A SUBMISSION ON THE UNIVERSITY ENTRANCE WORKING PARTY'S CONSULTATION DOCUMENT

UNIVERSITY ENTRANCE AND THE NATIONAL CERTIFICATE OF EDUCATIONAL ACHIEVEMENT

EDUCATION FORUM
FEBRUARY 2001

Introduction

The Education Act 1989 provides, at section 257, that the New Zealand Qualifications Authority (NZQA) has the function of setting a common standard as a prerequisite for entrance to university for people under the age of 20. For those aged 20 and over there is no common national entrance requirement. For those 19 years and under, entrance to universities can also be obtained under other provisions:

• applicants can be granted provisional entrance, with standards lower than the common entrance standard, and be granted entrance after a year's satisfactory full-time study. The Provisional Entrance Regulations are administered by the New Zealand Vice-Chancellors' Committee (NZVCC), but appeals are determined by the NZQA; and
  
  
• applicants with overseas qualifications at Form 7 standard or better can be granted ad eundem statum entrance, arrangements for which are, with the agreement of the NZQA, administered exclusively by the NZVCC except that appeals are determined by the NZQA.

The common entrance standard is currently set in terms of University Bursaries examinations and level 3 Unit Standards on the National Qualifications Framework (NQF). However, the main route is via Bursary, and the number of students applying with Unit Standards is extremely low.

The National Certificate of Educational Achievement (NCEA) is to be phased in over three years from 2002 and will replace the Sixth Form Certificate in 2003 and the Bursary examinations in 2004. Hence the perceived need to redefine the university entrance standard. It is proposed that that the common and provisional entrance requirements be set in terms of the NCEA credits which can be gained from both the proposed new Achievement Standards and from Unit Standards.

Four models, not necessarily mutually exclusive, are advanced for consideration. All are based on the number of credits gained, irrespective - in the case of Achievement Standards - of grades awarded. This is similar to the current standard in that there is no additional recognition of Bursary grades above 'C'. Unit Standards are awarded on a pass/fail basis.

Consultation questions are posed around three sets of issues:

• which of the proposed models are acceptable for the purpose and which is preferred;
  
  
• what subjects should be approved; and
  
  
• what minimum literacy and numeracy requirements should be set.

Preliminary observations and comments

The Consultation Document is very limited in scope. Apart from descriptive material and a short statement about the purpose of a common university entrance standard, it deals almost exclusively with the mechanics of resetting the standard in terms of the NCEA. There is no discussion about provisional entrance and ad eundem statum qualifications except a statement that the NZVCC will be working on provisional entrance requirements under the NCEA. There is no analysis in the document: conclusions are asserted (eg the agreed statement and key points) but the arguments leading to them are omitted.

The Consultation Document states that key requirements for a common entrance standard are that it "must be clear, easy to understand and an accurate assessment of the capability of students". Models are developed but no attempt is made to demonstrate that they meet these criteria. The NCEA is taken as a given, and there is no discussion as to whether it is suitable for setting a common entrance requirement, whether it provides sufficient and sufficiently reliable information for selection purposes, or about its influence in the preparation of young people for degree-level study. The conversion of the present common entrance requirement (basically 3 'Cs' in Bursary) into a model employing NCEA credits is seen as intrinsically unproblematic. Given this level of credulity, it is not clear what the NZQA expects to gain from consultation except to be able to say that it has been undertaken. But perhaps the most obvious omission in the Document is any consideration as to whether a common national entrance standard is still needed.

It is acknowledged that the NZQA, as the co-designer of the NCEA, is heavily committed to this new system of school qualifications. Indeed it declines to discuss NCEA policy, and this greatly diminishes any enthusiasm people might otherwise have in devoting effort to the submission process. However, the tertiary sector does not share the same commitment to the NCEA.[1] As far as is known, the only New Zealand academic educationalists that have written on the matter have been highly critical of it. At least three overseas educationalists have also been very critical of what is proposed. [2]

The New Zealand universities have their own interests and those of their students to consider, including their international reputations and the quality of senior school education as a preparation for degree-level study. They will not wish to avoid asking some fundamental questions before coming to a conclusion on the matter. This submission seeks to address these questions and considers that there is little to be gained from analysing the models advanced before they have been settled.

