Ofqual and the Department for Education plans for GCSE and A-level grades to reflect students’ current levels of attainment is “unworkable”, school leaders have said today.

In its response to Ofqual and the DfE’s consultation on GCSE and A-level grading, which closes tonight, the NAHT school leaders’ union said it was concerned about what grades would mean this year if the proposals went ahead.

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“NAHT has concerns regarding the expression of what grades mean this year.

“Ofqual suggests that grades should reflect the standard at which students are performing. Although a good principle, it is unworkable in reality,” its consultation response says. 

“The wording presupposes a system for awarding grades which does what the normal system of exams does; exams demonstrate the standard at which students are performing on a given day or days, grade boundaries are set and results awarded.

“This year, grades will reflect students’ performance over a longer period of time, potentially over the period of the course. In addition, this proposal does not account for the circumstances in which we are now operating with students having been taught different content and varying proportions of the specification.”

Its response also argues that schools should submit grades no earlier than the end of June to give more time for teaching and learning.

And it says schools must have the “flexibility” to draw on evidence from students from earlier in the course when assigning teacher grades.

“NAHT does not agree that there should be a limit on the period from which previous work could be drawn as part of the portfolio of evidence,” the response says.

“However, as a general principle students should not have evidence used to come to a judgement about their submitted grade which they did not know at the time was going to count towards it.”

It adds: “We believe that centres must be given the flexibility to draw on earlier evidence, with the knowledge of the students they teach.”

The response says this could be useful for students who are unwell while teacher assessments are taking place.

It says that rather than specifying a time limit on the evidence teachers use, it is more important that the work be completed independently.

NAHT says teachers should mark external tasks from exam boards, and that given varied circumstances nationally, the tasks should be optional.

“NAHT would, however, support a strong recommendation for their use in all [schools and colleges] provided there was sufficient flexibility for teachers to adapt these and select the topics and questions their students answer, to ensure they are assessed on what they have learned and been taught,” the response says, adding that this has the potential to address differential learning loss to a degree, although it adds that the issue of learning loss is “insufficiently addressed” in the proposals overall.

The response also states that NAHT disagrees with the idea that any assessments devised by teachers should be sat at the same time as those prepared by exam boards.

“Exams are not taking place this year and grades will be awarded using a range of evidence available to the teacher; teachers must be trusted to gather that evidence in an appropriate way not be constrained by a pseudo exam system,” it says.

A DfE spokesperson said: “Fairness to young people has been and will continue to be fundamental to every decision we take on these issues.

“We know how important this is to teachers, parents and students, which is why we have made sure everyone is able to have their say in our exams consultation.

“The impact of the pandemic means it won’t be possible to hold exams this year, and the department is working closely with Ofqual and the sector on arrangements to make sure teachers will be supported in making decisions with guidance and training from exam boards and young people can receive a grade that reflects their hard work and enables them to progress.”

An Ofqual spokesperson said: “We are considering all responses to our consultation on assessment in summer 2021, which closes today.”