Examinations/Assessments and Normal way of working – Deaf learners
The BATOD archive that dates back to the early 1900s reflects a long history among deaf education professionals of advocating for a fair playing field for deaf children and young people (CYP) in assessments and examinations. The BATOD magazines and National Executive Council (NEC) meeting records from the 1980s onwards reflect the role of BATOD in raising the awareness of the reasonable adjustments needs to be considered by the awarding bodies, regulatory bodies, educational settings and specialist deaf education workforce. Paul Simpson, National Executive Officer (NEO) (1999-2023) was a staunch representative in many stakeholder meetings and training sessions in this area. Paul’s legacy continues through the work of the UK-wide Statutory Assessment and Examination Access Arrangement Working Group (SA&EAAWG).
The SA&EAAWG plays a critical role in providing support and guidance, resources and shaping equitable assessment practices for deaf CYP from source with the awarding bodies to the practice in the exam room. Its remit covers statutory assessments, national examinations, and the consistency of access arrangements across the United Kingdom (UK).
The group’s work is rooted in a learner’s normal way of working and reviewing challenges and inconsistencies in assessment and exam access arrangements across all the age ranges ie early years foundation profile to university assessments. They meet online three to four times each year with additional meetings for those who volunteer for any sub-group activity. Some of the group’s activity is email based eg a collective response to a query from a member.
The SA&EAAWG brings together practicing practitioners: Qualified Teachers of Deaf Children and Young People (QToDs) from specialist deaf schools, deaf resource provisions, local authority sensory support services, educational audiologists, dual qualified ToDs/SENCos, exam officers, a retired Communication Support Worker (CSW), BATOD NEO, BATOD Accredited Language Modifier coordinator and representatives from the National Deaf Children’s Society (NDCS) to ensure fair, evidence-based access to statutory assessments and examinations for deaf CYP. The group has long standing representation on the Ofqual Access Consultation Forum (ACF) and regularly engages with Joint Council for Qualifications (JCQ) and Qualifications Scotland, which replaced the Scottish Qualifications Authority (SQA) on 1 February 2026. Different approaches across awarding bodies create challenges for consistency, emphasising the need for clearer national guidance and cross-agency dialogue.
Over recent years, the educational landscape has seen significant shifts, particularly with the expansion of digital assessments, evolving regulatory frameworks, and heightened awareness of inclusion. SA&EAAWG’s work therefore addresses both immediate challenges and long-term systemic change, ensuring assessment practices remain fair, evidence‑based, and embedded in the principle of normal way of working.
Every two years, often in partnership with the Scottish Sensory Centre, the working group, aim to organise an online webinar event to give professionals the opportunity to refresh their knowledge of exam access arrangements, any changes that have taken place and to offer a platform for discussion about pertinent issues related to examination access arrangements that impact on deaf students.
For further information contact [email protected]
Examination language feedback form
BATOD is keen to ensure that the quality of the modification of the language of examinations remains high. In order to monitor the quality it is important that we get feedback. We have designed a simple form which can be used to inform us of colleagues’ opinions – both positive and negative – of the language of examinations with which they have been involved.
Language modifier
Live speaker
Read Aloud
Read Aloud is when the candidate can read out loud to themselves. They can read aloud texts and questions or but also their own writing. Reading out loud will support the candidate to process what they are reading and also it may help them to spot any mistakes in their own writing.
As the arrangement needs to reflect the candidate’s normal way of working, it should be in place for all assessments and mock exams, as well as for external exams. Reading out loud does not come naturally for some and so ideally the candidate would need to have opportunities to read aloud regularly. This should be in a separate, quiet room i.e. separate invigilation.
A candidate who would usually have a reader, but cannot make use of a reader for assessments testing reading (or parts of papers that assess reading) can have 50% extra time and may read aloud during this time, which will help with processing what they are reading. This must be accommodated by separate invigilation.