A brief review of some overseas practices

The Working Party considers that setting an educational standard for entrance to university has the advantage of showing students that degree-level study is open to them and that they have a reasonable chance of success at it. It notes that some degree programmes and courses have additional selection mechanisms for entry. This, however, does not necessarily mean that a national standard should be set rather than leaving the matter to individual universities and other degree conferring institutions.

As far as we can ascertain in a very brief review of the situation, neither the Australian nor the United Kingdom government sets a national entrance standard. In Australia there is no federal minimum standard, and universities have autonomy to determine their own entry standards. Australian universities do cooperate, we understand, in ranking students for entry, and a mechanism has been developed for relating the different school exit qualifications of the various states and territories.

UK universities set their own entrance standards, and students' performances in the 'A' levels (and other exit certificates including the Scottish Highers and the Irish Leaving Certificate, BTEC, GNVQ and, in some cases, the International Baccalaureate) are used to rank students and assist selection. Samples of entry requirements for the Queen's University of Belfast and the University of Bradford are attached as Annex 1 to this submission. It will be seen that both universities set precise minimum standards for each subject or course, and we assume that these are not atypical.

Higher education in the United Kingdom has expanded far beyond the capacity of A-levels to act as a filter: more than twice the proportion of school students go on to university as used to pass the 11 plus. The vast diversity in ability and attainment among university entrants has meant that accepted entry qualifications have to extend beyond even vocational qualifications to so-called access routes which may mean no school qualifications at all, in some cases because A-levels were failed.

The Open University in the United Kingdom takes students on a first-come-first-served basis. Some students find they can't meet the expected standards and drop out. Others with no or minimal school qualifications go on to get good degrees. It enjoys a high reputation because there are careful controls on quality at the exit stage.

The UK government seeks, through a Quality Assurance Agency, to treat all universities the same, even though there is no common entrance requirement. In fact, of course, universities in the United Kingdom differ vastly in their entrance requirements, and it seems logical to assume that there will be significant differences also in the standards of education provided and the perceived values of the degrees awarded. Maintaining the polite fiction that this is not the case may well be causing problems for the Agency as it tries to maintain common quality measures across a group of very diverse institutions.

In the United States there is a hierarchy of tertiary institutions with very different entrance requirements as between, for example, the ivy-league universities and small, local community colleges. There is also a well developed system of ranking faculties and departments within the universities.

In the United Kingdom and Australia the redesignation of polytechnics (TAFE institutions in Australia) as universities has established a two-tier system with a well understood hierarchy within each tier. Calling institutions by the same name for public policy purposes does not mean they are thereby similar or that they will be treated as the same by students and the employers of their graduates.

Should there be a common minimum entrance standard for New Zealand universities and other degree conferring institutions?

The argument for a common minimum entrance standard given in the Consultation Document is that it provides prospective students with a valuable indication as to whether or not they are likely to succeed at degree-level study. Quite clearly not everybody is capable of degree-level study, and a minimum entrance standard may act to avoid much waste of student and university time and resources. To this extent an entrance requirement excludes as well as opens up. If one is to be set it should clearly apply to all degree-level study and not just to universities.

A common entrance requirement assumes, however, a common understanding of university- or degree-level work and that all degree conferring institutions are similar in academic standing and requirements. This may have been true when only a small 'academic' elite went on from school to university and the only institutions offering degree-level education were a few universities. This is no longer the case. As in the United Kingdom and elsewhere, the enormous increase in the percentage of the school population going on to degree-level study in New Zealand has necessarily led to a much wider range of ability, attainment and aspiration among university entrants. Also, as in the United Kingdom, degree conferring institutions in New Zealand set their own entrance standards, higher than the national minimum, for various programmes and courses.

It is thus far from obvious that a single common standard should be set for access to degree-level study. If it were set then it would have to be low in recognition of the wide ability and attainment ranges among entrants. Setting a minimum poses the serious problem that many students may aim to achieve the minimum and not their best - that in practice the minimum becomes the maximum.

