Accountability, Assessment and the New National Curriculum: Part One


This post examines the Primary assessment and accountability consultation document published on 17 July 2013, considering its contribution to the emerging picture of National Curriculum, assessment and accountability reform across the primary and secondary phases.

It is a revised, expanded and updated version of an earlier post, published on 10 July, which foregrounded the revised National Curriculum proposals published two days earlier. Given its length I have divided it into two parts of roughly equal length.

Readers who prefer to focus exclusively on the fresh material should go to the emboldened sections of the text, or to this separate post containing the core argument.

I had always intended that this final version would explore the interplay between three major reforms – the revised proposals for the new National Curriculum, its assessment from 2016 when National Curriculum Levels are taken out of service and the associated arrangements for the publication of assessment outcomes in School Performance Tables – and offer some preliminary judgement of whether, taken together, they amount to a coherent and viable policy package.

There is a symbiotic relationship between curriculum, assessment and accountability. There are also important considerations associated with continuity and progression between phases.

The long-delayed primary assessment and accountability document had been expected since June 2012 and the timetable for publication was extended on more than one occasion. Such delay is typically evidence that there is disagreement over fundamental aspects of the policy – and that securing consensus has been problematic.

We have still not seen a promised consultation on post-16 assessment and accountability, and we await the outcome of the parallel secondary consultation, which closed on 1 May.

The extended disjunction between curriculum and assessment – apparent in both policy development and the timetable for implementation of these various reforms – has created unnecessary and potentially avoidable difficulties, for the Government and stakeholders alike.

There are also issues with the additional disjunction between primary and secondary (and post-16) assessment and accountability reforms. The Government’s decision to consult on these consecutively, without addressing important questions about how they fit together, suggests that critical pieces of the jigsaw are missing.

Finally, the decision to remove National Curriculum levels raises several difficult questions about how the Government will measure and monitor national progress in raising educational standards and narrowing gaps between advantaged and disadvantaged learners.

Part of the purpose of this post is to expose these rifts, so we can judge how robustly they are addressed in the next few months.


What has been published?


Primary assessment and accountability reforms

17 July saw the publication of three documents in the following order:

  • A press release which appeared shortly after a midnight embargo;

There was no response to the parallel ‘Secondary school accountability’ consultation launched on 7 February and completed on 1 May, despite the connectivity between the two sets of proposals – and no firm indication of when that response would be published.

A third consultation, on post-16 assessment and accountability, was not mentioned either.

The staged publication of the primary material meant that initial analysis and questioning of Ministers was based largely on the headlines in the press release rather than on the substance of the proposals.

Initial media appearances appeared to generate a groundswell of hostility that Ministers could not readily counter. The answers to some reasonable questions on the detail were not yet in the public domain.

It was particularly noteworthy that the announcement had integrated within it a second, about the size of Pupil Premium allocations in 2014-15. This was clearly intended to sugar the pill, though the coating is rather thin and there are also potentially wider ramifications (see below).

The Pupil Premium announcement must have been the justification for presentation by Lib Dem Deputy Prime Minister Clegg and Minister of State Laws, rather than by Tory Secretary of State Gove.

He (Gove) must have been delighted at avoiding this particularly poisoned chalice, already delayed into the dog days of summer – often a deliberate strategy for downplaying a particularly contentious announcement.

The consultation has a deadline of 11 October, allowing a total of 11 weeks and two days for responses, including the entirety of the school summer holidays, so the majority of the consultation period occurs while most schools are closed. This may also serve to mute opposition to the proposals contained in the document.

There is a commitment to publish the outcomes of consultation, together with a response ‘in autumn 2013’, which is a very quick turn round assuming that autumn means November rather than December. If there is any degree of contention, this might well edge close to Christmas.


National Curriculum publications

Nine days earlier, on 8 July 2013, a raft of National Curriculum proposals had appeared. The first iteration of this post concentrated primarily on these documents:

  • A Press Release ‘Education reform: a world-class curriculum to drive up standards and fuel aspiration’.
  •  A Consultation Document ‘National curriculum review: new programmes of study and attainment targets from September 2014’, with responses due by 8 August.
  • An updated framework document ‘The National Curriculum in England’ which includes the generic elements of the National Curriculum as well as each Programme of Study.

I have retained largely unchanged in this final version my record of recent history, to set the context for the analysis that follows.


A Recap of the last round of consultation and developments


The February 2013 Package

Back in February, the Government released the draft and consultation documents that informed the preparation and publication of the latest round of material set out above.

They included:

  • A full set of draft National Curriculum Programmes of Study for Key Stages 1-3, as well as drafts of the PoS for Key Stage 4 English, maths, science, PE and Citizenship.
  • An earlier version of the National Curriculum Consultation Framework Document incorporating all those draft PoS, with the exception of the KS4 core subjects, plus the generic elements of the National Curriculum including draft Aims and a draft Inclusion Statement.
  • The Secondary School Accountability Consultation Document focused principally on the development of accountability measures and their publication within the School Performance Tables. Consultation closed on 1 May 2013. This promised parallel consultation documents on accountability for primary schools and post-16 providers ‘shortly’.
  • The Government’s response to an earlier consultation on reforming Key Stage 4 Qualifications and an associated letter to Ofqual. This resulted in a further consultation on the future shape of GCSE examinations (see below).

I produced an analysis and assessment of this package shortly after publication.

Key points included:

  • Significant disparities between the length and degree of prescription of different draft PoS, with the primary core at one extreme (long and prescriptive) and the secondary foundation subjects at another (short and flexible). This suggested that the Government’s commitment to schools’ autonomy is highly variable by subject and phase, and tailored deliberately to fit the profile of academisation.
  • The rather basic nature of the overarching National Curriculum Aims:

‘The National Curriculum provides pupils with an introduction to the core knowledge that they need to be educated citizens. It introduces pupils to the best that has been thought and said; and helps engender an appreciation of human creativity and achievement.

