The Frontier economics report on the qualifications market is the latest report in a series which stretches back to DfE’s analysis on UK examinations in 1999, managed by Christina Bienkovska, and the 2010 PWC report. Unusually, the report does not attempt to quantify the value of the market and the exact relations between costs in the education system, and who carries those costs.
Given the highly contested nature of regulation and market intervention – not least in the light of the present fundamental disagreements about market stimulation in the face of recession – it is somewhat of a surprise that the Frontier report makes no formal reference to alternative models of regulation and market operation. The report mentions the body of ‘evidence’ and ‘research’ which was considered, but does not list what this is. This is not a trivial matter of academic record. The report seeks not only to describe what HAS happened, but also predict what WILL happen. Prediction is a highly contested area of economics and there are strict limits to it (Hendry 1979, Bhaskhar 1998, Gonzalez 2015). Basing future regulatory policy on undependable prediction is a risky proposition; dependability relies on the factors considered and modelling of their interaction.
Regrettably, the report omits realistic consideration of some essential, complex interactions in the system. For example, regulation is increasing the similarity of qualifications in a subject such as mathematics. This enables schools to switch more readily between qualifications and to enter students for more than one board. This undermines the assumptions of ‘comparable outcomes’, the crucial statistical method used by the regulator to maintain standards between boards and over time. Thus, switching and standards are intimately connected. If, as in this report, any analysis underestimates the extent to which schools ‘chase’ apparently easier specifications and more ‘accessible’ assessments, a major dynamic of the market is inadequately recognised.
The report makes no reference to the purpose of public examinations, which are not some stand-alone leisure commodity, but support a vital public function, as a complex assurance of the content and quality of learning programmes, as well as supporting a wide range of other functions (See the 2010 CEDEFOP report Changing Qualifications). The report thus omits consideration of the wider economic purpose of qualifications. Their value to the State and to individuals – both those who possess them and those who use them - is not adequately recognised.
The report is weak on the importance of investment for renewal and innovation. Regulation has introduced very substantial additional cost to the system, both through its support to intensive and continuous programmes of State-led change, and through escalation in specific regulatory requirements. At the same time, award bodies continue to invest in transformation of delivery (including necessarily high levels of investment e-assessment), of assessment forms and procedures and curriculum content. These are not a ‘nice to have’ but are essential to modern domestic assessment and the country’s international lead in measurement and assessment. This is an issue not just for individual awarding bodies but affects international earnings to the UK economy.
The paper also makes assumptions about the composition of the market. While it reflects the Government’s emphasis on reformed GCSE and GCE, it ignores the issues of genuine interchangeability in some qualifications – a key matter in comprehensive market analysis. The Wolf Report (2011) legitimately reduced interchangeability by moving the system away from equivalences between UNLIKE qualifications, citing adverse educational impact. Such equivalences previously were driven by official funding regimes and accountability arrangements.
However, post-Wolf, outside GCSE and GCE regulation there exist high quality qualifications which are relied on extensively by high-performing schools and by universities, and which are directly interchangeable with regulated qualifications. These include IGCSE and PreU qualifications from Cambridge Assessment. Many non-GCSE ‘Level 2’ qualifications – the category in which IGCSEs sit – are very UNLIKE GCSEs – both in form and content. These are not genuinely interchangeable with GCSEs. However, pupils with IGCSEs progress to elite universities around the world – the qualifications share many elements of content and assessment with GCSEs and are genuinely interchangeable in most subjects – Maths, English, history and so on – by virtue of what they are and what they enable, not just by fiat or policy diktat. They are widely taken and prepare children well.
A full and comprehensive market analysis must include all active elements, and such qualifications remain essential to the operation of education arrangements as a whole. The omission of the impact and operation of such interchangeable qualifications renders the Frontier analysis highly partial, and detracts from its predictive power. The risks of undue restriction are not recognised.
Finally the report adopts a specific regulatory mindset, suggesting that the only response to risk is to increase regulatory intervention (see para 108 amongst others). Beyond the very real option that reduced regulation can be a suitable response in any system where regulation itself carries the possibility of inducing market dysfunction or breakdown, this is in stark contrast to UK Government education policy – which currently is committed to reducing State control of assessment in schools.
While the report has some interesting insights into switching behaviour and a number of dimensions of the market, the report possesses some serious limitations.
Tim Oates CBE,
Group Director Assessment Research and Development