Headteachers have warned that external tasks set by exam boards as part of the evidence for grading this year should not be viewed as “mini exams”, and that schools should be given the flexibility on how they use them - if at all.

In its response to Ofqual and the Department for Education’s consultation on GCSE and A-level grading this year - closing tonight - the Association of School and College Leaders said that the tasks must not be viewed as a form of exam.

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“In our proposals to the government and exams regulator Ofqual, we back the idea of exam boards providing a range of papers or banks of questions that teachers can use to assess their students this summer,” an ASCL statement says.

“However, these should not be treated as ‘mini exams’, and it should not be mandatory that schools and colleges have to use them.”

The school leaders union adds that “centres should be left with the flexibility to base grades on their own assessments if this is the best way of ensuring fairness”.

In its full response to the consultation, ASCL raises concerns about “the potential for external assessments to be perceived as exams by another name, when the government has assured students that exams will not go ahead”.

Geoff Barton, ASCL’s general secretary, said: “Students have suffered huge disruption because of coronavirus, and they have been affected to widely varying extents.

“That’s why it is vital that the way they are assessed this summer is as flexible as possible in order to ensure that they are tested on content they have covered rather than content they have missed.

“We understand that some people will argue that there should be a set of mandatory assessments because this will provide greater consistency.

“However, there is a danger of replicating the very problems that drove the decision to scrap exams in the first place, namely the fact that students who have suffered the most disruption may find themselves doubly disadvantaged by papers they cannot answer.

“Many of us have mulled over this dilemma for some time, but the prime minister’s announcement on Wednesday extending the period of lockdown restrictions swung the pendulum firmly in favour of maximising flexibility.

“We don’t claim the system we are proposing is perfect, because nothing can be perfect in these circumstances. But we believe it will provide the fairest way possible of assessing students this summer.”

The Education Policy Institute published its response to the consultation today, arguing that if external tasks are voluntary and many schools decide not to use them, there is a significant risk to external moderation processes.

ASCL’s proposals say:

• Exam boards should provide papers or questions on a wide range of content, so that schools and colleges can choose those which focus on content their students have been taught, however disrupted their learning has been.
• Schools and colleges should be encouraged to ask students to undertake these papers or questions under reasonably controlled conditions if possible, to increase their confidence that they represent a student’s own work. However, they should not be treated as ‘mini exams’. There should be no expectation that students come to these tasks unseen, or that all students sit them at the same time.
• The use of these papers or questions should be encouraged, rather than mandated. They will be helpful in determining submitted grades, and may prove particularly useful in the case of appeals. However, there may be some circumstances in which the use of these materials may not be appropriate, such as if some or all students are not able to return to face-to-face education for many more weeks.
• Schools and colleges should be given a clear indication of what other types of work, alongside the exam board-created materials, they could use as evidence for submitting grades.
• Schools and colleges should draw this evidence together for each student, and submit grades to the exam boards by mid June. The boards should quality assure these submitted grades, satisfying themselves that the [school] has followed the agreed process. This quality-assurance process should include comparison of the submitted grades with the [school’s] historical performance and prior attainment data. If the submitted grades are similar to the school’s prior performance and attainment, in the vast majority of cases the board should agree to award these to students as they stand.
• If a school or college’s submitted grades are significantly different from its previous performance, and it has not already discussed this with the board, the board should then initiate a discussion about this. The board should ask for evidence for why the school believes this year’s cohort is significantly different. If the board is not happy with this evidence, it should ask the school or college to adjust the submitted grades.
• The boards should release the grades to students on the normal results days, ie, 12 and 19 August. Any student unhappy with their grade should be able to appeal to the board, which will investigate the appeal. 

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.”