The National Curriculum is just one element in the education of every child. There is time and space in the school day and in each week, term and year to range beyond the National Curriculum specifications. The National Curriculum provides an outline of core knowledge around which teachers can develop exciting and stimulating lessons.’

and an associated proposal to dispense with subject-specific aims in each draft PoS, assumed to be superfluous given the generic statement above.

  • The wording of the draft Inclusion Statement, which was seriously flawed. It said (my emphases) that:

‘Teachers should set high expectations for every pupil. They should plan stretching work for pupils whose attainment is significantly above the expected standard. They have an even greater obligation to plan lessons for pupils who have low levels of prior attainment or come from disadvantaged backgrounds. Teachers should use appropriate assessment to set targets which are deliberately ambitious.’

I took issue with this because of the two infelicitous assumptions it contains –  first, that teachers somehow have a ‘greater obligation’ to plan for low attainers than for high attainers, rather than having an overriding obligation to  treat them equally;  second,  that learners from disadvantaged backgrounds cannot be included amongst the ranks of high attainers.

The first is against the basic principles of comprehensive education and profoundly inequitable; the second is anathema, including to Secretary of State Gove, who has constantly and correctly cautioned against harbouring low expectations of disadvantaged learners.

  • The decision to disapply the bulk of the existing National Curriculum, PoS, attainment targets and assessment arrangements in academic year 2013/14. Schools would be required to teach the subjects of the National Curriculum, but not the content of the PoS. At primary level this would apply across KS1 and 2 for all foundation subjects. But, for core subjects, it would apply only to Years 3 and 4. At secondary level, disapplication would apply across all subjects at KS3 and to English, maths, science, ICT, PE and citizenship at KS4. The disapplication at KS4 would continue until the new PoS came into force for each subject and year group (so leaving the way open for phasing). For, if schools – whether state-maintained or academies – can operate successfully without the PoS for a year, why bother to reimpose the requirement on the state-maintained only from 2014?
  • The ‘lowest common denominator’ approach to attainment targets, which relied on a single standard AT in each PoS:

‘By the end of each key stage, pupils are expected to know, apply and understand the matters, skills and processes specified in the relevant programme of study.’

This – together with the scrapping of associated level descriptions – removes all scaffolding for the effective differentiation of the PoS, (with potentially negative implications for high attainers, amongst others, if they are insufficiently stretched). It also raises potentially awkward questions about the relationship between the PoS and assessment (see below). Finally, it  leaves the accountability framework – with the possible addition of the ‘power of the market’ – as the last remaining policy levers to bring poor performing schools into line.

  • How low, middle and high attainers will be distinguished in Performance Tables once National Curriculum Levels disappear, since the current distinction is based on achievement of Level equivalents at KS1 (for KS2) and at KS2 (for KS4). Such a distinction will be retained since the secondary accountability consultation mentions a ‘headline measure showing the progress of pupils in each of English and mathematics’ that will continue to ‘show how pupils with low, medium and high prior attainment perform’.
  • Whether these distinctions will be applied in Performance Tables to those eligible for the Pupil Premium, so parents and others can understand the gap within each school between the performance of high attainers from advantaged and disadvantaged backgrounds respectively (not forgetting middle and low attainers too).
  • The future of Key Stage 3 assessment, given the disappearance of levels and proposals to remove the requirement on schools to report to the centre the outcomes of teacher assessment. Will it be left entirely to schools to design an assessment system or will a standard national framework continue to operate in the core subjects?
  • The potential implications of the proposed introduction of PISA-style sampling tests at KS4 to ‘track national standards over time’, including any potential ‘washback’ effect on the curriculum.
  • Several unanswered questions about the nature of the proposed value-added KS2-KS4 progress measure, with: separate and as-yet-unknown KS2 and KS4 grading systems; KS2 benchmarks based on performance in KS2 English and maths tests; and KS4 benchmarks based on a new ‘Average Points Score across a balanced scorecard of eight qualifications, including English and maths, three other EBacc subjects and three further ‘high value qualifications’. The consultation document says this measure:

‘Will take the progress each pupil makes between Key Stage 2 and Key Stage 4 and compare that with the progress that we expect to be made by pupils nationally who had the same level of attainment at Key Stage 2 (calculated by combining results at end of Key Stage 2 in English and mathematics).’

A week later I published another post: ‘Whither National Curriculum Assessment Without Levels?’ that set out the history of the decision to dispense with levels and explored some of the issues this raises for assessment, in a context where the majority of secondary schools and a minority of primary schools are no longer bound by the National Curriculum.

This noted:

  • One implication of wholesale exemption from the National Curriculum for academies is that KS2 tests will need to be derived somehow from the content descriptions in the Programmes of Study. The manner in which this will be done is unclear, since it is open to question whether even the detailed draft PoS in the primary core contain sufficiently robust outcome statements to support grade-based statutory assessment at the end of Key Stage 2, especially given the very basic approach to attainment targets outlined above.
  • The desirability of harmonised end of KS2 and end of KS4 assessment and grading systems, so that progression between those two points is easier for parents and learners to follow and understand.
  • The desirability of ensuring that schools’ internal end-of-year assessment systems harmonise with the external assessment systems at end KS2 and end KS4 respectively, so that parents (and teachers) can more easily track progression between those two points.
  • The development of a grading scale that links attainment to the concept of ‘mastery’ of the PoS and progress to a judgement whether performance has improved, been maintained or declined compared with the previous year. I proposed my own ‘aunt sally’ to illustrate this point.


