Discount Codes – our open government

Well, here it is – the answer to my freedom of information request. I will now be appealing….

Dear xxx xxxxxxxx,

Thank you for your request for information which was received on 1 March 2013.
Your request was as follows:
I would like to formally request the following information under the Freedom of Information Act, so that we are able to pursue this with our local MP and the Department of Education:
• Please can you identify by name the subject experts you refer to who were consulted in relation to the application of discount codes to all subjects
• Please can you provide the written recommendations from all the subject experts regarding all the new discount codes
• Please can you provide the minutes of meetings where the decisions were made regarding the application of new discount codes and the final decisions in relation to the different recommendations from these subject experts
This will allow me to be able to pursue with those responsible further explanation, such as, for example, why two different Performing Arts disciplines are being treated as if they are the same, but two Design Technology subjects, which share the same specification heading, as is the case with “Design Technology: Food” and “Design Technology: Product Design”, are treated as separate.
I have dealt with your request under the Freedom of Information Act 2000 (“the Act”)
The Department is withholding names of subject experts who were consulted for advice about new discount codes under section 40(2) of the Act, on the grounds that release of the information would breach one of more of the principles of the Data Protection Act 1998. This exemption is ‘absolute’ in these circumstances, which means that it is not necessary for the Department to run a test to balance the public interest in release against that in withholding the information.
Furthermore, while the Department holds the information you requested in your second question, it is being withheld under section 35(1)(a) of the Act on the grounds that it relates to the development of government policy. Section 35 is a qualified exemption so the Department has applied the public interest test to your request, and has concluded that the balance of public interest falls in favour of the exemption in relation to the information you have asked for.

Considerations in favour of a decision to disclose are a greater transparency, making government more accountable to the public, the public interest in being able to assess the quality of advice being given and subsequent decision making. Considerations against a decision to disclose information are that there may be a deterrent effect on external experts who might be reluctant to provide advice if it might be disclosed, narrowing the advice available, and the impartiality of the civil service might be undermined if early policy advice was routinely made public leading to poorer decision-making.
The Department does not hold the information you requested in your third question.
As already outlined to you, the learning objectives and assessment requirements are generally adaptations of one another, designed to recognise the variations and options within the wider field of the performing arts but in most cases the knowledge base and the cognitive demands are very similar. Even where the skills focus is clearly different the specifications still explore similar learning processes and often highly interchangeable knowledge and skills. In comparison although all GCSEs in Design and Technology cover skills in research, design, development, planning and creating a product and testing and evaluation, the skills and knowledge required for eg Food technology and Resistant materials are very different with no overlap in knowledge and skills.

Following the current consultation on 16-19 vocational reform a list of high-value 16-19 vocational qualifications that will be included in the 2016 KS5 performance tables will be published and we will follow a similar process to update the discount codes used for the KS5 performance tables from 2016 as we did for the 2014 KS4 performance tables. We will continue with the existing discounting process in use in the KS5 performance tables until 2016.

Your correspondence has been allocated reference number 2013/0014523. If you need to respond to us, please visit, and quote your reference number.
Yours sincerely,

Data and Statistics Division

Letter to my MP – Discount Codes

I have sent this letter this morning to my local MP. I would urge others to make similar representation.

I would like to ask you to discuss with your colleagues at the Department of Education our deepest concerns about the restructuring of the discount codes for KS4 and P16 subjects. You will be aware that there is currently a system of using discount codes to link subjects that have similar content, skills and understanding. This means that a school that enters a student for English GCSE with four different examination boards will have only one recognised in the school performance tables. This is an appropriate system to tackle what some have called “gaming” and protects a student from wasting learning time on additional qualifications which do not move the student on with their learning.


However, the recent (and retrospective for 2014 performance tables) changes to the discount codes are alarming as they do not seem to recognise the needs of students. You will be aware that we are an Arts College, with very successful outcomes for students studying Art in P16. Not only that, but our contribution to the local cultural climate is significant, having only just this week having been asked to make a significant artistic contribution to an event, which will place the work of our students on the national and international stage.


The recent changes to the discount codes mean that a student studying separate A Levels in Textiles and Photography will have only one of these qualifications included in the school performance tables. This means that there is a clear disincentive for a school to support a student in following this combination, or indeed any combination of two Art based courses, whether that be, for example, Fine Art, Graphics or Sculpture.


We have a significant number of students who choose to stay at our school to follow courses in Art and then progress on to specialist Art courses in Higher Education. It now appears that the DfE is clearly making it very difficult for students to make these kind of choices, or where they are supported by the school, the school itself will be penalised. Our school is penalised for supporting students making choices within the Arts, students who have discussed with us and their parents their future intentions and have chosen appropriately.


As you look through the list of courses that have now been given the same discount code, you will also see that the Department of Education sees Dance and Drama as effectively the same subject, having given them the same discount code.


When I see this I become deeply concerned that the Department for Education has little idea about what these subjects involve.