At a time when confidence in the exam system is at an all-time low, one might expect to look to the qualifications watchdog for solutions. Instead, the fallout from December's scandal over exam board seminars is revealing almost as much concern about Ofqual as about the behaviour of the boards themselves.
Professor Alison Wolf, the government's adviser on vocational education, told MPs last month that the regulator was "so busy looking at the blades of grass that it was missing the forests".
Another government adviser - Tim Oates, leader of the national curriculum review - was among several researchers warning the same Commons education select committee meeting that Ofqual lacked expertise and needed "reinforcements".
Others might wonder whether the watchdog is exhibiting the level of concern over The Daily Telegraph revelations - which were about examiners giving inappropriate information to teachers - that ministers would like.
A reportedly shocked Michael Gove declared that the stories showed the exam system was "discredited", warning that "nothing is off the table" when it comes to reform.
But Ofqual's report last month took a much more measured tone. The watchdog examined the newspaper's evidence and found that, while it backed up "some" of its allegations, "most of the material we have reviewed does not show such unacceptable practice".
Ofqual also seemed at odds with the education secretary in October when it reported that A levels "stood up pretty well" compared with equivalent qualifications in other high-performing countries. Mr Gove has said that exams in England are "below par when compared internationally".
Of course, independence is an essential regulatory quality and the fact that Ofqual is not automatically taking ministers' line could be seen as a very healthy sign. Less reassuring is the fact that experts working for, or sponsored by, the very exam boards that might be expected to welcome Ofqual's conclusions on A levels are actually questioning its methods.
Michelle Meadows, research director for the AQA board, told MPs that "what they are really looking at there (in its international A-level study) is the content of the qualifications ... which is somewhat different from grading standards".
She also said that the methodology in Ofqual's comparability studies of qualifications was not robust enough and that the watchdog needed more expertise.
Ofqual chief executive Glenys Stacey has described expertise in assessment as "a rare thing" and said that her organisation will be "reaching out" to those in exam boards and universities who possess it. The watchdog also said that it canvasses and takes account of opinion of its "robust" methodology before finalising it.
But Jo-Anne Baird, Pearson professor of educational assessment at the University of Oxford - a post paid for by the parent company of the Edexcel board - claims that Ofqual does not even have the necessary expertise to deal with any external advice it receives.
Cynics may suggest that exam boards have a vested interest in shifting attention from their own troubles and undermining a regulator that will soon have the power to fine them. But the boards argue that weak regulation does them no favours because it damages confidence in the system as a whole. And Ofqual's fiercest critic at the committee, Professor Wolf, has nothing to do with exam boards.
She wants the watchdog to abandon "completely nuts studies of pricing" so that it can afford "some decent in-house statistical help" for its comparability studies.
Fears that the watchdog was losing vital know-how when key staff left were being expressed as long ago as October 2010. But since then its job has got even tougher. Ofqual's extended remit requires it to ensure that England's exam standards are both consistent over time and comparable with other countries. Even ministers have conceded that this is a contradiction.
Ms Stacey has admitted a "seeming tension", but insists that she finds it "quite helpful". The lawyer, who once led the government's response to the 2007 foot and mouth outbreak, said last year that "it takes a fair while for regulators to develop, to mature, possibly 10 years".
But with Mr Gove considering major changes to the exam system now, Ofqual does not have that long.
"Could we see yet another radical reform of structure at great expense with risks for standards brought in because we have not got enough in place to resist it?" asked Graham Stuart, chairman of the education select committee. "If Ofqual is not in the best position to counter any misapprehensions, whether of this committee or ministers, is this a dangerous moment?"
Researchers connected to England's three main exam boards have told MPs that decisions taken by examiners are contributing to grade inflation.
Jo-Anne Baird, Pearson professor of educational assessment at the University of Oxford, said that small annual rises in results were often explained by examiners' judgements, which she had "not always been entirely convinced by".
Michelle Meadows from AQA said that examiners had to set grade boundaries within 1 per cent of where statistics from previous years suggested they should be. But there was still a tendency for them to "lean on the generous side" and go "slightly above" previous years.
Tim Oates, head of research at Cambridge Assessment, which runs the OCR board, said: "There is a culture of increasing results and an expectation of increased performance in every respect.
"It kind of pervades the system and insidiously affects individual decision-making on a day-to-day basis."