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1. Definition 

Awarding organisations must have in place the necessary systems and procedures to allow the provision of access arrangements, including reasonable adjustments. These should reflect the needs of individual learners and must also ensure that assessment continues to enable a valid, reliable and consistent judgement to be made about achievement of all learning outcomes against the stated assessment criteria.
 
The awarding organisation must also arrange for special consideration to be given to learners that experience temporary illness, injury or indisposition at the time of an assessment. This should allow them to demonstrate the achievement they are capable of for the units that are subject to special consideration.’[1]  

2. Audience 

2.1 The intended audience for this document is:

  • OCN London staff;
  • Centre staff responsible for Quality Assurance;
  • Assessors;
  • Internal Verifiers;
  • Quality Reviewers and External Verifiers;
  • Key stakeholders involved in unit and qualification development;
  • Qualifications Regulators. 

2.2 This policy applies to:

  • Qualifications and units approved under QCF;
  • Non qualification units approved by OCN London. 

3. Introduction 

3.1 The guidance sets out:

  • The principles which should be followed when making decisions about adjustments to assessment;
  • The procedures which should be followed when making adjustments to assessment requirements.
3.2 OCN London has a duty to ensure that the integrity of our qualifications, units and assessment is maintained at all times. At the same time OCN London and centres have a duty to ensure that the rights of individual learners to access qualifications, units and assessment in a way most appropriate for their individual needs are upheld. Disability and equal opportunity legislation and the regulatory criteria give support and guidance to awarding organisations and centres in creating an inclusive assessment process.
 
3.3 Note where the terms ‘access-related needs’ or ‘access-related issues’ are used in this guidance, they refer to any entitlement to access the assessment process resulting from legislation, regulation, or good practice, provided that the standards of the assessment are maintained.
 
3.4 OCN London's qualifications and units are developed to National Standards of knowledge, skills and competences. These are defined in the units of assessment as learning outcomes and assessment criteria. The unit assessment grids or benchmark assessments and where appropriate external assessments ensure that the required standards are met, these cannot be altered outside the unit and qualification approval process. 

4. Definition of Reasonable Adjustments 

4.1 A reasonable adjustment is any action that helps to reduce the effect of a disability or difficulty that places the learner at a substantial disadvantage in the assessment situation.

4.2 Reasonable adjustments must not affect the reliability and validity of the assessment outcomes, but may involve:

  • Changing usual assessment arrangements, for example allowing a learner extra time to complete the assessment activity;
  • Adapting assessment materials, such as providing materials in Braille;
  • Providing assistance during assessment, such as a sign language interpreter or a reader;
  • Re-organising the assessment room, such as removing visual stimuli for a learner with autism;
  • Changing the assessment method, for example from a written assessment to a spoken assessment;
  • Using assistive technology, such as screen reading or voice activated software.
 
4.3 Reasonable adjustments are approved or set in place before the assessment activity takes place; they constitute an arrangement to give the learner access to the units and qualification. The work produced by the learner will be marked in the same way as the work of other assessed learners.
 
4.4 Awarding organisations and centres are only required by law to do what is ‘reasonable’ in terms of giving access. What is reasonable will depend on the individual circumstances, the impact of the disability on the individual, cost implications and the practicality and effectiveness of the adjustment. Other factors, such as the need to maintain competence should be taken into consideration. 

5. Types of Assessment and Reasonable Adjustments  

5.1 Different types of assessment make different demands on the learner and will influence whether reasonable adjustments will be needed and the kind of reasonable adjustment which may be put in place.

5.2 The adjustments that are appropriate for a particular assessment will depend upon:

  • The specific assessment requirements of the units and/or qualification.
  • The type of assessment.
  • The particular needs and circumstances of the individual learner. 

6. Assessments which are Not Taken Under Examination Conditions 

6.1 These types of assessment form the basis of the majority of OCN London assessment activity. With these types of assessments the centre has greater flexibility to be responsive to an individual learner’s needs and choose an assessment activity and method that will allow the learner to demonstrate attainment.
 
