Regulatory strategy – will things change? 

Don’t overlook Ofqual’s Regulatory report on the License-linked qualifications used in the private security industry (published 31 January 2017). Since Ofqual are quite clear that it contains ‘wider lessons’ and walks through several things that concern Ofqual. Here’s my canter through the highlights.

Centre agreements

Amongst the key concerns in the report is the lack of written and enforceable agreements in AOs; or possibly that there may be an agreement document but perhaps not signed by centre/s or maybe not current? 

The report reminds me of some of those things we heard Ofqual’s Bryan Horne talk about in his ‘perfect storm’ some time ago now, it was the potential coming together of factors that presented highest risk and included: qualifications that are short duration; learner funded provision; direct claims status; qualifications that lead to a job (licence to practice); and of course the ineffective or not routinely monitored centre agreements. See  https://www.gov.uk/government/news/presentations-from-the-ofqual15-conference

Assessment, quality assurance and direct claims

In the report Ofqual touch on assessment arrangements and associated quality assurance arrangements too. The qualifications Ofqual were concerned with offered multiple choice papers, invigilated by the centre but marked by the AO; and practical assessments marked at the centre but moderated by the AO. Both delivery methods are not uncommon and can present considerable scope for potential malpractice or maladministration. Ofqual say In particular, where assessment are carried out and marked by centres, awarding organisations must put place arrangements to monitor the assessments and make sure they are able to take action before issuing results if there are problems. My sense is Ofqual want to see AOs doing something to check the status of a result before a certificate is issued and demonstrates their dislike of direct claims, where there is no intervention before a result is issued. I am wondering if direct claims may have its day in the not-too-distant future, certainly in this sector and possibly other sectors? This would be a very hard issue for those AOs who operate direct claims.

Another assessment scam highlighted is the repeated passing off of previously completed work and associated paperwork as ‘original’ in submitting evidence of assessments to the AO. I saw this scam back in the 90s, highlighted when the exam board I was with introduced full-time External Verifiers that brought greater consistency to centre scrutiny. I did the audit of all the centres of the national training provider that was under a fraud charge for false claims for major TEC (Training and Enterprise Council) funding and must say how remarkably cunning and at the same time witless centres can be in covering up! 

Assessment materials

Ofqual also remark on the same, or similar assessment materials often being often used by different centres on different dates creating risk. This is true, it does, but there are ways and ways of controlling things. Sometimes AO security arrangements are only administrative, there is no human intervention – calls, spot checks or similar that can help with confidence in the system.

Trainer qualifications

Another highlight from the report is the finding that trainers do not have the required trainer qualifications and centres falsifying trainer details. Easy-peasy one for centres. This one flips me back to centre agreements and how well centres are screened initially and the on-going monitoring.

Conclusions

The report suggests that Ofqual may consider additional regulatory rules for this sector. I just wonder whether they may decide some things must go sector-wide. Or certainly inform further guidance to the Conditions of Recognition.

There are some obvious things AOs could do right now:

• check out those centre agreements and whether they current and sufficiently monitored

• see what your AO’s qualification and centre risk profile looks like to identify any areas and/or centre arrangements to be addressed

• re-look at quality assurance and security arrangements – could things be done better, and are the checks and balances on security sufficient?  

• review the overall AO control framework. 

These would be good contributors to regulatory review and the self-assessment and the 2017 annual statement of compliance.  

Heather Venis

Principal, Awarding First

Heather@awardingfirst.co.uk

If you would like an external, independent view of your centre, assessment or quality assurance arrangements I can help. Call me on 0789 479 6262 or email heather@awardingfirst.co.uk

Watch out for my next blog, on 17th February, I’m planning to talk about AO controls.  

Ofqual’s Regulatory report link is here