers, is more likely to provide them with opportunities to influence the conduct of any new agency rather than tokenistic representation on its Board.” (Third Sector)

Wider Representation

While involving teaching professionals (i.e. teachers and lecturers) was considered important, several individuals and organisations cited other professionals who they believed should be included within the NQB’s Board and Committee, including:

  • a wider range of those delivering qualifications, including independent and third sector training providers, adult and community learning provision, the youth sector/Youth Workers/Youth Awards representatives, the SCQF Partnership, as well as prisons, secure settings and workplaces;
  • primary school/Broad General Education (BGE) teachers and early learning and childcare (ELC) practitioners;
  • professional representative bodies and teaching unions - although both were contested, several respondents indicated that staff on representative bodies tended not to be actively teaching in classrooms and so could be “out of touch”, while unions represented teachers interests, not the needs of young people or education more generally;
  • local authorities;
  • educational psychology;
  • specialists in support for learning and special educational needs and disabilities (SEND);
  • representation from the GME sector and those with experience in immersion education;
  • teacher educators; and
  • a range of end users, including universities, employers, industry/trade bodies.

Limitations and Non-Supportive Views

It was suggested across both written responses and in the events that more detail was required around the purpose of the Board, the roles, responsibilities and functions of the Board and Committee, how the Committee would operate and how it would differ to the SQA’s existing Advisory Council/Committee, and how the Board and Committee would interface. Specifically, the proposals were said to lack terms of reference, as well as details about reporting structures, who would appoint Committee members, the relationship between the Committee and the Charter outcomes, and how greater accountability and transparency would be achieved. It was felt that such information was necessary to determine how effective the governance structures would be. It was also felt that more detail was required about the nature and content of the Charter before respondents could comment on this, with a few suggesting this element may not be necessary.

Those who disagreed, or questioned the likely impact of the proposals generally noted that the new body sounded very similar to the status quo and way that the SQA operated, therefore they struggled to identify how this would make any real impactful difference. It was felt that additional committees and oversight was not necessary, but rather a meaningful change in staffing, operation and collaboration/ communication with the profession was required.

It was also argued, by a few, that the needs of employers and the economy was paramount in developing education and therefore, teachers voices should not necessarily be treated as the most important within the system.

Involving Scotland’s Pupils and Students in Decisions that Affect Them

In line with Professor Muir’s recommendation outlined at Q2, the consultation document also proposed that the new qualifications body be set up to provide clear and meaningful roles to those studying for qualifications to shape and influence decisions relating to qualifications and assessment made by the body. Again, three key steps were set out to achieve this:

  • the Board should include members that can specifically reflect the views of those studying for qualifications;
  • a dedicated Committee be established as part of the organisation’s formal decision-making structures. This Committee could be made up of those currently or recently studying for different types of qualifications; members of organisations that advocate for different pupils and students; and specialists in pupil and student engagement; and
  • the body must develop a specific user “Charter” for pupils, students and their advocates in collaboration with them. This will set out the expectations they should have of the organisation and is intended to ensure qualifications and how they are delivered meet the needs of those seeking to achieve qualifications.

Q3: How best can the Scottish Government ensure that the views of pupils, students and other learners are appropriately represented within the new qualifications body, and do these proposals enable this?

Most organisations were largely supportive of involving pupils and students in the NQB generally, and of the three specific proposals. However, views from individuals were more mixed.

Support for Learner Involvement

Many were in favour of the proposals, with respondents indicating that these were fair, appropriate and should deliver the desired representation and input from pupils and students. While it was argued (by written respondents and those attending events) that pupils and students should be involved throughout, again, many of the same caveats were outlined as noted at Q2 - i.e. that wide enough representation was needed on both the Board and within the Committee to include a range of social, economic and demographic backgrounds, ages and educational settings, stage of involvement with qualifications, geographic areas (including international qualifications), to ensure that neurodiverse, disabled, care experienced, young carers, at risk and other vulnerable learners are included; that the learners voice be truly impactful and not tokenistic; and that feedback regarding the impact and outcomes resulting from the pupil’s and student’s contributions should be provided. Several respondents noted that membership on both the Board and Committee would need to rotate frequently so that learners experience remained up to date. Others felt that it would be important for people who had recently completed a qualification (within four years) to be involved in the Board/Committee as they could provide recent experience as well as an understanding of the impact/value of the qualification. Many also stressed the need to ensure that hard to reach learners, and those who would less typically seek such a role, would be encouraged and supported to participate:

“It is essential that the involvement of young people is meaningful and not tokenistic. Young people who are to be involved in the proposed governance structure must represent the voices and views of a range of learners, including those in urban and rural settings and those with lived experience of sitting qualifications. This should include those studying a for a range of qualifications, including Foundation Apprenticeships and adult learners.” (Local Authority)

Several respondents indicated a lack of clarity over whether the proposals intended to ensure pupils and students (i.e. children and young people) were present on the Board directly, or if other (adult) representatives would be used. Most suggested that pupils and students themselves should be given this responsibility. However, it was also suggested that pupils and students may require capacity building, training, support and guidance in order to fully and meaningfully participate, to gather views and represent all pupils and students on the Board and Committee.

