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A Consultation on the future of AGE AND STAGE REGULATIONS

INTRODUCTION

This consultation exercise invites views on the Age & Stage regulations which impact upon the entry of candidates for National Qualifications. These regulations determine when pupils may be entered for Standard Grades and National Units and Courses.

This document is divided into three main sections and three annexes. The first section provides background information about the regulations. The second section sets out some general points for consideration. The third section sets out five options and invites you to record your views. The annexes contain background information for reference, and some relevant web links are provided at Annex C.

You are invited to read the document carefully, consider the advantages and disadvantages of the various options, and then complete the form. There is space provided for you to add comments or suggest alternative options if you wish to do so. You can respond without using this form, in which case please include all of the details requested on the form.

If you wish to access this consultation online, go to www.scotland.gov.uk/views/views.asp .

You can Freephone 0800 77 1234 to find out where your nearest public internet access point is, if you prefer to submit your response by e-mail.

We are inviting responses to this consultation by 4 June 2004. Please send your response to:

William Scott-Watson Scottish Executive Education Department Area 2-A, Victoria Quay Edinburgh. EH6 6QQ

E-mail: AgeandStage@scotland.gsi.gov.uk

For further information about the consultation, contact William Scott-Watson on 0131 244 0069, or by writing to the address above.

Once the period for consultation is over, responses will be considered and analysed by an independent consultant, who will report on the findings later in the year. Any changes as a result of the consultation will be introduced for session 2005-06.

Confidentiality

It is normal practice for responses to consultation papers to be made publicly available, unless respondents request that their comments remain confidential. Please complete the respondee information form in full, or, if not using the form, include all of the information requested. Any confidentiality disclaimer generated by your computer system in an e-mail will not be treated as such a request. Confidential responses will be included in any statistical summary of numbers of comments received or views expressed.

Acknowledgements

All responses will be acknowledged, either in writing or electronically. However, please note that in view of the size and nature of the consultation exercise, it will not be possible to respond individually to comments received.

SEConsult

A new email alert system for SE consultations (SEconsult) will be launched in Spring 2004. This system will allow stakeholder individuals and organisations to register and receive a weekly email containing details of all new SE consultations (including web links). SEconsult will complement, but in no way replace SE distribution lists, and is designed to allow stakeholders to ‘keep an eye’ on all SE consultation activity, and therefore be alerted at the earliest opportunity to those of most interest. We encourage you to register as soon as possible.

Access to consultation responses

We will make all responses available to the public in the Scottish Executive Library by 2 July 2004 unless confidentiality is requested. All responses not marked confidential will be checked for any potentially defamatory material before being logged in the library.

The Scottish Executive Consultation Process

Consultation is an essential and important aspect of Scottish Executive working methods. Given the wide-ranging areas of work of the Scottish Executive, there are many varied types of consultation. However, in general Scottish Executive consultation exercises aim to provide opportunities for all those who wish to express their opinions on a proposed area of work to do so in ways which will inform and enhance that work.

While details of particular circumstances described in a response to a consultation exercise may usefully inform the policy process, consultation exercises cannot address individual concerns and comments, which should be directed to the relevant public body. Consultation exercises may involve seeking views in a number of different ways, such as public meetings, focus groups or questionnaire exercises.

Typically, Scottish Executive consultations involve a written paper inviting answers to specific questions or more general views about the material presented. Written papers are distributed to organisations and individuals with an interest in the area of consultation, and they are also placed on the Scottish Executive web site enabling a wider audience to access the paper and submit their responses. Copies of all the responses received to consultation exercises (except those where the individual or organisation requested confidentiality) are placed in the Scottish Executive library at Saughton House, Edinburgh (K Spur, Saughton House, Broomhouse Drive, Edinburgh, EH11 3XD, telephone 0131 244 4552).

The views and suggestions detailed in consultation responses are analysed and used as part of the decision making process. Depending on the nature of the consultation exercise the responses received may:

• indicate the need for policy development or review
• inform the development of a particular policy
• help decisions to be made between alternative policy proposals
• be used to finalise legislation before it is implemented

If you have any comment about how this consultation exercise has been conducted, please send them to William Scott-Watson at the address above.

