Your article "Ofqual rules suggest it should have prevented GCSE grading changes" (7 September) contains inaccuracies that cannot be allowed to stand.
You argue that four out of the five conditions we identified in June as necessary for our "comparable outcomes" approach were not met for this year's GCSE English. This is not the case.
Our first condition was that the cohort for a subject be similar, in terms of ability, to previous years. As our initial report into this year's English GCSE said, there were some changes to the cohort which explain the 1.5 percentage point drop in outcomes in GCSE English. But they were not big changes.
The second condition was that the exams be "fit for purpose". The awarding has proved more challenging than expected, and ministers are concerned about the wider policy issues around GCSEs. But there were no problems with the assessments themselves. Our conditions also stated that the purpose, requirements and nature of the qualification should be the same. They were, despite changes to the structure and assessment.
Finally, your article refers to one of the conclusions of our report - that English GCSE grade boundaries were "too generous" in January 2012. You go on to argue that a fourth condition - that previous grade standards were appropriate - was therefore not met. But the purpose of comparable outcomes was to maintain qualification level standards year on year. The issues with January unit awards did not affect previous qualification level grade standards. Therefore, the condition was met.
All five of our conditions were fulfilled. In these circumstances it is appropriate that our comparable outcomes approach was used for awarding this year's GCSE English.
Cath Jadhav, Acting director of standards, Ofqual.