We have responded to Ofqual's formal consultation on its decision to use predicted grading during the COVID-19 pandemic, in place of this year’s summer assessments in England.

Read our full response to Ofqual's consultation (88KB, Word)

Using predicted grades in place of this year’s summer assessments could deepen the existing inequality in education and put the future of disadvantaged young people at risk if not correctly implemented, David Isaac, Chair of the Equality and Human Rights Commission has warned.

We have submitted our response to Ofqual’s consultation on the qualification regulator’s decision to cancel a range of exams and assessments across England due to the coronavirus pandemic. 

In our response to Ofqual, as Britain’s equality watchdog, we warned the use of predicted grades could have a lasting effect on young people from certain ethnic minority backgrounds, disabled pupils and those with special educational needs, who are already often disadvantaged compared to their friends.

Research suggests there may be patterns of conscious or unconscious race bias when predicting grades. With this in mind, there is a danger that predicted grading may have an adverse impact on some disadvantaged groups.

Chair of the Equality Human Rights Commission David Isaac said:

“We know this is a difficult time for people working in education. It is also difficult for pupils. After years of hard work, control of their grades will be taken out of their hands. If we don’t get this right the future of some disadvantaged young people is severely at risk.

“We can’t let the crisis happening now affect the future of disadvantaged pupils when so many, particularly disabled pupils and those of ethnic minority background, already face an uphill battle.

“Young people’s futures must remain at the heart of responses – we are ready to work with Ofqual to ensure young people can fulfil their potential and are not limited by any barriers put in their way during this time of crisis.

“At this time it is critically important that public authorities meet the requirements of the Public Sector Equality Duty to their fullest ability and consider the needs and disadvantages facing people with different protected characteristics when they are deciding and implementing their response to the Coronavirus emergency.”

We have made a number of recommendations, which include:

1. the Department for Education should issue guidance to schools on the approach which teachers should take to predicting grades and ranking pupils in order to minimise the risk of conscious or unconscious bias
2. Ofqual should publish a report evaluating the predicted grades process and outcomes for pupils. If the evaluation reveals higher than average disparities for pupils with protected characteristics, these should be investigated thoroughly, with appropriate remedial action taken
3. in the event that pupils are not happy with the outcome of their assessment and awarded grade, they must have a meaningful and timely route of appeal

As a public body in England, Ofqual has a legal duty to comply with the Public Sector Equality Duty by ensuring no young people are put at a disadvantage as a result of its decisions, particularly those with protected characteristics such as race and disability.

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