In fact the lack of any entrance standard for those 20 and over already provides easy access. It only requires a relatively short wait for a school leaver at age 16 (the present minimum leaving age) with no qualifications at all to gain entrance to an undergraduate course at age 20. There will be a much shorter wait for students who complete the 7th Form year but fail to obtain the necessary Bursary grades - most will be 18. Moreover, the Provisional Entrance Regulations allow universities to accept students with minimal qualifications (eg a Sixth Form Certificate in one subject) on a provisional basis. Further, the common entrance standard only applies to universities and not to degree programmes and courses at polytechnics and other non-university degree conferring institutions. The non-university degree conferring institutions are already determining their own prerequisites for entry and would presumably not wish to have a common minimum entrance standard imposed on them. The notion of the common standard is thus already something of a myth and an anachronism.

The Consultation Document doesn't address the issue of whether the age distinction between those 19 years and under and 20 years and over complies with the Human Rights Act 1993. This is strange as both the Education Amendment Act 2000 and the current Education Amendment Bill (No 2) Bill include provisions removing references to age from education legislation in order to bring them into compliance with the Human Rights Act. We would note that if the age distinction is removed from section 257 of the Education Act then a common entrance standard would apply to all applicants irrespective of age, subject to whatever the Provisional Entrance Regulations and the ad eundem statum provisions allow. This would also indicate the need for a very low common entrance standard. Alternatively institutions could be allowed to make their own selection decisions including whether and what allowance should be made for older applicants.

Universities and polytechnics have been quick to expand the number and types of courses, particularly of a vocational nature or 'studies' of various kinds, and to secure enrolment-driven public funding. This increasing diversification seems likely to continue, making the common entrance standard even more of an anachronism. Our conclusion is therefore that the common university entrance requirement should be scrapped and that the selection of students should be a matter to be left to the institutions.

There are advantages in a more US-like tertiary system which enables those with little or nothing at all by way of school qualifications, but with sufficient ability and determination, to work up through a very diverse system from the lowest level of community college to post-graduate work at a prestigious ivy-league university. The US system reflects in part inadequacies in school-level education which unfortunately are also becoming increasingly apparent in New Zealand and which are, and will be, exacerbated by the poor quality policies of recent years in the areas of school curriculum, assessment and qualifications (including, of course, the NCEA - see below). The aim of government policy should be to relax or remove government controls on schooling and to allow the continuing diversification of the tertiary sector.

Would the proposed NCEA be a suitable basis for setting a common minimum entrance standard?

If, contrary to the thrust of this submission, it is decided to set a minimum standard for degree-level study then it is still necessary to consider whether or not it is desirable to set it and provisional entrance requirements in terms of credits awarded for the proposed Achievement Standards and the existing Unit Standards. This is not the place to rehearse all the design faults of the NCEA system and the substantial problems that it is likely to encounter if implemented as currently proposed. We attach as Annex 2 a short Education Forum report which summarises the main issues and concerns, and the bibliography at the end of this submission provides references to more detailed material.

As noted above, we are not aware of any support for the proposed new system among academic educationalists who have written on the matter. Universities and other degree conferring institutions will be particularly concerned at the likely adverse effects on teaching and learning in the senior school and the consequences for the preparation of young people for tertiary education, the doubtful reliability of the information provided by students' NCEAs[3], and the difficulties that will be encountered in trying to use the information provided, even if reliability could be assumed, for student selection.

On the selection issue, and again ignoring the unreliability problem, there must be considerable doubt whether the NCEA, given its fragmented nature, would enable tertiary departments to distinguish fairly among candidates for courses that are oversubscribed. As one commentator has observed it "will be a bit like trying to pick thesprinters, long-distance runners, jumpers, throwers and hurdlers of an athletics team on the basis of some minimal decathlon".[4] On the other hand if the minimum requirement is set too low and/or becomes debased through widespread 'dumbing down'[5] , students who meet it will be able to demand entrance even if in the view of the institutions they should be excluded. Either way, tying entrance to degree-level study to the NCEA is likely to hinder rather than help universities and other tertiary institutions in their essential but difficult task of identifying those best able to benefit from the particular services they have to offer.