SECTION ONE: BACKGROUND

1. The Scottish Qualifications Authority (SQA) sets down conditions in respect of the entry of candidates for qualifications. However, restrictions on the age and stage of entry to national school examinations in Scotland go back to the inception of the Higher Grade in 1888, (although they are not regulations as such under statute).

2. In Educating for Excellence — The Scottish Executive’s response to the National Debate on Education the Executive has committed to consult on the future of Age and Stage regulations during session 2003-2004. Educating for Excellence also contained a commitment to promote flexibility in the curriculum in order that all pupils have the opportunity to achieve their full potential.

3. Centres approved by SQA, such as secondary schools, further education colleges, training providers and other public and private bodies, which present candidates for National Qualifications apply to SQA to enter each candidate for the relevant Standard Grade exams, National Units and National Courses each year.

4. The current position for Standard Grade and new National Qualifications is set out in the Conditions and Arrangements for National Qualifications, published by the SQA. (The relevant section is reproduced in Annex A.) The regulations were revised in 1999 after wide ranging consultation to allow centres to enter candidates for Standard Grade examinations from the end of S3 onwards, and for new National Qualifications (nNQ) examinations from the end of S4. Until session 2003-04 centres could apply for exceptional entry on an individual basis to allow candidates to take external examinations outwith these specified stages. To reduce the administrative burden for session 2003-04 an interim procedural change was introduced to allow centres, through their Director of Education or, for the independent sector, the Chair of the Board of Governors or equivalent, to make simplified multiple applications for a group, class or year for exceptional entry.

National Qualifications

5. The system of National Qualifications includes Standard Grades and new National Qualifications (nNQs). Standard Grade courses, normally taken in S3 and S4, take two years to complete and are offered at three levels: Credit (grades 1-2), General (grades 3-4) and Foundation (grades 5-6). nNQs are available at 5 levels: Access (1, 2 & 3), Intermediate 1, Intermediate 2, Higher and Advanced Higher. Access level qualifications are available for pupils who require support with their learning and can be taken from S3. Intermediate level courses and above were originally intended for pupils in S5 or above. The old SCE Higher has been phased out and replaced with the new Higher whilst the Advanced Higher has replaced the Certificate of Sixth Year Studies

6. nNQs are constructed from blocks of study called National Units which are internally assessed, although this assessment is quality assured by certification from SQA. Access level awards require candidates to pass three National Units. To attain a course award at Intermediate, Higher or Advanced Higher level candidates will normally take three National Units and an external National Course assessment. The Age and Stage regulations govern when candidates can receive certification from SQA for National Units and be presented for external assessment for Standard Grade and National Courses.

1998 consultation

7. Prior to 1999 centres could enter candidates for Standard Grade examinations in S4 and Higher examinations in S5 without application for exceptional entry. Standard Grade could be taken in S3 and Higher in S4 if centres made an application to SQA for exceptional entry. In the development of Higher Still policy, which brought about the introduction of nNQs in 1999, it was recognised that greater flexibility in provision could enable centres to better meet the needs of pupils. The paper which launched the reform, Higher Still: Opportunity for All (1994), suggested that able pupils should be able to take Credit level Standard Grade in S3. This required a change to Age & Stage regulations.

8. In addition, the report Improving Achievements in Scottish Schools (1996) suggested that Higher Still units (now referred to as National Units) might replace part of the curriculum for some pupils who were taking Foundation and General level Standard Grade courses. Allowing a mix of Standard Grade and National Units would not in itself have required a change to the conditions. However, improvements to this modular provision in terms of availability of course and group award certification would not have been available unless the regulations were amended.

9. A consultation on Age and Stage regulations was carried out in 1998 by the then Scottish Office Education and Industry Department which resulted in a relaxation of the regulations.

Current Age and Stage regulations

10. Following the 1998 consultation the regulations were relaxed by one year from 1999, as shown in the table below.

Table 1 - Minimum age and stage when candidates can be entered for Standard Grade and National Courses, showing changes made as a result of 1999 relaxation.

