Learning and Skills (Wales) Measure Committee

(Saesneg yn unig)

Written Evidence

Oxford Cambridge and RSA Examinations (OCR) is grateful to the Committee for its invitation to submit written evidence, further to the formal consultation response provided earlier in this legislative process.

This written evidence contains:

1. Brief introduction to OCR

2. Short executive summary of OCR’s response to the proposed measure (including the Explanatory Memorandum)

3. Direct response to the 4 questions posed by the Chair, Jeff Cuthbert AM

4. Contact details

1. Introduction to OCR

OCR (Oxford Cambridge and RSA) is a leading UK awarding body, providing a wide range of qualifications to meet the needs of learners of all ages and abilities. OCR qualifications include AS/A Levels, GCSEs, OCR Nationals, Key Skills, Entry Level qualifications, NVQs and vocational qualifications in areas such as IT, business, languages, teaching/training, administration and secretarial skills.

Each year more than three million students gain OCR qualifications, which are offered by 13,000 centres including schools, sixth form colleges, FE colleges, training providers, voluntary organisations, local authorities, and businesses ranging from SMEs to multi-national organisations.

OCR is a not-for-profit organisation; any surplus we make is invested back into the company, helping us develop qualifications and support which keep pace with the changing needs of today’s society.

OCR is part of the Cambridge Assessment Group, Europe's largest assessment agency, which celebrates its 150th anniversary in 2008. Cambridge Assessment plays a leading role in researching, developing and delivering assessment across the globe.

OCR Cymru is a branded identity for our team in Wales, working out of our office in Cardiff. OCR has had a base in Wales since 1994 and employs a team of staff to provide customer support and assessment services to the 400 Welsh centres that are delivering OCR qualifications to learners of all ages and abilities.

2. Short executive summary of OCR’s response to the proposed Measure (including the Explanatory Memorandum)

OCR welcomes the main policy objective of the proposal, namely to establish a broad range of learning choices for 14-19 learners that includes vocational and general programmes of learning and that these programmes should lead to the achievement of recognised qualifications.

Despite the Explanatory Memorandum that was issued following the initial consultation, some key matters remain unclear. Although some ambiguity should be expected, and actual experience will resolve a great deal in time, it is not helpful if some of the ambiguity is to do with the roles and responsibilities of key agencies and, moreover, how they can be held to account for the way in which they discharge these responsibilities.

A local curriculum based on a prescribed minimum offer to both 14-16 and 16-19 is a fundamental aspect of these proposals. It would be helpful if this aspect could be made more tangible - what do the drafters of this proposal think this local curriculum should contain? And is the process for developing this template transparent and inclusive? These issues remain debateable.

Greater choice in learning is a good thing, but it is also presents challenges. Two of the biggest challenges will be: creating capacity among deliverers, and improving the quality of guidance to learners so that they can make informed choices. The Proposal and Explanatory memorandum leave these matters unresolved.

Finally, there is an assumption at the root of this Proposed Measure that could be challenged. The assumption appears to be that in order to address a perceived skills need it is necessary to reform the supply side i.e. in order to make learners adopt a broader learning programme that better meets the skills needs of a modern economy, a duty needs to be placed upon providers to work together to develop a broader curriculum offer and a target should be set for what this offer should contain. But what if the problem is not to do with supply? It is arguable that there is a wealth of broader curriculum opportunities within the system at present BUT that this is not fully exploited. For example, OCR Nationals are a viable vocational alternative to GCSEs and A Levels that increasing numbers of schools and colleges in Wales are using - but their growth is hampered by an inflexible set of attainment targets (5 A*-C GCSE) and an obstructive system for recording such attainment (the infamous RE2). Particularly in the latter case, a significant step towards a broader curriculum could be taken without needing new legislative powers.

A fifth of the schools and colleges in Wales are currently offering the OCR Nationals, and this proportion is growing. Among them, several have replaced the ICT GCSE with the OCR National ICT Level 2 for whole cohorts. Their decision is based on their appreciation of the appropriateness of this qualification for the needs of their students. But the decision, for schools, is not facilitated by the target-setting and performance measurement systems in which they currently have to operate.

