Special Considerations and Reasonable Adjustments Policy2018-12-04T15:31:59+00:00
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Aim

The purpose of this policy is to ensure fair access to assessment.  It is the responsibility of all staff at PAL to ensure they are familiar with what constitutes ‘special considerations’ and how to declare such an interest and the consequences of not apprising the Quality Director of any such conflict.

What Constitutes Special Considerations?

Apprentices who have a permanent or temporary disability, specific learning needs or medical condition might need extra support to help them complete all aspects of the end-point assessment. To guarantee fair assessments, it may be necessary to amend or modify the assessment process or timings. The EPAO cannot change the assessment standards or requirements of the assessment plan, but the EPAO can contact the relevant EQA1 to discuss possible options and alternatives to give all apprentices a fair and equal chance of demonstrating their knowledge, skills and understanding to achieve the assessment standards. 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.

1In some cases, in addition to the EQA, specific awarding organisation considerations will need to be reviewed (where assessment instruments have been commissioned).

Reasonable Adjustments

The EPAO defines as what is ‘reasonable’ dependent on the individual circumstances, the impact of the disability on the individual, cost implications and the practicality and effectiveness of the adjustment. Adjustments to assessment based on the following criteria: must not make the assessment easier; not give the apprentice an unfair advantage and be based on the individual need of the apprentice.

The application of Special Considerations must be: auditable and capable of being internally and externally quality assured; preferably reflect the apprentice’s usual way of working, notably for any observation; give a realistic indication to any employer of what the holder of the certificate can do.

Changing Assessment Requirements

Reasonable adjustments involve (subject to EQA approval): changing the standard assessment arrangements, e.g. allowing apprentices extra time to complete the test or offer a paper-based version; adapting assessment materials, e.g. providing a screen reader for the test or a scribe for the project. Adaptations will also include adjusting of font size and backgrounds for written text and other assistive technologies that support accessibility. Providing facilitators during the assessment, e.g. a sign language interpreter or a reader also constitute special considerations.

The details provided here are not exhaustive, and the Quality Director discusses with the assigned assessor and IQA any proposed special considerations, which have to be ratified by the EQA body before implementation.

Arrangements for Special Considerations – The Procedure

  • The pre-assessment communications and assessment planning meeting with Apprentices and employers ask to discuss outcomes of the initial assessment and discreetly establish what assistance regarding ‘special considerations’ the Apprentice may require. The EPAO works with guidance issued by the external quality assurance agency and utilises specialists to ensure the assessment is fair and accessible; this could include for example providing background screen colours for those learners who have colour blindness or some forms of dyslexia. For a learner with a visual impairment that makes reading difficult the EPAO will consider assistive technologies such as screen readers. Requests for additional support should be recorded, and the Apprentice and employer will be advised of the outcome of the application at least seven days before the first component of End-point assessment.
  • It is the responsibility of the EPA assessor to make the assessment process fair and reliable and to discuss and agree on any alternative arrangements with all of the relevant parties and gain IQA sign-off. To supplement and provide effective aid, the EPA assessor asks what has worked well for the Apprentice during the training stage and where possible and within the assessment plan requirements replicates these arrangements. In some circumstances, discussions with the responsible training organisation will also be held to gauge what assistive technologies may assist the Apprentice.
  • Guidance for Apprentices and employers regarding special considerations and adjustments will be available via our website and from the appointed EPA assessor.
  • Special consideration arrangements have to be documented and signed off by the responsible IQA Where there is deemed to be any concerns or the assessor or IQA believes the considerations required wi.ll overly influence the assessment outcomes, i.e. distinctly advantage or disadvantage an apprentice, the Quality Director will adjudicate and consult with the EQA body to safeguard the assessment process.  Records are logged on the management information system
  • PAL provides the EQA body with relevant applications for special considerations via the PAL Quality Director. The PAL Quality Director advises the EQA body of the name and DOB of the apprentice and provides employer details and an account of the context of the special consideration requirement. The application will include any information that has been presented by the employer, a representative from the training organisation and Apprentice, as well as any supporting documentation from other relevant assessment EPAOs or bodies that establishes the Apprentice’s needs. The special consideration regarding assessment is required to demonstrate why the standard assessment instrument is inappropriate and the proposed adjustment and the rationale for using it. Requests for special consideration can be made at any point leading up to and including the EPA assessment planning meeting and require PAL Quality Director sign-off and confirmation from the EQA body that they support the application, on receipt of these authorisations the PAL Quality Director will advise the relevant IQA and the EPA assessor.  The assigned EPA assessor informs the Apprentice and employer accordingly.
  • PAL expects the following to be granted (where clear evidence exists for the support) with no EQA approval: allowing extra time to complete the test or professional discussion; the use coloured overlays, mechanical or electronic aids and assessment documentation with large print.
  • If the EPAO can provide additional support, this additional support should be described in the assessment planning documentation, once approved by the QA function and where appropriate the EQA body and logged on the management information system.
  • If the EPAO cannot provide additional support, as the EQA does not uphold the case, the EPA must advise the candidate and employer immediately of this decision and inform them of the appeals and disputes policy and the complaints policy. If the candidate and employer select to continue with the End-point assessment, without any special considerations, the assessment will be undertaken in line with standard practices. A record should be maintained of all decisions and outcomes and be made available for any internal or external quality assurance check and noted on the summative EPA assessor report.