11. Candidates can be entered for National Units, other than those at Advanced Higher, (i.e. those at Access, Intermediate 1 & 2 and Higher) in S3 or above. This means candidates can be entered for these units the year before they are able to be entered for the full Course award. This allows the opportunity for them to study for the full course(s) over two or more years from S3 onwards. The table below shows the regulations in respect of entry to National Units.

Table 2 - Minimum age and stage when candidates can be entered for National Units.

Impact of 1999 relaxation of Age & Stage regulations

12. Some centres appear to have used the 1999 relaxation of the regulations to adapt provision to suit local needs and circumstances. This is more marked in S3 and S4 than in S5 and S6. As the table below shows, the number of candidates achieving awards at Standard Grade in S3 and Intermediate level 1 and 2 in S4 has increased considerably since the regulations were relaxed. There has been little interest in centres offering Higher in S4 to whole classes; rather acceleration at this level tends to take place on an individual rather than group basis, with pupils entering the S5 class to study for the examination.

Table 3 - Number of candidates achieving an award at Standard Grade in S3, and at Intermediate and Higher level in S4, following the 1999 relaxation of the regulations.

13. At the time of the last relaxation of the regulations, centres — almost without exception — entered candidates for Standard Grade courses followed by progression to nNQ courses. Since 1999 however a growing number of centres have chosen to replace some or all Standard Grades with Intermediate 1 & 2 courses. These correspond with Standard Grade General and Credit level respectively, and are set at the same point on the Scottish Credit and Qualifications Framework (SCQF) - see Annex B. This has created what is perceived as an inconsistency in the Age and Stage regulations; while pupils may be entered for Standard Grade course assessments at the end of S3, they may not be entered for Intermediate level courses until S4. There is concern that this acts as a disincentive to centres to offer more flexible progression routes through S3 and S4, counter to current education policy of encouraging flexibility in the curriculum. There is also some concern that the requirement to apply for exceptional entry for certification for Access level courses in S2 or earlier deters uptake of this qualification.

Exceptional entry

14. Prior to session 2003/04 centres could apply to SQA for the exceptional entry of candidates where they did not meet the age and stage criteria. However, these applications had to be made on an individual case by case basis on the grounds of either possible hardship or exceptional attainment. In cases of possible hardship, centres had to estimate that the candidate was sufficiently competent to obtain a grade C in the relevant National Course or grade 3 at Standard Grade. For cases of exceptional attainment, centres had to estimate that the candidate was sufficiently competent to obtain a grade A in the relevant National Course or grade 1 at Standard Grade. SQA had to ensure that each application had considered the social maturity and academic ability of the candidate and would request further rationale from the centre if they deemed it necessary.

15. Following an increase in the number of exceptional entry cases there were concerns from teachers and centres about the growing administrative burden from the need to complete separate application forms for each candidate. The Scottish Executive and SQA therefore introduced an interim procedural change for the current session 2003/04. This allows centres to submit applications for exceptional entry on a group, class or year basis through their Director of Education or, in the case of independent schools, Chair of the Board of Governors or equivalent. The Director of Education, or Chair of the Board of Governors or equivalent, must be satisfied that there is sufficient rationale for the group/class/year to be entered for the Units or Courses in question. This will include consideration of the level of maturity and academic ability of the candidates for whom the application is being made. SQA will automatically approve all valid applications for exceptional entry received with the Director of Education’s, or the Chair of the Board of Governors’ or equivalent’s, approval. Centres can still make individual applications direct to SQA who must be satisfied that the social maturity and academic ability of the candidates involved have been considered.

16. The table below shows the number of successful applications made for exceptional entry to Standard Grade examinations, National Units and National Courses for 2003 and 2004. Directly comparable figures are not available for previous years due to a change in the data management process at SQA. Figures for 2004 are provisional but show a large increase in applications under the new simplified procedure. This has been accompanied by a significant rise in unnecessary applications where exceptional entry has been sought for candidates who already meet the age and stage criteria. The table below shows the number of successful applications for exceptional entry by year and level.

Table 4 - Number of successful applications for exceptional entry by level.

• * figures for 2004 are provisional.
• It should be noted that centres can withdraw candidates from a Course or Unit — the figures above will not necessarily represent the number of candidates achieving an award at an age and stage where application for exceptional entry was required.

