Christine Chapman AM
Chair, Children and Young People Committee
National Assembly for Wales
Cardiff
11 January 2013
Dear Christine
14-19 Qualifications Review and “Qualifications Wales”
We followed with interest your Committee’s discussion of the 14-19 Qualifications Review with Huw Evans and Kate Crabtree on Wednesday, which was particularly timely as the Minister had issued a statement the previous day in relation to “Qualifications Wales”.
WJEC’s brief initial response to the overall 14-19 report was issued on 28 November, and is included as an annexe to this letter. We welcomed the overall recommendations, but on the report’s proposals on matters such as regulation and organisational structures we indicated that these “merit further evaluation and detailed discussion”, and suggested that “these must not distract from the urgent need to develop 14-19 qualifications and learning programmes which fully meet the needs of young people in Wales”.
Whilst we agree with Huw Evans that Wales can indeed build “world class” arrangements for 14-19 qualifications, we have several real concerns that the overall vision and strategy is not being helped by the sequence in which matters are currently being addressed by the Welsh Government. Given the scrutiny role of the Children and Young People Committee, we thought that it might be helpful if we shared with you the following perspective on this week’s developments:
i.
we fully agree with
the Minister’s statement that regulation needs to be
"strengthened and separated from Government" (first stated on
5th Dec and reaffirmed in 8th Jan
statement)
ii.
the need to
strengthen regulation in Wales is urgent in order to deal with the
major development agenda that's being set out for 14-19
qualifications
iii.
the independence of
the regulator for Wales, from government and from awarding
organisations, will (amongst other things) ensure that it is better
placed to engage with the other nations on the current and evolving
provision of qualifications that come within the GCSE and GCE
frameworks, including work relating to comparability of
standards
iv.
Huw Evans is
therefore absolutely right in his suggestion, as conveyed to the
Children and Young People's Committee (9th Jan) that the
"Qualifications Wales" organisation needs to be established in the
first instance as a regulatory body, reflecting the wording of
recommendation 5 of the 14-19 Qualifications Review
v.
in order to do this,
the urgent priority is to achieve clarity on (a) what policy role
will be retained by Welsh Government in relation to curriculum,
skills and qualifications frameworks for Wales, and (b) what
regulatory functions does government want "Qualifications Wales" to
undertake on its behalf, in relation to general qualifications and
vocational qualifications; it then becomes possible to define the
kind of arm's length relationship which "Qualifications Wales" as
regulator should have with Welsh Government; any due diligence
exercise (for which a specification has already been issued by
Welsh Government) in relation to "Qualifications Wales" is
potentially meaningless unless (a) and (b) have been clearly
defined
vi.
in the interests of
learners in Wales, the strengthened regulatory arrangements should
be in place as early as possible; this is because a considerable
proportion of the 14-19 qualifications development work will need
to be instigated in 2013, for completion and accreditation in 2014
so that the resulting programmes of learning can be delivered
by schools and colleges from September 2015
vii.
our understanding is
that the technical/legal aspects associated with establishing
"Qualifications Wales" as a regulator in the first instance are
considerably more straightforward than the very different set of
issues that would need to be addressed in order that it should also
be an awarding organisation; hence it would not be unreasonable to
aim for a twelve-month timeline to set up "Qualifications Wales" as
a strong regulator that's independent of government and of awarding
organisations; this would allow “Qualifications Wales”
to be the organisation which accredits several new qualifications
which will need to reach that stage in 2014 if they are to be
delivered in 2015 as recommended by the 14-19 Qualifications
Review; we believe that the alternative is unacceptable to
stakeholders, i.e. that current regulatory arrangements (not
strengthened and not separated from Government) continue to oversee
a major part of the intended 14-19 qualifications reform
programme
viii.
the new regulatory
model for Wales needs to be carefully defined to be fit for purpose
in the systems context within which it is to work: key features of
that systems context include whether the regulator (a) will be
working solely with qualifications frameworks which are
Wales-specific, or whether there needs to be engagement with
frameworks which are shared with other nations; (b) will be working
with one or several awarding organisations; (c) will be regulating
Wales-based awarding organisations only, or will also be regulating
provision in Wales by awarding organisations that are based outside
Wales
ix.
