LONDON’S GLOBAL UNIVERSITY
Universities UK, Guild HE, Quality Assurance Agency discussion paper on the review of
external examining arrangements – response from UCL
UCL welcomes the opportunity to comment on the discussion paper. Our responses to each of the
questions can be found below.
Principle 1: In the UK system each institution has responsibility for setting the standards of
its awards within the context of common guidelines, and subject to audit/review by an
independent agency. This should continue to be supported and strengthened. External
examining is only one part, albeit a very important part, of this system.
Principle 2: Institutional Audit/Review is an important mechanism for testing whether
external examining is working in practice and external examining arrangements should
remain one of the key areas for Institutional Audit/Review and a critical system in
determining the outcome of Institutional Audit/Review.
Principle 3: More should be done to articulate, explain and promote the role of the external
examiner. More nationally consistent, developed and supported external examining
expectations would improve the effectiveness, transparency and credibility of the system,
especially with external audiences.
Question 1: Are these principles acceptable and are there other principles that should be
considered?
On the whole these principles are acceptable to UCL. We endorse Principle 1, which emphasises
the importance of the external examiner system as part of a broader set of robust and
comprehensive institutional quality assurance mechanisms. Regarding Principle 3, it is vital that
any nationally consistent external examining expectations should not be overly prescriptive and
should be sufficiently flexible to encompass the rich variety of assessment methods which are
used across disciplines.
Question 2: Are these initial ideas and the distinction between judgement and advice a
helpful starting point for developing minimum expectations? Where might these initial
ideas be clarified or developed to ensure that it is relevant to all institutional practices?
UCL strongly endorses the points made at paragraph 31 of the discussion paper, in particular the
view that the principal role of the external examiner lies in contributing to the maintenance of
academic standards and that responsibility for the setting of academic standards rests primarily
with the awarding institution.
We feel that the ideas outlined in this section of the discussion paper are a helpful starting point
for developing minimum expectations. However, in developing such minimum expectations it will
be important to ensure that they are sufficiently flexible to allow for diversity.
1
Question 3: In order to increase transparency and public confidence there should be clear
expectations about the selection processes in institutions and the process should be
publicly accessible, do you agree?
UCL agrees with this proposal.
Question 4: There should be a national set of generic criteria established for the
appointment of external examiners, do you agree? What should be included in the criteria?
In principle, UCL agrees with this proposal, but this will obviously depend on the content of the
criteria. They will need to be flexible and not overly prescriptive in order to guard against the
unintended consequence of appearing overly restrictive and bureaucratic, as this may deter wellqualified potential external examiners from undertaking the role. If a sensible way can be found of
making explicit what is currently implicit regarding the acceptable levels of expertise required to
undertake the role of external examiner, then UCL would welcome this.
At UCL, we have increasingly used external examiners from outside the UK as these individuals
can provide a fresh and valuable perspective. However, one omission in the paper is that it does
not make reference to the considerable practical difficulties in appointing overseas external
examiners resulting from (i) the requirements of the Points-Based Immigration System and (ii) HM
Revenue and Customs regulations regarding the payment of external examiners. UCL would, in
particular, welcome a change to HMRC regulations so that external examiners of undergraduate
programmes can be paid as consultants and paid on submission of an invoice for their services,
as is currently the case for external examiners of research and taught masters programmes.
Question 5: Should all institutions provide induction for external examiners who are new to
the institution, and training and development for first time external examiners? Should a
common core programme and template for induction and training be developed?
While UCL feels that it is important that external examiners are provided with comprehensive
written briefing material, we do not support the proposal that external examiners should be
required to physically attend a formal programme of induction here at UCL. If appointment criteria
are robust, selection processes sufficiently thorough and full briefing material provided, then
induction or training is unnecessary. New external examiners will also usually have the opportunity
to learn from existing externals. The obligation to attend formal induction, development and
training events may well deter busy potential external examiners and would not be resourceneutral for the institution. Nor, therefore, would we support the proposal for a template for
induction and training.
Question 6: The importance of this role should be recognised by all universities and
institutions with degree awarding powers in promotion procedures, including clear and
demonstrable recognition of the value to the institution, the subject and the sector, do you
agree? How else should it be recognised?
UCL agrees that the role of the external examiner is of considerable importance and agrees that
consideration should be given to ways of improving institutional recognition of this role.
Question 7: Should there be a national template for external examiners reports?
In principle, UCL considers that this is a good idea, provided that the template is not overly
prescriptive and sufficiently flexible that it can be built upon as necessary to reflect institutional and
subject-specific requirements.
Question 8: Should there be a specific section written for students and should this be
made available to all students within the institution, and made available to any external
party on request?
UCL’s view is that the creation of a student-specific section in the external examiners’ report and
the proposal that this be made available to all students within the institution are unnecessary. (See
also our response to Question 9 below.)
2
With regard to access to external examiners’ reports by any external party on request, UCL has
issued guidance to external examiners indicating that their reports may be given to third parties as
a result of freedom of information/data protection requests. This is brought to their attention at
appointment. If an external examiner raised an objection to this, UCL would not be able to employ
them.
Question 9: Should all reports and all analysis of reports be shared with student
representatives?
We have discussed the issue of whether students should receive full external examiners’ reports
and analyses of reports previously within UCL. On each occasion, student representatives and
officers of UCL [students] Union have advised us that students find the sharing of external
examiners’ reports a more useful process when they are able to see the specific comments which
external examiners have made and the departmental responses which have been made to the
external examiners’ comments, rather than just receiving the full report. Therefore, and with the
agreement of all parties, the summary reports from Chairs of Boards of Examiners (rather than the
full external examiners’ reports) are shared with all students via Departmental Teaching
Committees and Staff-Student Consultative Committees.
Question 10: Should all institutions publish names of all external examiners, their job titles
and institutions? What would be the most effective way of ensuring that this information is
easily accessible?
No. UCL would be very concerned about any requirement that the names, job titles and institutions
of external examiners be published as there would be a risk that:
(i) security for staff working in sensitive subject areas might be compromised;
(ii) students might write directly to the external examiner with complaints or grievances or prior to
decisions on awards and mark processing;
(iii) external examiners might be less inclined to make candid comments on assessment and
academic standards;
(iv) concerns about (i) (ii) and (iii) might create an additional barrier to external examiner
recruitment.
Question 11: Institutions should have in place transparent internal procedures for
considering and dealing with robust discussion of issues and concerns which include the
possibility of making a report direct to the head of an institution. Do you agree and what
else might these procedures include?
We agree that there should be transparent internal procedures. UCL has in place a clear, tiered
structure, where issues or concerns raised by external examiners can be referred upwards along
our pyramidal structure of boards of examiners, from the Board of Examiners of the reporting
Department, to the Faculty Board of Examiners, to the UCL Board of Examiners, and ultimately to
UCL’s Academic Committee. If necessary, issues can then be referred upwards to, or directly to,
UCL’s President and Provost, as head of the institution.
Question 12: Should there be a clear and independent mechanism for external examiners
to use once they have exhausted internal procedures? Does the QAA Causes for Concern
procedure represent an appropriate mechanism?
We endorse the principle that there should be a clear and independent mechanism for external
examiners to use once they have exhausted internal procedures and that the QAA Causes for
Concern represents an appropriate mechanism.
3