Reforming Key Stage 4 Qualifications Consultation Response Form The closing date is: 10 December 2012 Your comments must reach us by that date. Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the access to information regimes, primarily the Freedom of Information Act 2000 and the Data Protection Act 1998. If you want all, or any part, of your response to be treated as confidential, please explain why you consider it to be confidential. If a request for disclosure of the information you have provided is received, your explanation about why you consider it to be confidential will be taken into account, but no assurance can be given that confidentiality can be maintained. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department. The Department will process your personal data (name and address and any other identifying material) in accordance with the Data Protection Act 1998, and in the majority of circumstances, this will mean that your personal data will not be disclosed to third parties. Please tick if you want us to keep your response confidential. Reason for confidentiality: Name Jocelyn Wyburd Organisation (if applicable) University Council of Modern Languages Address: www.ucml.ac.uk / [email protected] If your enquiry is related to the policy content of the consultation you can contact The Department on: Telephone: 0370 000 2288 e-mail: [email protected] If your enquiry is related to the DfE e-consultation website or the consultation process in general, you can contact the Consultation Unit by e-mail: [email protected] or by telephone: 0370 000 2288 or via the Department's 'Contact Us' page. Please mark the box that best describes you as a respondent. School College Academy Higher Education Institute Further Education Institute Local Authority Subject Association Parent Student Union HT/Teacher Employer-Business Sector Awarding Organisations Governor Other Higher Education subject association – University Council of Modern Languages represents all departments/faculties of languages in UK Higher Education. I am responding as the elected Vice Chair, with responsibility for liaison with other educational sectors. Title 1 Do you agree that the new qualifications should not be called "GCSEs"? x Agree Disagree Not sure Comments: There needs to be a distinction between new qualifications and old reflected in the name 2 a) Do you agree that the new qualifications should be called English Baccalaureate Certificates? Agree x Disagree Not sure Comments: A Baccalaureate is commonly understood as the equivalent of a level 3 rather than level 2 qualification (cf the French Baccalaureate and the International Baccalaureate). The term Baccalaureate is therefore misleading. Is it also understood that no Welsh, Scottish or Northern Irish schools would ever want to enter pupils for these qualifications? Unless this is so, the concept of them being called ‘English’ is also problematic. 2 b) If not, what alternative title should be adopted? Comments: No strong views. Secondary School Certificates? SSCs? It is also not clear in the consultation what thought has been given to what the eventual replacements for GCSEs in subjects other than those currently listed/counted towards the ‘English Baccalaureate’ would be called. High expectation of performance and accurate grading 3 Do you agree with our expectations for grading structures, set out in paragraphs 5.4 to 5.5? x Agree Disagree Not sure Comments: Clear grading related to transparent descriptions of what grades mean in terms of attainment is vital to HE. 4 Do you believe that we should insist on a common grading structure for all English Baccalaureate Certificates or should we allow Awarding Organisations the freedom to innovate? x Common Grading Structure Freedom to innovate Other Comments: There is the danger that different subjects, offered by different awarding bodies would be graded in different ways causing confusion to employers and HEIs if full freedom to innovate is offered. Comparability is also important across subjects (and therefore potentially across awarding bodies). There has been evidence in the past of ‘severe grading’ affecting languages GCSEs negatively and we would not want this to continue through a lack of comparability in new structures. No tiering 5 Do you agree that it will be possible to end tiering for the full range of subjects that we will be creating new qualifications for? x Yes No Not Sure Comments: Grade capping through tiering is not a useful tool and candidates should be given chances to outperform expectations which are currently capped by decisions on the level at which they are entered. 6 Are there particular approaches to examinations which might be needed to make this possible for some subjects? x Yes No Not Sure Comments: Languages: examinations should be structured to differentiate performance by output. Currently, candidates entered at foundation level only may not have the opportunity to demonstrate some aspects of language learning only tested in higher level exams. We would like to see all pupils encouraged to cover the whole curriculum and to be given the chance to demonstrate the skills they have achieved, through inclusion of more open-ended question sets. Assessed 100% by examination, or minimising reliance on internal assessment 7 a) We intend that English Baccalaureate Certificates should be assessed 100% by externally marked examinations. Do you agree? All English mathematics sciences history geography x languages None Comments: We agree for languages – especially if the internal conduct but external examining of speaking tests is continued. Cannot comment for other subjects. 7 b) If not, which aspects of English, mathematics, the sciences, history, geography or language do you believe absolutely require internal assessment to fully demonstrate the skills required, and why? Comments: Size requirement for syllabus 8 Should our expectation be that English Baccalaureate Certificates take the same amount of curriculum time as the current GCSEs? Or should schools be expected to place greater curriculum emphasis on teaching the core subjects? Same amount of curriculum time Greater curriculum emphasis x Other Comments: We would not want study of other subjects to be limited by excess concentration on the so-called EBC subjects. However, there are concerns that in many schools insufficient curriculum time is currently given to languages and this may need to be rectified in recommendations. Examination aids 9 Which examinations aids do you consider necessary to allow students to fully demonstrate the knowledge and skills required? Comments: Consideration could be given to the use of bilingual dictionaries in written (but not spoken) language exams. Dictionary use is an important skill in itself which should be taught more proactively within the curriculum and usage would therefore not be inappropriate. Linguistic competence is not merely judged on the basis of vocabulary memorisation, but on the ability to manipulate language structures, select appropriate lexical items and to use appropriate registers. Some performance is currently hampered by lack of memory/knowledge of individual lexical items while concentration should be given to broader linguistic challenges of comprehension and production. If exams are structured appropriately, minimal dictionary use would be possible within the time available anyway. However, this requires further and deeper discussion. Subject suites 10 Do you agree that these are appropriate subject suites? If not, what would you change? x Yes No Not Sure Comments: They look appropriate to us as non-specialists in these fields. 