Ofqual first identified a major problem at the heart of this summer's English GCSE grading crisis almost three years ago but failed to act on it, TES can reveal.
The exams watchdog highlighted concerns that modular GCSEs created particular risks in maintaining standards because they allowed pupils to "bank" grades early. It even came up with a workable solution that might have avoided the row that has erupted since last week, but decided not to implement it.
The news came as the number of schools that say their pupils have lost out because of a shift in grade boundaries between January and June continued to rise.
As TES went to press, figures supplied by the Association of School and College Leaders (ASCL) suggested that a quarter of all secondaries in England and Wales had been affected, with complaints from elite independent schools starting to filter through.
Ofqual is today due to publish the interim findings of its inquiry into the English GCSE controversy. But the watchdog's chief regulator, Glenys Stacey, has already set out where she thinks some of the problems may lie.
In a letter sent last Saturday, responding to heads' union the NAHT's concerns about grade boundary changes, she admitted: "It is always a challenge to secure comparable outcomes in modular graded qualifications.
"The key difficulty posed by modular qualifications is that when the qualification awards come to be made, some modules have already been awarded, so the scope for adjusting grade boundaries so that standards are set correctly is reduced," Ms Stacey continued. "Modular GCSE English presented particular difficulties this summer."
Her predecessor as Ofqual chief regulator, Isabel Nisbet, raised precisely that issue in October 2009 when modular GCSEs were first introduced. She identified the potential problem with Ofqual's duty to maintain standards between whole qualifications when they were modular.
Grading of individual modules could mean that when it came to the overall grade "the outcome is automatic", Ms Nisbet said. "The machine goes ping and out pops the candidate's results. There is no discretion."
As a solution, she proposed banning pupils from "banking" grades from modules towards final results. Marks from modules could stand, but the grades awarded would remain provisional until the overall mark for the qualification had been finalised.
This week, Ofqual said that the idea "was put forward for discussion" but "was not a formal proposal".
Brian Lightman, ASCL general secretary, said modular exams made avoiding grade inflation more difficult. "But there are ways of dealing with this and the awarding bodies should have applied the experience they had years ago when implementing these exams," he said. "This clearly hasn't happened and may well be a reason for the crisis we are now facing."
Ms Nisbet, who left the regulator last year, did recognise downsides to her solution. Pupils might feel cheated if provisional grades were changed and it might encourage "game-playing" among schools over when was a good time to cash in modules.
She also revealed that Ofqual had rejected an alternative strategy of allowing the modification or "hyper-correction" of a final module as an adjustment mechanism to the overall result.
But some fear that something similar may have happened this year as Ofqual and exam boards sought to ensure that this summer's grades remained comparable to previous years.
Asked this week by TES whether Ofqual was aware of the specific changes made to GCSE English language and literature grade boundaries this summer, Ms Stacey was equivocal.
"I won't say we were aware of the specific details of all grade boundary changes," she said. "We were aware that awarding bodies were following processes to make sure that their grade boundaries were right. And we were aware that was particularly challenging for them on the controlled assessment units."
Some critics argue that because of Ofqual's key role in the exams system and ensuring that grades are comparable with previous years, the watchdog is effectively investigating itself.
Russell Hobby, NAHT general secretary, said he wanted "an independent review of the whole situation".
The Headmasters' and Headmistresses' Conference (HMC), a group of elite independent schools, revealed this week that members were starting to come forward with stories of pupils who received lower English GCSE grades than expected.
Ian Power, from the HMC, said the CD borderline appeared to be a particular problem, but there were also concerns in the "AA* area". But the ASCL believes that pupils from the most disadvantaged backgrounds have been hit hardest by the grade boundary changes.
The story so far
- Many schools receiving GCSE results last Wednesday found that their English grades were significantly below what was expected.
- The furore the next day overshadowed the first overall fall in A-A* and A*-C GCSE grades in the qualification's 24-year history.
- Efforts to curb grade inflation appeared to have badly backfired as schools feared their pupils' futures and their own floor targets were jeopardised by grade boundaries that rose between January and June.
- On Friday, TES revealed that heads were investigating whether the changes discriminated against ethnic minority and disadvantaged pupils.
- By Saturday afternoon, Ofqual had bowed to calls for an inquiry.