6.2 These types of assessments may include, for example, coursework, set assignments which are researched in the learner’s own time, assessment activities devised by the centre or OCN London, assessments where the learner has to collect evidence in order to demonstrate competence. The assessment requirements for the majority of vocationally related units and qualifications fall into this group.
 

6.3 In these types of assessments the learner may meet the specified assessment criteria in any way that is valid. To facilitate access where there is evidence of need, the centre may allow the learner to use any mechanical, electronic or other aids in order to demonstrate achievement as long as the aids:

  • Are generally commercially available;
  • Reflect the learner’s normal way of working;
  • Enable the learner to meet the specified criteria;
  • Do not give the learner an unfair advantage.
 
6.4 The centre may present assessment materials or documents in a way that reflects the learner’s normal way of working and enables him or her to meet the specified assessment criteria, for example, materials do not have to be in written format, unless specified by the assessment requirements.
 

6.5 The centre may allow the learner to present their answers or evidence in any format as long as it enables them to demonstrate that they have met the assessment criteria, for example, answers or evidence do not have to be in written format unless specified by the assessment criteria.

6.6 The centre is advised to adopt a flexible approach in identifying alternative ways of achieving the assessment requirements.

6.7 The centre is advised to contact OCNLR to discuss alternative arrangements that may be appropriate for specific situations.

6.8 The outcome produced by the learner must at all times:

  • Meet the requirements of the specifications regardless of the process or method used;
  • Be as rigorous as assessment methods used with other learners;
  • Be assessable;
  • Be able to be moderated or verified.
6.9 In the case of long-term illness of an individual learner or when a permanent health condition/disability means a learner’s completion of assessment takes additional time it may be possible to permit an extension to the deadline for the submission of work for certification. A centre should note that it will not be possible to allow time extensions for all units and qualifications.
 
6.10 Where reasonable adjustments are put in place for these types of assessments, the centre should check whether permission needs to be obtained from OCN London. The centre should ensure that they adhere to OCN London's requirements for record keeping and supporting evidence.
 
6.11 The benefits of being able to vary the assessment evidence and choose the most appropriate method of obtaining evidence should be considered when the learner is first accepted onto a programme.
 
6.12 Where there is an identified need, the learner may present their evidence in any format as long as it enables them to demonstrate that they have met the specified assessment criteria. For example, a learner may present their evidence through the medium of Braille, on audio cassette or on video. Alternatively, oral questioning or witness statements may replace written responses. Where evidence is produced in Braille or signed onto video, it is the centre’s responsibility to ensure that a person who is suitably qualified in Braille or sign language is available to translate the material for the internal verifier and Quality Reviewer if this is required.
 
6.13 The learner must fulfil the demands of the criteria, regardless of method used to obtain the evidence. The assessment criteria may not be amended, re-worded or omitted.
 
6.14 The learner may use any mechanical or electronic aids which are available in the workplace or which are commercially available in order to demonstrate competence. For example, these may include specially adapted equipment or assistive technology.
 
6.15 The centre is required to provide the necessary resources to enable a learner with access-related needs to produce evidence of developing the portfolio.
6.16 All adjustments should be consistent with the learner’s normal way of working and must not give the learner an unfair advantage over others.
 
6.17 While assessors, internal moderators and Quality Reviewers normally prefer to see a portfolio made up of evidence which is varied, the centre should be prepared to accept a more restrictive variety of evidence as a means of enabling access. It is sensible, however, to discuss this matter with the internal moderator and/or Quality Reviewer at an early stage.
 
6.18 The learner must achieve all the required units to gain an OCN London qualification. It may sometimes be the case that some full qualifications are inaccessible because of a learner’s inability to demonstrate competence in all parts of the qualification. In these cases unit certification will always be available.
 
6.19 Where reasonable adjustments are put in place for verified types of assessments, the centre should check whether permission needs to be obtained from OCN London or the Quality Reviewer. The centre should ensure that they adhere to the OCN London's requirements for record keeping and supporting evidence. 

7. Assessments which are taken under examination conditions 

7.1 Where the method of assessment is more rigidly determined, such as for assessments taken under specified conditions, there may be a greater need for adjustments to standard assessment arrangements in order to give access. 