The Consultation Document says that the entrance requirement will be set in terms of the NCEA and that the results of other qualifications may be recognised in the future and would be benchmarked against NCEA results. This places an enormous degree of faith in the NCEA as a basic entrance standard for which no justification is provided, presumably because none is available.

The Consultation Document explicitly assumes that a credit grade at level 3 will be approximately equal to a grade C in Bursary but doesn't say whether it thinks that this equality exists, nor does it explain how such equivalence could be established between two such different systems - one largely based on norm-referenced and scaled examinations and the other on a competency form of standards-based assessment. [6]Nor is it clear what a credit grade at level 3 of the NCEA means. It presumably doesn't refer to a single level 3 Achievement or Unit Standard but, if not, to how many Achievement or Unit Standards does it refer?

It may well be that the development of some form of aggregation of credits for Achievement Standards within a subject is envisaged. But under the proposed NCEA there would no longer be any such thing as a 'subject' except in the very limited sense of a category within which to group Achievement Standards which are, often arbitrarily chosen, aspects or 'slices' of a subject (Education Forum, 2000, pp 21-23). The school curriculum will be delivered by Achievement Standards, not by subjects. Each Achievement Standard will be assessed either by internal assessment or by external assessment and reported separately. There is to be no aggregation of Achievement Standards at any point.

The official view, and it is a key part of the NCEA system, is that it is invalid to aggregate credits gained from different Achievement Standards within a 'subject' because each standard represents a distinct and separate component of knowledge and skills and that no significant correlation between a student's achievements in the various components of a subject can be assumed: the example given on page 19 of the Consultation Document of a student's results for English reflects this view. Hall (2000a; 2001) has shown convincingly that this approach is seriously mistaken. [7]A similar view is expressed by Elley (2000). But if the NZQA intends to proceed with some form of aggregation of Achievement Standards by 'subject' - and three of the four models advanced in the Consultation Document incorporate the concept of 'subject' - it should explain why, in this context at least, the official view (for which it shares responsibility) is wrong and why the NCEA system can nonetheless be accepted as an educationally viable qualifications system even without this key element. It will also need to explain how credits from a competency form of standards-based assessment can be validly aggregated for selection purposes.

Given the problems with the NCEA, it would seem far more logical to set the requirement in terms of established overseas qualifications with a successful track record. Suitable overseas qualifications would include the International Baccalaureate, the UK A-levels and Cambridge University's Advanced International Certificate of Education (AICE) which are already accepted by the NZVCC as ad eundem statum qualifications. It is not at all clear whether it would be possible to benchmark the NCEA against them, but that possibility could be investigated. The main point is that a benchmark must be an established, robust point of reference, and it would be absurd to use a totally untried one about which there are so many serious doubts.

In its agreed statement about the purpose of university entrance, the Working Party says that:

Furthermore, and notwithstanding the existence of a common entrance standard, many degree programmes and courses of study will also have additional selection mechanisms for entry.

It is not entirely clear what is intended here. It appears that the Working Party is saying that for university entrance students will have to meet whatever requirement is set in terms of the NCEA and that the "additional selection mechanisms" will be on top of the national NCEA minimum, perhaps requiring more credits, or credits at a higher (merit or excellence) grade in the NCEA, or success in some other examination deemed superior. This would entrench the NCEA, making it essential for virtually all students aspiring to degree-level study even if they are being prepared for, say, the International Baccalaureate or the AICE. Given the particular design problems in the NCEA and the general problem of statutory monopolies, this would be a disaster.

We have noted above that there is no discussion about ad eundem statum qualifications or the Provisional Entrance Regulations except for the statement that the latter will also be set in terms of the NCEA. These alternative routes are presently administered by the NZVCC, but only with the agreement of the NZQA which could be readily withdrawn. If a common entrance standard is to be set, it must in our view be left to the degree conferring institutions to decide what alternative (not additional) qualifications, local as well as overseas, may be accepted for entry including entry to programmes and courses for which superior prerequisites are required.

