Heads have criticised Ofqual's “complete absence" of a plan for large numbers being unable to take GCSEs and A levels next year as "bordering on reckless".
The Association of School and College Leaders response today to the exam watchdog's proposed changes to exams in 2021, also warns that the changes proposed to are too minor.
But Geoff Barton, ASCL general secretary, reserves his biggest criticism of Ofqual for not planning for candidates not being able to take the exams at all.
“Most worrying of all, is the complete absence of a contingency plan in the event that large numbers of students are unable to take exams next summer," he said. "It is bordering on reckless to have no Plan B when we have literally experienced at first-hand an actual national lockdown."
GCSEs 2021: No science practicals, more history choice
The association also says Ofqual's proposed changes to GCSEs and A levels in 2021 are too minor and "do not go far enough in recognising the disruption to learning that many students have already faced".
Earlier this month, the exam regulator proposed a series of measures to help pupils sitting GCSEs and A levels next year, such as a later start date for exams, removing the need for science practicals and introducing greater choice in GCSE history exams.
However, ASCL wants the regulator to consider more choice for pupils within all their exams.
"The consultation does propose introducing more choice into history exams, it says. "We would encourage Ofqual and the awarding bodies to consider different – potentially radical – ways in which greater choice could be fairly and effectively introduced in other subjects."
ASCL also suggests that Ofqual considers other approaches to exams to accommodate the fact that pupils will have had less time in school to learn content, such as the use of open-book exams in English, or the use of formula sheets in maths and science exams.
It says Ofqual's proposals do not go far enough in recognising how pupils' learning has been disrupted by the pandemic, as well as the fact some pupils will have experienced far greater levels of disruption than others.
And it notes that the proposals do not "sufficiently recognise and plan for likely further disruption to learning over the period between now and the 2021 exam season – and indeed potentially over the exam season itself".
Ofqual should have gone "much further" in planning ahead for further disruption to learning, ASCL says. It says "suitable contingency plans" must be ready alongside its proposals for the 2021 series.
"Those plans need to address a range of scenarios from no new serious outbreaks, through intermittent local outbreaks up to and including repeated national lockdown, potentially over the exam period itself," the association's response says.
"There must be approaches introduced to support students who may not be able to sit exams because of local lockdowns. These approaches might involve a parallel centre-assessed grading process, similar to that used in 2020, which could be used to inform a student’s grades in the event of them not being able to sit an exam as planned.
"They might involve staged assessment opportunities, so that students could ‘bank’ a proportion of their grade over the course of the year. Schools need to plan now for any such contingencies, as any approach would be likely to involve teachers collecting evidence over the year."
Geoff Barton, general secretary of ASCL, said: “Ofqual’s proposals for next summer’s exams seriously underplay the extent to which students will have been disrupted by the coronavirus pandemic and amount to no more than tinkering at the edges.
“It isn’t going to be business as normal next academic year. Students will be returning to schools and colleges in September having missed a huge amount of time in the classroom.
"It simply isn’t going to be possible for all students to cover all the content in GCSEs and A-levels to the depth required. Added to that is the likelihood of students having to intermittently self-isolate and further lockdowns next academic year which will make the situation even more challenging.
“The government and Ofqual really do need to think again about the planning for next summer’s exams, hoping for the best, but preparing for the worst.”