Additional/Alternative Engagement Methods

While seeking the views and input from pupils and students was considered by most to be highly important, the preferred mechanisms for doing so varied. Some wanted to see the current proposals supplemented by additional engagement activities to allow a wider range of views to be fed into the NQB/Committee/Board. Others felt the current proposals were tokenistic and should be replaced by alternative measures to allow more/all pupils and students to contribute.

Concerns Regarding the Proposals

Other respondents, however, were unsupportive or expressed concerns with the proposals. Largely, it was felt that it would be difficult to ensure that such a small number of pupils and students on the Board or Committee could adequately represent the views and experiences of the full range of pupils and students, both across Scotland and internationally. It was felt that the proposals would simply “pay lip-service” to pupils and students rather than allow any meaningful and representative input. Several were concerned that the voices of a few individuals (who may bring their own biases and agenda) would influence changes for the many without truly representing or considering their views or experiences:

“I have major concerns around this. With teachers there are bodies which seek to represent the views of all, this is not so with young people. The voices of the few will be heard and influence the outcomes of many.” (Individual)

“Spokesperson won't work as it's just the loud/confident kids every single time across the country. You need to hear from the quiet/ forgotten kids who are struggling” (Individual)

Some felt that children and young people lacked the wider knowledge and experience to understand and comment on qualifications, particularly the needs of work or higher education. It was felt that they would struggle to make informed, realistic and workable suggestions. Even where respondents supported pupils and students being involved in an advisory capacity, several felt that the decision making powers should be retained by trained and qualified adults. A few also felt that children and young people’s views were often heavily influenced by their parents, while others argued that the needs of society, the economy and employers should be paramount, not the views of pupils and students.

As per comments about teacher involvement, similar concerns were again expressed in relation to the effectiveness of a Charter and the Committee. Respondents (both those providing written responses and event participants) noted that no detail was provided in relation to accountability, measures of success, how the interplay between teacher and pupil and student advisory committees would operate, or what would happen if views were not taken on board or were ignored. Indeed, it was noted that the creation of a “Advisory” Committee allowed scope for the advice not to be listened to.

There was also less support among individuals for a pupil and student Charter (compared to the Charter proposed for teaching professionals), with many of those who specifically mentioned it feeling this was unnecessary and likely to have only a minimal or no impact:

“The charter is a gimmick, it is more important that these actions are embedded in the organisation aims and strategic plans.” (Individual)

Others, however, including organisations and several individuals were supportive of a pupil and student Charter, provided it was straightforward and did not contain jargon:

“The introduction of a charter for learners is welcomed as this helps to set clear expectations and help young people to understand what they can expect from the new body.” (Local Authority)

A handful of respondents also suggested that, rather than creating separate Committees and Charters for teaching professionals and pupils and students, these could perhaps be more usefully combined into a single Committee to include both perspectives and facilitate discussion between the two cohorts, and a single Charter to address both groups.

Finally, a few felt that the Charter, or some other element of the new body should set out the expectations on pupils and students - to acknowledge the partnership approach needed for successful education and the pupil’s/student’s roles and responsibilities within education and achieving a qualification.

High Standards for Qualifications in Scotland

The consultation paper set out proposals for the accreditation function (i.e. ensuring that qualifications meet nationally recognised standards). It was stated that the accreditation function should remain at arms-length from government and so would be held by the NQB. As such, the NQB would be responsible for setting the standards for those awarding bodies offering qualifications in Scotland (apart from university degrees) which seek accreditation for their qualifications, as well as deciding what qualifications have met these standards in order to be accredited. In the NQB, governance structures would be established to ensure the responsibilities for setting the standards and accrediting qualifications would be carried out separately and independently from the delivery of the body’s qualifications.

Q4: How can the Scottish Government ensure qualifications being offered in Scotland are reliable, of a high standard and fit for purpose?