8. Identifying learners who are eligible for reasonable adjustments 

8.1 Any adjustment to assessment will be based on what the learner needs to access the assessment. Below are some examples of learner needs that may be adjustments to assessments. This list is not exhaustive and it should be noted that some learner needs will fall within more than one of the categories set out below.

  • Communication and interaction needs;
  • Cognition and learning needs;
  • Sensory and physical needs;
  • Behavioural, emotional and social needs.
 
8.2 The learner will be eligible for reasonable adjustments if their performance during an assessment is likely to be substantially affected by a particular impairment. Many of these learners will be defined as being disabled under the Equalities Act 2010.
 
8.3 An adjustment to assessment should only be considered where the difficulty experienced places the learner at a substantial disadvantage, in comparison with persons who are not disabled. Where the difficulty is minor, the centre should assist the learner by offering help with study and assessment skills.
 
8.4 A learner does not necessarily have to be disabled (as defined by the Equalities Act 2010) to be entitled to reasonable adjustments to assessment. Every learner who is disabled will also not necessarily be entitled to or need an adjustment to assessment. The learner may have developed coping mechanisms which minimise or remove the need for assistance. 

9. Identifying learners’ needs 

9.1 The centre has a responsibility to ensure it has effective internal procedures for identifying learner’s needs and that these procedures comply with the requirements of Equalities legislation.

9.2 A centre should use the following guide:

  • Identify those learners who are having difficulties or are likely to have difficulties accessing assessment;
  • Identify whether reasonable adjustments may be needed;
  • Identify the appropriate adjustment;
  • Ensure that the adjustment is in accordance with the OCN London guidelines. 

10. Identifying and Obtaining Supporting Evidence 

10.1 In order to ensure that any adjustment to assessment will only provide the learner with the necessary assistance without giving him or her an unfair advantage over others, the centre must be clear about the extent to which the learner is affected by the disability or difficulty.

10.2 Where the centre can verify evidence of the disability or difficulty and where the implications are clear, such as for a learner with physical difficulties, profound hearing impairment or who are registered as blind or partially sighted, the centre does not need to provide further evidence of these physical difficulties.

10.3 Where the implications of the difficulty are not obvious, such as for learning difficulties, or mental health difficulties, the centre will have to provide additional evidence of the effect of the impairment on the learner’s performance in the assessment. Any of the following types of evidence would be acceptable. The centre should decide which of these will best assist understanding of the learner’s situation:

  • Evidence of assessment of the learner’s needs in relation to the particular assessment, made within the centre by the relevant member of staff with competence and responsibility in this area; staff include learning support staff, teaching staff, trainers, assessors and other specialist staff. If necessary, external experts may be called upon to assess the learner.

    This evidence should include an indication of how the centre plans to meet the learner’s needs and should show that the candidate can cope with the level and content of the assessment. The evidence should be documented for audit purposes. Information from previous centres attended by the learner may also be included;
  • History of provision within the centre. This should include information about the support received by the learner during the learning or training programme and during formative assessments. Evidence of the way in which the learner’s needs are being met during the learning programme should be documented for audit purposes;
  • Written evidence produced by independent, authoritative, specialists. This could take the form of medical, psychological or professional reports or assessments. These reports should state the name, title and professional credentials of the person who wrote the report. The report should set out the nature of the difficulty and extent to which the learner is affected by the difficulty, including the effects of any medication that the learner may be taking. In cases where it might be expected that there could be changes in the way the learner is affected by the difficulty, there will have to be recent and relevant evidence of assessments and consultations carried out by an independent expert.
 

10.4 A learner with a Statement of Special Educational Need does not automatically qualify for reasonable adjustments. The demands of the units and qualification should be taken into account. The reasons for the statement may have only limited effect on achievement in the assessment.

10.5 It is the centre’s responsibility to ensure that all applications for reasonable adjustments are based on the individual need of the learner and that the evidence in support of the application is sufficient, reliable and valid. A centre should maintain records of all cases for audit purposes and to monitor the effectiveness of the reasonable adjustments which have been made. 