Sign Language Professional
CSWs in exams
Andy Owen, retired Senior CSW and BSL/English interpreter, has revised the former adept publication ‘How can CSWs be confident in exams?‘
Passport to Access
Andy Owen, retired Communication Support Worker, shares his recommended access arrangement requisites in this article about his resource ‘Passport to Access’
2023 Sensory impairment BATOD, VIEW, RNIB, NatSIP
In February 2023, BATOD has created with VIEW, RNIB and NatSIP, an updated version of the ‘Examination access for children and young people with sensory impairment‘ publication.
2021 Scottish Sensory Centre (SSC) and BATOD
In September 2021 the Scottish Sensory Centre (SSC) and BATOD hosted a successful webinar on Exams and Access Arrangements specific to deaf learners. The webinar generated a range of questions and answers. They are available to read here.
Question 1
I am a QToD, do I need to complete Language Modifier training?
BATOD response
Qualified ToDs are able to act as LMs because of the nature of the ToD qualification.
JCQ 5.11.5 “A fully Qualified Teacher of Deaf Children and Young People may act as a Language Modifier without the need to successfully complete accredited training.”
Question 3
Should schools order modified language papers or will these have been checked by BATOD before being sent out?
BATOD response – These are the relevant sections from the LM Handbook produced by CIEA and updated recently by Lina Read the CEO at Communicate-Ed who works closely with NIck Lait at JCQ
Candidates working with the help of a language modifier should always be given a language modified paper. The language in these papers is a simple as possible, while still conveying the meaning of the questions set by the examiner. Usually papers are modified at source by the awarding body. In most cases, this means that a specialist in modification will have made suggestions about language before the paper is finalised. Such a paper is thus modified for all candidates. Where a paper has not been modified at source, it is possible for the SENCo to order a paper specially for that candidate through the Access Arrangements Online system.
The SENCo will receive immediate notification through AAO as to whether the arrangement has been approved. For LM, there will be an automatic rejection. The centre must then make a referral to the relevant awarding body.
Question 4
Should all staff who might need to sign papers aim to be doing a language modification course?
BATOD response
This is the relevant section from the JCQ regulations:
BATOD response
Unit K318 – Accessible English for Deaf and Deafblind People is not an accredited language modification course. The only stand-alone accreditation on offer is run by Communicate-Ed Language Modifier (LM) course. It is robust and rigorous. It is accredited by CIEA. JCQ regulations state that anyone acting as an LM in an exam must have successfully completed accredited training. This applies whether or not the awarding body has used a BATOD accredited LM (BALM).
Question 6
Lower secondary pupils are due to start their internal school exams soon. Staff have been told the students are not allowed to have their usual classroom assistant with them as this is not ‘best practice’. The replacement staff will never worked with them. As a QToD, how can I challenge this decision professionally?
BATOD response:
BATOD advises the QToD investigates what specific access arrangements purpose would the staff be doing? How does it correspond with what would happen in real GCSEs in the future?
If the support staff are supporting in the capacity as communication professionals eg CSWs etc or Language Modifiers, these arrangements would be requested for the actual exams and should be the – ‘normal way of working’.
Question 7
“A deaf student will be taking French GCSE next summer… and for the oral/listening elements the school have said the student can’t have their own French teacher as the live speaker, is this correct?”
BATOD response:
BATOD would contest the school’s statement. The SENCo is allowed to provide a live speaker for pre-recorded examination components, e.g. MFL Listening examinations, where it is the candidate’s normal way of working within the centre… and JCQ AAA 23/24 “5.12.5 The live speaker should, wherever possible, be the candidate’s subject or specialist teacher.” That is, the learner has access to the individual who can provide the familiar voice/lip patterns.
BATOD would also recommend the learner has access to a separate invigilation.
*Please note this would be the same for someone who is acting as a reader or any other role where the candidate needs to listen to live voice/use lip-reading to support listening.
Question 8
Is it necessary for a QToD to attend an exam with the CSW? (College student)?
“As a ToD I could go to the exams as well as the CSW – is this necessary? I don’t support the student in lessons or have the BSL to sign well enough for the student but could ‘modify’ orally and CSW sign?”