Given the broad nature of the question asked, a wide range of different views and suggestions were given by respondents, many of which were unrelated to accreditation or the proposed accreditation arrangements. This included preferences regarding the nature and timing of assessments or the type of qualifications to be offered; practical arrangements for assessments/exams; the need to evidence specific skills, knowledge or understanding within assessments; the use of technology, IT and AI within courses, assessments and qualification development; and suggestions on the system needed to improve Scotland’s educational standing in international league tables. Those issues discussed which had more direct relevance to the proposals around accreditation of qualifications included the governance structure of the NQB; the need to match international standards; the voluntary accreditation system; and the need to involve stakeholders in accreditation. Reasons for not supporting the proposals were also provided.

Governance Structures

Some respondents felt that making the NQB responsible for setting standards and accreditation was sensible, provided clear responsibilities and opportunities to ensure connections between the two duties. Being independent from the government was also considered to be highly important:

“To uphold the reliability and high standards of qualifications, it is imperative that the accreditation process remains independent of direct government control. Placing the responsibility within the purview of the new qualifications body ensures impartiality and insulation from potential political influences. This independence should be clearly emphasized, underlining the commitment to fair and unbiased accreditation decisions.” (Post School Sector/College/ University)

However, it was noted by a few respondents that, as the organisation would be under the authority of the Scottish Government/answerable to Ministers, the level of independence being achieved was questionable.

Several respondents also indicated that the proposed remit and governance arrangements for this aspect of the NQB were unclear and lacked detail. In particular, the role of the Convener, the role and membership profile of the Committee led by the Convener, and their relationship to the NQB’s Board, were questioned by respondents. It was felt that greater detail was needed before respondents could either provide an informed view on this aspect or be reassured about the appropriateness of such arrangements. Respondents also sought greater detail in relation to how this aspect/function of the NQB would operate in practice:

“…there is insufficient detail outlined in the consultation to assess the robustness of governance arrangements proposed and whether they can ensure transparency, equity and fairness in the discharge of these functions.” (Trade Union/Professional Representative Body)

A few other respondents discussed the need to ensure high quality, well trained and experienced staff were employed by the NQB, and stressed that accreditation should take a teacher and pupil and student centred approach.

Accreditation to International Standards

One of the main issues discussed by respondents was the importance of ensuring that qualifications offered in Scotland/by the NQB were comparable or equitable to those gained across the rest of the UK and internationally in terms of high quality/ standards. To achieve this, it was suggested that international benchmarking should be undertaken and monitored:

“The review process should look to include external validation and benchmarking by collaborating with international education quality assurance bodies. This can provide an external perspective on the quality and comparability of qualifications.” (Third Sector)

A few also suggested that existing and successful qualification systems used in other countries should be adopted by Scotland in order to avoid delays or “reinventing the wheel”.

Voluntary Accreditation System

There were mixed views expressed in relation to whether voluntary accreditation remained appropriate for qualifications provided by other bodies. Some felt the voluntary nature of accreditation should be removed to ensure all qualifications were quality assured and equally valued:

“All qualifications… including those contained within apprenticeships in Scotland, should be accredited, regulated, and included on the Scottish Credit and Qualifications Framework (SCQF).” (Awarding Body)

“All qualifications should be accredited and provide quality choices that meet the needs of a wide range of learners.” (School/Early Years)

Others, however, noted that alternative awarding bodies already had their own accreditation, validation and quality assurance processes, and therefore, felt that the voluntary system of accreditation by the NQB would be more appropriate. In particular, it was felt appropriate that university level qualifications remained separate and outwith the remit of the NQB’s accreditation processes due to universities using their own rigorous quality assurance processes:

“…we conclude that this does not mean compulsory regulation and accreditation of all non HEI [Higher Education Institute]-owned qualifications credit rated onto the SCQF. We would support this approach of continuing a devolved, flexible and responsive quality assurance model.” (Awarding Body)

Involving and Supporting Stakeholders in Accreditation

It was widely agreed that it would be vital that the NQB and range of qualifications offered were ‘fit for purpose’, with many respondents indicating that wider stakeholders needed to be involved in order to achieve this. There was a common desire to involve teachers and other stakeholders in the accreditation process:

“Involve key stakeholders, including educators, industry professionals, and students, in the accreditation process. This ensures that a diverse range of perspectives is considered, and the qualifications align with both educational and practical needs.” (Local Authority)

Ensuring the necessary resources and funding was available throughout the education system was also said to be necessary to ensure high standards and the development of high quality comprehensive qualifications. A few local authorities and schools in particular were concerned that the accreditation and quality assurance processes may become burdensome and time consuming for schools/ school staff, and so were keen to stress that any approach must be proportionate and properly resourced.

A few organisations also indicated that they had previous experience of either designing qualifications, becoming an accredited centre, or in developing suitable quality assurance and accreditation processes and offered to discuss their experiences and share learning with the government to inform this element.