Quality Assurance for Scribes

A scribe is allowed for Apprentices deemed to have a disability – we would make suitable adjustments and allowances

For Assessment of Standards, the following criteria will be applied to standards

  • A representative from the employer or training organisation (the individual selected must not have been involved in the on-programme delivery or be the line –manager of the apprentice) are allowed to scribe for an apprentice
  • ESOL learners are not categorised as substantially disadvantaged, but we would encourage DVR, bite-sized activities (such as spidergrams), work placed evidence, the use of bi-lingual dictionary so that they can practise writing skills, extra time, extra visits from the training organisation. In these circumstances, PAL may request additional time for testing and advise the apprentice to be additionally mentored for written work, by their employer or training organisation mentor. Observations and Skills Challenges would be undertaken in the standard fashion; professional discussions, subject to IQA authorisation may be slightly adapted, regarding language phrasing.
  • A scribe or reader can be appointed subject to authorisation from the EQA body. The scribe or reader would need to be correctly briefed and advised of what actions and support they could provide. The EPA will be responsible for assuring the assessment is fair and equitable and that the scribe or reader records only the words, opinions, answers of the Apprentice.
  • The company would need to be advised of the scribe/reader’s details before the End-point assessment, third parties unknown to EPA are not permitted to scribe or write up evidence and would not be allowed access to the End-point assessment. It is recommended that any scribe or reader is independent of the Apprentice and if the Apprentice has not got access to such independent support, the EPAO will discuss with the Apprentice and employer about making alternative arrangements. The EPAO would seek to provide an independent reader or scribe so that assessments could be facilitated.

Malpractice Relating to Special Considerations

Malpractice will be judged as happening in the instances such as the assessor (EPA) putting into place arrangements without seeking prior approval from the IQA and Quality Director. IQA malpractice will be judged as happening where the assessor has provided the IQA notification of a special consideration adjustment, but the IQA has not  advised the assessor correctly of PAL’s policy in relation to special considerations or advised the Quality Director as appropriate; exceeding the allowances typically applied for a specific need and relative adjustment; failing to maintain records of  reasonable adjustments and special considerations for audit. For the Quality Director malpractice will be judged for failing to report adjustments to the relevant EQA  body where required.

Types of Assessment and Reasonable Adjustments

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.

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

  • The specific assessment requirements of the standards and accompanying assessment plan
  • The type of assessment.
  • The particular needs and circumstances of the individual apprentice.

Assessments which are Not Taken under Examination Conditions

These types of assessment include observations at the workplace assessment activity. With observations in a synoptic assessment, it is crucial that the assessment planning ascertains what situation/shift and time will best allow the apprentice to showcase their skills. The assessor must secure with the apprentice and their line manager that the observed activities are part of the apprentice’s natural job role and it must be understood by all parties that the apprentice can receive no help or instruction during the observation, other than standard work instructions and request.

These types of assessments may include, for example, coursework, business projects, set assignments and portfolios which are researched in the apprentice’s own time and presented as an element of the end-point assessment. In these situations, the assessor and IQA function must ensure that the work is that of the apprentice’s and advise all concerned parties of the consequences of cheating and plagiarism. The use of the professional discussion can be used to clarify any anomalies within a submitted piece of work, this is different from proven cheating, and all written work will be subject to a plagiarism scan.

For non-examined types of assessment the following principles should be adhered to:

  • Assessment planning should consider viability (to include commercial viability for the EPAO and employer) of all assessment activities
  • Observations reflect typical working practice and are not ‘’
  • Assessment planning should ensure the apprentice and their employer are aware of the criteria and know what is expected to pass, or gain a higher grade
  • The assessment method and assessor does not give an unfair advantage to a specific apprentice

The EPAO may present assessment materials or documents in a way that reflects the learner’s usual 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.

The outcomes produced by the apprentice must at all times:

  • Meet the requirements of the standards and assessment plan
  • Be as rigorous across all apprentices
  • Be assessable;
  • Be able to be moderated or verified.

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. Discussions would need to take place with the employer, apprentice and training provider, as well as the relevant EQA; it would be expected that the apprentice is suspended from training.

Where reasonable adjustments are put in place for these types of assessments, PAL WILL check whether permission needs to be obtained from the relevant EQA. PAL will keep all communications with relevant parties in connection with any reasonable adjustments and will appraise the apprentice, employer and training provider of any decision made by the EQA or in some cases the ESFA or IfA.

Where there is an identified need, the apprentice 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, an apprentice may present their evidence through the medium of Braille, on audio cassette or video. Alternatively, oral questioning or witness statements may replace written responses. Any such adjustments will only be allowed with the approval of the EQA, and where evidence is presented in a format that requires specialist translation, PAL will enlist such support.