BATOD response
Practice in the exam must be the ‘normal way of working’ for the student in the college.
The candidate must be accommodated separately and there must be an invigilator present. If it is the ‘normal way of working’, is the student comfortable with three adults being present in the exams?
What access role will the CSW be performing? If it is SLP and you want to be there as well, you will need to apply for LM. The regulations do not disallow both roles for one exam candidate, but the regulations for LM and SLP are slightly different. For example, the SLP can proactively sign the exam questions, but the LM must wait for a candidate to request a question to be modified/signed: “An assigned Language Modifier must only rephrase or explain the instructions/rubric of a question paper when a candidate indicates a specific need for help. JCQ AAA
Question 9
To access a language modifier assessment arrangement, do we have to ‘prove’ the student has less than standard score with a language assessment?
Working group response
Failing in assessments is not a benchmark for gaining access arrangements, as the ‘failure’ may be due to reasons other than the understanding of English. Awarding bodies require recognised standard tests that demonstrate the need for access arrangements. Also, one important requirement is that modifying English must be a ‘normal way of working’ for the student in the college. This means for example that your CSWs are modifying course handouts etc, and crucially, modifying questions in class tests and mock exams. And this must be demonstrated and evidenced on documentation available to view by a JCQ representative.
To get the Language Modification access arrangement (which is additional to the modifications made for the Awarding Body and is specific to a particular candidate) the centre must follow instructions in JCQ Adjustments for candidates with disabilities and learning difficulties section 5.11 pp 72-75 ( www.jcq.org.uk )
JCQ AAA 25/26 – “5.11.2 As part of the supporting evidence to an awarding body, the candidate must have a standardised score of 69 or less (a very substantially below average standardised score) in relation to reading comprehension and/or vocabulary. The candidate will have been assessed using current editions of nationally standardised tests conducted within 26 months of the final examination. (The candidate may be assessed by a Qualified Teacher of Deaf Children and Young People who will record the results of their assessment within Part 2 of Form 8.) The extensive modification of language must reflect the candidate’s normal way of working within the centre, as evidenced within Part 1 of Form 8. An awarding body reserves the right to request ‘call-in’ evidence from the centre”.
Question 10
How would a QToD make a case for the student being able to reply to some questions in BSL (not just single words), and his language modifier to act as a scribe?
“I am supporting at first year GCSE student. The student is profoundly deaf. The student uses BSL to access the curriculum and to communicate. The student’s level of English is clearly affected by BSL structures and possible other language processing and producing difficulties. How would a QToD make a case for the student being able to reply to some questions in BSL (not just single words), and his language modifier to act as a scribe?
For similar student profiles, how can a QToD ensure from the earliest stage that, drawing on the normal way of working with the candidate, appropriate representations are made for access arrangements when the time comes?
BATOD response:
Please note this response is not applicable in Scotland as students can respond in BSL whereas the rest of the UK requires students to respond in English.
The issue of the use of British Sign Language in examinations has arisen from time to time.
The fundamental aspect of any assessment is to ensure that the candidate can show what he or she knows and can do whilst preserving the integrity of the assessment.
JCQ regs indicates such a profile is entitled to a Language Modifier and Scribe and this should be embedded as the normal way of working from the earliest stage.
To date BATOD is aware of only one case, in a school for the deaf, where a late arrival to the country had little or no English in which an awarding body granted permission for a scribe to be used in similar circumstances.
Effectively an exemption is the only possible solution if the learner cannot use SSE because BSL is not English and therefore a mark cannot be given in an English exam for a BSL contribution. In the same way that BSL interpretation in an English exam is not allowed other than for the rubric.
Other colleagues have accepted this as the absence of a spoken language mark would not penalise a person who does not use spoken language at all as they would not be expected to have achieved a mark for spoken language.
The document is still valid and may provide further useful reading.
Question 12 (posed in 2024)
Should schools order modified language papers or will these have been checked by BATOD before being sent out?
