As we pass the first anniversary of Ofqual’s new rules for reviews of marking and moderation (RoMMs), many subject departments will be nearing completion of what are now called “non-examined assessments” - coursework - and setting in motion the wheels of their internal moderation procedures.

It will be a much more arduous and potentially more divisive process than in previous years - and certainly more fraught. Previously, schools were not obliged to tell students what their coursework marks were - though in practice they often did. Now the Ofqual/Joint Council for Qualifications rules stipulate not only that schools have to inform students of their marks, but also that they have to:

• advise them that they may request copies of materials to assist them in considering whether to request a review of the centre’s marking of the assessment;
• having received a request for copies of materials, promptly make them available to the candidate;
• provide candidates with sufficient time in order to allow them to review copies of materials and reach a decision;
• allow sufficient time for the review to be carried out, make any necessary changes to marks and inform the candidate of the outcome, all before the awarding body’s deadline;
• ensure that the review of marking is carried out by an assessor who has appropriate competence, has had no previous involvement in the assessment of that candidate and has no personal interest in the outcome of the review;
• instruct the reviewer to ensure that the candidate’s mark is consistent with the standard set by the centre;
• inform the candidate promptly in writing of the outcome of the review of the centre’s marking.

And for all of this “centres must plan to complete the following activities ahead of the awarding bodies’ published deadlines for the submission of marks” - that is, the middle of May. In order to fulfil these requirements, schools will, therefore, have to ensure that students submit the final versions of the NEA weeks earlier than in previous years.

As a result, over the past months many schools have been setting up pseudo-appeals panels to deal with appeals against the marking within their centres, should a student wish to contest a NEA mark - a mark which, it should be remembered, has already been internally moderated.

Across the country, departments have had to “quarantine” some teachers so that they play no part in the teaching or marking of NEAs. Where departments are too small to have the human resources to run this extravagant process, they have had to form cross-centre alliances to field a moderator if required.  

It should also be noted that many hours have already been invested in the processes necessary to arrive at a fair mark: initial marking of scripts (2,500-3,000 words for English literature); a second reading by another qualified member of the department; and, in the case of our department and many others, a meeting to discuss the merits and limitations of the coursework assignments. No one would argue that these stages are not good practice; indeed, the awarding bodies (exam boards) explicitly require them, along with copious annotation in the margins of the essay indicating where levels of achievement have been met; an extended summative statement at the bottom of the essay which summarises and evaluates the achievement overall; and a mark by the side split between assessment objectives.

An extra burden on overworked teachers

In contrast, the online exam marking of some exam boards (Edexcel, for example) involves no annotation whatsoever. If a school wishes to challenge the marking after results have been issued, it has to pay a fee higher than the original exam entry fee to have the script annotated by a senior examiner. Why do teachers acting (unpaid) as internal moderators have to provide such copious justification of marks awarded when examiners (paid) do not?

The disproportionate level of effort expected from internal moderation is designed to ensure that external moderators employed by the exam boards can readily verify the standards and be equally satisfied, when comparing schools within their allocations against national standards, that a fair mark has been awarded. Moderators have the power to overturn or modify the original marking and put the grade(s) up or down. It is also possible for them to apply scaling, whereby a centre will not need to be re-marked completely if its totals are judged to be consistently too generous or too mean.

Given that board-appointed moderators are there to do the very job that centres pay them for - ie, check the marking and make any necessary adjustments - it seems incomprehensible that centres should now be expected to put in place their own moderators.

This latest requirement instigated by Ofqual is a poorly-judged initiative for the following reasons:

1. It places undue pressure on the teacher-student relationship by giving students the power to challenge their teachers’ judgements. Just recently, Ofqual has had to consider the wisdom of allowing teachers to set exams because it perceives (on the basis of a tiny rogue minority) risk in a teacher being too close to students and therefore crossing the professional line. Yet it has put in place for NEA a procedure that will make it very difficult for teachers to remain impartial in their coursework assessment in the face of parental pressure. The effect on school-home relationships is potentially very harmful.

2. Imagine a scenario where a student does challenge the marking and is awarded a higher mark by the in-school moderator. The effects on confidence in the judgement of the original markers can be detrimental to the trust that should exist and to the impartiality of the teacher-markers next time.

3. It wastes human resources that should have been available to assist with the cross-checking of the marking in the first place.

4. Even where a student is given a higher mark than the original one, there is still no guarantee that the new mark will stand - it has yet to be moderated and validated by the external moderator.

5. An appeal has the potential to skew the centre’s marking by disrupting a rank order that has been very carefully checked through the internal moderation procedure. This could result in the whole centre needing to be re-marked if the marking is then judged inconsistent by the external moderator.

6. Whilst exam boards can command a fee for their appeals, centres cannot - they pick up the time tab and have to absorb it into their system.

7. It adds considerably to the workload of the department.  

Finally, schools and colleges are compelled to “outsource” their marking, and they pay a hefty fee for the services they are given by the various boards. Surely moderation of coursework should come into that category without expecting quasi-appeals panels to be set up all over the country. 

As Ofqual once reminded Mark Dawe, the then-head of OCR, it is the examination board’s responsibility to provide enough markers to do the assessment job. It ought to be the same with moderators, too. Teachers are already doing the marking and moderating for the boards and for the regulator - and they are expected to do the appeals as well as completing the job that the board has been paid to do.

It is like employing a gardener to watch you mow your lawn and trim the edges.

Yvonne Williams is a head of English and drama in the south of England.  Her wide-ranging article on the impact of changes to the review of marking and moderation will soon be published in  the spring edition of The Use of English, the journal of the English Association.

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