Primary and Final FRCA examinations regulations
Appendix 3: Disability and Reasonable Adjustments Policy
Reasonable adjustments at examinations – arrangements for disabled candidates
This policy has been updated following the guidelines set out in the Academy of Medical Royal Colleges (AoMRC)’ ‘Reasonable Adjustments for Candidates with Disabilities in High Stakes Assessments’ document (July 2017), which was produced following collaborative work from medical colleges. This policy also takes account of the AoMRC document ‘Managing access arrangements for candidates requesting adjustments in high stakes assessment (May 2018).
1. Policy statement
The College is committed to ensure that all candidates have equal opportunity to demonstrate their ability in all types of FRCA examination settings. To this aim, the College will make ‘reasonable adjustments’ to examination arrangements as appropriate for individual disabled candidates. The College will take account of a candidate’s personal circumstances and any professional advice given in the corroborative evidence of the disability that has been supplied. Therefore adjustments are not merely based on the impairment(s) but how the impairment(s) would potentially impact on a candidate’s performance.
2. Definition of disability
Disability is a protected characteristic as defined by the Equality Act 2010 (the Act). The definition of disability under the Act is as follows:
In the Act, a person has a disability if:
- they have a physical or mental impairment
- the impairment has a substantial and long-term adverse effect on their ability to perform normal day-to-day activities.
For the purpose of the Act, these words have the following meaning:
- ‘substantial’ means more than minor or trivial
- ‘long term’ means that the effect of the impairment has lasted or is likely to last for at least twelve months
- ‘normal day-to-day activities’ include everyday things such as eating, washing, walking, working and examinations.
Persons with certain conditions are deemed to be disabled for the purpose of the Act without having to satisfy the criteria set out above. Those conditions are:
- HIV infection, cancer and multiple sclerosis
- severe disfigurements (with the exception of unremoved piercings and tattoos)
- blindness, severe sight impairment, sight impairment and partial sightedness (provided this is certified by a consultant ophthalmologist)
3. Definition and provision of reasonable adjustment
3.1 ‘Reasonable adjustment’ is any action that helps to reduce the effect of a disability or difficulty that places a candidate at a substantial disadvantage in an examination situation.
3.2 The College will make reasonable adjustment for disabled candidates who undertake FRCA examinations, where any provision, criterion or practice and/or physical feature of the exam environment puts disabled candidates at a substantial disadvantage compared with those who are not disabled. The College will provide or allow the use of auxiliary aids, where without one a disabled candidate will be put at a substantial disadvantage. See paragraph 6.
3.3 The College will also consider temporary (such as; broken arm, back pain), on-going or fluctuating medical conditions for the purpose of examination adjustment, where the condition affects a candidate’s ability to take a planned sitting of an examination. See Section 9 of these regulations regarding special arrangements for Pregnancy or short-term related conditions.
3.4 Reasonable adjustment to examination arrangements is provided to candidates with a disability in order to reduce the potential disadvantage they face compared to a non-disabled candidate. It is not designed to give any type of advantage to disabled candidates in the receiving of additional examination accommodations. Reasonable adjustments must not affect the reliability or validity of the examination and does not apply to the application of a competence standard. The College recognises that it is not possible or appropriate to attempt to define a pre-determined set of reasonable adjustments and therefore any decisions will need to be made on a case-by-case basis.
4. Procedure for requesting reasonable adjustment
4.1 Any candidate who has a physical or mental disability, specific learning difficulty (SpLD) or on-going or fluctuating condition that they believe could affect their performance in an examination may be entitled to reasonable adjustments or special arrangements. All such candidates should initially inform the College at the time of application by ticking the appropriate pop-up boxes during the online application process. This should also be carried out at all reapplications and repeat attempts at any component(s) of the examination. Candidates should not assume that they will be granted adjustments at forthcoming exams just because they were provided certain adjustments at previous attempts.
4.2 On completion of submitting their exam application and in addition to indicating they require adjustments during the application process, all candidates seeking reasonable adjustments must submit full written details of any adjustments they require by emailing email@example.com.
The subject heading of the email should include the name of the examination applied for and the wording ‘request for exam adjustments’. For example; “Primary FRCA MCQ, September 2019 - request for exam adjustments”. This process should be followed at all attempts. Candidates must supply supporting evidence of their disability from an appropriate authority, such as; the candidate’s GP, their college tutor or supervising consultant. See paragraph 4.4 regarding the evidence required for candidates with a specific learning difficulty (SpLD).
4.3 Candidates whose need for reasonable adjustments or special arrangements (see Section 9 of these Regulations) arises after the submission of their application (due to an accident or sudden condition/illness) must contact firstname.lastname@example.org as soon as practicable.
4.4 If a candidate is seeking reasonable adjustments for an SpLD then they must provide a report from an approved assessor* . This assessment needs to have been obtained after the age of 16. The report must include recommendations in regard to exam adjustments.
*Approved assessors include:
- Specialist teachers who hold a practicing certificate, such as Dyslexia Action, BDA or PATOSS. Candidates can check if an assessor holds the appropriate qualifications on the SASC (SpLD Assessment Standards Committee) website
- A practicing chartered or educational psychologist who is registered with the Healthcare Professionals Council. A candidate can check if an assessor is registered on the HCPC website.