Developments since February

In the five months that elapsed between the appearance of the two curriculum-related consultation packages there were several material developments that impacted significantly on the outcomes of the process and the future of the National Curriculum, assessment and accountability, including on the other side of the 2015 General Election.

I sought to capture those in this recent round-up of activity on the Gifted Phoenix Twitter feed.

Some of the most significant include:

  • A piece by Brian Lightman of ASCL arguing that we should not be trying to drive the curriculum through the assessment system.
  • A speech from David Laws confirming that the future equivalent of Level 4b will become the new KS2 ‘pass’ with effect from 2016, so heralding a recalibration of expectations on individual learners and raising the stakes for accountability purposes.
  • A speech from Brian Lightman at the ASCL Annual Conference which argued that the abolition of National Curriculum levels creates an unhelpful policy vacuum.

‘So I predict that in the months and years to come the best curriculums will be developed – and refined – in schools across the country by teachers for teachers.

And that is why I think this national curriculum may well be the last national curriculum. Because in future teachers will be doing it for themselves.’

  • An admission that the deadline for the publication of the consultation document on primary accountability had slipped to the end of the summer term (Col 383W).
  • Apparent confirmation from DfE that pupils ending Key Stage 2 in 2015 would be taught the new National Curriculum in  academic year 2014/15 but would be assessed against the old one in May 2015.

‘So Labour will give all schools the same freedom over the curriculum that academies currently enjoy while continuing to insist that all schools teach a core curriculum including English, Maths and Science.’

Some have suggested that this is different to the current requirement imposed on academies but the highlighted part of the sentence above explicitly counters that – and adding any greater specificity to future core curriculum requirements would of course reduce academies’ freedoms – an idea that goes against the entire tenor of Twigg’s speech:

‘Academies say freedom to innovate in the curriculum has given their teachers a new sense of confidence and professionalism. All young people should benefit from the positive impact this brings – trusting teachers to get on with the job.’

‘Develop progress measures to identify how well the most able students have progressed from Year 6 through Key Stage 4 to the end of Key Stage 5.’

  • A Sunday Times story announcing that the primary accountability consultation document would not be released alongside the National Curriculum documentation as anticipated, and suggesting that Ministers were considering KS2 tests in English, maths and science that would enable them to rank learners by performance and so identify the top 10%, (though it was unclear at this stage whether this was across the piece or in each subject).


Three idiosyncratic interventions

One day after the publication of the second tranche of documents, Mr Twigg published a piece on the Labour List website implying a ‘volte face’ from his previous position, or else a contradictory muddle that requires urgent clarification.

The broad theme of the article is that the draft National Curriculum is insufficiently ambitious. But this would prompt the obvious riposte – if that’s the case, why are you committing Labour to doing without a National Curriculum altogether? Isn’t that even less ambitious by definition?

Mr Twigg strives to unhitch himself from the horns of this dilemma by repeating the commitment in his June speech:

‘Michael Gove believes only Academies and Free Schools can be trusted with the freedom to innovate in what they teach, other state schools must follow his highly prescriptive curriculum. Labour would end this divided system and extend these freedoms over the curriculum to all schools. All qualified teachers should be trusted to get on with the job and all schools should have the same freedoms to raise standards and innovate.’

That must mean extending to all the existing curricular freedoms enjoyed by academies. But then another paragraph is tacked on to the end of the article, almost as an afterthought:

‘His [ie Gove’s] divisive approach means curriculum freedom only applies to some schools. Instead, Labour would develop a reformed National Curriculum which allows teachers in all schools the freedom to innovate and prepares young people for the challenges of the modern economy.’

It is not possible to square these two contradictory statements. The freedoms currently enjoyed by academies do not amount to a National Curriculum (they are required to teach the three core subjects but are free to determine their content). As noted above, any universal National Curriculum would reduce academies’ freedoms rather than increase them.


Slightly before the 8 July publications, DfE released a short statement on ‘Assessing without levels’ which restated its case for abolishing them, adding:

Schools will be able to introduce their own approaches to formative assessment, to support pupil attainment and progression. The assessment framework should be built into the school curriculum, so that schools can check what pupils have learned and whether they are on track to meet expectations at the end of the key stage, and so that they can report regularly to parents.

Ofsted’s inspections will be informed by whatever pupil tracking data schools choose to keep. Schools will continue to benchmark their performance through statutory end of key stage assessments, including national curriculum tests. In the consultation on primary assessment and accountability, the department will consult on core principles for a school’s curriculum and assessment system.

Although schools will be free to devise their own curriculum and assessment system, we will provide examples of good practice which schools may wish to follow.’

So the core principles would be an important feature of the upcoming consultation document, but it would need to extend beyond those to satisfy the June 2012 commitment:

‘In terms of statutory assessment, however, I believe that it is critical that we both recognise the achievements of all pupils, and provide for a focus on progress. Some form of grading of pupil attainment in mathematics, science and English will therefore be required, so that we can recognise and reward the highest achievers as well as identifying those that are falling below national expectations. We will consider further the details of how this will work.’

And of course some kind of framework would be required for the KS2 core to support the commitment to KS2-4 progression measures in the consultation on secondary accountability.

This statement rather set to one side the strong case for aligning schools’ own internal end-year assessment arrangements with the statutory end of Key Stage arrangements that will be in place from 2016.


One further important signal towards the future direction of travel appeared, in the shape of Ofqual’s GCSE reform consultation published in June 2013, which sets out as its ‘preferred approach’ to GCSE grading an eight point numerical system, from Grade 8 down to Grade 1.