11 Is there also a need for a combined science option covering elements of all three sciences? Yes No x Not Sure Comments: Track Record 12 What qualities should we look for in English Baccalaureate Certificates that will provide evidence that they will support students to be able to compete internationally? Comments: In languages, there has been considerable European research (e.g. SurveyLang) on second language competence levels of school pupils and indicators for the UK (England) are consistently lower than those in other countries (for most of whom the first foreign language studied is English). If our KS4 qualifications are to be comparable internationally, they should at least reflect the level of competence in languages that our neighbours achieve in English at the same level. This is a major challenge for our whole education system, not only for the qualifications under consideration here. The KS2 initiative for languages is key to this, as is managing progression from KS2 to KS3 if such standards are to be reached. Assurance of literacy and numeracy 13 Do you agree that we should place a particular emphasis on the successful English language and mathematics qualifications providing the best assurance of literacy and numeracy? Agree Disagree x Not sure Comments: Up to a point. But the study of languages (modern and ancient) also provides assurance of and enhances literacy skills. This is often overlooked. We consider that there are or should be vital links in the ways that literacy skills (including stronger emphasis on linguistic awareness/grammar/structures) are taught in the English language curriculum and reinforced in the curricula for other languages to the mutual benefit of both. Employer skills surveys (including CBI, 2012, cited) also demonstrate high levels of dissatisfaction in the language and intercultural skills (higher than their dissatisfaction in numeracy and literacy!!) of school leavers and graduates and concentration only on English and Mathematics risks ignoring these factors. School and Post-16 institution Support 14 In order to allow effective teaching and administration of examinations, what support do you think Awarding Organisations should be: a) Required to offer? Comments: Clear marking criteria and marking schemes. Clear indications of how learning outcomes will be assessed and how higher levels of performance will be rewarded. Past/sample papers are important so that candidates know what to expect of them in terms of the balance of task/question types, layout etc. For languages: Training in the conduct of speaking tests. A range of topics/situations within which candidates will be expected to demonstrate their language skills and a range of functions which candidates will be expected to be able to manipulate. (It is vital that these represent a range rather than a closed set of specific situations and contexts so that candidates and their teachers are given the opportunity to construct language curricula which are relevant, creative and engaging, which is often not the case in respect of teaching to the current GCSE.) 14 b) Prevented from offering? Comments: For Languages: Vocabulary lists. Overly prescriptive topics. Excessive ‘closed’ sample questions. 15 How can Awarding Organisations eliminate any unnecessary burdens on schools and post-16 institutions relating to the administration of English Baccalaureate Certificates? Comments: If examinations are to be 100% externally assessed, some administration will be lower than for current controlled assessments anyway The challenge in languages will always be the conduct of the speaking tests in schools and this needs careful consideration by the relevant awarding body. Qualification supports progression of lower achievers 16 Which groups of students do you think would benefit from a "Statement of Achievement" provided by their school? Comments: Statements of achievement could be useful for all students, not only those who are not entered for the new qualifications . There are concerns, however, about lower achieving students having only a statement of achievement but no qualifications at all. This still needs to be tackled. Statements of achievement for those who do gain qualifications can be compiled from statements from the awarding body of what that achievement means in respect of the grade awarded etc. 17 How should we ensure that all students who would benefit from a "Statement of Achievement" are provided with one? Comments: With so many schools opting out of local authority control (Free Schools / Academies etc) it is difficult to know what powers there are to insist that these be provided by all schools as a matter of course. Equalities 18 a) Do you believe any of the proposals in this document have the potential to have a disproportionate impact, adverse or positive, on specific pupil groups? Adverse impact Positive impact x Both No impact Comments: Raising the status of languages within the qualifications framework will have a positive impact on a range of pupils whose first/home/heritage language is not English, as multilingualism should become more highly valued within the school system. Achievement in languages is central to the qualification. However language study can be seen as ‘foreign’ and language use of relevance only for overseas travel and high-flying ‘global’ careers. The result is sometimes that languages are perceived as demotivating and irrelevant to some socioeconomic groups and risk potentially being obstructive to the achievement of wider academic goals. But see 18b below. 