An Open Letter to the Cabinet Secretary


by Melvyn Roffe

Dear Cabinet Secretary

Arrangements for the Assessment of National Qualifications 2021

I am writing to place on record my concern and that of many of my colleagues about the current situation regarding the “Alternative Certification Model” [ACM] for this year’s National Qualifications and the resulting risk to the credibility of the award of National Qualifications this August.

The system of National Qualifications has many purposes, but chief amongst them is to recognise and reward the attainment of pupils in school at key points in their learning, most significantly as they transition to Further or Higher Education or the world of work from the end of S5. This requires a system of assessment that is consistent, transparent and effective. It must be easy for pupils to understand, practical for schools to implement and robust enough to command confidence from institutions and employers who will be making decisions based upon its outcomes.

As you will be aware, the Scottish Qualifications Authority [SQA] has the statutory power under the Education (Scotland) Act 1996 (Section 2) to to devise and determine the entitlement of individuals to SQA qualifications and to award and record such qualifications. Furthermore, it has a duty under the Act (Section 7) to “have regard to the interests of persons using its services”. It is my view that the current circumstances relating to the ACM demonstrate a failure of SQA either to properly exercise its powers under Section 2 of the Act or to fulfil its Section 7 duty. I know this view is shared by many colleagues in schools and other settings across Scotland, by parents and above all, by young people who are the ultimate “persons using [SQA] services”.

The COVID-19 pandemic has challenged organisations in all sectors of the economy and public life in all jurisdictions around the world. Whilst the nature and severity of the pandemic was unprecedented, the outbreak of a pandemic and the possible impact on the functions of the SQA could have been the subject of contingency planning well before the beginning of January 2020. It is perhaps forgivable, that the SQA did not see this as a priority at that stage, but it is difficult to understand why the lessons of summer 2020 were not reflected in planning for the 2021 diet in the period between August and November 2020 when the decision was taken that the 2021 diet would not take place.

Two threats to the viability of the diet and the reliability of the qualifications could have been identified at that stage. Both the public health risk of physically sitting exams and the risk to the fairness of the qualifications process due to variable learning loss caused by school closure and self isolation should have been considered as equal threats to the reliability of the assessment of the National Standards in the 2021 diet. The cancellation of the diet itself may have addressed the first risk, but it only exacerbated the problem of the second.

By now, it is obvious that the impact of variable learning loss is undermining the credibility of this year’s award of SQA qualifications and none of the measures taken by SQA have addressed it in a way that safeguards the reliability of standards.

From the outset there was no attempt by SQA to standardise the approach across subjects. In reducing the requirements for assessment, some subjects made significant reductions to the amount of content required whilst others made no concession whatsoever. The result was a set of provisions which caused confusion and were inherently unfair. The extent to which a pupil experienced any mitigation for potential disruption to their schooling and any learning loss depended not on the extent of that disruption but on the choice of qualifications for which they were being presented.

Even recognising the challenges to the organisation, the high level instructions and guidance from the SQA have been at best vague, often confusing and at worst evasive. For example, there has been no proper acknowledgement in the guidance on applying National Standards of widespread grade inflation in the system between 2019 and 2020. We seem to be invited to believe that 2020 was just a standard year and that the better grades generally achieved by candidates had nothing to do with the way in which they were awarded.

The use of Internally Assessed Question Papers (IAQPs) appeared to provide a way in which reliable and objective data could be obtained to inform the ACM. However, with no meaningful method of maintaining the integrity of the material in an age of social media, this should have been recognised as flawed from the outset rather than promoted as a core requirement for many subjects. With no practical route to redress, the effect of IAQPs may, in fact, have been to penalise schools and candidates who have done the right thing.

It remains to be seen how effective the quality assurance model which is to be implemented by SQA will be. The scale of the task is huge and it is therefore alarming to learn that some of those who have been engaged to undertake this task are still awaiting training in mid-May, only a matter of a few weeks before the deadline for the submission of “Provisional Grades”.

The lack of clarity and the multiple missteps and muddled communication from SQA and Government sources continue with conflicting messages about the relative role of “professional judgement” and “demonstrated attainment” in arriving at Provisional Grades. 

The Alternative Certification Model has resulted in a huge amount of additional work for teachers in schools across Scotland. For the “persons using its services”, the young people whose futures depend on the reliability and credibility of the qualifications awarded by SQA, the ACM has provided little except uncertainty, inconsistency and anxiety.

In school, we have done our best to provide structure and reassurance. Colleagues have worked tirelessly to provide the opportunities for pupils to acquire and demonstrate the required knowledge, skills and competences. But we can only do so much. The SQA remains the awardingbody and only it can provide the assurance required by young people that grades will be properly awarded, recognising the particular challenges of this year but also ensuring that every grade is a credible reflection of achievement, irrespective of a pupil’s school, circumstances or choice of subjects. The SQA should set out clearly and unambiguously on its own behalf and on behalf of the Government how this is going to be achieved.

I recognise that as the incoming Cabinet Secretary you will have a great deal to consider at this time. However, I would argue that the credibility of the system of Scottish qualifications and the interests of young people taking them must claim your top priority.

Yours sincerely

Melvyn Roffe


George Watson’s College



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