The IPA have formally written to their members responding to criticism of the dreadful issues experienced by CPI students on 20 November. NTI respond beneath - our comments to their statements are in bold.
It is vital that you know the truth and are not misled by a note from your regulator.
This morning, a technical issue emerged in the delivery of the Certificate of Proficiency in Insolvency (CPI) examination. This issue was completely out of the IPA’s control.
On behalf of our students, your candidates, and our clients NTI cannot accept this. Your duty, one that you are paid handsomely for with the fees paid to you for students to sit the CPI, CPPI and CPCI examinations, is to set an exam which is fit for purpose, on tried and tested software in a seamless, competent way.
The IPA instructed their invigilators and must accept responsibility for not ensuring that everything was correct and in place given the number of complaints about the software, its application and the guidance given to its they had received prior to the exam sitting. This feedback, much of it being forwarded to the IPA well before 20 November from NTI students, included lack of clear guidance and instructions, lack of ability to test the software and a paucity of information received.
When using a third party every principal must accept responsibility for their actions. The IPA have consistently claimed that the issues suffered by students during the exam were 'outside their control'.
The software should have been checked and re-checked multiple times before it 'went live' at 9.00am on Friday 20 November. The claim that it was caused by 'a Google update' on Monday 16 November is not satisfactory. There was enough time to check the software many times before the exam on 20 November.
Usually the exams are held in physical locations, however due to the unpredictable nature of the pandemic response, we took the decision, in consultation with students and providers to hold the exam online. It was felt that an online solution would mean that students would not be disadvantaged through unpredictable lockdown measures or isolation. This was undertaken in partnership with the Chartered Governance Institute (ICSA), who provided the online platform.
NTI were never consulted about the decision to move to remote invigilation and an 'at-home exam', and we are the primary tutor of CPI students. It was imposed upon us and our students with little notice before the actual sitting and only two opportunities to teach the use of the software (the second of which was only offered to students after we asked repeatedly for the chance for them to be given practise at doing so).
The strategy to use remote invigilation during a pandemic is a good one, but it was very poorly executed with little communication and minimal involvement of those who train towards and take the exams.
This year, all students were notified in good time that the examination was to take place online, and they were provided with instructions, help and a testing link, so that they were prepared for the examination.
The decision to move to at-home exams with remote invigilation was made after all training and study courses had started and came as a huge surprise to us all. This is only the IPA's view of 'being notified in good time'.
The instructions on how to use the software did not arrive with NTI and our students until significantly later, despite numerous requests for them. The testing link was made available once, and at a time students could not use it, as they were not at that time in a place to test their knowledge.
This is not sufficient exposure to a new exam-setting system. Students were not able to prepare properly for a significant exam and this fact was brought to the attention of the IPA by members of the NTI administration team on multiple occasions. The IPA ignored our concerns and refused to allow further access to try and test the software.
Students were given access to testing, and a series of tests were undertaken to ensure that the system would work. However, an update by Google this week, on its Chrome browser, resulted in some students being unable to access the online CPI platform via the provided link.
We have dealt with this argument above. There was ample time between the Google update and the exam to test and test and test the software. This clearly was not done and on this alone the IPA are negligent.
As soon as we became aware of the issue, the IPA immediately contacted the ICSA to ensure that they very quickly provided a solution to students, enabling them to take the examination on the same day and with less than an hour’s delay for the majority of students ...
On Friday 20 November many students have informed us, and have written directly to the IPA to inform them, that were interrupted repeatedly when typing their answers, because many students started the exam at different times.
... students were advised that they had not lost any of the time allowed for the examination, which would begin the moment they access the examination. Examiners will be informed and amelioration given for the distress caused to students affected by the temporary error.
This is almost artful under-exaggeration. NTI have received multiple reports of students in tears, too stressed to type, being unable to get onto the software for an hour, sometimes an hour 40 minutes and, in the worst example we have heard of to date, until 2.00 in the afternoon.
The IPA informed all training providers as soon as we were aware of the issue and kept them and students updated ...
NTI are the principal study provider for CPI and we heard nothing at all from the IPA until a call hugely apologising at 2.15pm. None of our students tell us that they heard from the IPA until the earliest almost noon - 15 minutes before the exam was due to stop. The truth is that NTI informed the IPA, students and sponsors that there was a problem within 10 minutes of being made aware of the ongoing issues (at 9.45am). The first IPA email was sent to students at 11.57am.
We are aware of one student who, as a result of the delay brought on by the issue, was unable to take the examination this morning. It has been arranged that this student will sit the examination this afternoon. The IPA has carried out a risk assessment and judged that there is next to no risk of the delay causing disadvantage or increasing the risk of unfairness.
This was an NTI student and when he was talking to the IPA he was also on the phone to us. There was no attempt at security or checking his status and, if we had wanted to, we could have given this student the questions and answers two and a half hours before his sitting. Of course we did not, but this is down to our discretion and professionalism, not to any alleged risk assessment by the IPA.
It is obfuscation at best to suggest there was any degree of 'risk assessment'. At worst it is a lie from one of the UK's two biggest insolvency regulators.
It is clearly unfair to allow a student to sit an exam one and a half hours after some had finished theirs. To suggest otherwise is shameful.
The IPA wholeheartedly apologises for any (the) inconvenience, distress and any other difficulty caused to any students. We worked as quickly as possible to ensure that the online examination provider minimised disruption as soon as the technical issue came to light. While we did take steps to risk manage and carefully implement the technology solution, introducing a new system, at pace and in response to a global pandemic, has been challenging. We hope that plans put in place to rectify have mitigated this unfortunate incident’s impact.
On behalf of our and all CPI students we point out that it is also very difficult to train and study for a professional qualification during a pandemic, not least when the goalposts are changed after you have started studying and minimal information given about those changes.
We have heard little of your plans to mitigate this incident's impact and question what will happen to those who were too stressed to continue with flawed software and incompetent invigilation. We are compiling a great deal of data on the detail of this and will ensure this is made available to everyone, as we do not want to receive another message from the IPA with unacceptable excuses.
As soon as we became aware of the issue, the IPA immediately contacted the ICSA to ensure that they very quickly provided a solution to students, enabling them to take the examination on the same day and with less than an hour’s delay for the majority of students. Students were advised that they had not lost any of the time allowed for the examination, which would begin the moment they access the examination. Examiners will be informed and amelioration given for the distress caused to students affected by the temporary error.
The IPA knew about these issues having been told about them by NTI, and from then it was one part of a shambles after another. Invigilators were given contrary instructions and were making rules up as they went along. We have heard many examples of candidates being told by their invigilator that the second camera did not matter, as well as being informed that they needed their IPA membership number before they could continue (which they did not) and then being left hanging on for more than 50 minutes before this position was rectified.
There are many examples of the incompetence of the IPA, the ICSA and your invigilators which NTI are gathering from our students and all of them will be given to the IPA at the same time as being made public.