Unsupportive of the Proposals

Some respondents (including those submitting written responses and event attendees) disagreed that the NQB should be responsible for both designing and awarding qualifications, and verifying/accrediting those qualifications. It was felt these two aspects needed to be dealt with by different independent bodies:

“We would support the formation of a separate board, independent of the NQB, to oversee the accreditation process. The proposed committee within the NQB, even with a separate convenor and reporting requirements, may not offer the same level of independence and robustness that an entirely separate board would provide.” (Trade Union/Professional Representative Body)

“We urge the Scottish Government should review its position to place both accreditation and awarding roles in the new qualifications’ organisation and instead take advantage of the momentum created by these reforms to remove the fundamental conflict of interest in the current arrangements.” (Industry/Private Sector)

It was also highlighted that packaging both functions within the same body did not meet the recommendations in this respect from the 2021 OECD Report and the Muir Report, both of which called for a separation of such functions:

“We were of the understanding that this body would be separate and distinct from the SQA Accreditation body, and this was certainly the recommendation made in the Muir report. However, the consultation document suggests that although each body would have separate governance, they would still be connected in some way. We stress that… two distinct and separate bodies are needed to avoid any unintended overlap or bias across those functions. The organisation suggested in the consultation document does not sound dissimilar to SQA in its present form as having two arms - one for qualifications and one for accreditation. It feels counterproductive to go through a period of reform and keep this same structure in place, and we feel that the only way to avoid the Scottish system having the same issues in the future is by having these two bodies completely separate from one another.” (Awarding Body)

As also illustrated by the quote above, a few respondents felt that the proposals simply repackaged the existing system in relation to accreditation and therefore felt that little change had been offered by the proposals.

A few also questioned the use of terminology or language used in the consultation document. In particular, it was felt that certain terms, such as ‘reliable’, ‘high standard’, and ‘fit for purpose’ needed to be better defined, and that detail was required in relation to who would be responsible for determining the scope of such terminology and whether the NQB was meeting these requirements.

Qualifications in the Education and Skills Landscape: A Holistic System

In order to address Professor Muir’s recommendation: “Scottish Government and other national bodies should collaborate more effectively to ensure that policies align well with each other and with any revised vision for Scottish education”, the consultation paper set out ways in which the NQB could provide national delivery and leadership on qualifications whilst also being part of a holistic education and skills system that delivers for all. The specific proposals included:

  • establishing an effective national forum for providing independent and objective views from members’ areas of expertise to the NQB - similar to the SQA’s Advisory Council;
  • that the NQB should work closely and collaboratively with all national education and skills bodies, with the Scottish Government, and with local and regional networks such as colleges and skills groups; and
  • the NQB should provide clear and timely communication, ensuring all parts of society are informed as to what it is doing, and why it is doing it. This will ensure that all with an interest can hold the organisation to account.

Q5: How do you think the qualifications body can best work with others across the education and skills system to deliver better outcomes for all?

While some respondents again discussed issues unrelated to the specific proposals, (including practical elements of how the NQB should operate, how qualifications should be designed, preferences for different types of assessment models, or areas for improvement within education generally), most respondents appeared to be in favour of the NQB adopting a strong and effective collaborative, partnership and co-working approach.

National Forum for the NQB

Some respondents indicated that the creation of a National Forum to advise and facilitate input/feedback to the NQB was a good idea. They felt this would provide an additional mechanism/opportunity for communicating views and feedback, facilitate the provision of independent and objective perspectives and advice, and provide an additional layer of scrutiny and accountability in relation to the NQBs actions. It was argued that this forum needed to include a broad range of groups, should be open to everyone concerned, and should report publicly and regularly:

“I endorse the proposal for a national forum to provide independent and objective perspectives to the qualifications body. This has the potential to be a platform of diverse voices, enhancing transparency, accountability, and informed decision-making, reinforcing the credibility and fairness of Scotland's qualifications system.” (Individual)

“Establishing an effective national forum, similar to the Advisory Council, will provide diverse insights and expertise, ensuring that the qualifications system meets industry and learner needs.” (Industry/Private Sector)

Again, it was suggested that if this forum was to be made up of specific people then membership needed to be for a fixed period and then rotated to ensure views remained fresh and a range of people could be involved. Caution was also expressed about the potential for the forum to be ineffective if not carefully managed and containing appropriate representation:

“…it runs the risk of becoming a bland and ineffective ‘talking shop’ unless meaningful representation is assured.” (Trade Union/ Professional Representative Body)

Most respondents, however, did not comment specifically on the creation/use of a National Forum, but again talked more generally about the need for the NQB to take advice from stakeholders. It was felt that whatever form the committees, boards, forums or groups take, they should involve a wide range of stakeholders, use ongoing widespread consultation and engagement, or employ/second stakeholders to work directly for the NQB, in order to ensure a wide range of views were incorporated and joint working achieved.

