ASCL supports the overall objective of creating a more coherent and consistent 16-19 accountability framework, including the introduction of performance measures across new qualification pathways and greater consistency between qualifications at the same level. However, consistency must not come at the expense of recognising the different purposes of qualifications, the diversity of learner groups, and the importance of provider professional judgement.

ASCL strongly supports proposals that remove perverse incentives and enable providers to act in students' best interests, particularly the proposal to remove the English and maths non-entry penalty for students who have been with a provider for only one year. This change is more likely to support appropriate assessment decisions and reduce pressure for premature exam entry.

ASCL does not support the proposal to increase the cap on negative English and maths progress outcomes from -1 to -2. We are concerned that increasing the accountability penalty for poor outcomes risks creating disincentives for providers to recruit and support students with the greatest barriers to achieving level 2 English and maths, including disadvantaged learners, students with SEND and those with very low prior attainment. Accountability measures should support inclusion and opportunity rather than increase perceived risks associated with admitting the most vulnerable learners.

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