The new chief regulator at Ofqual, Jo Saxton, has had a hell of a first week.

Her first decision was (hopefully) one of the hardest she will have to make: how to grade GCSEs and A levels next year and thereafter.

After all, over the past two years - during the suspension of standardised exams - we have seen a massive increase in top grades with As and A*s at A level rising from 25 per cent of the total in 2019 to 45 per cent this summer.

This meant Ofqual had to decide whether to maintain grades at this higher level for future years, leading to accusations of “baking in grade inflation” or drop grades back to the 2019 level, which could feel very unfair to future cohorts.

GCSEs and A levels 2022: The challenge with grades

In the end, it decided to split the difference in 2022.

Grade boundaries will be set at an average of 2019 and 2021, though this won’t be exact as it will be adjusted according to the entry profile for each subject. Then in 2023, grades will drop back down to 2019 levels.

This is, in the language of the civil service, a brave decision.

For GCSEs it should work fine as rises were not that considerable, but for A levels it will see very substantial drops in the top grades on offer for two consecutive years.

We have never, in the history of our qualifications system, seen even one drop of this nature, let alone two in a row, so it is hard to know how it will play out.

One reason it’s hard to read is that the way our assessment system works is poorly understood.

Most people think we have a criterion-based approach to grading - ie, there is a defined standard for each grade and anyone who meets it gets that grade, like passing a driving test.

But that is not how our system works.

Instead, exams get marked and then those marks are fitted into a preordained grade profile (which can be tweaked).

This means students sitting exams in 2022 and 2023, and their parents, may simply not realise that their grade profile has been auto-fixed at a level lower than the cohort before them.

On the other hand, if parents and students realise that the profile has been fixed statistically in this way they may feel it’s unusual and thus unfair - even though it has happened in every pre-pandemic year since 2011 (albeit that in the past this has led to stability, not a reduction, in the number of higher grades awarded).

A hostage to fortune 

While I understand Ofqual’s decision - and I hope it works out for the sake of young people and their schools - I feel it’s an unnecessary hostage to fortune.

There is nothing about the 2019 standard that is intrinsically “correct” or “normal”.

It is not benchmarked to any external standard, but is simply what the grades were when the current system was introduced in 2011.

Rebasing at a higher level would be entirely plausible, especially as an additional grade could have been introduced at the top if needed for differentiation by the most selective universities.

The approach Ofqual has chosen will mean we have four consecutive years - from 2020 to 2023 - with a changing standard.

Inconsistent data 

This is something of a nightmare for universities, the main users of A-level grades, as they have to adjust their offers against a moving target.

This year they were caught off guard by the extent of the rise, which has meant selective universities ended up well over capacity, even offering £10,000 grants for students to defer, while others have had to make staff redundant due to falling rolls.

Next year they will have the unenviable task of comparing 2021 students, who have applied after a gap year, with the 2022 students graded on a different scale.

It is impossible to do this fairly as there is no way of knowing what a 2021 student would have achieved in 2022. Then they’ll have to do it all over again in 2023.

Ofqual has left itself some wriggle room by saying it will review 2023 based on how things go next summer.

Of course, if there is a lot of pushback from students and parents, it may yet end up sticking to the 2022 standard permanently. Especially as 2023 students will not benefit from the adjustments - like greater topic choice - being made to exams in 2022.

The need for change

This whole mess highlights the need for a proper longer-term secondary assessment strategy.

As I set out in a paper for the Institute for Government, the pandemic has shown up the lack of resilience in the way we do exams, as well as highlighting confusion around the purpose of assessment.

Now this decision has been made, we have to hope that Dr Saxton is given the space to work with schools and colleges to develop a more substantive response to the flaws in our system.

Sam Freedman is a former senior policy adviser at the Department for Education and a senior fellow at the Institute of Government