ASCL welcomes this important consultation and is pleased that the regulator is being proactive in making assessments more accessible for more learners.

We agree strongly with much of the proposed guidance, and would advocate its implementation with immediate effect, as suggested.

We do not think the proposed guidance would affect the workload or planning of school and college leaders and teachers; nor would it disadvantage any learners currently preparing for national assessments.

However, we believe that the omission of a specified reading age for qualifications is wrong. A revised reading age should be included in the guidance.

The current statutory reading age of GCSE and other level 1 and 2 qualifications is 16. This makes exam papers and other assessments inaccessible to almost a quarter of students. A recent study (Fernandes & Gallacher, 2020) found that 25% of 15-year-olds have a reading age of 12 or below.
 
The first principle of the proposed guidance is that an assessment task should only measure what it intended to measure. It is ASCL’s view that not addressing the issue of reading ages undermines this principle, as it could result in an assessment construct assessing a quarter of learners on their literacy rather than the knowledge and skills being measured.

ASCL believes that Ofqual should consult on the specified reading age of general and other qualification assessments; and adapt the guidance accordingly with immediate effect.

Full response to consultation