Finally some guidance on external examiners
David Kernohan is Deputy Editor of Wonkhe
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At the nuts and bolts level of running courses, the external examiner holds an exalted position.
It is they who determine whether a course can be said to reach equivalent standards to similar courses elsewhere in the sector. Alongside the other two pillars – professional bodies and the QAA subject benchmarks – external examiners hold responsibility for the consistent standard of courses in UK higher education (and for others internationally based on the UK model).
You’ll look in vain in the current Office for Students regulatory framework for any mention of the practice (it was in B3 guidance when the original framework was published, but is not mentioned in the most recent iteration of B3, or in the updated condition B5 – which actually covers sector standards, or in the rather presumptive list of sector recognised standards).
So the Standing Committee for Quality Assurance (UKSCQA) – a UK sector representative body – has published, along with Universities UK, Guild HE, and the Quality Assurance Agency (the QAA, who developed the principles in consultation with the sector and other interested stakeholders) has published a set of twelve principles for external examining. This is the first salvo in the development of detailed advice and support, which ties in to the actual sector recognised standards (the UK Quality Code) in use in most of the UK.
The remarkable thing is that this needed to be done at all. External examining is one of the most fundamental (if perhaps least understood by non-specialists) elements of UK higher education. There should, really, be detailed regulatory support (and indeed requirements) for the practice – there should be (as Dearing called for) a national college of external examiners with the support of professional bodies where relevant. There should be mandatory training courses.
QAA says that:
Further advice to support institutions and externals in implementing these principles and reviewing their own external examining policies and practices is under development and will be made available in autumn 2022.
For the moment we have a very simple and straightforward list of principles, covering both the conduct of the external examiner and the institution at which they are examining. Most providers should be doing this stuff already, but we do now have it in writing at least.
“It is they who determine whether a course can be said to reach equivalent standards to similar courses elsewhere in the sector.”
This is a great theoretical ideal but the practice is somewhat different. More and more Universities simply do not act on what the EE says – you can make the same comments year after year to no real impact.
Any similarities to previous chapters of the UK Quality Code entirely incidental … More seriously it’s another example (subject benchmarks, review of Transnational Education) of the English sector needing to fill gaps left by the official regulator, given the ‘distinctive’ approach OfS is choosing to take to academic quality and standards. While in some ways it’s good to see the sector stepping into these gaps, it does point to the significant problems with the current official regime.
There’s a fair few references to external examiners in the OfS analysis and response to their B Conditions consultation (March 2022), where the OfS notes that “By not referring to external examiners or other reference
points in our requirements, we are providing a significant opportunity for high quality providers
to dismantle complex internal processes that may have accreted over many years and may
have resulted in gold plating of their approaches” which is pretty clear if not as explicit as they’ve been in person, where they’ve straight up said that external examining is unnecessary gold-plating that they do not wish to see.
Given that external examiners are (a) useful and (b) not especially burdensome as bureaucracy goes, the QAA statement is good to see.
Although the OfS’s conditions of registration do not mandate the use of external examiners, lying beneath the DAP criteria, which I believe all OfS-registered degree-awarding bodies are assumed to fulfil on pain of losing degree-awarding powers, is evidence requirement B3o: ‘The organisation makes scrupulous use of external examiners including in the moderation of assessment tasks and student assessed work.’
I remember when OfS was established lots of people asked ‘where has the Quality Code gone’ given the way the Quality Code was gutted in the revisions of 2018. Someone said ‘it’s all still there, it’s in the DAPs criteria’ and it is. What I’m less convinced about is the claim we have to meet these on an ongoing criteria. As Andy says, senior figures at OfS have been encouraging established providers to ditch external examining claiming it’s gold plating that OfS doesn’t require.
OfS Regulatory Advice 17 says HERA gives the OfS express powers to revoke any form of DAPs authorisation that has been granted to a provider irrespective of how it was granted, under three conditions. Condition B relates to concerns regarding the quality of, or the standards
applied to, higher education which has been or is being provided by a provider. Under this condition, HERA requires the OfS to seek advice from the DQB before making an order to revoke a DAPs authorisation. The DQB’s assessment will include the provider’s ongoing compliance with the DAPs criteria. So, if an awarding body ever found itself in a position where the OfS was considering revoking DAPs, my reading of the Regulatory Advice is that the body better demonstrate it meets the criteria.