11. Adjustments permitted by the centre 

11.1 In some cases OCN London may permit the centre to implement reasonable adjustments without seeking prior permission. OCN London will require the centre to report back when they have permitted reasonable adjustments. (See Appendix 1).
 
11.2 The centre should declare that the information provided for OCN London is accurate and that the adjustments to assessment have been made in accordance with the guidance of OCN London. The declaration should be signed and dated by a member of the centre staff who has formally been given delegated authority for this by the Head of Centre. 

12. Adjustments agreed with the Quality Reviewer 

12.1 For other externally verified units and qualifications, the centre must consult with and get agreement from the Quality Reviewer if reasonable adjustments need to be implemented. (See Appendix 1). 

13. Adjustments permitted by OCN London

13.1 The centre is required to apply for adjustments to assessments on behalf of the learner. (See Appendix 1).

13.2 A separate form should be completed for each learner and submitted by the deadline stipulated by OCN London. It should be noted that applications received after the deadline may not be processed in time for the learner to take the assessment. The application should be signed and dated by a member of the centre staff who has formally been given delegated authority for this by the Head of Centre and should include the following declaration:

  • The information in the application is accurate;
  • The centre will be able to provide the arrangements requested if their use is approved by the OCN London;
  • The reasonable adjustment will be implemented in accordance with the guidance given by the OCN London;
  • The centre will not exceed the allowances given. 

14. The range of reasonable adjustments 

14.1 The Permissions Table (Appendix 1) lists the most commonly requested adjustments to standard assessment arrangements in a template which can be used when considering where the decisions on applying different reasonable adjustments need to be applied. It is not intended to be a comprehensive list and centres are advised to contact OCN London for advice on alternative ways of accessing assessment for particular situations.

14.2 Centres and Quality Reviewers have a duty to seek advice from OCN London in any case where they do not consider that they have the necessary expertise to judge whether a reasonable adjustment is needed, and/or how it should be applied. The following sections provide guidance for centres on how various types of reasonable adjustments should be implemented.

14.3 Centres should note that:

  • Not all the adjustments to assessments described below will be reasonable, permissible or practical in particular situations. If in doubt, the centre is advised to contact OCN London for advice. In some circumstances it may be more appropriate to select an alternative assessment task for the learner;
  • The learner may not need, nor be allowed, the same adjustment for all units and qualifications. Some learners may need a single adjustment; others may require a combination of several adjustments;
  • Adjustments to assessments will most commonly be needed for assessments which are taken under constrained/examination conditions. The list of reasonable adjustments is organised under the following headings: 

Extra Time

Invariably applied to examination based assessment.

Extra time should not be allowed where its use will invalidate the assessment criteria.

Extra time should not give the learner an unfair advantage over others. The amount of extra time must be realistic.

Supervised rest breaks

Centres should ensure that both the learner and his/her work is supervised during the break.

The duration of the break should not be deducted from the assessment time.

Rest breaks should not be allowed where their use would invalidate the assessment criteria.

Changes in organisation of the assessment room

The centre should consider the needs of each individual learner and, where possible, arrange the assessment room to suit the learner.

Separate accommodation within the centre

Centres should ensure that, where learners are accommodated separately for assessments taken under examination conditions, usual examination conditions apply and separate invigilation is arranged.

Taking the assessment at an alternative venue

For assessments taken under examination conditions, standard examination conditions should be in place at the alternative venue and the standard procedures for security of assessment material and despatch of the learner’s work should be followed.

Use of coloured overlays, low vision aids, tinted spectacles, cctv and ocr scanners

The learner should be familiar with how the aid works.

The use of aids should not give the learner an unfair advantage over other learners or invalidate the assessment criteria.

Use of assistive technology

The learner should be familiar with how the assistive technology works.

The assistive technology should not give the learner an unfair advantage over other learners or invalidate the assessment criteria.

Use of bilingual dictionaries and bilingual translation dictionaries

The use of a bilingual dictionary should not give the learner an unfair advantage over other learners or invalidate the assessment criteria.

Assessment material in enlarged format

Where appropriate, the centre should meet OCN London deadlines for requesting enlarged assessment material.

In cases where the centre is permitted by the OCN London to enlarge assessment material, the centre should take responsibility for the security of the material and for ensuring that the entire document is enlarged.

