Proposals for a new independent regulator of qualifications were given qualified support in OCR's response to the DCSF consultation, 'Confidence in Standards'. Of the 20 substantive proposals in the consultation, OCR was only able to fully support four of them.

In a covering letter (PDF, 111 Kb) that accompanied OCR's response, Greg Watson welcomed the intention to create a new independent regulator: 'The creation of Ofqual offers us a once-in-a-generation opportunity to tackle the fruitless annual debate about standards and to unpick the conflicting roles of the Qualifications and Curriculum Authority which have contributed to public unease.'

However, he was less positive about the detail of the proposals, arguing that they had lost sight of the key role of the regulator as one of safeguarding standards. He also accused the proposals of being founded on a number of deeply flawed assumptions. He challenged the notion that the current system has worked reasonably well and that the new arrangements need be nothing more than a clarification and realignment of existing roles. He questioned if top-down government initiatives really can produce the best qualifications, and cautioned against dividing the world into high stakes and low stakes qualifications.

Within OCR's detailed response (PDF, 75 Kb), OCR questions how the promise of a light-touch, strategic regulator can be reconciled with the proposal to radically increase its powers and the examples given in which the regulator can intervene in every aspect of the system, organisations and individual qualifications. It tries to understand why a new term, 'public qualifications' has entered the language of the DCSF and what is behind this notion. The governance structures proposed are revealed as still open to strong government influence and OCR recommends steps to strengthen the independence of the new body.

The response goes on to question how innovation can be encouraged under the proposals. It identifies the risk of a regulator working with fossilised and unnecessary design criteria which prevent new developments. In particular, it seeks to confront the Anglo-centric features of the proposals which do not seem to have taken into account the relationship with other UK countries, let alone the potential impact of globalisation and the internationalisation of qualifications.

Perhaps most strikingly of all, OCR rejects the proposals to create a new 'development agency', out of those QCA activities which would not transfer to the new regulatory body. OCR is highly dubious of the need for such a body which either duplicates activity and expertise that lies elsewhere in the system, or undertakes roles better managed within the machinery of government itself: 'many of QCA's current curriculum and policy functions are duplicated in DCSF or DIUS and much of the actual work is carried out by consultants, with QCA simply acting as a procurement agency and a passporter of government funds.'