the key features of
the systems context can be different for vocational and general
qualifications, and this will need to be reflected in the design of
the regulatory model
x.
whilst the
regulatory model for Scotland is one which is well worth studying
in further detail, transference to Wales of what can be learned
from it needs to take account of very important differences in the
systems contexts of the two countries
xi.
doing anything other
than pressing ahead urgently with designing and implementing
a strengthened regulatory model for Wales adds huge risk to current
arrangements in Wales and prejudices the quality of the excellent
set of 14-19 qualifications development proposals that are
contained in the Huw Evans report
xii. unfortunately, the statements and documents that have emerged from Welsh Government this week provide little assurance that addressing the regulatory model is being recognised as an urgent priority in its own right; there is potential to do immense damage by getting this wrong, especially by focusing instead on the different and more complex issues which arise in the context of designing a single organisation that fulfils regulatory and awarding functions; such a model, at best, can’t be in place until late 2015, and even then it might not be the optimal model for Wales’ systems context; we consider the strategic implementation of the vision for 14-19 qualifications set out in the Huw Evans report to be currently at risk, and this should be a matter of major concern to all learners and stakeholders in Wales.
The above high level perspective is not the right vehicle for us to clarify more detailed specific issues, some of which have been handled with considerable inaccuracy in the public domain this week. We are therefore in the process of compiling a summary of such issues, which we will forward to you once it is completed.
In terms of forthcoming discussions with Welsh Government, WJEC is focussing on the early priorities within the 14-19 qualifications development proposals. These include the proposed qualifications for literacy, numeracy and digital literacy, the proposed evolution of the Welsh Baccalaureate framework and its component parts, and the IVET/CVET proposals. We have no formal meetings scheduled to discuss “Qualifications Wales”, but we will do all that we can to encourage urgent consideration of the regulatory model in the context of the imminent qualifications development work.
In closing your Committee’s session on Wednesday, you indicated that you would expect to be returning to the 14-19 Qualifications theme over the coming months. Please be assured that WJEC will be very willing contributors to any discussion which you would wish to have, and indeed would be pleased to meet with you and/or the Committee.
Yours sincerely,
Gareth
Pierce
Chief Executive
cc
Members of Children and Young People Committee
Minister and Deputy
Minister
other Stakeholders
Annexe
WJEC’s response to the publication of 14-19
Qualifications Report
[20th November 2012]
WJEC welcomes the thorough approach taken by Huw Evans and his
review board in addressing a range of complex and important
educational issues. As the major organisation in Wales tasked with
delivering qualifications and providing related support to schools
and colleges, we also welcome the report’s recognition of the
central role WJEC plays at the heart of the nation’s
education system.
Huw Evans’ report makes a number of significant recommendations regarding 14-19 qualifications, which are of vital importance because of their influence on learning programmes for this age group. We must ensure that these programmes and the qualifications to which they lead are of the highest quality and that the public can have full confidence in their integrity and their international comparability.
It is WJEC’s priority in Wales to support the Welsh Government in meeting the educational needs of the young people of Wales. We endorse the report’s recommendation that qualifications in Wales should diverge from those in other parts of the UK where this is the best way of achieving this aim.
We agree that the Welsh Baccalaureate framework should be developed further, and we are already working on refinements to the qualification with the Welsh Government. We also agree that A levels should be retained in Wales; these are an important part of WJEC’s services for learners in Wales, England and Northern Ireland. In addition to supporting new general and vocational qualifications for Wales we are also committed to continuing our current provision of qualifications in England, including GCSEs and any proposed successor qualifications.
The report’s proposals on matters such as regulation and organisational structures merit further evaluation and detailed discussion, however these must not distract from the urgent need to develop 14-19 qualifications and learning programmes which fully meet the needs of young people in Wales. We look forward to studying the report’s recommendations in detail and contributing to opportunities for debate during the period leading up to policy decisions by the Welsh Government.