Where candidates are unclear if the person who completed their assessment is an ‘approved assessor’, they should contact email@example.com for clarification.
4.5 Many assessors may not be familiar with the range of assessments undertaken by candidates sitting the FRCA examinations and working towards a CCT in anaesthetics. Therefore to assist assessors in completing their reports, the College is happy to provide information to help them tailor their recommendations more effectively for specific examinations. Candidates should contact firstname.lastname@example.org and provide the contact details of the assessor compiling the report.
4.6 If the rationale for reasonable adjustments in the evidence or report provided is unclear or it is felt that further explanation is required, the College may seek consent from the candidate to approach the relevant GP, consultant or assessor/expert concerned for further clarification.
4.7 Candidates are advised that failure to contact the College promptly may mean that there will be insufficient time for some or all of the reasonable adjustments requested to be put in place. In such cases, candidates can either agree to sit the examination with no or some reasonable adjustment or withdraw and receive a full refund. They can then reapply for the next sitting of the examination, where a full and fair assessment of the reasonable adjustments required can be made.
5. Consideration of Reasonable adjustments
5.1 All decision makers will have received training in equality and diversity, reasonable adjustments and unconscious bias. The College is responsible for undertaking an evidence based evaluation of the entitlement to adjustments for disabled candidates, as defined by the Act and to those with conditions similar to those raised at paragraph 3.3. The College will undertake reevaluations of entitlement for each exam application made by individual candidates requesting reasonable adjustments.
5.2 Whilst it cannot be assumed that candidates with the same type of disability will all benefit from the same adjustments, where a precedent has already been set, previously awarded adjustments will be used as a starting point for consideration and discussion. See paragraph 5.3 in regard to SpLDs.
5.3 Good practice in the support of candidates with SpLDs such as dyslexia is applied in offering a provision of extra time for written examinations, although this should be raised as a recommendation in the assessor’s report in order to be used as a starting point for reasonable adjustment considerations. Extra time accommodations for candidates with SpLDs will also be considered for other exam components where the reading of information is required. Additionally, such candidates may have different or further requirements, such as the use of particular fonts, overlays or exam questions printed on coloured paper. Where this is the case different and/or additional reasonable adjustments will be considered on a case-by-case basis.
5.4 Where the College has no precedent for an adjustment for a particular disability or special need or where the adjustment requested is more significant than any previous adjustment permitted, then the case may be referred to the examinations committee. If the examination date is before the next meeting of the committee then the request will be forwarded for their consideration by confidential email, to the chair of the examinations committee, the Director of Education, Training and Examinations and at least three members of the committee which will include the chair/deputy chair of the relevant examination and the lay committee representative. The head of examinations will coordinate and compile the response and keep the candidate advised throughout the process.
5.5 All candidates who have submitted written requests for reasonable adjustments will be notified in writing of the reasonable adjustments that have been permitted for their examinations.
5.6 On late diagnosis of a condition that requires reasonable adjustments, all previous attempts at the examinations taken prior to the diagnosis will still stand. Candidates are strongly advised that should they feel that their performance may have been impaired by an underlying disability, they should seek advice after their initial failure rather than taking further attempts at the examination.
5.7 The FRCA OSCE and SOE examinations are regarded as competence tests, assessing understanding, cognitive skills and behaviour as well as clinical knowledge. As such the method of assessment is a crucial element of these examination components and any adjustments made must maintain the integrity and validity of these assessments and not affect the format of the examinations.
GMC guidance† indicates that while there is a duty to make a reasonable adjustment, in enabling the competency standards in Tomorrow’s Doctors‡ to be met, there is no requirement to make adjustments that would alter the standard of competency required.
5.8 In all cases the College reserves the right to take independent advice to ensure that any proposed adjustments are appropriate and in accordance with any applicable legislation.
5.9 Details and statistical information of requests for reasonable adjustment shall be regularly reported to the examinations committee for the purpose of monitoring and review.
5.10 Where a candidate does not believe the adjustments they have been granted are reasonable, they should refer to the Primary and Final FRCA examinations (Reviews and Appeals) regulations.
6. Examples of reasonable adjustments
The Act sets out three types of situations where the duty to make reasonable adjustments might arise. They are;
- where the College applies a provision, criterion or practice which substantially disadvantages a disabled person compared with a person who is not so disabled;
- where a disabled person is substantially disadvantaged (compared with a person who does not have that disability) as a result of a physical feature of the premises; or
- where, but for the provision of an auxiliary aid, a disabled person would be placed at a substantial disadvantage (compared with a person who does not have that disability)
The following table gives examples of the reasonable adjustments that could be applied to each of the three situations above - they are included for guidance purposes only:
Element of exam requiring adjustment
Example reasonable adjustments
Provision, criterion or practice (for example; requiring the exam to be completed within
Extra time for candidates with SpLD.
Adjusting exam cubicles to allow wheelchair access.
Provision of access lifts, accessible toilets and staircase ramps.
Hearing induction loop.