The British Association of Teachers of the Deaf
Promoting Excellence in Deaf Education

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Elizabeth Mackinder

Access to Examinations and Assessments for Deaf Students - What is Reasonable Adjustment in Schools and Further Education?

This conference built upon the previous year’s event and was an opportunity for awarding bodies and educational institutions to develop their understanding of assessment issues arising from the specific needs of deaf students. It was also an opportunity to reflect upon 25 years of hard work and development by The Council for the Advancement of Communication with Deaf People (CACDP).

Chris Hughes CBE opened the conference by reminding us of CACDP's position as the fourteenth largest awarding body out of 115 (financial turnover), but that it is one of the most specialist. CACDP is committed to raising the standard of communication between deaf and hearing people.

From spring 2005 the Disability Discrimination Act (DDA) brings qualification bodies into scope, with the majority of qualifications covered by 2007. The awarding bodies will have responsibility to ensure that the needs of all candidates are assessed and appropriate adjustments made.

These fair and reasonable adjustments are part of building a fair and just society. The focus must now be on equality of outcomes enabling all individuals to achieve their potential. This means that how a qualification is constructed, assessed and awarded is important. This can only be achieved if all the different interested parties work together to ensure deaf awareness, access and fair assessments for deaf learners.

Dr Linda Badham from ACCAC spoke about the regulatory framework in which all examinations and assessments have to operate. She identified the three key players in an assessment of an individual. These are the regulators, the awarding bodies and the centres (schools, colleges, training providers etc).

Regulators are required to set the criteria for the qualifications which the awarding bodies must follow, they accredit qualifications ensuring that a qualification conforms to the regulatory criteria, keep all the qualifications under review and have a duty to publish and disseminate information.

The awarding bodies’ role is to design and write up qualifications including exams and coursework, in line with the regulatory criteria. Each awarding body issues regulations and guidance to centres including guidance on reasonable adjustments for examinations.

Each centre has a crucial role in making accurate assessments of individual needs. Part of the assessment involves the learner demonstrating independently all the skills the qualification has been designed to assess. If a learner cannot demonstrate the skills even with access arrangements that a qualification requires, centres should question whether the learner should be taking that specific course. It is important to ensure fairness for all candidates.

An awarding body must establish what the competent standards are that are required for a course. These competent standards can result in less favourable treatment for a disabled candidate if they are justified. For example, for a shorthand test, a candidate requiring double the time for the test would not be supported, as speed is an essential element of the competent standards.

The regulatory bodies are currently reviewing all 14-19 qualifications (key stage 3 SATs and GCSEs) for any unnecessary barriers to access. The competent standards need to remain, even if they cause a barrier for some students in terms of access. Disability groups and representatives will be given an opportunity to feed into the reviews prior to the outcomes going forward to formal consultation.

A new publication for awarding bodies is on the QCA website on designing qualifications that minimise barriers to access (Fair Access by Design).

Dr Badham then spoke about certificate indications. The current regulations make provision for some groups of candidates where there is an access arrangement you can make, for example, speaking within the modern foreign language exams. The current system awards marks for the parts of the exams students can do and the certificate is annotated to state what has not been attempted. Legal advice on this practice has been sought and it appears that it does not comply with the DDA, as a different competency standard is given to some candidates, which is discriminatory. The regulators are fully aware of the concerns of our profession. They are looking for the best solution to the speaking and listening element of GCSE English which is acknowledged as a huge issue.

An additional notice is due out to centres this autumn term to help identify access arrangements that could be available to candidates.

The problem of carrier language is being investigated at the design stage of exams. The regulators will be looking into this in greater depth as part of the review of A levels and GCSEs. The principle of making carrier language fully accessible is supported but the practicalities are proving to be more problematic.

Next to speak was Miranda Pickersgill from CACDP and Ian Robinson from Deaf START, Leeds. They launched the first draft of their publication on access to external assessment for deaf candidates. This is designed to supplement the guidance available from the Federation of Awarding Bodies (FAB). It is not exhaustive and is given as guidance only. The publication is available on the website and will be updated and amended as time progresses.

The purpose of the publication is to provide greater consistency on how decisions about reasonable adjustments are made.
Four key issues were identified.