We noted in our preliminary observations the view expressed in the Consultation Document that the common entrance standard must be "clear, easy to understand and an accurate assessment of the capability of students". We do not think any models employing the NCEA can meet these criteria (with which we concur), and the Document, understandably perhaps, includes no attempt to demonstrate that the ones put forward for consideration will in fact do so. The confusions in the Consultation Document itself suggest that not even the NZQA, the co-designer of the NCEA, [8] has understood some of the implications of the scheme it is vigorously promoting. As for accuracy of assessment, Professors Hall (2000a and b; 2001) and Elley (2000) have shown that reliability will be unacceptably low for selection purposes.

If a criterion of manageability were also included, as it should be, several critics (eg Hall 2000a and b; Irwin 2000) have demonstrated that the NCEA will impose considerable burdens on schools, significantly reducing teaching and learning time. Nor is it likely that the information provided, even if reliable, would be useful in selection (Education Forum, 2000, p 25). If a criterion were that the model should be based on an assessment scheme that helped to prepare young people for degree-level study (also vital in our view), then again an NCEA-based model would fail. This would be because of the NCEA's adverse effects on teaching and learning, arising from the fragmented nature of Achievement Standards and the narrowing of the curriculum that would result (Austin 2000; Education Forum, 2000, pp 25-26), as well as the serious incursion into teaching and learning time that will be caused by the additional assessment and administration required.

If the NZQA wishes to advance models of a common entrance standard it must show how they meet its own criteria as well as, we consider, the two additional ones suggested above. We do not believe it can do this based on the NCEA as currently designed.

The Treaty of Waitangi

It is unclear what relevance the Treaty of 1840 could possibly have to the issue of university entrance. If the Consultation Document is implying that Maori students should have superior rights of access to degree-level education simply on the grounds of Maori ancestry, we would find this discriminatory and objectionable.

Maori and Pacific Island students

We are uncertain about the intentions expressed in the Consultation Document for seeking feedback on approaches "designed to close the gaps" consistent with the need to give learners a fair indication of their likely chances of success at university.

The feedback is to relate to possible beneficial ways of responding to different learning needs. It is one thing to educate students, including preparing them for degree-level study, taking account of their modes of learning (though we understand that there is much debate and little consensus on what this means for epistemology and pedagogy), but it is quite another thing to adjust entrance standards to suit students of particular ethnicities if indeed that is what is envisaged.

'Closing the gaps' is not an appropriate objective of degree-level education, and nor is it an appropriate concern of a qualifications authority. 'Closing the gaps' could just as well mean discriminating against Asian students who perform disproportionately well under our school examination system as giving students of other minorities an advantage based only on their racial origins. We are not aware that positive discrimination in education has achieved anything 'positive' for the education of minority groups, and we understand that California, where 'whites' are now a minority, has moved decisively against it in recent times with positive results for the education of minorities.

Subjects

On page 13 of the Consultation Document there is a reference to "traditional European notions of subject". These notions are not described, although the Document states that they need to be "rethought". In context it appears that these unspecified notions are seen as not necessarily forming "coherent packages of learning".

There is a considerable literature on the organisation of knowledge which centres around issues of types and categories.[9] It would seem very probable that academics and others of many races have contributed to this literature, and not only Europeans. In fact, of course, several subjects have their intellectual origins in Asia, the Middle East and North Africa. It is not at all clear why the Maori skills and knowledge to which the Document refers cannot be taught and assessed in ways that are consistent with current thinking about 'subjects'.

In the context of entrance to degree-level study it is important to note that such study is still largely organised around those notions of 'subject' which the authors of the Consultation Document consider to be limited in some unspecified way. In any case the official view, as discussed above, is that under the NCEA there would be no 'subjects' except as categories within which to group distinct and separate units of learning called 'Achievement Standards'.

