6. A qualifications and assessment body
This section focuses on the creation of a new qualifications and assessment body.
Background to the SQA
The SQA is an executive Non-Departmental Public Body that reports to Scottish Ministers and the Scottish Parliament. It is sponsored by the Scottish Government's Learning Directorate and employs nearly 1,000 people. Unlike some other jurisdictions where schools can select from a range of examination bodies in which to present their students, the SQA is the single such body in Scotland.
SQA carries out the following functions:
- Accredits, assesses and awards qualifications.
- Devises and develops qualifications and assessments.
- Provides qualifications to support all learners.
- Approves and quality assures centres (secondary schools, colleges, training providers and employers (private and public sector)) who are approved to deliver SQA qualifications.
- Delivers SQA qualifications.
- Certificates qualifications.
- Provides consultancy services.
- Delivers contract services.
SQA's staff has extensive expertise, developed over many years, in carrying out its awarding and accrediting/regulating functions. As an organisation, it faces many challenges which
are well recognised, not least by its Board of Management, which is appointed by Ministers, its Advisory Council, which represents SQA stakeholders, and its Executive Management Team. These challenges include continuing to deliver the annual diet of NQ examinations for the foreseeable future while putting in place contingencies for potential crises; the design, development and delivery of the Next Generation of Higher National (HN) Qualifications; and expanding the use of technology in support of qualifications and assessments.
SQA has two distinct parts, SQA Awarding and SQA Accreditation, the latter of which involves it operating as the Scottish qualifications regulator. The Education (Scotland) Act 1996 sets out SQA's statutory remit and the governance arrangements to oversee SQA's accreditation and awarding functions.
As an awarding body, SQA is responsible for all qualifications in Scotland (other than university degrees), it develops assessments, devises and develops a portfolio of qualifications, validates qualifications (makes sure they are well written and meet the needs of learners and tutors) and reviews qualifications to ensure they are up to date. SQA Awarding also arranges for, assists in, and carries out, the assessment of people taking SQA qualifications, quality-assures education and training establishments which offer SQA qualifications and issues certificates to candidates.
As an accrediting and regulatory body, SQA sets and maintains standards for many other awarding bodies, accredits vocational qualifications that are offered across Scotland, including Scottish Vocational Qualifications, and approves bodies that wish to award them. As Scotland's Qualifications Regulator, this work is undertaken by SQA's Accreditation Directorate, so called to separate it from SQA's Awarding functions.
SQA Accreditation provides a badge of quality for awarding bodies and their customers. This part of SQA works with Standards Setting Organisations and other stakeholders in the development of National Occupational Standards; the development of the qualification structures and associated products; and SCQF credit rating of qualifications.
SQA also plays an important role in supporting Foundation Apprenticeships and the wider Developing the Young Workforce (DYW) policy and their qualifications form part of the majority of Scotland's Modern Apprenticeships.
SQA offers a wide range of qualifications including NQs. These include Advanced Certificates and Diplomas, National Progression Awards, Professional Development Awards and Customised Awards that are developed in conjunction with teachers, lecturers, professional and industry bodies and are delivered by colleges, universities and training providers. The range and type of qualifications currently offered by SQA are illustrated in Figure 2. More detail on the work of the SQA can be found in the overview submission that was provided to me and was made available as part of my consultation supporting documents.
This section focuses on the creation of a new qualifications and assessment body designed to replace the functions undertaken by SQA Awarding.
SQA qualifications were the focus of much discussion during my engagements with all stakeholders, including Senior Phase and tertiary students. In terms of its non-NQ provision and much of its work-based qualifications, stakeholders expressed general satisfaction with SQA and with the relationship they had with SQA staff. The value and significance of SQA's Accreditation/Regulation, commercial and international activities were also positively commented on, as was the organisation's work which it was suggested enhanced Scotland's educational reputation outwith the country.