The apprentice must fulfil the demands of the standard, regardless of the method used to obtain the evidence. The assessment criteria may not be amended, re-worded or omitted and it must be proven that the assessment methodology prescribed in the assessment plan is not suitable and the alternative assessment method selected, confers no advantage of the individual apprentice, against the broader apprenticeship community.

The apprentice may use any mechanical or electronic aids which are available in the workplace or which are commercially available to demonstrate competence. For example, these may include specially adapted equipment or assistive technology.

Where portfolio evidence is allowed in the independent assessment and the assessment plan has specified the quantity and variety of the portfolio evidence, it might be that to support reasonable adjustments, the variety of evidence is restricted, ensuring the necessary criteria and standards are met.

Where reasonable adjustments are put in place for assessments, PAL will only do this with EQA approval.

Assessments which are Taken under Examination/Test Conditions

Where the method of assessment is more rigidly determined, such as tests and exams or skills challenges and to a lesser extent professional discussion, PAL will need to decide what adjustments are required, with the apprentice, employer and training provider; ideally, this discussion should be had early on in the apprentice’s programme.

Identifying Apprentices who are Eligible for Reasonable Adjustments

Any adjustment to assessment will be based on what the apprentice’s needs to access the assessment and the requirements of the assessment plan, along with guidance from the relevant EQA. Below are some examples of apprentice needs that may necessitate adjustments to assessments. This list is not exhaustive, and it should be noted that some apprentice 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.

The apprentice 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.
An adjustment to assessment should only be considered where the difficulty experienced places the apprentice at a substantial disadvantage, in comparison with persons who are not disabled. Where the difficulty is minor, the employer and training provider should assist the learner by offering help with study and assessment skills.
An apprentice does not necessarily have to be disabled (as defined by the Equalities Act 2010) to be entitled to reasonable adjustments to assessment. Every apprentice who is disabled will also not necessarily be entitled to or need an adjustment to assessment. The apprentice may have developed coping mechanisms which minimise or remove the need for assistance.

Identifying Apprentice Needs

It is the responsibility of the apprentice, their employer and training provider to identify any specific assessment needs and to discuss these with the selected EPAO. Training Providers have a responsibility to ensure they have sufficient internal procedures for identifying apprentice’s needs and that these procedures comply with the requirements of Equalities legislation.

A Training Provider should use the following guide:

  • Identify those apprentices 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 by the EPAO and assessment plan guidelines

Identifying and Obtaining Supporting Evidence

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

Where the apprentice, training provider and/or employer can verify evidence of the disability or difficulty and where the implications are evident, such as for an apprentice with physical difficulties, profound hearing impairment or who are registered as blind or partially sighted, there is no need to provide further evidence of these physical difficulties.

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

  • Evidence of assessment of the apprentice’s needs in relation to the particular assessment, made by a relevant member of staff at the employer organisation or from the training provider with competence and responsibility in this area;This evidence should include an indication of how the apprentice’s needs have been catered for thus far 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 EPAOs attended by the learner may also be included;
  • 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.

An apprentice with a Statement of Special Educational Need does not automatically qualify for reasonable adjustments. The demands of the standards should be taken into account. The reasons for the statement may have an only limited effect on achievement in the assessment.

It is the apprentice’s responsibility or if the apprentice designates this responsibility to their employer or training provider to ensure that all applications for reasonable adjustments are based on the apprentice’s needs and that the evidence in support of the application is sufficient, reliable and valid. PAL will maintain records of all cases for audit purposes and to monitor the effectiveness of the reasonable adjustments which have been made, and training providers and employers should do likewise.

Adjustments Permitted by the EPAO

In some cases, the EPAO may be able to implement reasonable adjustments without seeking prior permission of the EQA.

Where the EQA body requires a declaration from the EPAO. the declaration should be signed and dated by a member of the EPAO staff who has formally been given delegated authority for this by the Quality Director.

Adjustments Agreed with the EQA

The EPAO must consult with and get agreement from the EQA if reasonable adjustments need to be implemented, that involve the use of assistive technology and third-party support.

Records

PAL will keep records for audit purposes regarding requests for adjustments and the outcomes of these discussions, in line with GDPR principles and where such information is necessary to fulfil the assessment contract. These records are classed as assessment records and should be kept for at least three years form the end of the year to which they relate. 

Training Providers or employers should retain copies of any special consideration or reasonable adjustment requests, made to the EPAO.

The Range of Reasonable Adjustments

Please download the PDF version of this policy to access our Permissions Table appendix which contains examples of the most commonly requested adjustments to assessment arrangements.  This can be used when considering where different reasonable adjustments may need to be applied.  It is not intended to be a comprehensive list, and apprentices, employers or training organisations should always contact PAL directly to discuss any special considerations, reasonable adjustments and/or access arrangements.

PAL will not uphold any arrangements made that require adjustments, where they have not been advised of the request and agreed to the actions.

Apprentices, employers and training providers should note

  • Not all the adjustments to assessments described below will be reasonable, permissible or practical in particular situations. If in doubt, the EPAO is advised to contact the relevant EQA 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 will most commonly be needed for assessments which are taken under constrained/examination conditions.
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