No convincing explanation is given for placing Grade 8 at the top of the scale rather than Grade 1, so following the precedent set by musical examinations rather than the more universally familiar approach taken in CSE and O level examinations (the latter prior to 1975).

Were this to be applied to the ‘APS8 measure outlined above, it would mean each student achieving a numerical score between 8 and 64. Top-performing schools could vie with each other over the number of their students achieving the magical 64 rating.

Assuming a similarly constructed grading system for the three primary core tests, this could provide the basis for a straightforward ratio of progression from KS2 to KS4, and even possibly on to KS5 as well.

But the Sunday Times story led us to assume that this might be set aside in favour of an equation based on percentiles. Whether this would be designed to accommodate the current predilection for ‘comparable outcomes’ remained unclear.


An Aside: The Pupil Premium

The assessment and accountability announcement was sugar-coated by confirmation of the size of Pupil Premium allocations in 2014-15.

But close scrutiny of the coating reveals it as rather a thin veneer.

It was already known that the total Pupil Premium funding envelope would increase  by £625m, from £1.875bn in 2013-14 to £2.5bn in 2014-15, so the overall budget was not in itself newsworthy.

But the decision to weight this towards primary schools was new. Ministers made much of the 44% increase for primary schools, from £900 to £1,300 per pupil, while barely mentioning that this must be achieved at the expense of the allocation for secondary schools.

One assumes that the secondary allocation has been frozen at £900 per learner but, at the time of writing, I have seen no official confirmation of that. Hence there is a degree of economy with the truth at play if the funding is claimed to be ‘new money’.

We do know, from the Spending Review, that the total budget for the Premium will be protected in real terms in 2015-16 but will not be further increased.

It remains to be seen whether the new weighting in favour of the primary sector will be retained, but that seems highly likely given the level of disruption that would be caused by frequent recalibration.

One influential commentator – Institute of Education Director Chris Husbands – has suggested that the bracketing of the two announcements marks a significant adjustment:

‘This is a further twist in the evolving purpose of the pupil premium – once intended as an incentive to primary schools to admit more disadvantaged children, then a compensatory payment for the additional costs involved in meeting the needs of disadvantaged children, it is now more clearly a fund to secure threshold levels of attainment.’

This argument runs like a leitmotif through the analysis below.

But it also runs counter to the Government’s official position that the Premium is designed to support all disadvantaged pupils and close the attainment gap between them and their peers, a position reinforced by the fact that the Government has delineated separate ‘catch-up premium support’ exclusively for those below the thresholds.

There is no change in recent announcements about strengthening the accountability underpinning Pupil Premium support. Husbands’ argument also runs against the tenor of Ofsted’s publications about effective use of the Premium and the latest Unseen Children report, published following deliberations by an expert panel on which Husbands served.

The source appears to be a recent IPPR publication ‘Excellence and Equity: Tackling Educational Disadvantage in England’s Secondary Schools’, Chapter 4 of which asserts (without supporting evidence) that:

‘Policymakers talk interchangeably about the pupil premium being used to support pupils who are falling behind, and it being used to support those who are on free school meals.’

This despite the fact that:

‘The overlap between these two categories is not as large as many people suppose. Last year, only 23 per cent of low-attaining pupils at the end of primary school were eligible for free school meals, and only 26 per cent of pupils eligible for free school meals were low attaining. This puts schools in the difficult position of having to decide whether to spend their pupil premium resources on pupils who have a learning need, even though many of them will not be eligible for free school meals, or whether they should focus them on FSM pupils, even though many of them will be performing at the expected level.’

The notion that pupils who are performing at the expected levels do not, by definition, have a ‘learning need’ is highly contentious, but let that pass.

The substantive argument is that, because ‘tackling the long tail of low achievement is the biggest challenge facing England’s school system’ and because the Premium ‘provides insufficient funds targeted at the right age range’:

‘In order to have maximum impact, the pupil premium should be explicitly targeted towards raising low achievement in primary and early secondary school… The Department for Education should therefore focus the additional funding at this age range. It should… create a higher level of pupil premium in primary schools, and… increase the ‘catch-up premium’ (for year 7 pupils) in secondary schools; the pupil premium in secondary schools would be held at its current level. This would provide primary schools with sufficient resources to fund targeted interventions, such as Reading Recovery, for all children who are at risk of falling behind. It would also compensate secondary schools that have large numbers of pupils starting school below the expected level of literacy and numeracy.

…Secondary schools are currently given a catch-up premium for every pupil who enters below level 4 in English and maths. However, there is no mechanism to guarantee that these pupils benefit from the money. The ‘catch-up premium’ should therefore be replaced with a ‘catch-up entitlement’. Every pupil that falls into this category would be entitled to have the money spent specifically on helping to raise his or her attainment. Schools would be required to write a letter to these pupils and their families explaining how the resources are being spent.’

As we now know, the Government has front-loaded the Pupil Premium into the primary sector, but not – as far as we are aware – the early years of secondary school. Nor has it increased the catch-up premium, unless by some relatively small amount yet to be announced, or made it an individual entitlement.

Husbands’ initial argument – that the linking of Premium and assessment necessarily means a closer link being forged with tackling below-threshold attainment – depends on his assertion that:

‘The core message of the consultation is that the concern is with absolute attainment – secondary readiness – rather than the progress made by primary schools.’

The analysis below examines the case for that assertion.


What the Primary Assessment Consultation Says

The commentary below follows the sections in the consultation document


The case for change

The second paragraph of ‘The case for change’ says:

‘We believe that it is right that the government should set out in detail what pupils should be taught…’

a somewhat different  slant to that adopted in the National Curriculum proposals (and which of course applies only to the core subjects in state-maintained schools).

