The Consultation

The most important consultation exercise the profession has been involved in within the last twenty years is to be undertaken this year. It does not relate to the curriculum, to conditions or to faculty arrangements: it relates to the structure and operation of the GTC (or GTCS as it has become).

There must be no mistaking the intent: what is proposed is a radical change,

intended to reduce the influence of teachers on the GTC.

The Government did undertake a pre-consultation exercise on the future of the GTC. The Association was consulted. The questions asked did no more than reinforce our feelings of alarm.

The consultation document is available via the Scottish Government website at http://www.scotland.gov.uk/Consultations and can be answered online.

THE CLOSING DATE FOR THE CONSULTATION IS

26 JUNE 2009

The paragraph references below are the relevant paragraphs in the consultation document.

Background and status of the GTC

The Government alleges that the GTC is "classified" as a "Non-Departmental Public Body" (NDPB). The GTC is (as everyone knows) a Professional Regulatory Body (PRB). The consultation document admits this in annex A where the GTC is compared with "other regulatory bodies".

This deliberate misclassification of the GTC alone should be enough to cause teachers to mistrust the purpose of the whole consultation.

The "independence" of the Council

The Government attempts to justify its action by claiming that it wants an independent GTC. The SSTA has never seen the GTC's "independence" as an issue. The Government has already indicated that it will discontinue the use of the six members of the Council nominated by Scottish Ministers as long as "the public interest would be properly represented on the new independent (sic) GTCS". (See paragraph 51.) The Government then goes on to try to ensure this "public interest" by deciding on who should be represented on the new Council.

If the Government remains adamant that public interests must continue to be represented, the Government should safeguard those interests by giving places to representatives of those interests in an open manner. The Association is happy that the Ministers decide which interests should be represented.

Composition of the Council

The Government makes much of this issue, asking what size the Council should be. The answer is clear: it needs to be whatever size is needed in order to ensure that all

entitled groups are represented and large enough to allow the Council to carry out its

functions.

The question should be "who should be represented on the Council and in what numbers?" The current representation is shown below. The numbers should help clarify why the GTC might be seen as too large. Certain groups are significantly over-represented (particularly headteachers) and certain groups need not be represented at all.

The Association suggests that the Ministers' six appointees should remain, ensuring the "public interest" representation and that the other membership be amended as indicated. The Association's suggestions would reduce the size of the Council from 50 to 46. This reduction would still permit the Council to undertake its core functions.

Elected Members

Appointed Members

Use of non-Council Members

The Government recognises that if it reduces the number of Council members, it will be more difficult for the GTC to undertake its core functions and in particular with regard to the Council's disciplinary function. The suggested solution is that external appointees should be co-opted to the Council to fulfil these functions. This approach is best summarised as "We have created one problem and will solve it by the introduction of another problem".

Extension to the role of the GTC

While admitting that the GTC is having difficulties in completing its current core functions, the consultation includes reference to a possible expansion of the GTC role. One of the suggested roles is that the GTC approves programmes of CPD and takes on a greater role with regard to the general professional development of teachers. The Association rejects such attempts: the GTC does not have the resources.

Alternative models for the composition of the Council

The most outlandish aspect of the consultation is the suggestion that it might be possible that all Council members are appointed. It is, quite amazingly, suggested that such an arrangement would ensure that the "method by which the Council is appointed is open and accountable".

Again, the inclusion of this option should be sufficient to cause all teachers to mistrust the purpose of the whole exercise.

Use of non-Council members

A system of "retained ex-members" is fundamentally wrong. All members who are not appointed must be currently elected. A system using Government appointees is totally unacceptable.

The consultation questions

Members may wish to consider the following:

Q1. Clearly "yes".

Q2. Most definitely "yes". The minimum standard has to be maintained at all costs. It should never be possible for an unsuitable candidate to gain entry simply to ensure University numbers are maintained.

Q3. The GTC is already responsible for accrediting these courses. Responsibility for them would be an appropriate method of maintaining standards.

Q4. The GTC does not have the resources to undertake this additional function.

Q5. It is wholly appropriate that teachers should be in the majority. Other interests should also be represented but on a reduced basis. The number of teacher

members should be correspondingly increased leaving the Council the same size as it is currently.

Q6. By the Ministers continuing to nominate six members for this purpose.

Q7. The only acceptable option is the status quo.

Q8. There are no groups missing from interests which should be represented.

Q9. The GTC should continue to issue an annual report as approved by the GTC Council.

Q10. There must be no attempt to restrict the number of terms an elected member may serve on the Council.

Additional Comments

1. The concept that a "Management Board" will be able to undertake the current

   functions of the GTC is totally untenable. It will concentrate far too much power in too few hands.