18 b) If they have potential for an adverse impact, how can we reduce this? Comments: There is a strong burden on the languages qualification and the teaching which leads to it to be much more relevant and inclusive in their approaches than has been the case in the past. This could include encouragement of the study of languages spoken in our multicultural society in addition to languages of relevance to the global economy and professional/personal mobility. Implementation 19 Should we introduce reformed qualifications in all six English Baccalaureate subjects for first teaching in secondary schools in 2015, or should we have a phased approach, with English, mathematics and sciences introduced first? x In all six subjects from 2015 Phased approach Other Comments: Although this might be difficult to achieve, we believe that there will be more parity of esteem for the 6 subjects if they are all introduced together – even if it means actually delaying all of them until they can be introduced well. 20 How best can we prepare schools for the transition to these reformed, more rigorous qualifications? Comments: For languages: As a result of the ‘haemorrhage’ in language teaching in KS4 over the past 8 years, there is a diminished and often under-motivated teaching base in these subjects. Language teachers will, if the new qualifications represent a real departure from GCSEs, need considerable professional development to step back and look at new ways of delivering new curricula. Furthermore, subject to outcomes from the KS2 consultation, there will need to be considerable training provided on managing progression from KS2 to maximise pupil learning and progression towards the new KS4 qualifications. This training must be a major priority for government funding. 21 How long will schools need to prepare to teach these reformed qualifications? Up to 12 months x 12 - 18 months More than 18 months Other Comments: This really depends on the availability of training for new approaches to teaching, curriculum reform and the demands of the new qualifications. Languages 22 Should all languages in which there is currently a GCSE be included in our competition? x Yes No Not Sure Comments: As mentioned above (18a and 18b) a wide range of languages of relevance to multicultural Britain, as well as to employers in the global economy should be offered as qualifications at this level. Ancient languages should also be included alongside modern languages. 23 Should the number of languages for which English Baccalaureate Certificates are identified be limited? If so, which languages should be included? Yes x No Not Sure Comments: We understand that there are practical and costly implications for Awarding Bodies in administering examinations in languages for which there are few entrants. However, the presence of languages as a central plank to the reform of KS4 qualifications needs to be accompanied by a renewed drive to communicate why languages are important educationally. This includes valuing the languages spoken in our multicultural and diverse society as well as the languages of relevance to employers and the global economy, motivated by issues of socio-cultural cohesion and intercultural understanding, in addition to the instrumentalism of languages as vital to a skilled workforce and the UK economy. 24 Given the potential number of new languages qualifications to be developed, should they be introduced to a later timescale than history and geography English Baccalaureate Certificates? Yes No x Not Sure Comments: Yes and no: ideally they would all happen at once, but for practical purposes we believe one tranche could be introduced earlier (e.g. French, German, Spanish, Latin, Mandarin, Arabic) – with others to follow. We would not want all languages to have to be delayed and therefore relegated below history and geography in terms of public perception of their importance as academic subjects. Post-16 25 Should we expect post-16 institutions to be ready to provide English Baccalaureate Certificates at the same time as secondary schools? x Yes No Not Sure Comments: There is an issue of equality of opportunity here. If the new qualifications do indeed achieve the aims of being seen to be of higher quality and validity, then post 16 candidates should have equal access to them from the moment they are available. 26 How best can we support post-16 institutions to prepare to provide English Baccalaureate Certificates? Comments: Training – in clusters with local secondary schools. The issue of workforce deficit is surely a current challenge (implementation of Wolf review) unrelated to the introduction of the new qualifications. Choosing the best qualification in each subject 27 Do you agree that five years is an appropriate period for the new qualifications to feature in the performance tables before the competition is rerun? Agree Disagree x Not sure Comments: At least 5 years? 28 Please let us have your views on responding to this call for evidence (e.g. the number and type of questions, whether it was easy to find, understand, complete etc.). Comments: All documentation was clear, easy to find and understand and the form is easy to complete. Thank you for taking the time to let us have your views. We do not intend to acknowledge individual responses unless you place an 'X' in the box below. Please acknowledge this reply Here at the Department for Education we carry out our research on many different topics and consultations. As your views are valuable to us, would it be alright if we were to contact you again from time to time either for research or to send through consultation documents? xYes No All DfE public consultations are required to meet the Cabinet Office Principles on Consultation The key Consultation Principles are: departments will follow a range of timescales rather than defaulting to a 12-week period, particularly where extensive engagement has occurred before departments will need to give more thought to how they engage with and consult with those who are affected consultation should be ‘digital by default', but other forms should be used where these are needed to reach the groups affected by a policy; and the principles of the Compact between government and the voluntary and community sector will continue to be respected. Responses should be completed and emailed to the relevant consultation email box. However, if you have any comments on how DfE consultations are conducted, please contact Carole Edge, DfE Consultation Coordinator, Tel: 0370 000 2288 / email: [email protected] Thank you for taking time to respond to this consultation. Completed questionnaires and other responses should be sent to the address shown below by 10 December 2012 Send by post to: Public Communications Unit Level 1 Area C Castle View House East Lane Runcorn WA7 2GJ Send by e-mail to: [email protected]
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