Assessment material in Braille

Where appropriate, the centre should meet OCN London deadlines for requesting brailled assessment material.

In cases where the centre is permitted by OCN London to braille assessment material, the centre should take responsibility for the security of the material and for ensuring that the entire document is brailled.

Assessment material in BSL

The centre should meet OCN London deadlines for requesting assessment material in BSL.

In cases where the centre is permitted to translate the assessment material into BSL, it should take responsibility for the security of the material and for the accuracy of the translation.

The centre should provide sufficient playback equipment that is in full working order.

Assessment material on coloured paper

Where appropriate, the centre should meet OCN London deadlines for requesting externally set assessment material on coloured paper.

Where the centre is permitted to modify the assessment material, it should take responsibility for the security of the assessment material and for the accuracy of the modification.

Assessment material in audio format

Where appropriate, the centre should meet OCN London deadlines for requesting assessment material in audio format.

Where the centre is permitted to produce an audio version of the assessment material, they should take responsibility for the security of the material and for ensuring that the entire document is copied. The centre should ensure that sufficient playback equipment is provided in full working order.

Use of ICT to present responses

The centre should ensure that: 

  • the computer is used solely by the learner and not by someone acting on the learner’s behalf unless the learner has permission to use a scribe;
  • the computer is working correctly at the time of an assessment. It is the centre’s responsibility to arrange the ICT provision for the learner;
  • the learner has access only to those facilities (for example spell/grammar checker, voice activated software, speech reading software,) which have been agreed in advance with OCN London;
  • the learner is not able to gain access to existing files or documents. Where a system operates from flash drive, CD or floppy disk, the learner must be supplied with a formatted flash drive or disk containing only the software required for the assessment;
  • the computer should be free-standing and not be connected to the Internet, unless this is required in the assessment;
  • the learner is accommodated separately if the use of a computer is likely to distract other learners. In this case separate invigilation should be arranged;
  • the learner is present when his/her work is printed. It is normal practice for a printed version of the learner’s work to be submitted and authenticated for assessment, and not the disk;
  • where a question/answer booklet is provided, the learner might need to answer some questions in the booklet and type other answers. Answers should be clearly labelled and the printout must be attached to the question paper/answer booklet;
  • the learner should be proficient in the use of the computer and its software;
  • the learner’s work is saved frequently and, if possible, using an auto-save facility.

Responses using electronic recording devices

The centre should check whether permission should be sought from OCNLR to record the learner’s responses electronically.

Recording the learner’s responses electronically should not be allowed where it will invalidate the assessment requirements.
The centre should ensure that the appropriate recording equipment is provided in full working order.

The learner using recording equipment should be accommodated separately, with separate invigilation, where its use will disturb other learners.

Responses in BSL

The centre should check whether permission should be sought from OCNLR to sign the learner’s responses on video.

Signing of the learner’s responses on video should not be allowed where it will invalidate the assessment requirements.

Responses in Braille

A scribe should not be allowed where such use would invalidate the assessment requirements.

Reader

The centre should check that the use of a reader is the most appropriate arrangement to enable the learner to undertake the assessment. The centre should select a reader and fully brief him/her on their responsibilities.

A separate invigilator should be present when a reader is used.

A reader should not be allowed where such use would invalidate the assessment requirements.

Scribe

The centre should check that the use of scribe is the most appropriate arrangement to enable the learner to undertake the assessment.

The centre should select a scribe and fully brief him/her on their responsibilities.

A separate invigilator should be present when a scribe is used.

BSL interpreter

The centre should check that the use of BSL interpreter is the most appropriate arrangement to enable the learner to undertake the assessment.

The centre should select a BSL interpreter and fully brief him/her on their responsibilities.
A separate invigilator should be present when a BSL interpreter is used.
A BSL interpreter should not be allowed where such use would invalidate the assessment requirements.

The BSL interpreter should meet the person specification provided by OCNLR, or should have an appropriate qualification in the sign language so as not to disadvantage the learner.

Prompter

The centre should check that the use of a prompter is the most appropriate arrangement to enable the learner to undertake the assessment.

