Ofqual has asked the Department for Education to consider delaying the proposed reforms for level 3 qualifications.
The government is considering cutting the number of alternative qualifications at level 3, which include Btecs and are equivalent to A levels, and putting more focus on the new T levels.
In its response to the government's consultation on the level 3 qualifications review, the exams regulator said that in response to the impact of the coronavirus on the system, "we would ask the department to consider whether there are aspects of the proposed reforms for which implementation could be delayed by a year, in recognition of these exceptional circumstances".
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Ofqual added that 2021 would be an “exceptionally demanding year for awarding organisations because of the pandemic” and that AOs needed to concentrate on managing the continuing implications of that.
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The regulator said the DfE had to reflect on the variety of level 3 qualifications used by learners. While the DfE estimates that the qualifications that may no longer be funded could account for around 62 per cent of current non-A-level 16- to 19-year-old enrolments at level 3, Ofqual says that the number of learners using qualifications other than A levels to access higher education is growing.
It added: “We can see from Ucas data about 2019 undergraduate admissions that the number of applicants accepted to higher education with A levels alone has fallen from 63 per cent in 2017 to around 60 per cent in 2019.
"While this accounts for more than 145,000 learners, nearly 22,000 learners were accepted with Btecs only in 2019, along with almost 18,000 learners who combined A levels with Btecs. This is not an insignificant number and we should consider the impact on learners who may not be able to benefit in such a way when the reforms introduce an apparently more binary choice around qualification purpose and content.”
The regulator warned of too strong a focus on T levels in place of other current level 3 qualifications, saying there was “potential risk” and that some of the “design features” like the size and structure of the T-level programme may be barriers for learners to accessing it.
Qualifications more likely to have funding removed currently had a higher proportion of learners with particular protected characteristics (such as disability, ethnicity or gender) or who are disadvantaged, said Ofqual, adding that consideration must be given to how “qualifications funded in future can be designed to continue to allow a diverse range of learners to access level 3 qualifications effectively and successfully”.
Ofqual said it predicted “market instability” in the years after the reforms as a number of centres would choose to change the qualifications they offer, particularly if they are reliant on public funding.
The response added: “It is not straightforward, however, to predict how the 120 awarding organisations who currently have level 3 qualifications eligible for 16-19 funding might respond to the reforms. For some, this may offer opportunities for growth. Conversely, there may be others who are significantly impacted by the defunding proposals; for example, if their business model is currently heavily reliant on their funded qualifications. Indeed, a number could potentially lose the majority or all of their level 3 funded offer as a result of the reforms.
“We have a responsibility to identify where there are risks to learners if, for example, an awarding organisation becomes financially fragile or market instability causes a fall in confidence in regulated qualifications. We will continue to monitor such risks as these proposals are further developed and implemented.
Tom Bewick, chief executive of the Federation of Awarding Bodies, said it was "good to see Ofqual broadly supporting our own members’ conclusions in response to the level 3 and below review".
"The independent regulator highlights the disproportionate impact for disadvantaged learners of the proposed changes; the instability it will cause in the market and the kind of choices available to learners in future," he said. "Ministers need to be particularly mindful of the unintended consequences of defunding qualifications at a time when the planned alternative quals, like T level roll-out, are being hampered by the pandemic.
"We welcome therefore Ofqual’s call for a delay by a year of the government’s ambitious reforms. Indeed, we pointed out the need for this recalibration of the timetable back in June 2020.”
James Kewin, deputy chief executive of the Sixth Form Colleges Association, said: “The content of the government’s proposals is of much more concern to us than the timescale for their implementation. Ofqual is right to highlight that some young people will be negatively affected by a move to a binary model of A levels and T levels. As we set out in our own consultation response, we believe that applied general qualifications have a vital role to play in the future qualifications landscape.
"Removing funding for the majority of AGQs [applied general qualifications] to aid the introduction of this binary model would be disastrous for employers, young people and social mobility. Instead, the government should retain the current three-route model of A levels, AGQs and technical qualifications. We need the government to fundamentally rethink its approach to qualification reform at level 3, not just slow down its plans for implementation."
A DfE spokesperson said: “These reforms to improve the quality of technical education are more crucial now than ever as the country prepares to recover from the pandemic. For too long we have allowed too many young people to leave education without the skills employers need – it’s critical we act now to address these skills shortages.
“We want to phase these reforms in so that they are manageable, and we will continue to work closely with Ofqual and the Institute for Apprenticeships and Technical Education to consider the responses to the consultation.”