BATOD response
These are the relevant sections from the Language Modifier Handbook produced by CIEA and updated recently by Lina Read the CEO at Communicate-Ed who works closely with NIck Lait at JCQ
Candidates working with the help of a language modifier should always be given a language modified paper. The language in these papers is a simple as possible, while still conveying the meaning of the questions set by the examiner. Usually papers are modified at source by the awarding body. In most cases, this means that a specialist in modification will have made suggestions about language before the paper is finalised. Such a paper is thus modified for all candidates. Where a paper has not been modified at source, it is possible for the SENCo to order a paper specially for that candidate through the Access Arrangements Online system.
The SENCo will receive immediate notification through AAO as to whether the arrangement has been approved. For LM, there will be an automatic rejection. The centre must then make a referral to the relevant awarding body.
A member asked “How should teachers support pupils in Year 6 SATS spelling test? The child understands the BSL sign but may not then identify the derivative e.g. beauty, beautiful, beautifully. Is it best to use a form of visual phonics?”
BATOD response
BATOD sought guidance from STA. Their response “We would not expect a pupil dependent on accessing the curriculum via BSL or any other sign language to be able to access the spelling test. That is why the compensatory mark is offered.
Finger spelling is not allowed, however lipreading is allowed and to facilitate this, we recommend that the test is administered 1 to 1 by someone well known to the child. However, very few 11-year-olds have acquired the ability to reliably lipread derivatives such as the examples given and to discriminate between them.
We recommend that the school administers a practice test using a previous year’s paper to see if it would be better to award a compensatory mark. Please note that the school would need to make that decision before the administration of the 2024 tests, following the guidelines in the ARAs. They can’t administer the test and not send it for marking if they decide the child would have done better on a compensatory mark.”
BATOD response:
The Standards and Teaching Agency (STA) do employ people to consider the accessibility of their papers. STA opt not to recruit BALMs (BATOD Accredited Language Modifiers).
Question 3:
“Is the value of the qualification affected by the use of the ‘compensatory mark’?
BATOD response:
The following is a response from STA– “The status of the assessment outcome isn’t affected at all and the pupil’s results will be just like every other pupil – either having met or not met the expected standard. The school would see a ‘c’ next to the GPS paper 2 – just so they know the compensatory marks have been applied and it’s not a mis-assigned script, for example. But in short – the qualification is not affected at all.”
Question4:
The multiplication tables check (MTC) is a test, statutory from 2022 in England, and being carried out in June by the majority of Yr4 children.
The list of access arrangements provided in the MTC administration guidance document is not exhaustive and schools are able to make arrangements for individual pupils that are in line with normal practice and that do not advantage or disadvantage the pupil. Does this mean that the class teachers can feel free to make whatever access arrangements they usually use?
BATOD response:
BATOD would raise the concern that, without the close partnership working with a QToD, majority of mainstream teachers are unlikely to be informed enough about the needs of deaf learners to make decisions that do not advantage or disadvantage the pupil. Without the input of the specialist teacher, QToD, the “normal school way of doing things” is may likely be unfair and non-inclusive for the needs of each deaf learner.
First consideration – the ‘pause button’. BATOD understands this test is assessing fluency of recall therefore additional time is not allowed.
QToDs should be aware that the “pause” button in the test actually functions as a “next” button ie it moves the question on to enable a child who has answered within 1 or 2 seconds to be able to control their pace ie not have to sit on a question for 4-5 seconds if they’d find it easier to move on.
The ‘pause’ button does not allow the learner to “pause” the timer to have an extra few seconds on each question. The pause button only pauses between the individual questions and doesn’t affect the 6 seconds per question (see YouTube video link- https://youtu.be/EOj3ZPv2mqQ).
BATOD raised with the Agency the concern relating to those deaf children who also have processing difficulties.