"Throughout the 12-years we have been regulated by SQA Accreditation we have had a very positive and professional experience. We value the regulatory principles and directives which frame our approach to qualification quality assurance whether they fall within SQA Accreditation's remit or beyond."
"SQA Accreditation provide support for awarding bodies who have an international qualification portfolio…. The international dimension of awarding is an important one to consider for employers and workers in Scotland as well as for the Scottish economy."
Following the decision by the Cabinet Secretary for Education and Skills to replace SQA, a number of those with whom I engaged offered the reminder that altering structures alone would not, in itself, bring about the changes needed. Indeed, this point was raised many times and with almost all commentators signalling that cultural and mindset changes are as important, if not more so, than structural change.
"The functions of the SQA will still be required to exercised, whatever the structural landscape. Some question whether consideration at this time should be less on structures and more on how the expertise built up within SQA can be most effectively channelled to ensure that those functions are maintained without disruption and loss of valued relationships."
(School/Centre Leader, Secondary School)
Some respondents felt that SQA had become a victim of circumstances, some of which were outside its own control. Like many examination and assessment bodies in the UK the SQA faced significant challenges in adopting new approaches to its work in a very short timescale.
"I feel that the SQA is a bit of a political scapegoat. It offers much that is good in Scottish education. I think it is wrong that the SQA is made to shoulder the blame for critisms of the system as a whole."
Despite recognition of the important role SQA has played, throughout the consultations and engagements, a variety of views were expressed about the decision to replace the SQA.
"The SQA used to do a good job. It set exams/assessment, marked and graded them. It just got too ambitious with some types of assessment i.e. assignments. Certain elements of these were unworkable, but they wouldn't listen and bend. This is when things became more confrontational."
(Teacher/Practitioner, Secondary School)
"We see this by the removal of SQA as an opportunity to shift the system away from one which was appropriate in the late 19th century to one which reflects the needs and context of 21st century society. We seek the creation of an agency which measures attainment outcomes in a variety of ways and responds to/meets the needs of the system rather than driving it."
(School/Centre Leader, Secondary School)
In recent years, SQA has taken a number of steps to address known issues including the setting-up of a new Communications Directorate, a new Policy, Analysis and Standards Directorate, more focus on digitisation over the pandemic and the creation of a Learner Panel. Despite these actions, criticism from teachers and lecturers in particular was levelled at SQA's management of NQs and, at times, its HN provision and some of its processes, the latter of which depended too much on traditional 'pen and paper' administration. Criticism also covered a range of topics including poor communications, a disproportionate focus on NQs, perceived weaknesses in aspects of leadership and governance and ineffective processes, including a failure to acknowledge the lived experiences of Scotland's diverse learners.
As can be seen from Figure 2, National Qualifications (Nationals, Highers, Advanced Highers, Skills for Work courses and Scottish Baccalaureates) make up only 10% of SQA's portfolio. However, in their own Guide to Scottish Qualifications, (2019) the SQA notes that:
'National Qualifications (NQs) are one of the most important types of qualification in Scotland. Almost everyone leaving school or college today has one or more NQ. NQs are taken by students in secondary schools and colleges (and some training providers). They can also be taken by adult learners.'
The significance and profile of NQs within SQA's portfolio is highlighted by the fact that in 2021 it processed 1.3 million assessment marks, 800,000 Unit entries and 632,000 Course entries. In total in that year, SQA certificated 136,000 candidates for NQs. More than any other part of its portfolio, NQs have consistently attracted the close attention of the press and media over many years, not least when school examination results are issued in August each year.
As shown above, SQA's NQs affect well in excess of a six-figure number of candidates every year. While there has been some degree of ongoing disquiet expressed about SQA's assessment arrangements, guidance and communications on NQs introduced in 2014 and subsequent changes, the last two years in particular have increasingly called into question the trust and confidence teachers and practitioners, the public and others have in SQA's handling of its high-profile NQs. Criticisms have been levelled from various quarters at SQA's responses to its 2020 and 2021 NQ diets of examinations. In response, SQA has consistently stressed that it has always responded in good faith to the challenges of the pandemic and to the requests made of it by the Scottish Government in respect of changing its assessment and examination arrangements.