We would agree that the issue of what comprises an educationally sound programme for the senior secondary school, along with the implications for curriculum design and summative assessment, are vitally important matters. We would have welcomed a well-informed, quality discussion about them. However, it is highly likely that such a discussion would have led to conclusions contrary to the official view held in the context of the NCEA that subjects should be decomposed, that it is productive to have teachers and students work to vague statements of intent (outcomes, standards, objectives etc) and that the accumulation of a large number of units or credits is a sensible means of obtaining a higher qualification.

Conclusions

Our recommendation on the basis of this review of the issues, and in the absence of any substantial information or analysis in the Consultation Document, is that the common entrance standard be scrapped. It may be possible to include the necessary statutory amendment in the Education Amendment Bill (No 2) presently with parliament's Education and Science Committee.

Given the diversity of ability and attainment among the student body, a single requirement makes little sense. The lack of any requirement for those 20 and over and for those undertaking degree-level study at an institution other than a university and the provisional entrance provisions make it almost meaningless anyway. If the age distinction is removed, it will be all the more important that individual institutions decide their own entrance requirements. Further, as long as the funding system encourages roll growth, not quality, ways will always be found to circumvent requirements that threaten to curtail enrolments below the levels to be funded.

The NCEA as presently designed would be a highly dubious educational measure. It is a new, untried system the design of which has been severely criticised by New Zealand and overseas educational experts and for which there is no successful precedent elsewhere (Donnelly 2000). Trying to set an entrance requirement in terms of it is fraught with problems which the authors of the Consultation Document do not appear to have recognised, let alone solved. It is absurd to suggest that it be used as a 'benchmark'.

Universities and other degree conferring institutions should be extremely careful not to give this proposed new school qualifications system an endorsement which they are unable to justify and would come to regret.

If an NCEA-based common entrance standard is set it will be very important that the institutions themselves decide what might be equivalent (ad eundem statum) local as well as overseas qualifications or superior prerequisites and what provisional entrance arrangements should apply. The NZQA as co-designer and administrator of the NCEA will wish to ensure that it has, as far as possible, a monopoly of school exit qualifications in order to protect the NCEA from unflattering comparisons. Indeed it is likely to argue that the success of its proposed new qualification depends on wide public confidence which would be undermined by any significant haemorrhaging from its new system to other qualifications and that adopting alternatives must be prevented or at least made as difficult as possible.

The NZQA hasn't shown how the models advanced meet its own suggested criteria (nor the two additional ones suggested above) for a common entrance standard - nor can it. If a requirement is to be set it should be defined in terms of established respected qualifications. It is essential that the NCEA is not made the basic requirement for all students.

A much better route is to allow tertiary institutions to set and publish their own standards, which would vary between programmes and courses, and to select their own students. This will place the responsibility on each institution, their faculties and departments and on potential students themselves, to determine whether or not they are likely to benefit from degree-level study. It will also avoid the fruitless search for a form of words that sets an unequivocal common entrance standard for a sector whose component institutions are far from homogeneous. While some institutions and departments within them will seek to accept only top qualifying school leavers, for others it may well make better sense in terms of maintaining standards and reputations to apply strict quality controls over student performance during and at the end of study rather than at entry (see earlier reference to the Open University in the United Kingdom).

The twin aim in the current context of university entrance should be to improve both schooling as a preparation for tertiary study and tertiary level education itself. Current bureaucratic controls over curriculum, assessment and qualifications at the school level are harmful and should be relaxed or removed altogether. The tertiary system should be allowed to develop a system of 'bridges and ladders', as in the US system, catering for the diverse range of ability, attainment and aspiration among tertiary students. Controls over tertiary institutions by category or function and over selection procedures are likely to hinder this development.

