Open letter to the British Council

Copies to:

• the organisations owning IELTS


• the British Council in Germany, France and Greece


• the General Medical Council


• the Nursing and Midwifery Council


• the General Dental Council


• the General Pharmaceutical Council


• the European Commission

29 February 2016

Dear Sir / Madam,

RE: Request for a public audit of Academic Writing IELTS results for 2014-15.

On 25 June 2014 the General Medical Council – the medical regulator for the United Kingdom – started to apply its new guidance[1] whereby doctors with European Union rights are required to submit evidence of knowledge of English as a prerequisite for obtaining the licence to practise. What the GMC has since required from the vast majority of EU applicants is an academic IELTS pass with a minimum overall band score of 7.5 and no individual paper marked below 7.0, in the same sitting.

The other major regulatory bodies are following the GMC’s lead, each in their different way. The Nursing and Midwifery Council (NMC) will soon require a score of 7.0 overall plus at least 7.0 in each paper as a requirement for allowing EU professional nurses and midwives to practise in the UK. The General Dental Council (GDC) still licenses EU citizens without requiring proof of English language skills, however, once licensed, most dentists have to apply for a Performer’s Number from the National Health Service, at which point a similar language requirement applies. Finally, the General Pharmaceutical Council (GPhC) is conducting a consultation exercise in the GMC’s footsteps, in order to impose a similar requirement in 2016. Again, Academic IELTS is proposed as the ‘gold standard’.

The British Council’s influence over the policy making of the above regulators has been of great importance, as some of the regulators themselves have publicly acknowledged. For instance, apparently the British Council advised NMC that for an IELTS pass to indicate that language skills have not been eroded by the passage of time (the ‘recency’ check), it should have been achieved less than two years before applying for professional registration as a nurse. This is significant as it creates an ongoing demand for test retakes, adding to the costs incurred by the affected professionals across the European Union, the European Economic Area and Switzerland.

All the above developments have made academic IELTS a virtually compulsory qualification.

We the undersigned are doctors, nurses, midwives and other professionals who are all EU citizens. We have all sat one or more Academic IELTS tests recently, or are booked to take the test in the near future, or are otherwise subject to regulations mandating proof of knowledge of English. We therefore have a legitimate interest in seeking assurances that Academic IELTS tests are functioning in a fair, transparent and appropriate manner that operates in exactly the same way across territories. We therefore believe that the British Council and its IELTS partners should be concerned to consider and provide a full, public, comprehensive and swift reply to the following pertinent concerns. In particular, we hope that the voice of the examiners and principal examiners for IELTS will reach us with unfiltered clarity and based on evidence.

Issue 1 – The significance of a 6.5 score

Time and again the GMC has rejected doctors’ applications for a licence to practise because their Academic IELTS passes were a mere 0.5 short of 7.0 in Academic Writing. NMC and possibly GPhC are likely to adopt an equally rigid policy. This is supported by empirical observations but also is strongly suggested by the combined consideration of the limited statistics published for Academic IELTS tests sat in 2014. Specifically IELTS.org has published the following:

• A 6.5 was achieved by 19% of the Academic candidates whose reason was “Registration as a doctor”. The most common score was 7.0 (24%).


• A 6.5 score was achieved by 25% of the Academic candidates whose reason was “Registration as a nurse”. This was the second highest behind 7.0 (26%).


• A 6.5 score was achieved by 15% of the Academic candidates whose reason was “Registration as a dentist”. This was the second highest behind 7 and 7.5 each of which was achieved by 18% of test takers.

In addition it is worth noting that:

• Academic Writing has the lowest mean score among all four papers in every country of origin in the top 40 for 2014. For instance Germans score an average 6.6, the French score 6.1 and Greeks score 6.0, to take three of the top 40 places of origin and the only EU countries to feature in the top 40 except for the UK. Test takers in the UK score an average 6.5.

Academic Writing is therefore a pivotal paper and deserves more focused attention.

Although published data is welcome, we think that the currently available data leaves gaps and questions that are unanswered, and far more analysis is needed to help a professional in planning their English learning and examinations. Further, the data is currently presented in a manner that does not allow meaningful correlations to be made which could help improve local and regional examination and marking processes. We as potential test takers must make justified decisions that lead to professional improvement. Therefore, in the interests of transparency and public accountability and to further boost the reputation of IELTS globally, we kindly ask you to:

1. compare and publish the Academic Writing scores in tests sat prior to 24 June 2014 with those sat after 25 June 2014 by doctors, nurses, midwives and dentists. To narrow this down, we kindly request that this is done for EU countries of origin only.


2. publish and explain a representative sample of examiners’ comments from specific anonymised tests from Germany, France and Greece where the candidates were marked 6.5 in Academic Writing papers since 1^st January 2014.


3. declare and quantify which and how many test centres were required to provide a sample of examiners’ marked scripts for second marking by principal examiners since 25 June 2014, the EU countries involved, and if possible the key outcomes.


4. explain how and how much “targeted sample monitoring” was applied and when exactly in 2014-15 in order to identify “possible faulty ratings”.


5. present in detail the amount and type of “face-to-face training”, “retraining and recertification” that IELTS examiners based in EU countries undertook during 2014 and 2015.

(All quotes taken from IELTS.org on 7 November 2015.)

Issue 2 – The need for more structured guidance on improving Academic Writing performance

As planners, educators and administrators of the IELTS system you have a pedagogical duty to provide appropriate support and guidance for participants in the process. In addition to this, there are serious financial and time implications for us all. We are all busy professionals, students, husbands, wives, parents and grandparents. We have no time to waste in resitting exams – let alone paying expensive tuition and examination fees – and our personal and family budgets are stretched, often to the limit. We have a duty to focus on serving our patients and the public, not on retaking tests ad infinitum. We therefore ask the IELTS partners to go well beyond simply suggesting a reading list of prep material or promoting prep courses.

IELTS examiners should know very well where the common weak points are with respect to Academic Writing. They have access to hundreds of thousands of recent scripts. You could easily publish some of these in textual or visual formats to help us and all our colleagues who will take the test in future to prepare better and at less cost. In this way you would also be helping us make informed choices about what to improve, how to improve and who to consult.

Last but not least, a publicly available and well-organised body of material with clear examples of good and bad practice would spare us the agony and disappointment of missing out on life-changing job and training opportunities often for just half a point.

Yours faithfully,

[1] “Evidence of English language skills: Guidance for European doctors applying for a licence to practise.” Guidance made under s29G (2A) of the Medical Act 1983.