The next section works towards a definition of the term ‘secondary ready’, described as ‘the single most important outcome that any primary school should strive to achieve’.

It is discussed exclusively in terms of achievement in KS2 English and maths tests, at a level sufficient to generate five GCSE Grades A*-C including English and maths five years later.

This despite the fact that the secondary accountability consultation proposes two quite different headline measures: good GCSE grades in both English and maths and Average Points Score in eight subjects from a three-category menu (neither of which is yet defined against the proposed new 8 to 1 GCSE grading scale).

No other criteria are introduced into the definition, rendering it distinctly narrow. This might arguably be the most important outcome of primary education, but it is not the sole outcome by any stretch of the imagination.

The Government states an ‘ambition’ that all pupils should achieve this benchmark, excepting a proportion ‘with particular learning needs’.

There is no quantification of this proportion, though it is later used to identify a floor target assumption that 85% of the cohort should achieve the benchmark, so the group with ‘particular learning needs’ must be something less than 15% of all learners.

The introduction of a second and parallel floor target, relating to progression, is justified here on the grounds that ‘some schools have particularly demanding intakes’ so ‘will find it challenging to reach the ambitious [attainment] threshold…’. This will also help to identify coasting schools.

This approach to progression, as a fall back in circumstances where the threshold measure is problematic, lends some weight to Husbands’ contention that absolute attainment is now paramount.

Note that the wording in this section is unclear whether the new floor target consists of both of these measures – secondary readiness and progression – or the imposition of one or the other. This issue comes up again later below.

There is nothing here about the importance of applying measures that do not have in-built perverse incentives to focus on the threshold boundary, but this too will reappear later.

There is early confirmation that:

‘We will continue to prescribe statutory assessment arrangements in English, mathematics and science.’

The ‘core principles’ mentioned in the Assessment Without Levels text appear at this stage to be those proposed in the June 2011 Bew Report rather than any new formulation. Note the second bullet point, which pushes in directly the opposite direction to Husbands’ assertion:

  • ongoing assessment is a crucial part of effective teaching, but it should be left to schools. The government should only prescribe how statutory end of key stage assessment is conducted;
  • external school-level accountability is important, but must be fair. In particular, measures of progress should be given at least as much weight as attainment;
  • a wide range of school performance information should be published to help parents and others to hold schools to account in a fair, rounded way; and
  • both summative teacher assessment and external testing are important forms of statutory assessment and both should be published

Already there are mixed messages.

The next section justifies the removal of National Curriculum levels:

‘Imposing a single system for ongoing assessment, in the way that national curriculum levels are built into the current curriculum and prescribe a detailed sequence for what pupils should be taught, is incompatible with this curriculum freedom. How schools teach their curriculum and track the progress pupils make against it will be for them to decide. Schools will be able to focus their teaching, assessment and reporting not on a set of opaque level descriptions, but on the essential knowledge that all pupils should learn. There will be a clear separation between ongoing, formative assessment (wholly owned by schools) and the statutory summative assessment which the government will prescribe to provide robust external accountability and national benchmarking. Ofsted will expect to see evidence of pupils’ progress, with inspections informed by the school’s chosen pupil tracking data.’

Paraphrasing this statement, one can extract the following rather questionable logic:

  • We want to give schools freedom to determine their own approaches to formative assessment
  • The current system of levels has come to be applied to both formative and summative assessment
  • So we are removing levels from both formative and summative assessment.

The only justification for this must lie in recognition that the retention of levels in summative assessment will inevitably have a ‘backwash effect’ on formative assessment.

Yet this backwash effect is not acknowledged in respect of the proposed new arrangements for summative assessment. There is a fundamental issue here.

Schools will still be required to report to parents at the end of each year and key stage. There will be no imposition of a system for them doing so but, as we have already recognised, parents will more readily understand a system that is fully consistent with that applied for end of key stage assessment, rather than a substantively different approach.

The next segment begins to explore the case for shifting the baseline assessment – on which to build measures of progression in primary schools – back to Year R. This will ‘reinforce the importance of early intervention’. The EYFS profile will be retained but might be rendered non-statutory.

The introduction of new summative assessments at end KS1 and end KS2 is confirmed for 2016, with interim arrangements as noted elsewhere and accountability reforms also taking effect at this point (so in the December 2016/January 2017 Performance Tables).

There is also confirmation that academies’ funding agreements require compliance ‘with statutory assessment arrangements as they apply to maintained schools’. This is as close as we get to an explanation of how statutory assessments that apply to all schools will be derived from the National Curriculum PoS and single ‘lowest common denominator’ attainment targets.


Teacher assessment and reporting to parents

This section begins with a second justification for the removal of levels. Some anecdotal evidence is cited to support the argument:

‘Teachers have told us that the use of levels for assessment has become burdensome and encouraged crude ‘best fit’ judgements to differentiate pupil progress and attainment.’

This is the beginning of the justification for a more sophisticated (and hence more complex) approach.

Schools are free to design their assessment systems, though these must be integrated with the school curriculum (in a way that these separate government proposals have not been integrated).

There is a hint that these systems might be different for different subjects (adding still further complexity for parents) though ‘groups of schools may wish to use a common approach’.

Paragraph 3.7 is a confusing complement to the Bew-based core principles that appeared earlier:

‘We expect schools to have a curriculum and assessment framework that meets a set of core principles and:

  • sets out steps so that pupils reach or exceed the end of key stage expectations in the new national curriculum;
  • enables them to measure whether pupils are on track to meet end of key stage expectations;
  • enables them to pinpoint the aspects of the curriculum in which pupils are falling behind, and recognise exceptional performance;
  • supports teaching planning for all pupils; and
  • enables them to report regularly to parents and, where pupils move to other schools, providing clear information about each pupils strengths, weaknesses and progress towards the end of key stage expectations.