Despite this, feedback from the public consultation, the online survey completed by secondary-age students and through my engagements, especially with Senior Phase students, the Scottish Youth Parliament and SQA's Learner Panel, have confirmed many of the concerns expressed about SQA and how these have impacted adversely on teachers, candidates and the organisation's overall reputation. It was significant that the SQA's own Learner Panel suggested to me that they felt the relationship between SQA and young people had been damaged over the past two years and were of the view that SQA should display more interest in the needs of young people.
"The SQA always failed to listen to teachers and believed it had the monopoly on good ideas. The lack of accountability developed an arrogance and reluctance to listen, the total lack of oversight meant there was no consequences for failure."
(Teacher/Practitioner, Secondary School)
"The SQA simply does not understand its changes cause more harm than good. They also seem incapable of understanding that most schools change timetable in May/June and so releasing changes in August (or later!) does not help. They made a promise that they would make no changes for 3 years and then promptly made changes."
(School/Centre Leader, Secondary School)
"The SQA felt totally disjointed and separate from teaching as a profession. The agency that replaces the SQA must be held more accountable and be more transparent."
(Teacher/Practitioner, Secondary School)
"Currently there can be great disparity between the decisions/guidance of one SQA External Verifier who carries out an annual verification visit and a different verifier who visits the following year. SQA is very clear to learning institutions on the need for standardisation but this is not replicated in their own systems. In summary, it is a subjective rather than objective process."
(Lecturer, Tertiary/Further/Higher Education)
"Teacher voice must be central to the formation of a replacement qualifications body. It is essential that governance arrangements are configured to avoid the tone deafness to its needs that the teaching profession has experienced from the SQA over a long number of years."
(Trade Union/Professional Association)
Responses from those in the college sector, have also been mixed with criticism of aspects of SQA's work as shown in the following comments.
"More flexibility required from SQA to support innovative approaches to delivery, transferable skills development and assessment – core certification restricts creativity and collaboration."
"SQA currently are very slow in their responses, even pre COVID-19. Curriculum can be very dynamic and response can take months or years to adapt/modify and modernise curriculum."
Overall, it was evident to me in my engagements that there are significant relationship issues within the current SQA. Feedback from some of my engagements with PSAG members and others also questioned the effectiveness of leadership, the culture, accountability, and appropriateness of current governance structures within SQA.
Parity of esteem
Figure 3 shows that just over half (51%) of public consultation responses felt that the full breadth of existing SQA qualifications played an important part of the curriculum offered by secondary schools.
However, some students at the start of their Senior Phase, reflecting on the range of opportunities open to them to progress their learner journey, questioned why in some schools this range of opportunity was available to all students while in others, sometimes in the same local authority, the range was much more limited. It was felt that this was an important issue of equity and one that needed to be addressed by local authorities and schools, in discussion with learners, parents/carers and other stakeholders. Also, many Senior Phase and college learners noted that the impression given to them by some teachers, parents/carers and wider society was that academic qualifications were of greater value than vocational qualifications and other awards, such as youth achievement awards, available to them.
"So, when it comes to opportunities for professional qualifications we are able to achieve them but vocational these are slim to none or maybe if they do offer it, there isn't a lot of awareness for it"
(Secondary school age learner)
The issue about the value given to academic qualifications such as NQs as opposed to vocational qualifications and awards has been a constant tension in Scottish education for many years. The creation of SQA in 1997 by merging the two major Scottish examination authorities, the Scottish Examination Board (SEB) and the Scottish Vocational Education Council (SCOTVEC) – itself a merger of the Scottish Business Education Council (SCOTBEC) and the Scottish Technical Education Council (SCOTEC) in 1985 was designed to address this issue.