The centre should select a prompter and fully brief him/her on their responsibilities.

A separate invigilator should be present when a prompter is used. A prompter should not be allowed where such use would invalidate the assessment requirements.

 

15. Records 

15.1 A centre should keep records for audit purposes where they are permitted to agree reasonable adjustments, where they apply to OCN London for permission or where they agree adjustments to assessment with the Quality Reviewer.

15.2 The centre should retain a copy of the application form and supporting evidence sent to OCN London, and relevant documentation received from OCN London. 

These records are classed as assessment records and should be kept for at least 3 years form the end of the year to which they relate. 

16. Special consideration 

16.1 Each request for special consideration will be unique to each learner or assessment. These guidelines offer some broad principles for the centre to follow. Further information should be sought in each case from OCN London.16.2 A learner who is fully prepared and present for a scheduled assessment may be eligible for special consideration if:
  • Performance in an assessment is affected by circumstances beyond the control of the learner for example recent personal illness, accident, bereavement, serious disturbance during the assessment
  • Alternative assessment arrangements which were agreed in advance of the assessment prove inappropriate or inadequate
  • Part of an assessment has been missed due to circumstances beyond the control of the learner
  • There is a sufficient difference between the part of the assessment to which special consideration is applied and other parts of the qualifications that have been achieved to infer that the learner could have performed more successfully in the assessment. 

16.3 A learner will not be eligible for special consideration if:

  • No evidence is supplied by the centre that the learner has been affected at the time of the assessment by a particular condition;
  • Any part of the assessment is missed due to personal arrangements including holidays or unauthorised absence;
  • Preparation for a component is affected by difficulties during the course, for example disturbances through building work, lack of proper facilities, changes in or shortages of staff, or industrial disputes. 

16.4 Centres should note that, where an assessment requires the learner to demonstrate practical competence or where criteria have to be met fully, or in the case of qualifications that confer a Licence to Practice, it may not be possible to apply special consideration.

16.5 In some circumstances, for example for on-demand assessments, it may be more appropriate to offer the learner an opportunity to take the assessment at a later date.

16.6 Special consideration should not give the learner an unfair advantage neither should its use cause the user of the certificate to be misled regarding a learner’s achievements. The learner’s result must reflect his/her achievement in the assessment and not necessarily his/her potential ability. 

17. Applying for special considerations 

17.1 A centre should apply for special consideration using the form supplied by OCN London. A separate form should normally be completed for each learner for each unit or qualification. However, in cases where a group of learners has been disadvantaged by a particular event (for example fire alarm) a single form should be submitted. A list of learners affected should be attached to the form.

17.2 The learner needs to submit evidence in support of special consideration. This may include medical evidence or a statement from the invigilator or any other appropriate information.

17.3 The application should be signed and dated by a member of the centre staff who has formally been given delegated authority by the Head of Centre. The signatory must declare that the information given is accurate.

17.4 The application for special consideration should be submitted as soon as possible after the assessment and not later than seven working days after the examination. Requests for special consideration may only be accepted after the results of the examination have been released in the following circumstances:

  • Application has been overlooked at the centre and the oversight is confirmed by the Head of Centre;
  • Medical evidence comes to light about a learner’s condition, which demonstrates that the learner was affected by the condition at the time of the examination, even though the problem revealed itself only after the assessment;
  • For on-screen assessments where results are immediately available.
 
17.5 If the application for special consideration is successful, the learner’s performance will be reviewed in the light of available evidence. It should be noted that a successful application of special consideration will not necessarily change a learner’s result. 

18. Useful links 

The OCN London Equality and Diversity Policy and the OCN London Assessment Definitions document can be found on the OCN London website at www.ocnlondon.org.uk.   

19. Policy responsibility and review 

OCN London will review the policy and procedure periodically and revise it when necessary in response to customer and stakeholder feedback, changes in practice, requirements of the Qualifications Regulators or external agencies or changes in legislation. The review will ensure that procedures continue to be consistent with the regulatory criteria and are applied properly and fairly.
 


[1]  Regulatory arrangements for the Qualifications and Credit Framework August 2008, paras 5.7, 5.8 p27