Centre Assessment Standards Scrutiny

With such an extraordinary summer 2020 exam series now (almost) behind us, and the new academic year well underway, many awarding organisations caught up in this maelstrom could be forgiven for feeling overwhelmed by the constant changes and demands on their time, expertise and priorities, and forgetting how to exist in an operational "norm". In other words, the day job.

Statements of compliance are soon to be submitted in part to the regulators, and the focus for many Responsible Officers between now and the September 2021 deadline will include marshalling their troupes, tactics and tasks towards developing a strategy to comply with Ofqual's Centre Assessment Standards Scrutiny (CASS).

Why is this required?

A couple of years ago awarding organisations were invited to share their approach to "Direct Claims Status" and models of verification with Ofqual. When Ofqual's General Conditions of Recognition were originally established, they determined the term "moderation" also covered other methods of quality assurance, but "verification" meant different things to different people and was not a model under current GCoR that could be regulated (the terms "DCS" and verification do not appear in the conditions, and Ofqual cannot therefore regulate these approaches). Accountability for Awarding (A4A) was launched as a consultation which ran between February and May 2019 which, along with their thematic audits focussing on centre controls, resulted in Ofqual confirming back in September of that year that awarding organisations were going to have to change the way they scrutinised centre assessment judgements. And thus, CASS arrived, along with a raft of conditions and guidance from the regulator to help awarding organisations affected by this, comply with this new approach.

Who needs a CASS strategy?

Any awarding organisation which has qualifications where their centres are approved to mark part/all of the associated assessments on behalf of the awarding organisation.

According to Ofqual: "whilst all awarding organisations will need to have a CASS strategy for all centre-marked assessments, they will have the flexibility to determine the form this takes. An awarding organisation could choose, for example, to have a single strategy covering all of its qualifications, or it could have separate strategies for each qualification. It may also decide to take other approaches, for example, having a single overarching strategy, but which sets out the approaches it might take for different types of assessments, or the centres delivering them. It will be for an awarding organisation to determine this, and Ofqual won’t prescribe a particular approach."

So, for "verification" now read "assessment standards scrutiny". Moderation in its original and well-understood form is also required for a specific prescribed list of qualification types, and where an awarding organisation decides it is necessary over and above this. It is a distinct form of quality assurance, with the key factor being that it must take place before results are issued for the qualifications where it is carried out, allowing for adjustments in those results as necessary, following a moderation process.

CCEA (Northern Ireland) are adopting the CASS requirements but - at the time of writing - not the accompanying guidance published by Ofqual; QW (Wales) apply their own conditions and criteria at qualification level, so will not be including requirements CASS at this time.

So, where to start?

The deadline may seem a way off still, but if you have not started to contemplate your CASS strategy, you have a sizeable task ahead of you and remain non-compliant with Ofqual's criteria until you have one in place.

Ofqual's CASS-related conditions (predominantly Section H in their handbook here https://www.gov.uk/guidance/ofqual-handbook/section-h-from-marking-to-issuing-results ) and accompanying guidance are unusually detailed. This is because their aim is to enable compliance with these conditions. A recent consultation on their entire set of GCoR resulted in several revisions to their language and terminology, to ensure they are as easily understood as possible, for the same reason.

Start from where you are and cross reference; create a plan for compliance:

?What do you currently do? How does your current approach to quality assurance align to the new conditions? How do you approve, standardise, monitor and verify your centre assessment activity? Is it a "one size fits all" or do you separate it according to risk, centre, qualification type?

?What do you currently have? How do your published policies, strategies and processes align to the new requirements? Are they sufficient to comply both now and ongoing?

?Who do you currently have? Are your staff, representatives, including at centre-level sufficiently competent and experienced with your requirements, products and processes? Do they understand what to do, and how to do it - even when things go wrong?

?What are your current risks? How do you identify them in relation to CASS requirements? How do you also report, record and review them?

The minimum requirements

Ofqual has published the minimum requirements needed for all CASS strategies and activities. They are also keen to ensure that awarding organisations have the ability to increase these where and when necessary (ie when identified risks requires an increased approach). The minimum evidence is required for these areas:

• Annual activities
• Sampling
• Training and competence
• Risk-based approach

Amongst these, awarding organisations must explain their overall approach, how they approve and allow centres to mark their assessments, their approach to monitoring centres and managing risk, plus how and when they need to take action or make adjustments based on evidence.

So, if you haven't started to consider how to review where you are now, and where you may need to get to in order to become compliant with CASS, this brief reminder will have hopefully served to help steer your thinking and planning.

Need some help?

Artemis Associates Consultancy exists to advise, support and guide our clients through regulatory audits, governance reviews, and provide an expert objective eye on quality assurance strategies. We can also support awarding organisations with appeals and malpractice investigations that require independent oversight and scrutiny.

Unlike other standard professional consulting firms, the team at Artemis has worked within and alongside awarding organisations and training providers of all shapes and sizes, at both senior executive and board level.

Our unique perspective ensures we are able to identify and recommend improvements in operational processes, helping Governing Boards assure themselves of their organisation's regulatory compliance.

Do get in touch if you think we can help you [email protected] or visit our website for more information on how we can help: www.artemisassociates.co.uk