BATOD was advised “The range of access arrangements available enable disabled pupils to participate in the onscreen, online assessment without affecting the purpose of the MTC (the check); to test the fluent recall of multiplication tables. For pupils with processing difficulties, additional time was considered as an access arrangement when the check was designed, however, it is the case that additional time would be unlikely to address the processing issue without also giving enough time for pupils to work out the answer. Since this is a test of fluent recall, additional time would therefore provide a less valid outcome given the purpose of the test. Although the check was designed to be accessible to 99.3% of pupils, in exceptional circumstances, even with the use of the range of available access arrangements, headteachers may decide that some pupils will not be able to participate in the check. If appropriate, a headteacher should discuss this decision with the pupil’s Special Educational Needs Coordinator (SENCO), educational psychologist, medical officer, or other specialist staff. When a pupil is not entered for the check, schools must explain the decision to the pupil’s parents in advance. If appropriate, they should provide parents with documentary evidence to support the decision.
To mitigate the impact on pupils with processing difficulties unable to participate in the check, schools should also explain how they are helping the pupil to learn their multiplication tables check. Multiplication and division in a wider context will continue to be assessed through the Key stage 1 and Key stage 2 mathematics assessments enabling further opportunity for pupils to demonstrate their understanding of multiplication tables.”
Second consideration – Recorded voice
BATOD also raised with the Agency that for children with vision impairment with processing difficulties, the option of audio delivery is available in the Year 4 Multiplication Tables Check. However, for deaf learners with processing difficulties, the only arrangement for processing difficulties is the audio option, which would not be helpful for most deaf children it is via a computer.
BATOD feels having this as an access arrangement to support processing does not offer deaf children with processing needs the same access.
Third consideration – Read aloud and separate invigilation
BATOD was informed the list of arrangements was not exhaustive. It was suggested that if the child has arrangements in place such as read aloud and separate invigilation normally then this should be in place for the assessment. BATOD has requested the use of the read aloud facility and separate invigilation, is added to list of arrangements.
Question:
Suggestions for supporting requests for deaf CYP in community language schools?
The documentation needed for the assessment adjustments were:
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A letter from the QToD or doctor outlining their deafness.
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Individual Education Plan (IEP) – with permission from the family.
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JCQ Form 9. (Sections: P2, P4, P11)
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Other documentation options are accepted and listed on the Form 9 submission.
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discuss the arrangements with the deaf CYP, and family
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emphasise with school the needs for usual teacher to read the transcript of the listening exam
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approval discussion with awarding body essential ahead of mock exams and exams to enable time for the CYP to practice
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present of an invigilator in a separate room has not specific section – consider noting in P2 and P11.
Question 1:
Should invigilators have signing skills?
“As we come towards the start of mocks for GCSEs and A-Levels I have a conundrum:
Many of our students use Language Modifiers and Communication Professionals (BSL interpreters) in exams due to their needs.
Our school provides invigilators in each room along with our students and their BSL Interpreter.
The invigilators do not sign (we have tried to find those who do without luck) and we have been asked how they can invigilate when they cannot access the BSL or understand any of the communication between the Interpreter and the student.”
BATOD response:
BATOD recommends a direct conversation with JCQ.
JCQ’s guidance for invigilators or access arrangements makes no reference to invigilators needing to be qualified in sign language. On use of communication professionals (CPs) the guidance simply states that invigilation may need to take place in a different room with a separate invigilator.
In the absence of any guidance/recommendations, the BATOD exam access arrangement working group does not think it is unreasonable if a school does not provide an invigilator qualified in BSL. Schools have to trust the integrity of the professionals involved. The invigilator is a colleague of whoever is performing the role of LM or CP and not there to check on a colleague’s work per se.
Let’s consider the purpose of the professionals present.
The invigilator has a multi-faceted role involving layout of room, keeping time, agreeing and setting up extra time frameworks, delivering the rubric of the exam, checking equipment, bags, calculators etc etc., providing time checks, controlling interruptions, answering queries and generally ensuring candidates satisfy the requirements of the exam. And more.
