The Education Policy Institute has published its response to the Department for Education and Ofqual consultation on awarding GCSE and A level grades in summer 2021.

The consultation follows the announcement earlier this month from the government that exams will not go ahead as usual this year, and grades will be based on teacher assessment.

EPI concludes that while the government is proposing the “least bad” option for grading students without the usual public examinations, there are still significant risks associated with its approach.

You can read the paper here.

Summary of proposals


The three principal risks that EPI has identified are:

  • A risk that real student learning losses in 2020/21 will be masked by the process of “centre assessed” (teacher) grading, leading students to progress into further study or work without the skills and knowledge they need.
  • A risk of inconsistency and unfairness of grading between different schools and colleges, and between students
  • A risk of further, significant, grade inflation in 2021, which might undermine the credibility of grading.

To mitigate these risks, EPI proposes five major changes to the government’s proposals

1) The distribution of pupils’ exam grades within schools in 2019 should be used as the anchor point when schools apply teacher assessed grades in 2021.

Schools and colleges would be subject to only light touch external checking if the range of their grades are set at around the 2019 level, with a margin of permitted variation which would be set to reflect the typical annual change in grades which can be seen from year to year.

Schools and colleges would still be permitted to submit grades that were outside this range, but they would then be subject to greater external scrutiny by exam boards and the exams regulator. We consider that this step would help avoid excessive grade increases in 2021 which could undermine confidence in the exams system.

We would expect this to lead to an overall grade distribution in 2021 which would sit somewhere between the 2019 and 2020 level.


2) Students in all schools and colleges should take a short, standardised assessment in the May/June period in most subjects

The papers would be prepared by exam boards, to reduce teacher workload, and they would be designed to allow students to focus on the areas of the curriculum they have covered this year.

The assessments would help inform the teacher assessed grade, alongside other work that students have completed over their course. Making this assessment a universal requirement would help teachers to assess pupil learning, and improve the ability of exam boards to quality assure grading, where this is necessary. It would help assure students and parents that grading is as fair and consistent as possible.


3) Far clearer advice is needed for schools and colleges to inform grade setting this year, and to take Covid learning loss fairly and consistently into account.

The government has already made clear that grades can be awarded this year on the basis of the graded standard being achieved with students’ covering only a portion of the full syllabus content.

This will help in most cases to avoid students being unfairly graded at a lower level due to their inability this year to cover the full course content. But in some subjects, students whose learning has been deeply damaged by the pandemic may find it difficult to prove they are working at the standard they were on course to achieve before the severe disruption of the last year.

In this minority of cases, it is reasonable for schools to take into account evidence on the standard that these pupils were working at before the pandemic related disruption – at the beginning of their course. It is in any case essential that guidance is clear enough to ensure that as far as possible students in all centres are graded on the same basis.


4) There is a strong case for final grades to be released in August, rather than earlier, in July, to allow enough time to quality assure them.

The need to properly quality assure results after they have been submitted by schools and colleges means it is unlikely that grades can be checked and published in early July, as the government and Ofqual have suggested.

There is a strong case for allowing more time for the quality assurance process and even for releasing final grades to students at around the same time in August as is usual. This might also reduce the risks of imposing additional burdens on school staff in late July, just after term has ended.


5) The government must move quickly to address the huge problem of pupils’ underlying learning loss

A major effort will be needed this year to help some students who have not been able to cover the whole qualification syllabus, and therefore who have been awarded a grade which will not reflect the same subject mastery as in previous years.

It is essential that students are supported to catch up, particularly where they have not been able to cover key subject content in areas such as maths, English and vocational learning.

There is a danger that the awarded grades will cause schools, colleges, universities and employers to assume that all students have the same knowledge as would normally be associated with such grades.

Schools, colleges and universities must work together to identify real learning loss, and government should deliver catch up funding to support institutions in making good this learning loss.



EPI is also proposing that students in Alternative Provision, who would usually have to leave these education settings at age 16, should be funded to stay on for one or two additional years, to ensure they have the skills they need to secure employment or take up further learning opportunities.

We also recommend that to tackle extreme cases of learning loss, the government considers introducing a new right for students to repeat a year of education, where this is supported by their parents or carers.