Racial equality groups are not convinced that Ofqual and the Department for Education "are doing enough to address any possible bias" in this summer's teacher-assessed A levels and GCSEs.
They are writing to the exams regulator Ofqual and to education secretary Gavin Williamson this week to raise concerns over potential bias against disadvantaged or black students.
Both racial equality think tank the Runnymede Trust and BME Governors, a group representing black and minority ethnic school governors, are raising their concerns in a joint letter.
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Meanwhile, the Equality and Human Rights Commission has told Tes that it is "monitoring" Ofqual's plans for this summer's exam grading.
It says that, as a regulator, Ofqual has "a duty to comply with the Public Sector Equality Duty, so that no one is put at a disadvantage because of their protected characteristics".
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One of the concerns in the Runnymede and BME Governors letter is that Ofqual's suggestion that students unhappy with their grade can sit an exam in the autumn will benefit middle-class pupils and "puts the burden of proof on the student".
And as Tes revealed last week, exam boards have not committed to offering autumn exams for all GCSEs and A levels.
Earlier this month, the Runnymede Trust wrote to education secretary Gavin Williamson, warning that "a generation of young people could lose out" because of biased teacher assessments.
That came two weeks before Ofqual published details of its consultation process, which then made it clear that its plans would not involve looking within schools' teacher-assessed GCSE and A-level grades to guard against ethnic, gender or class bias.
Dr Kathlyn Wilson, a psychologist whose research focuses on accuracy and fairness of assessment within organisations, and who represents BME Governors, said the latest letter notes comments made by Michael Gove, when he was education secretary in 2012, about reforming GCSE and A-level qualifications with the removal of coursework and teacher-assessed components.
He said that “there is a tendency for “ethnic minority children to be under-marked and students from non-minority backgrounds to be more generously marked”. An exams-based system would help to combat the “soft bigotry of low expectations” that some disadvantaged and BAME students faced, Mr Gove added.
The letter also raises concerns about Ofqual's proposal not to allow appeals against teachers' professional judgement in this summer's grades, which it argues can be prone to unconscious bias.
The letter concludes by calling on Ofqual to work with schools to carry out an equality impact assessment of the grading process prior to the release of the results in August, and suggests that experts and stakeholders in bias and decision-making should be involved in delivering guidance to schools about how they should implement these proposals.
Dr Zubaida Haque, deputy director of the Runnymede Trust, told Tes: "At the moment, we’re not convinced that either the DfE or Ofqual are doing enough to address any possible bias in the assessment system with high-achieving disadvantaged students or black students.
"Our two key recommendations in the first letter were around how teachers should be given more support and guidance on how to assess their students’ grades.
"Now Ofqual are also asking them to rank students – between assessing students’ grades accurately, and ranking them in a school, we think that’s an even stronger argument for the DfE to give teachers more guidance about how to calculate students’ grades so that they are accurate and fair. It’s a big ask for teachers – we’ve heard that teachers themselves are nervous about this."
She added: "It appears as though Ofqual are saying that they don’t really intend to address any possible bias in assessments – despite admitting that there may be some bias in the system.
"And it’s not clear how looking at the school’s previous years’ results will address any group biases in assessments. There does not appear to be any obvious equality assessment by Ofqual or the suggestion that they have processes to identify unequal assessments or rankings.
"We don’t want this debate to be pitted between teachers and students, because I don’t think that helps anybody. Teachers are incredibly committed to their students and we have no doubt that they are trying to do the best to accurately assess their students and to give a fair grade. What we’re trying to recommend is a system where teachers and schools are supported to do something that’s a big ask.
"We know there’s racial disproportionality in school exclusions – it was the entire reason that Theresa May [as prime minister] commissioned the Timpson Review – so any notion that teachers will not also have unconscious biases in grading or assessments is somewhat unrealistic."
An Ofqual spokesperson said: "Our overriding priority is to ensure that this year’s grading is as fair as possible and we have developed clear guidance for schools and colleges, which sets out how teachers can make objective, evidence-based judgements of student performance.
"We are confident that schools and colleges will be able to use this fairly and consistently and believe that assessment grades are the most reliable way of ensuring students get the grade they need to progress this year.
"We do recognise there are concerns about the potential for students to be disadvantaged by this approach and have published an equality impact assessment alongside our consultation. This was informed by a review of research literature on bias in teacher assessments, which shows mixed findings, depending on the context in which judgements are made.
"Our standardisation model will be designed to ensure, so far as is possible, that students are not advantaged or disadvantaged on the basis of their socioeconomic background or whether they have a protected characteristic."
The DfE was contacted for comment.