SECTION TWO: GENERAL POINTS FOR CONSIDERATION

Flexibility in the curriculum

17. The 1999 relaxation of Age and Stage regulations has to some extent achieved its aim of providing centres greater flexibility to adapt provision to suit local needs and circumstances, and increasing opportunities for accelerated progression where appropriate for individual pupils. However, there remain concerns that the current regulations restrict options for some pupils by discouraging centres from offering more flexible progression routes through secondary school.

Timetabling and maturity issues

18. Many responses to the 1998 consultation pointed out that it could be difficult in practice to find the staffing and other resources, and spaces in the timetable for those taking qualifications at an ‘earlier’ stage. The teaching of the same course to pupils of different ages who may vary significantly in social maturity was regarded as undesirable. The appropriateness of course content was also highlighted as a potential issue for younger pupils, particularly in relation to nNQs which were originally designed to articulate with Standard Grades at the post-16 stage.

19. There is evidence from HMIE reports which indicates that timetabling to deliver courses at an earlier age has not in itself created a major difficulty; rather, limited resources in terms of staff and classroom space to deliver the courses to make full use of the flexibility remains an issue in some centres. However the aim of the previous relaxation of Age and Stage regulations was not to offer all courses at all levels, but rather to enable centres to deliver more appropriate and flexible provision to suit the needs of pupils. It is also important to note that the relaxation of Age and Stage regulations permits rather than requires centres to enter candidates ‘early’.

20. Under the current regulations the Director of Education, or the Chair of the Board of Governors or equivalent for the independent sector, must be satisfied that centres have considered the social maturity and academic ability of those candidates put forward for exceptional entry. Any further changes to the regulations would need to ensure maturity issues continue to be addressed. However as age is not the only factor, albeit an important one, in determining social maturity, it should be remembered that it is up to education authorities and centres to decide what provision best suits their local circumstances.

21. The options discussed on the following pages all have advantages and disadvantages for the pupil. Respondents are asked to carefully consider the impact of any possible change to the regulations for individual pupils before completing the response form.

Links with other education policy

22. The outcomes of this consultation may impact on forthcoming work taking forward the commitments made in the response to the National Debate on addressing the relationship between Standard Grades and the nNQs, and on reducing the amount of time spent on external exams.

SECTION THREE: OPTIONS

Option 1 — Revert to the regulations as operated prior to session 2003-04

23. This option would revert to the regulations as they operated prior to session 2003-04, as described earlier in this document. Applications for exceptional entry would be made on an individual candidate by candidate basis.

Some advantages of this option:

• Some consider that the regulations would act as a safeguard to prevent undue pressure being placed on pupils to take exams early.
• Issues regarding the social maturity of candidates would be considered by teachers before application for exceptional entry is made.
• The system is familiar to all those involved in education.

Some disadvantages of this option:

• The regulations would restrict initiatives to introduce more flexibility in the delivery of the curriculum and therefore would inhibit efforts by centres to respond to the needs of the individual pupil.
• The applications process for exceptional entry would increase the work burden for teachers and might act as a disincentive to put candidates forward.
• This option would reverse the interim procedural change which was introduced in session 2003-04 to simplify the process for exceptional entry and reduce teacher workload and bureaucracy for centres.

Option 2 — Maintain the regulations as operated in session 2003-04

24. This option would make permanent the interim procedural change currently in operation where applications for exceptional entry can be made on a group, class or year basis through the Director of Education, or, for the independent sector, the Chair of the Board of Governors or equivalent.

Some advantages of this option:

• As above for Option 1, some consider that the regulations act as a safeguard to prevent undue pressure being placed on pupils to take exams early.
• The ability to make simplified applications for exceptional entry reduces the workload for teachers and centres.
• More coherence and consistency in the applications process for exceptional entry within local education authority areas through the involvement of the Directors of Education.

Some disadvantages of this option:

• The regulations restrict initiatives to introduce more flexibility in the delivery of the curriculum and so constrain efforts to respond effectively to the needs of the individual pupil.
• The regulations add a layer of bureaucracy for centres and education authorities.
• Given the high incidence of unnecessary applications for exceptional entry, there is some evidence that the existing regulations are causing confusion. This increases the workload for teachers, centres, education authorities and SQA.