Evidence shows that it clearly remains a significant issue today. Feedback such as that below reflects the sense of concerns expressed for the education system and for diversifying curriculum pathways in all schools to give all young people opportunities to study vocational qualifications.
"The challenge is how these [vocational and other awards] are included in the curriculum with parity of esteem and recognition by employers, universities and colleges."
"Some vocational routes such as Duke of Edinburgh were viewed as being for the misbehaving kids and not valued or seen to be as important as for example Maths or English, if you weren't taking exams, then you're looked down upon."
"To ensure parity of esteem across the SCQF framework or indeed a new qualifications framework, it is essential that courses and awards, where appropriate, are accepted as valid entry requirements to further and higher education courses. While there is evidence emerging that Foundation Apprenticeships and other accredited courses being accepted this has nor progressed at the pace required."
Broader issues in respect of qualifications and assessment
Professor Gordon Stobart in his report, Upper-secondary education student assessment In Scotland: A comparative perspective: OECD Education Working Paper No. 253, noted that the COVID-19 pandemic disrupted education and forced decision makers and education stakeholders worldwide to find emergency solutions to adapt or replace examinations and student assessment processes overall. However, he adds a further layer of concern
about the current assessment and examination arrangements suggesting that Scotland needs to review them urgently. He points to Scotland's relatively traditional, cautious, single-subject examination system, with its pen-and-paper timed examinations under standardised conditions, being unable to respond to crises and incompatible with a future-facing curriculum such as CfE.
This need for an urgent review of NQs was echoed by many respondents to the consultations and in engagements with me, not least from practitioners and professional associations. The announcement by the Cabinet Secretary on 27 October 2021 to ask Professor Louise Hayward of Glasgow University to lead a review of NQs was warmly welcomed by almost all with whom I have engaged. However, concerns were expressed about the resource and capacity within the system to take on board further changes to NQs while still dealing with issues arising from the ongoing pandemic.
SQA accreditation and regulation
SQA is the statutory body for qualification awarding and regulation in Scotland. This means that as well as being the body that awards qualifications, it also regulates those qualifications. It does so through the SQA Accreditation part of the organisation, with SQA's Chief Executive also overseeing this work. This regulatory role performed by SQA is similar to that carried out by the regulatory bodies such as Ofqual in England and Qualifications Wales in Wales which are separate from their respective qualifications and examinations bodies.
SQA's Accreditation Regulatory Framework document sets out that there is a requirement that maintains separation between its accreditation and regulatory body functions from its awarding body function to ensure that there is no conflict of interest. It states that this separation of functions must apply to SQA staff supporting the accrediting and awarding functions and must be capable of being publicly demonstrated. SQA has in place arrangements for separation of functions and the accreditation procedures which are subject to the approval of Scottish Ministers.
However, the OECD suggested that:
'consideration should be given to a separate body that might be responsible for the regulation and quality of qualifications which is currently part of the remit of the Scottish Qualifications Authority (SQA)' (page 123 of the OECD report).
SQA's dual function of awarding and accrediting/regulating attracted criticism from some respondents and stakeholders who felt that it was not appropriate for both functions to be carried out by a single body. When taken together with what many saw as the organisation's poor record of communication and ineffective engagement with the teaching profession, it was suggested that allowing SQA to 'mark its own homework' in this way further called into question its credibility. As such, they suggested, the timing was appropriate to give serious consideration to implementing the OECD's suggestion.
It was argued by some that in such a small education system as we have in Scotland, there are advantages of integration and cost benefits in having SQA's current awarding and accrediting/regulating functions within a single body. However, it is my view that these advantages are significantly outweighed by the need to restore the trust and confidence of the public, practitioners and learners in a revitalised single qualifications, examination and awarding body for Scotland. Separating the SQA's functions will help ensure that the proposed qualifications, examination and awarding body is able to give increased attention to those functions. There is already significant demand for change in these areas of work and these will almost certainly increase significantly in the future. In addition, such separation will help to address some of the criticisms levelled at the current SQA.