It is clear that the Measure, as proposed, will contribute to achieving the declared policy objective; it is less clear, however, if it will deliver the breadth that it appears to be aiming for without further clarification of key aspects.

3. Direct response to the 4 questions posed by the Chair, Jeff Cuthbert AM

i) Is there a need for legislation to re-organise 14-19 provision?

Yes, legislation is required if the curricular aspirations of the Learning Pathways initiative are to be realised. But significant steps towards these aspirations remain possible without the need for legislation.

Estyn reports have recently shown that there is a great deal of collaborative effort among providers that is delivering a broader curriculum offer to 14-19 learners than in previous generations of learners.

But this breadth falls short of the aspirations that are linked to the Learning Pathways initiative. This shortfall can be partly explained by systemic factors, including the existence of separate funding and decision-making structures at 14-16 and post-16.

At 14-16, Local Authorities have a lead role; in post-16, WAG has a lead role. If this distinction continues, it is unlikely that the aspirations of the learning Pathways initiative will be realised in full because of the difficulty involved in aligning two separate centres of influence. This distinction will need legislative action if it is to be resolved conclusively.

ii) Does the proposed Measure achieve the policy objective or could changes be made without legislating?

A great deal can still be achieved without needing legislation. For instance, many schools continue to resist the introduction of viable vocational alternatives to GCSEs because, they say, their attainment targets and the system for recording them do not give due recognition for vocational achievement. Schools are penalised for adopting vocational alternatives to GCSEs and the stubborn disparity of esteem between general and vocational education is re-enforced. Despite many assurances that these systems would be reformed (the RE2 system), it continues to skew the market and inhibit innovation in curriculum development. It does not appear that any legislation is required to bring about this change.

OCR Nationals are the fastest growing suite of vocational alternatives to GCSEs and A Levels in the UK. The growth of OCR Nationals in Wales has been led by schools that have been determined enough to defy this systemic disincentive to innovation. A system in which they were able to work with the grain is surely desirable.

A fifth of the schools and colleges in Wales are currently offering the OCR Nationals despite this systemic disincentive, and a minimum of 3,500 14-19 year olds are currently registered as candidates.

iii) What are the views of stakeholders who will have to work with the new arrangements?

OCR currently supports many of the initiatives that are unique to Wales - the Welsh Baccalaureate, revised Diplomas, and a unique Key Skills assessment are just a few examples And our record of working collaboratively with the authorities and agencies in Wales, both before devolution and after, is a positive one. OCR fully intends to continue with this collaborative approach as the education and learning system in Wales continues to develop.

But this collaborative approach does require reciprocity if it is to flourish.

It is important that a transparent and open system of stakeholder engagement underpins the work of the agencies that will be responding to the challenges that they will be given in light of this Measure. Specifically, the development of a template for the local curriculum that specifies minimum learning options would benefit from the early and thorough engagement of OCR and other awarding bodies.

iv) What might be the barriers to delivering the policy agenda and does the proposed Measure take account of them?

Among the barriers that are frequently discussed are: funding inconsistencies between 14-16 and 16-19 learning; a legacy of competition between schools and colleges; unclear lines of responsibility for learners as they access different providers; rural-urban characteristics requiring different approaches; transportation of learners; and Welsh medium requirements. The Measure and the Explanatory Memorandum takes some account of some of these.

One of the lesser-discussed barriers to delivering the policy agenda that is worth emphasising here is the information, advice and guidance (IAG) that learners receive. There is a wealth of qualifications available that are ideally suited to sustaining the breadth (and depth) of provision that most learning providers, and many learners, aspire to. There is no lack of supply. But there is a problem in demand. Many practitioners, let alone learners, are not as well informed about the qualification options available to them as they need to be if they are to make informed decisions. It is essential that more choice of learning opportunities is supported by well-informed, impartial and current Information, Advice and Guidance (IAG) activities.

4. Contact details

Robin Hughes
National Manager, Wales
OCR Cymru
Windsor House
Windsor Lane
CARDIFF
CF10 3DE
Tel.: 02920 537 810
Fax: 02920 537 820