Working Collaboratively

It was suggested that the NQB should utilise truly collaborative and participative processes to engage with a wide range of stakeholders at all levels, as well as those with specialist knowledge, in order to ensure qualifications align with need:

“By working closely and effectively with education and skills bodies, and with business and employers, the new qualifications agency can ensure that qualifications are aligned with the needs of young people, educationalists, and the dynamic and changing academic and workplace landscapes.” (Local Authority)

Some respondents outlined who the NQB should work with and/or who should be included on the National Forum. This included teachers and lecturers (importantly to include classroom workers, who should be fully resourced to be released from classroom duties or using secondments); learning centres; pupils and students (across the full age and stage spectrum); parents/carers; local authorities; further and higher education; businesses/employers; employment/trade bodies; GME representatives; equalities representatives and other specialist agencies to advise on minority groups and issues; other awarding and funding bodies; the third sector; representative, professional and support organisations; and other public bodies.

It was also felt that the NQB needed to be more responsive and agile, consulting all stakeholders regularly and making changes/updates as required.


Most comments in relation to communication were focused on the need for the NQB to listen to stakeholders, rather than discussing ways for the NQB to disseminate its own communications. It was felt that robust and effective feedback and communication systems were needed, and most importantly, to ensure stakeholder views were listened to, taken on board and acted upon:

“Those in the system need to feel listened to and the new organisation must be responsive and move at pace to reflect views/evidence being shared by stakeholders... SQA need to engage more, listen and hear the views of all stakeholders.” (Local Authority)

In relation to those who did discussed outward communication, it was suggested the NQB should develop transparent communications along the lines of “You Said, We Did” to ensure stakeholders were informed and could see where feedback had been listened to, and understand the rationale when advice may not have been adopted. It was also suggested that minutes of meetings should be published and made publicly available, and that communications should be disseminated widely, including in the national press rather than just educational journals:

“I think it's important that they actually listen to the views of others… I know it is not possible to do what every stakeholder wants, but where views have been ignored, it would be valuable if the decisions made were explained and the objections acknowledged.” (Individual)

It was also suggested that a clear communications strategy be developed, which should include timings to allow planning to take place.

A few respondents also suggested that a wide range of local, regional and national networks already existed which the NQB could tap into, both to disseminate information and to seek views and feedback. It was also felt that such networks could also be useful for recruiting committee/forum members.


Some respondents stressed that any collaboration needed to be meaningful and impactful, and they were concerned that simply creating committees and forums would not necessarily achieve improvements. It was also felt that the creation of numerous committees, forums and other advisory groups could make the new body slow to react, overly complicated and bureaucratic:

“This also seems to once again suggest that a further Forum - much like the other sub committees or ‘charters’ discussed - would be a place for influence. But influence of what? What does the Board itself understand and do? How many further groups, charters, forums do we need for the Board of the new agency to be effective? Having multiple semi-independent groups, charters and forums runs the risk of experiences, views and new ideas being lost or diluted.” (Representing parents/carers and/or children and young people)

Several respondents again felt that the proposals lacked clarity about how these core purposes and options would be implemented, how the system would operate in practice, and where specific partner organisations would sit within the various committees, advisory groups, forums, and collaborative working practices.

Similarly, issues with terminology were again raised by a few respondents. This included concerns over what was meant by ‘better outcomes’ and ‘fitness for purpose’, and who would be responsible for deciding what the success criteria would be. Respondents also wanted to see a clear statement of ‘purpose’.

Several respondents suggested that, while they had no real issues with any of the proposals, they did not address many of the key issues within education. It was argued that the reforms needed to be wider reaching than just the NQB (and Education Scotland and the inspectorate as dealt with in the following chapter), and should address the full spectrum of educational delivery and other existing organisations. In addition, it was said a widespread culture change was required rather than focusing on structures. It was also suggested that Initial Teacher Education (ITE) should form a critical element of the change agenda.

A few respondents, again, suggested that the proposals did not represent any marked difference to the existing purpose and structure of the SQA:

“Presently, there is ambiguity regarding how the new body will differ from the existing one… The new qualifications body must collaboratively engage with national education and skills organisations, the Scottish Government, and local and regional networks, encompassing schools, colleges, and skills groups - however is this not just what SQA strive to do?” (Local Authority)



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