Question 1: Will these principles underpin an effective curriculum and assessment system?’

The ‘and’ in the opening sentence suggests that this isn’t part of the set of core principles, but the question at the end suggests these are the principles we should be considering, rather than those derived from Bew.

So we have two competing sets of core principles, the latter referring to schools’ own curriculum and assessment frameworks, but not to accountability.

The references here – to steps relative to end of KS expectations, measuring progress towards those expectations, identifying areas where learners are ahead and behind, supporting planning and reporting to parents – are entirely familiar. They really describe the functions of assessment rather than any principles that govern its application.

There is a commitment that the Government will ‘provide examples of good practice’ and:

‘Work with professional associations, subject experts, education publishers and external test developers to signpost schools to a range of potential approaches. Outstanding schools and teaching schools have an opportunity to take the lead in developing and sharing curriculum and assessment systems which meet the needs of their pupils…Commercial providers and subject organisations may offer curriculum schemes of work with inbuilt assessment, including class exercises, homework and summative tests.’

The second consultation question asks respondents to identify additional support and ‘other good examples of effective practice’.

The final section on reporting confirms that the Government plans to continue to publish teacher assessment outcomes in the core subjects, in line with Bew’s recommendation.

There is a brief reference, almost an afterthought, to schools providing information on transfer and transition. There is no acknowledgement that this process becomes more complex when schools are following different curricula and pursuing different in-house assessment systems.


National Curriculum tests in English, maths and science

This section begins with a further set of Bewisms, this time on the uses of data derived from statutory assessment. They are the justification for the continuation of externally-marked National Curriculum tests.

The proposal is that these should continue in maths and in English reading and grammar, spelling and punctuation. Writing will continue to be assessed through externally moderated teacher assessment, while national science sampling will also continue at the end of KS2. The Year 1 Phonics Screening Check will also continue, with results available in Raise Online but not in Performance Tables.

The timetable, including phasing, is rehearsed again, before the critically important tripartite approach to reporting is introduced.

This comprises:

  • A ‘scaled score’
  • Decile-based ranking within the ‘national cohort’ and
  • Progression from the baseline

The scaled score is the threshold marker of whether the learner is ‘secondary-ready’. We knew from previous announcements that this standard would be raised from the equivalent of 4c to the equivalent of 4b.

It is also necessary to know by how much any given learner has undershot or overshot this threshold. Hence:

‘We propose to report this attainment using a scaled score. Because it is not possible to create tests of precisely the same difficulty every year, the number of marks needed to meet the secondary readiness standard will fluctuate slightly from one year to another. To ensure that results are comparable over time, we propose to convert raw test marks into a scaled score, where the secondary readiness standard will remain the same from year to year.

Scaled scores are used in all international surveys and ensure that test outcomes are comparable over time. The Standards and Testing Agency will develop this scale. If, as an example, we developed scaled scores based on the current national curriculum tests, we might employ a scale from 80 to 130. We propose to use a scaled score of 100 as the secondary ready standard.’

The notion of a scaled score, with current Level 4b benchmarked at 100 and a scale sufficiently long to accommodate all levels of attainment above and below, is familiar from PISA and other international comparisons studies.

If the scale has 50 points, as this example does, then there are 50 potential levels of achievement in each assessment – about three times as many as there are currently.

But the score will also be accompanied by a norm-referenced decile, showing how each learner’s performance compares with their peers.

And an average scaled score is generated for learners with the same prior attainment at the baseline, which might or might not move to Year R, so enabling parents to compare their child’s scaled score with this average.

This material would not be used to generate simpler ‘proxy’ grades but would be provided in this tripartite format.

Assuming the illustrative elements above are adopted:

  • The highest possible KS2 performer would receive a scaled score of 130, confirmation that he is within the top decile of his peers and a comparative average scaled score. If this is less than 130, he has made better progress than those with the same prior baseline attainment. If it is 130 he has made the same progress. By definition his progress cannot be worse than the others.
  • A lowest possible KS2 performer would have a scaled score of 80, confirmation that he is within the bottom decile of the cohort and a comparative average scaled score which could be as low as 80 (all peers with the same prior attainment have made the same limited progress as he) but no lower since that is the extreme of the scale;
  • A median KS2 performer would obtain a scaled score of 100, confirmation that he is within the fifth decile and a correspondingly variable average scaled score.

No illustrative modelling is supplied, but one assumes that average scaled scores for those with similar prior attainment will typically group in a cluster, such that most learners will see relatively little difference, while some outliers might get to +15 or -15. It also seems likely that the ‘progression score’ will eventually be expressed in this manner.

The progress measure is based exclusively on comparison with how other learners are progressing, rather than any objective standard of the progression required.

The document claims that:

‘Reporting a scaled score and decile ranking from national curriculum tests will make it easy to identify the highest attainers for example using the highest scaled scores and the top percentiles of pupils. We do not propose to develop an equivalent to the current level 6 tests, which are used to challenge the highest attaining pupils. Key stage 2 national curriculum tests will include challenging material (at least of the standard of the current level 6 test) which all pupils will have the opportunity to answer, without the need for a separate test.’

But, while parents of high attainers who score close to the maximum might reasonably assume that their offspring have performed in the top one or two percentiles, they will be told only that they are within the top decile. This is rather less differentiated than securing a Level 6 under current arrangements.

Moreover, the preparation of single tests covering the full span of attainment will be a tall order, particularly in maths.