Option 3 — Relax the regulations to allow entry to Intermediate level National Courses from S3

25. This option would relax the current regulations in respect of Intermediate level courses by one year to allow pupils to be entered at this level from S3 onwards.

Some advantages of this option:

• This would address the current anomaly whereby candidates are able to sit Standard Grade course assessments in S3 but not external assessment for Intermediate level courses which are effectively set at the same level on the Scottish Credit and Qualifications Framework.
• Relaxation would provide more flexibility to centres in planning progression and curriculum delivery and would enable schools to better respond to the needs of the individual pupil.
• Relaxation would permit rather than require change.

Some disadvantages of this option:

• Intermediate level courses were originally designed for pupils in S5 or beyond and material in some subjects may not be suitable for pupils in S3. Local authorities and schools would have to make sure that procedures are put in place to ensure that issues of maturity and academic ability are fully considered.
• There might be less coherence and consistency within and across education authority area boundaries as individual schools pursue differing policies on the use of Intermediate level courses in S3.

• Application for exceptional entry would still be required for candidates wishing to undertake Access courses before S3, Standard Grade exams before S3, Higher exams before S4 and Advanced Higher exams before S5, maintaining a layer of bureaucracy for centres.

Option 4 — Replace the Age and Stage regulations with guidance

26. This option would replace the current national system of prescriptive Age and Stage regulations with guidance provided by the Scottish Executive for local authorities to operate at their own discretion. This guidance could ensure that education authorities establish a clear framework within which individual schools would be expected to operate, and could stress that candidates are not entered for an excessive amount of exams and that maturity issues are considered. If this is the favoured option the Scottish Executive would prepare the guidance after full consultation with stakeholders, taking into account comments made in response to this consultation.

Some advantages of this option:

• •Removing the current prescriptive regulations would devolve decision making to a local level and help centres better meet the needs of the individual pupil by providing maximum flexibility in planning candidate progression and curriculum delivery.
• Would remove a layer of bureaucracy — centres would no longer need to apply through their education authority to SQA for exceptional entries. The guidance could ensure that teachers continue to consider issues of the social maturity and academic ability of candidates as at present.
• Would reduce the workload on teachers and centres.
• This would permit rather than require change.
• The HMIE inspection regime would continue to ensure good practice is followed in all individual schools and local authorities.

Some disadvantages of this option:

• Parental, school or other pressures could result in pupils being encouraged to take exams too early.
• Lack of prescriptive regulations operated nationally may result in variations in practice and provision between different education authorities which could make it more difficult for pupils to adapt if required to move to a different area during their secondary school career.

Option 5 — Abolish the Age and Stage regulations entirely

27. This option would abolish the regulations entirely. It would be left to education authorities and head teachers to decide on policy relating to examination ages and stages.

Some advantages:

• As with Option 4, the system would be better prepared to respond to the needs of the pupil by providing maximum flexibility to centres in planning progression and curriculum delivery.
• Would reduce the workload on teachers and centres.
• Would devolve decision making to local level.
• Would remove a layer of bureaucracy — education authorities would no longer need to apply to SQA for exceptional entries.
• Abolition of the regulations would permit rather than require change.
• The HMIE inspection regime would continue to ensure good practice is followed in all individual schools and local authorities.

Some disadvantages:

• Abolition could remove a layer of protection for younger pupils in terms of social maturity and the stress associated with the sitting of national examinations.
• Parental, school or other pressures could result in pupils being encouraged to take exams too early.
• Lack of prescriptive national regulations or discretionary guidance could result in significant divergence in policy between education authorities or within education authority areas as different authorities and head teachers pursue varying strategies. This could make it more difficult for pupils moving between schools within or across education authority area boundaries.

PLEASE RECORD YOUR VIEWS BELOW

ANNEX A

Extracts from Conditions and Arrangements for National Qualifications. (Scottish Qualifications Authority 2003/2004)

2.3 Entering candidates for National Qualifications

It is the responsibility of the centre to ensure that candidates are entered for the qualifications that they are seeking. Our acceptance of an entry is subject to our requirements for internal assessment being met, and is also subject to the fulfilment of the following age and stage regulations.