The LM/CP has a very different role, but can support the invigilator and perform the communication link for the invigilator with the candidate. Should the candidate voice a query about a particular question that the LM/CP is unsure about, the invigilator is there as a colleague to refer to. They should work together, making sure that the examination runs smoothly, that the requirements of the exam are maintained and that the candidate with the access arrangement has fair access to the questions. If the invigilator cannot sign, there is a colleague there to make sure the invigilator can understand any communication that is directed toward them. The one cannot work without the other. An inability to sign should not be a reason to question the presence of an invigilator.
BATOD does not feel it is a reasonable request for the schools to consider as the invigilator(s) probably would need to be a qualified interpreter to make competent judgements on whether a BSL interpretation was in breach of the guidelines. The school would be experiencing a significant additional cost.
In English exams, only the instructions/rubric can be signed so it could be considered reasonable for the invigilator to be seated near enough to the LM/CP to see which page they’re signing from ie is able to observe that there is no signing of questions or texts.
JCQ
JCQ’s website provides guidance on ‘Instructions for conducting examinations‘. The webpage contains content such as a YouTube video on ‘How to ensure exams run smoothly’ and further information for exam officers.
On this BATOD website, retired Senior CSW and BSL/English interpreter, Andy Owen’s revised version of the former adept publication How can CSWs be confident in exams? can be found.
JCQ ‘Access Arrangements and Reasonable Adjustments regulations for 2025-26’
The ‘Access Arrangements and Reasonable Adjustments regulations for 2025-26’. Overview of evidence requirements and other related documents can be found on the JCQ Regulations and Guidance webpage. These regulations continue to apply during the 2026/27 academic year.
Ofqual
Ofqual student guide to exams and assessments in 2026
(2026)
WJEC (2025)
WJEC announced that “Following the publication of our approved specifications and Sample Assessment Materials (SAMs) for the first wave of our Made-for-Wales GCSEs and related qualifications, and in line with the Qualifications Wales’ agreed timeline, we have now published the associated Guidance for Teaching (GFT). These will support teachers and lecturers in their preparation for first delivery from September 2025.”
Most of the information in the Guidance for Teaching is specific to subject teachers but Qualified Teachers of Deaf Children and Young People may value accessing an overview of any changes. For this first ‘wave’ the main impact on many deaf learners will be the increased focus on oracy in the new English Literacy/Language specification.
Tier 1 Online Language Modification
This course will be useful CPD for any Qualified Teachers of the Deaf (QToDs) who want to refresh their knowledge and understanding of written language and its use.
It will also be available for anyone with an interest in writing accessible examination questions including those colleagues working in the post-16 sector and those in support roles .
It provides a balance of knowledge based learning and practical quiz type assessments which can be taken as many times as required.
Cost £50
To register click here
Language modifier access arrangement
Chartered Institute of Educational Assessors (CIEA), which undertakes Language Modifier training, has a handbook (2023) for Language Modifiers and a LM guidance examples booklet.
Ofqual consultation: Regulating post-16 vocational and technical qualifications at levels 2 and 3 (Member only access)
BATOD/NDCS Curriculum and Assessment Review (2024) (Member only access)
Ofqual consultation ‘Introducing principles into the General Conditions of Recognition‘ (Member only access)
Ofqual’s consultation on the use of formulae and equation sheets for GCSE mathematics and equations for GCSE physics and combined science in 2025 (Member only access)
Ofqual’s consultation on the use of formulae and equation sheets for GCSE mathematics and equations for GCSE physics and combined science in 2024 (Member only access)
Guidance on designing and developing accessible assessments (Member only access)
GCSE BSL Technical Consultation (Member only access)
Ofqual’s consultation on the Conduct, Marking and Grading of Spoken Language Skills in GCSE English Language (Archived) (Member only access)
DfE/STA primary assessment in England consultation (Archived) (Member only access)
Rochford review consultation (Archived) (Member only access)
Ofqual’s consultation on GCSE Reform (Archived) (Member only access)
BATOD response to Reformed GCSE subject content consultation (Archived) (Member only access)