This DfES publication from 2004 notes:

‘It is well known that individual differences in arithmetical performance are very marked in both children and adults.  For example, Cockcroft (1982) reported that an average British class of eleven-year-olds is likely to contain the equivalent of a seven-year range in arithmetical ability. Despite many changes in UK education since then, including the introduction of a standard National Curriculum and a National Numeracy Strategy, almost identical results were obtained by Brown, Askew, Rhodes et al (2002).  They found that the gap between the 5th and 95th percentiles on standardized mathematics tests by children in Year 6 (10 to 11-year-olds) corresponded to a gap of about 7 chronological years in ‘mathematics ages’.’

There is no reference to the test development difficulties that this creates, including the risk that high-attaining learners have to undertake pointless ramping of easy questions, unnecessarily extending the length of their tests.

The text claims that the opposite risk – that ceilings are set too low – will not exist, with at least Level 6-equivalent questions included, but what will their impact be on low attainers undertaking the tests? This is the KS4 tiering debate rewritten for KS2.

One assumes that statutory teacher assessment in the core subjects will be reported in whatever format schools prefer, rather than in the same manner as test outcomes are reported but, like much else, this is not made clear in the document.

By implication there will be no reporting from the national sampling tests in science.


Baselines to measure progress

The section on baselines is particularly confusing because of the range of choices it offers consultees.

It begins by stating bluntly that, with the removal of levels, KS1:

‘Teacher assessment of whether a pupil has met the expectations of the programme of study will not provide sufficient information to act as a baseline’.

This is because teacher assessment ‘will not provide differentiated outcomes to allow us to measure progress’. This despite the fact that the document says later on that KS1 data collected under the existing system might be used as an interim baseline measure.

Two core options are set out:

  • Retaining a baseline at the end of KS1, through new English and maths tests that would be marked by teachers but externally moderated. These would be introduced in ‘summer 2016’ Views are sought over whether these test results should be published, given that publication might reduce the tendency for schools to ‘under-report pupils’ outcomes in the interest of showing the progress pupils have made in the most positive light’.
  • Introducing a new baseline at the start of the reception year, from September 2015, an option that gives credit for progress achieved up to the end of Year 2 and removes a perverse incentive to prioritise early intervention. This is described as ‘a simple check…administered by a teacher within two to six weeks of each pupil entering reception…subject to external monitoring’. It would either be developed in-house or procured from a third party. The existing EYFS Profile would remain in place but become non-statutory, so schools would not have to undertake it and the data would not be moderated or collected.

But an array of additional options is also offered:

  • Allowing schools to choose their preferred baseline check (presumably always undertaken in Reception, though the consultation is not clear on this point).
  • Making the baseline check optional, with schools choosing not to use it being ‘judged by attainment alone in performance tables and floor standards’. In other words, the progress measure itself becomes optional, which would appear to run counter to one of Bew’s principles articulated at the beginning of the document and support the Husbands’ line.
  • Assuming a Reception baseline check, making end of KS1 tests non-statutory for primary schools, while retaining statutory tests for infant schools because of their need for such an accountability measure and to provide a baseline for junior schools. KS1 tests would still be available for primary schools to use on an optional basis.

Much of the criticism of the document has focused on the Reception baseline proposal, especially concern that the check will be too demanding for the young children undertaking it. On the face of it, this seems rather unreasonable, but the document is at fault by not specifying more clearly what exactly such a check would entail.



The penultimate section addresses performance tables and floor standards. It begins with the usual PISA-referenced arguments for a high autonomy, high accountability system, mentions again the planned data portal and offers continuing commitments to performance tables and floor standards alike.

It includes the statement that:

‘In recent years, we have made the floor both more challenging and fairer, by including a progress element’

even though the text has only just suggested making the progress element optional!

The section on floor standards begins with the exhortation that:

‘All primary schools should ensure that as many pupils as possible leave secondary ready.’

It repeats the intention to raise expectations by increasing the height of the hurdle:

‘We therefore propose a new requirement that 85% of pupils should meet the secondary readiness standard in all the floor standard measures (including writing teacher assessment). This 85% attainment requirement will form part of the floor standard. This standard challenges the assumption that some pupils cannot be secondary ready after seven years of primary school. At the same time it allows some flexibility to recognise that a small number of pupils may not meet the expectations in the curriculum because of their particular needs, and also that some pupils may not perform at their best on any given test day.’

So the 85% threshold is increased from 60% and the standard itself will be calibrated on the current Level 4b rather than 4c. This represents a hefty increase in expectations.

The text above appears to suggest that all pupils should be capable of becoming ‘secondary-ready’, regardless of their baseline – whether in Year R or Year 2 – apart from the group with particular unspecified needs. But, this time round,  there is also  allowance for a second group who might underperform on the day of the test.

Once again, the justification for a parallel progress measure is not to ensure consistency with the Bew principles, but to offer schools with ‘particularly challenging intakes’ a second string to their bows in the form of a progress measure. The precise wording is:

‘We therefore propose that schools would also be above floor standards if they have good progress results.’

Does this mean that schools only have to satisfy one of the two measures, or both? This is not absolutely clear, but the sentence construction is perhaps more consistent with the former rather than the latter.

If we are right, this is substantively different to the requirements in place for 2013 and announced for 2014:

‘In key stage 2 tests in 2014, primary schools will be below the floor standard if:

  • fewer than 65% of its pupils do not achieve Level 4 or above in reading, writing and maths, and
  • it is below the England median for progression by two levels in reading, in writing, and in maths.

*Results in the new grammar, punctuation and spelling test are likely to be part of the floor standard in 2014.