Bibliography

Lydia Austin (2000), "Shades of 19th Century in Using Overseas Exams", New Zealand Herald, 29 June.
Kevin Donnelly (2000a), New Zealand's National Certificate of Educational Achievement (NCEA): An International Perspective, Education Forum, Auckland, August.
Kevin Donnelly (2000b), "NZ in danger of 'Dumbing Down' ", Otago Daily Times, 27 September.
Warwick Elley (2000), "Destination Unknown" in NZ Education Review, 17 November.
Education Forum (2000), Policy Directions for School Qualifications: A Report on the National Certificate of Educational Achievement, prepared with the assistance of Professor Alan Smithers, Education Forum, Auckland, August.
Education Forum (2000), What Teachers and Parents Should Know About the National Certificate of Educational Achievement (NCEA), Education Forum, Auckland. [NB this is attached as Annex 2 to this submission.]
Cedric Hall (2000a), "National Certificate of Educational Achievement: Issues of Reliability, Validity and Manageability", in Livingstone, I (ed) (2000), New Zealand Annual Review of Education 9:1999, School of Education, Victoria University of Wellington, pp 173-196.
Cedric Hall (2000b), "Reliability, Validity and Manageability?", NZ Education Review, 21 July.
Cedric Hall (2001), "NCEA: Issues related to Reliability, Validity and Manageability", paper appearing as an appendix to Victoria University of Wellington document AB 01/01.
Michael Irwin (1999), "Achievement 2001", paper for the New Zealand Council for Educational Research Examining Assessment Conference, Wellington, October.
Michael Irwin (2000), "Results Cannot be Trusted", NZ Education Review, 1 September.
Michael Irwin (2001), "Deaf to Future Troubles", NZ Education Review, 19 January.
Greg and Howard Lee (2000), "The National Certificate of Educational Achievement (NCEA): 'Fragile - Handle with Care' ", paper presented to the NZARE conference, Hamilton, December.
Terry Locke (1999), "Lacks of Achievement 2001", English in Aotearoa, 39, 62-67. This is accessible at <http://www.tmc.waikato.ac.nz/ESD/>.
Terry Locke (2000), "Design for Study", NZ Education Review, 18 August.

Acknowledgement:

This submission was prepared with the assistance of Michael Irwin and benefited from comments on earlier drafts provided by Jim Doyle, Cedric Hall, Mark Harrison, Terry Locke and Alan Smithers. However, the views and recommendations are those of the Education Forum.

1. New Zealand educationalists who have commented adversely on the NCEA include Professor Cedric Hall (Victoria University of Wellington), Dr Terry Locke (University of Waikato), Dr Lydia Austin (University of Auckland) and Professor Emeritus Warwick Elley (University of Canterbury). We are not aware of any supportive analyses from any New Zealand academic educationalist.

2. These are Professor Alan Smithers of the University of Liverpool whose analysis was largely incorporated into the Education Forum's report Policy Directions for School Qualifications (Education Forum, August 2000); Dr Kevin Donnelly, an independent education consultant of Melbourne, who prepared New Zealand's National Certificate of Educational Achievement (NCEA) - An International Perspective (Education Forum, August 2000); and Professor Sam Ball, professorial Fellow in the Department of Mathematics and Statistics at the University of Melbourne and formerly CEO of the Victorian Board of Studies, who contributed to Dr Donnelly's report (op cit).

3. On the issue of the reliability of the assessment of Achievement Standards see especially Hall (2000a and b; 2001).
Personal communication.

4.This would appear to be highly probable in the case of internally assessed Achievement Standards as there is to be no cross-moderation against externally administered tests.

5. For a discussion of the type of standard-based assessment used for Achievement Standards see especially Locke (1999).

6.Hall (2001) notes that there are many possible ways of dividing a subject of which the proposed Achievement Standards form only one. He goes on to point out that the designers of the NCEA seem to have made the mistake of assuming that the standards chosen form independent components of the assessment of a subject. In fact, however a subject is divided, it doesn't follow that each division, or standard, is separate from the others in a pedagogical sense.

7.The standards, Hall says, may be thought of as the 'bricks' forming a course, but the 'mortar' - the knowledge and skills connecting the 'bricks' and providing integration and transfer of knowledge between the various parts of the subject or course - will be de-emphasised or de-contextualised in any scheme that treats standards as separate entities.

8. The other designer was the Ministry of Education.

9. For a recent discussion of the organisation of some disciplines within the New Zealand context, see Brian Crittenden's article "Social Studies: The Plan for New Zealand's Schools" in Agenda, Volume 5, Number 2, 1998, pp 189-200.