2. Members of the GTC must not be paid. Such an arrangement, especially in current circumstances, is bound to lead to doubts as to the GTC's credibility and impartiality. It would also increase costs.

The Association has written to the Cabinet Secretary condemning the mechanism used to consult on the new examinations intended to replace Standard Grades and the Intermediate National Qualifications.

The consultation took place earlier this session. Many members responded on an individual basis. Additionally, a formal SSTA view was submitted. Regardless of the merits (or otherwise) of certain of the proposals, the Association commented unfavourably on the questions posed in the consultation, noting that many were loaded towards the provision of supportive responses.

The Association's rejection of proposals from compulsory assessment in Literacy and Numeracy was a major part of our submission. There is no sign that the Government has heeded warnings on this issue: the proposal still figures in arrangements for the new "Curriculum for Excellence".

The Association became alarmed when it was noted that the summary of the results of the consultation attempted to quantify the various responses. It was immediately clear that every organisation submitting a view on any question was regarded as having one "vote". The Association raised objections with the Cabinet Secretary. Members will be informed of any response.

There can be no doubt of the enormous importance of the link between CfE and the new examination arrangements for S4. While the Association is the first to recognise that assessment arrangements cannot drive the curriculum, these arrangements must reflect the curriculum.

The failure to address these concerns does not bode well for prospects in relation to the general acceptance of CfE. The vital "Outcomes and Experiences" (version 2) are now published. Members are strongly encouraged to examine these via the LTS website. The Association's internal consultation on the value of the O&E begins in mid-April. It will be conducted via our new website and members are strongly encouraged to respond.

Jim Docherty

Acting General Secretary

1 April 2009

In addition to the comments made on the consultation proforma, the SSTA would wish to add the following. It is disappointing to note the loaded nature of certain questions. Questions 1, 2, 8, 9 and 10 involve the adoption of certain assumptions in order to provide an answer. Question 4 and 7 are so loaded that they cannot be answered. The inclusion of such questions has raised doubts as to the validity of the entire consultation exercise. The SSTA notes with regret that certain questions are not asked. It is clear to all that the narrowing of the certificated middle secondary curriculum to one year has been the subject of constant criticism. We believe that the failure to include any question as to the extent of the certification available to young people in the middle years and the consequent effect on the S5/6 curriculum detracts from the value of the consultation exercise to the extent of making parts of the exercise meaningless. There is scant recognition within the consultation paper as to that hugely important (but often ignored) question "Why assess?" There is little by way of opportunity to comment on the amount of time spent on assessment and the value of assessments. The loaded nature of the question relating to the introduction of literacy and numeracy awards bear eloquent testimony to the fact that the proposal has very little support within the profession. The SSTA notes the lack of any documentation (within the consultation document or elsewhere) as to curriculum and timetabling models. It is difficult to envisage how certain of the proposals inherent in Curriculum for Excellence and examined in the National Qualification consultation can be put into practice. Such models are essential. There is a lack of questioning relating to the generality of support for a "new" S4 examination system. It would have been simple to ask the question "Do you support the concept of the middle school certificate course being completed in one year of study? This is a question which should have been asked. The SSTA is therefore disappointed in the nature of the questions and their limited scope but hopes nevertheless that enough can be gained from the consultation to allow us to maintain and hopefully improve our National Qualification system. Ann Ballinger, President Jim Docherty, Acting General Secretary

Q1. Do you welcome the intention to update all qualifications at Access, Higher and Advanced Higher in line with Curriculum for Excellence? Please comment on any implications to be considered.

The Question is clearly loaded and requires an assumption to be made as regards "updating". The requirement for articulation is obvious and accepted. The retention of Higher as a "Gold Standard" is welcomed.

Progression and coherence between courses are essential. There are substantial resource implications for any new National Qualification structure. This latter point has been given insufficient attention.

Q2 Early consultation has identified the 'best' features of Standard Grade and Intermediate qualifications as:

• the 'inclusive' approach to certification contained in Standard Grade; and
• the 'unit based' structure of Intermediate qualifications

Are there any other features in the present Standard Grade and Intermediate qualifications which should be included in the new qualification at SCQF levels 4 and 5? There is an assumption that the best features have been accurately identified. There has from the outset been an assumption that the best features (whatever they are) can in fact be amalgamated.

There is a requirement to completely redraft current unit based assessments (NABs) to create a better consistency across the Curriculum. There will have to be extensive work done by practitioners in this area. As a consequence there are significant resource implications, in particular with regard to the release of staff. Q3 One of the proposals is to grade units. Do you agree that units should be graded A - C rather than pass/fail?

NO. The use of graded units would totally change the nature of unit assessment. Practical issues include absenteeism, administration problem, pressure regarding resits and more. Q4 Do you want graded units to count towards the final award?