For tests taken this year, primary schools will be below the floor standard if:

  • fewer than 60% of its pupils do not achieve Level 4 or above in reading, writing and maths, and
  • it is below the England median for progression by two levels in reading, in writing, and in maths.

*Results in the new grammar, punctuation and spelling test will not be part of the floor standard this year.’

It is also substantively different to the arrangements proposed for secondary schools.

Slightly later on, the text explains that schools which exceed the floor target on the basis of progression, while falling below the 85% secondary-ready threshold, will be more likely to be inspected by Ofsted than those exceeding this threshold.

However, Ofsted will also look at progress measures, and:

‘Schools in which low, middle and high attaining pupils all make better than average progress will be much less likely to be inspected.’

The text argues that:

‘Progress measures mean that the improvements made by every pupil count – there is no perverse incentive to focus exclusively on pupils near the borderline of an attainment threshold.’

But, assuming the progression target only comes into play for schools with ‘particularly challenging intakes’, the large majority will have no protection against this perverse incentive.

As already stated, the progress measure will be derived from comparison with the average scaled scores of those with similar prior attainment at the baseline – in essence the aggregation of the third element in reporting to parents. Exactly how this aggregation will be calculated is not explained.

Of course, an average measure like this does not preclude schools from giving disproportionately greater attention to learners at different points on the attainment spectrum and comparatively neglecting others.

Unless the performance tables distinguish progress by high attainers, they might be likely to lose out, as will those never likely to achieve the ‘secondary-ready’ attainment threshold.

The precise score for the floor targets is yet to be determined, but is expected ‘to be between 98.5 and 99’:

‘Our modelling suggests that a progress measure set at this level, combined with the 85% threshold attainment measure, would result in a similar number of schools falling below the floor as at present. Over time we will consider whether schools should make at least average progress as part of floor standards.’

So the progress element of the standard will be set slightly below average progress to begin with, perhaps to compensate for the much higher attainment threshold. This may support the argument that progress plays second fiddle to attainment.

Finally, the idea of incorporating an ‘average point score attainment measure’ in floor targets is floated:

‘Schools would be required to achieve either the progress measure or both the threshold and average point score attainment measure to be above the floor. This would prevent schools being above floor standards by focusing on pupils close to the expected standard, and would encourage schools to maximise the achievement of all their pupils. Alternatively we could publish the average point score to inform inspections and parents’ choices, but not include the measure in hard accountability.’

The first part of this paragraph reinforces the interpretation that the floor standard is now to be based either on the attainment threshold or the progress measure, but not both. But, under this option, the threshold measure could have an additional APS component to protect against gaming the threshold.

That goes some way towards levelling the playing field in terms of attainment, but of course it does nothing to support a balanced approach to progression in the vast majority of schools.

The section on performance tables begins with a further reference to the supporting ‘data portal’ that will include material about ‘the attainment of certain pupil groups’. This is designed to reduce pressure to overload the tables with information, but may also mean the relegation of data about the comparative performance of those different groups.

The description of ‘headline measures’ to be retained in the tables includes, for each test presumably:

  • the percentage of learners who meet ‘the secondary readiness standard’;
  • the school’s average scaled score, comparing it with the average score for the national cohort
  • the rate of progress of pupils in the school

There will also be a ‘high attainer’ measure:

‘We will also identify how many of the school’s pupils are among the highest-attaining nationally, by including a measure showing the percentage of pupils attaining a high scaled score in each subject.’

The pitch of this high scaled score is not mentioned. It could be set low – broadly the top third, as in the current ‘high attainer’ measure, or at a somewhat more demanding level. This is a significant omission and clarification is required.

Statutory teacher assessment outcomes will also be published (though presumably these will follow schools’ chosen assessment systems rather than scaled scores – see above).

All annual results will also be accompanied by three year rolling averages, to improve the identification of trends and protect small schools in particular from year-on-year fluctuation related to the quality of intake. There is an intention to extend rolling averages to floor targets once the data is available.

All these measures will be shown separately for those eligible for the Pupil Premium. This means that, for the first time, high attainers amongst this group will be distinguished, so it will be possible to see the size of any ‘excellence gap’. This is an important and significant change.

There will also be a continuation of the ‘family of schools’ approach – comparing schools with others that have a similar intake – recently integrated into the current Performance Tables.

The Pupil Premium will be increased:

‘To close the attainment gap between disadvantaged pupils and their peers and to help them achieve these higher standards…Schools have the flexibility to spend this money in the best way possible to support each individual child to reach his or her potential.’

So, despite the rider in the second sentence, the purpose of the Premium is now two-fold.

In practice this is likely to mean that schools at risk of being below the standard will focus the Premium disproportionately on those learners that are not deemed ‘secondary-ready’, which further supports the Husbands theory.


Recognising the attainment and progress of all pupils

Rather disappointingly, this final short section is actually exclusively about low attainers and those with SEN – presumably amongst those who will not be able to demonstrate that they are ‘secondary ready’.

It tells us that access arrangements are likely to be unchanged. Although the new KS2 tests will be based on the entire PoS:

‘Even if pupils have not met the expectations for the end of the key stage, most should be able to take the tests and therefore most will have their attainment and progress acknowledged’.

There will also be ‘a small minority’ currently assessed via the P-scales. There is a commit to explore whether the P-scales should be adjusted to ‘align with the revised national curriculum’.

There is an intention to publish data about the progress of pupils with very low prior attainment, though floor standards will not be applied to special schools. The document invites suggestions for what data should be published for accountability purposes.

Here ends the first part of this analysis. Part Two begins with a review of the issues arising from the revised National Curriculum proposals and from the summary of the assessment consultation document above.




July 2013

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