  • Defining candidates: a centre makes a request for a reasonable adjustment for an individual. They must provide evidence of the assessment of needs. The centres must provide as much information as possible. The reasonable adjustment requested should reflect the normal ways of working with that candidate. It is up to each centre head to decide which staff are appropriate to produce the assessments.
  • Defining the process of adjustments: this usually relates to the language of assessment and response or a change to the language ie from standard to modified. The awarding body may provide a modified paper. A centre may present orally what is presented on paper. All the different processes depend on the assessment criteria for the exam. There is a concern about the lack of standardisation of curriculum signs in BSL that are acceptable for assessment purposes.
  • Defining the providers of reasonable adjustments: guidance describes the role of the access facilitator ie BATOD/NATED list of approved modifiers. The oral modifier (rephrasing of carrier language, word order and word substitution) is not included in JCQ or FAB's guidance. The awarding bodies need to be confident that the integrity and assessment standards are safeguarded whatever the adjustments made.
  • Defining and assessing minimum standards: BSL candidates need interpreters. The awarding body needs to balance concerns about the credentials of the access facilitator and the aim of removing obstacles. The awarding bodies can define skills and issue instructions. They can indicate on an exam paper where language cannot be changed, issue BSL papers (video exam paper), request a paper is annotated to state support given etc.

After lunch Jane Couper spoke about the language modification of exams. She argued that language modification is an essential reasonable adjustment, taking away any unnecessary complexity. Language modification is not used when the assessment is testing a reader's skill. However in all other cases clear language benefits all candidates.

Oral and BSL modifications may differ. Examination boards do not have to accept alterations given by a language modifier and a paper may have gone through the process of modification with very little change to the final paper. There is no guarantee that even where a paper has been modified at source it will be modified sufficiently for a specific candidate.

Anyone can become a language modifier including deaf adults. Jane reminded us that language modification wasn't just about changing the language but also layout, format or the inclusion of diagrams.

With regard to endorsed certificates for the English GCSE qualification, Jane reminded us that it is an essential qualification opening doors to further qualifications and employment. Without endorsed certificates a good deaf candidate who cannot achieve on the speaking and listening element will never achieve an A or A* grade.

Each disability is unique and needs an individual response. We should be recognising the skills that candidates can prove. We need to encourage all people with disabilities to stretch themselves and fulfil their potential. It is ironic that the DDA is promoting discrimination on this issue.

Sarah Rendell, Patricia Neville and Deborah Drew from Oak Lodge School continued on this theme. Reasonable adjustments are about demonstrating ability not highlighting disability.

There are many students who are capable of getting good grades in the written part of the English GCSE exam but they may not use spoken English, or have very poor oral skills. By 2007 the English exams will not be accessible to many deaf students as speaking and listening is at the heart of the assessment.

Entry level qualifications allow candidates to demonstrate ability to communicate including through BSL. This actively encourages students to develop these skills.

The speaking and listening element of current examinations discriminates against many deaf students. Solutions need to be found to this issue and urgently.

With regard to BSL exams, some deaf candidates are experiencing problems with the use of cue cards. They are unable to read the cue cards as they have poor reading skills. Lip reading may not be the solution. There is a need for students to have access to BSL cue cards. BSL exams should be a test of BSL skills not English skills.

Nick Lait from Edexcel spoke about the assessment process from the view of an awarding body. He told us that the JCQ was formed to act as the administrative hub of the awarding bodies providing regulations to which each awarding body must agree. These regulations are in two categories: access arrangements and special considerations.

The National Assessment Agency (NAA) (an offshoot of QCA) has the task of modernising exam administration. The system is paper driven. It has introduced an on-line system for delegated access arrangements. Exam officers and SENCOs make access arrangements on-line. It is hoped that further arrangements will come on-line in the future.

Nick reminded us that it is important to seek advice from awarding bodies on exam access arrangements before a student begins a course. He advised that all awarding bodies appreciate approaches from language modifiers to work with them on the production of papers.

The JCQ website is reviewing specialist teacher qualifications. It is currently consulting on appropriate qualifications with a deadline of 17 November 2005.

Cathy Barnes was the final speaker for the day. She launched the FAB good practice guidance for vocational qualifications. This is sister guidance to the JCQ advice.

Vocational qualifications have a wide variety of assessment types and locations so the JCQ guidance is not always appropriate. Centres need to be consistent in the reasonable adjustments they make. Many of the specialist vocational awarding bodies are very small and do not have the same level of experience of reasonable adjustment requests.

The guide lists the range of acceptable evidence for a person authorised by the head of centre to request access arrangements. Centres complete a simple form stating which adjustment is required and why.

The guidance from FAB is only guidance. But when an awarding body issues it to centres, with its own logo and adjustments added it is a requirement. It can be downloaded from the website The publication will be reviewed after a year's use. FAB welcome any feedback you may have.

This was another interesting and informative conference from CACDP. Unfortunately, though, more questions seem to be raised than solutions provided!

BATOD Magazine January 2006