It is my view that SQA's core two functions should now be separated across two bodies. I propose that a new executive Non-Departmental Public Body (NDPB) should be set up. NDPB status would recognise the specialist expertise required to conduct its proposed role, set out below, and would maintain the appropriate distance from government that provides public confidence. This new body should take on board SQA's current awarding functions, i.e. chiefly the responsibility for the design and delivery of qualifications, the operation and certification of examinations and the awarding of certificates. The make-up of the new organisation's board of management should be reviewed to ensure the involvement of a wider range of stakeholders.
The role of the new body should include preparing examination papers and other examination materials; determining procedures for the conduct and supervision of examinations; arranging for, assisting in, and carrying out, the assessment of people taking SQA qualifications. The new body, which for the purpose of this report I have suggested is called Qualifications Scotland, would quality assure education and training establishments which offer SQA qualifications; ensure the drafting of examinations; arrange for marking of work presented for assessment and examinations; and issue the results of examinations. The new body would also determine procedures to enable the review and appeal of results, charge fees for qualifications as appropriate and liaise with relevant bodies, for example in industry and commerce, where there is employer-led assessment.
The proposed public body Qualifications Scotland, must be able to adapt to new forms of qualification and assessment that arise, for example from the outcomes of Professor Hayward's work once she has reported. It will need to be agile and responsive to the rapidly changing needs of learners as well as employers and the tertiary sector. A critical feature of its work will be to ensure it communicates clearly and regularly with all stakeholders.
The creation of the proposed public body, Qualifications Scotland, provides an opportunity for its culture and engagement arrangements with all stakeholders to be set positively from the outset. It also provides an opportunity to ensure its governance structures reflect and represent the range of stakeholders it serves and users of its services; those to whom it should be accountable. Overall, creating this body will provide the opportunity for all users of its services and the public in general to have increased trust and confidence in qualifications and assessments, including examinations.
To maintain and enhance the reputation and profile of Scottish qualifications, those income-generating contract services currently provided by SQA for organisations, governments and businesses, such as those on behalf of UK Government clients, for example with the Home Office, Department for Education, and Department for Transport, should be part of the new NDPB's remit. SQA's current international work in support of the Scottish Government's international agenda should also be part of this remit.
SQA's second core function of current accrediting and regulating functions should transfer to the proposed national agency for Scottish education. This separation of current awarding and regulation/accreditation functions will significantly strengthen the oversight of qualifications in Scotland while providing an external perspective on the effectiveness of the examination and qualifications system.
Recommendation 3: A new body, Qualifications Scotland, should be established. This new body should be an executive Non-Departmental Public Body (NDPB). 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.
Recommendation 4: 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.
Recommendation 5: 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.
The establishment of a new body, Qualifications Scotland creates the opportunity for the new body to:
- focus more closely on its core business, the bulk of which is currently carried out by the awarding part of the current SQA;
- respond to changes, for example, the increased use of digital technology and alterations to the curriculum by the proposed national agency for Scottish education;
- rebuild the trust and reputation in the examination system by resetting the organisational culture and the relationship with the users of the services they provide;
- extend commercial markets and services that relate to qualifications and examinations; and
- develop new governance arrangements that take better cognisance of the views and expertise of those the body is designed to serve. This should result in an increase in representation of teachers, practitioners and learners with lived experiences of the current procedures relating to assessment, qualifications and examinations.
Change to the current SQA must avoid negatively impacting on things that are currently working well. I have noted the view from some that they are satisfied with SQA's work in regard to its portfolio of vocational qualifications and that significant reform to processes relating to them are not needed at this stage. I also note the view of many with whom I engaged that reform of SQA must focus on ensuring the adoption of a wholly inclusive culture, what one respondent to the consultation described as "the development of a transparent culture and ethos." Many feel that such a culture is not obviously apparent with the SQA at present. I acknowledge there are risks with the recommendations being made. However, it is overwhelmingly my view that the risks associated with not making these changes are greater.
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