The question again makes an assumption that the answer to the previous question is "yes". Such practices might call into question the impartiality of the consultation exercise. Q5 Which option for introducing compensatory arrangements would you most support?

Option A - Extend the range of grading in course awards to grade E.

Option B - Recognise unit passes only.

Option C - Compensatory award at the level of the course studied with no grade awarded.

Option D - Compensatory grade C award at the level of course below that studied

Option E - Compensatory grade A award at the level of course below that studied.

Retain the status quo whereby positive achievement is recognized on the Certificate. Q6 The proposed name for the new award is General (SCQF 4) and Advanced General (SCQF 5). Please indicate if you are content with this suggestion. If not please offer an alternative and explain your choice.

NO. The Proposal for the name is particularly unwelcome. The use of the word "General" (a term used in the current arrangements) can only cause confusion.

There is a clear tautology which teachers find displeasing. Further thought is required.

Q7 Do you agree with the proposal to offer literacy and numeracy awards at a range of SCQF levels (3 to 5)? If not please offer an alternative.

The question again makes the assumption that the proposal for literacy and numeracy awards is acceptable.

It is impossible to support any proposal which might ever label any young person as illiterate or innumerate. This concept cuts totally across the inclusive nature of a modern curriculum.

Q8 National Qualifications at Access 3 (SCQF level 3) do not have an external examination. Do you agree that any new awards in literacy and numeracy at SCQF level 3 should have an external examination?

There requires to be further investigation and thought given to the question "Why assess?" The "level" discussion is irrelevant. We have embedded core skills across the curriculum: these suffice. Q9 Should the weighting between the internal and external assessments for the literary and numeracy awards be equal? If not should more weight be attached to the internal or external assessment? Please explain.

· Option A - Equal weight

· Option B - More weight to internal assessment

· Option C- More weight to external assessment

Irrelevant in the light of earlier responses Q10 When should young people be assessed for literacy and numeracy awards? Please select one option.

Option A - At the end of S3 as part of the summer diet of examinations

Option B - In the December of S4 as part of a winter diet of examinations

Option C - At the end of S4 as part of the summer diet of examinations

Irrelevant in the light of earlier responses.

We would favour a form of formative assessment to allow pupil support needs to be addressed at an earlier stage. Q11 Do you agree with the proposal to allow the study of Highers and Advanced Highers over 12 months, 18 months and 2 years? NO. The proposal is not feasible. It would be unworkable in even the best resourced schools. Q12 Do you agree with the proposal to introduce a winter diet of examinations? NO. The proposal is hopefully optimistic betraying a significant lack of appreciation of the problem inherent in such a suggestion. Q13 If you agree with the proposal to introduce a winter diet of examinations, what subjects and levels of qualifications might first be offered?

Irrelevant in the light of the previous response. Q14 Would you agree with changes to the system which allowed the most able students to bypass qualifications at lower levels and begin study for Highers from S4 onwards? NO. Any such suggestion fails to address how the "most able" are identified. The risks are enormous. Education is not simply the passing of examinations. The development of skills and maturity within our young people is of great importance. There is a total lack of a "safety net" for candidates. They will be under enormous pressure to succeed. It should be noted that the proposed arrangement has been available for 20 years and more and has never gained any form of acceptance.

It is noted again that the proposal is the cheap option. Q15 Do you have any other ideas for increasing flexibility within the senior phase (S4 to S6)?

More teachers, more funding and more available classes.

Q16 It is intended that planning for the new curriculum should commence in 2008/09, with approaches based on the new curriculum introduced from school year 2009/10. This suggests that the new and revised qualifications and any increased flexibilities would be required from 2012/13 onwards to ensure smooth progression between the curriculum and qualifications. Is this indicative timeline realistic? Please comment on any implications to be considered.

NO. The timeline is totally unrealistic. Given the timescale for the publication of the revised "outcomes and experiences", the lack of timetabling models and the current reduction in CPD opportunities, a delay is absolutely essential.

ANY OTHER COMMENTS The use of internal assessment as the sole measure of achievement has a place for the least able: it lacks the validity of external assessment and should be used only where the pressures of external assessment may be too much for the candidate. The rigor of external assessment is totally necessary.

It is noted that the consultation exercise does both directly refer to the study of only up to 5 subjects at the new middle level. There is total opposition to the proposal to restrict curricular choice. The traditional strength of the middle secondary curriculum is being destroyed at a stroke. The consultation exercise should raise the issue.

There are resource implications for any new National Qualification system. The resources for the development of material and the relevant CPD for new courses do not exist.

Teachers currently work well beyond their contractual obligations. The situation cannot be relied upon in the face of unwelcome proposals.

The Associations response to the above consulation is available to read here. Additional comments made by the Association are available from here.

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