Age and stage regulations

Standard Grade

In the academic session in which the Course assessment takes place, candidates must:

National Units except those at Advanced Higher (ie Access; Intermediate 1 and 2; Higher; those still to be levelled)

In the academic session in which the Unit assessment takes place, candidates must:

National Courses at Intermediate 1, Intermediate 2 and Higher

In the academic session in which the Course assessment takes place, candidates must:

National Courses at Advanced Higher

In the academic session in which the Course assessment takes place, candidates must:

National Units at Advanced Higher

In the academic session in which the Unit assessment takes place, candidates must:

Notes on age and stage regulations

Other than in exceptional cases, no National Units are available for certification until S3. National Units at Intermediate and Higher can be certificated after internal assessment in S3 or above. National Units at Advanced Higher can be certificated at S4 or above. This means that candidates will be able to take National Units and have them certificated one year before they can take the external assessment for a full Course, allowing them to embark on a two- year Course beginning the year before the external assessment is available. Failure to observe these conditions will lead to the entry for the qualification concerned being withdrawn. The entry for any other qualification may also be withdrawn. This will be the case whether or not the candidate has already completed the assessments for the qualifications.

2.4 Exceptional entry

Scottish Executive Ministers and SQA have decided to introduce an interim change to the Age and Stage Regulations for session 2003 — 2004. This change will allow schools, through their Director of Education, to make simplified multiple applications (ie for a group, class or year) to SQA under the exceptional entry provision.

It will be for the Director of Education to confirm that there is sufficient rationale for a group/class/year to be considered as exceptional cases. This will include consideration of the levels of maturity and academic potential of the students for whom the application is being made. If the Director judges an application to be appropriate, he or she will write to Tom Drake, General Manager – National Qualifications, SQA, Ironmills Road, Dalkeith, Midlothian, EH22 1LE.

All applications must include details of the school (name and centre number), qualification (name and SQA product code including level) and names and Scottish Candidate Numbers of candidates in the group/class/year where exceptional entry is being sought. To ensure we amend our data entry system to take account of exceptional entries, it would be helpful if applications could be sent to Tom Drake by mid-September.

Independent schools can also take advantage of this interim arrangement. Head teachers of independent schools should write to the General Manger – National Qualifications as indicated above. Their applications should be counter-signed by the Chair of the Board of Governors or equivalent.

The rationale for this change is to respond to the needs of schools where there is an increasing pressure and case for changes to the current Age and Stage regulations to meet the flexibility agenda. The increasing numbers of exceptional entries being made by schools backs this up. This change to the exceptional entry procedure for National Qualifications will ease the administrative burden in the interim, until the Scottish Executive can consult with stakeholders about the future of the Age and Stage Regulations.

ANNEX B

The Scottish Credit and Qualifications Framework

The SCQF is a new way of making sense of the large and varied number of Scottish qualifications/training programmes. The framework shows at a glance how different types of learning compare with each other, as shown in the table above. Each qualification is allocated a level according to how demanding the qualification is. At any level the qualifications can cover a wide range of skills and knowledge — some may be specialised, others more general, but they are comparable in terms of knowledge, skills or competence required.

For further information about the framework visit: www.scqf.org.uk .

ANNEX C

Relevant web links

The Scottish Executive — www.scotland.gov.uk

The National Debate on Education - www.scotland.gov.uk/education/nd_homepage.htm

Scottish Qualifications Authority — www.sqa.org.uk

National Qualifications Online — www.ltscotland.org.uk/nq

Scottish Credit and Qualifications Framework — www.scqf.org.uk

Parentzone — www.parentzonescotland.gov.uk

References

Scottish Executive (2003) — Educating for Excellence: The Scottish Executive’s Response to the National Debate. www.scotland.gov.uk/library5/education/ndser-00.asp . (The Scottish Executive)

Scottish Office (1994) — Higher Still: Opportunity for All. (The Scottish Office)

Scottish Office Education and Industry Department (1996) — Improving Achievements in Scottish Schools: A Report to the Secretary of State for Scotland. (The Stationary Office)

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