A clear analysis of the role of the facilitator in MFHEA processes, including institutional responsibility, organizational autonomy and the correct use of external consulting support.

In recent months, the role of the facilitator within MFHEA procedures has attracted renewed attention, particularly in the context of External Quality Assurance (EQA) audits and accreditation processes.

As the regulatory framework evolves and interpretative clarifications are issued, institutions are increasingly required to distinguish clearly between institutional responsibility, official representation and external technical support. This article aims to provide a structured and updated analysis of the facilitator role within MFHEA processes, taking into account both the accreditation guidelines and recent clarifications issued by the Authority.

Institutional responsibility and official communication

A foundational principle of the Maltese quality assurance framework is that responsibility for governance, academic provision, regulatory compliance and internal quality assurance rests unequivocally with the institution itself. This principle is fully aligned with the European Standards and Guidelines (ESG) and underpins all MFHEA interactions.

Recent clarifications from MFHEA have reaffirmed that all official engagement with the Authority must be conducted through a member of the institution’s internal staff who possesses direct and operational knowledge of the institution. Institutional representation, regulatory accountability and formal liaison with MFHEA cannot be delegated or outsourced.

This clarification does not prohibit the involvement of external consultants. Rather, it reinforces the expectation that internal institutional representatives remain visibly and substantively responsible for all official communication and regulatory accountability.

Institutions must therefore ensure that their governance and operational structures clearly identify an internal official contact person for MFHEA interactions, particularly during audit procedures.

The facilitator: procedural coordination and technical supportt

Within the accreditation guidelines, the facilitator is described as a procedural and administrative coordination function during accreditation and audit processes. Traditionally, this role has focused on:

• coordinating documentation,
• managing timelines,
• supporting internal preparation,
• ensuring orderly interaction with review panels.

The facilitator is not defined as a governance organ nor as the holder of regulatory responsibility. Rather, it is a supportive function designed to assist the institution in managing complex procedural requirements.

In light of recent MFHEA clarifications, it is important to distinguish between:

• the official institutional liaison, who must be internal staff and retains formal representation and accountability; and
• the facilitator, whose function remains technical and procedural in nature.

Where institutions engage external expertise, such support should operate in a clearly defined advisory capacity, without replacing or appearing to replace internal institutional authority.

Organisational structures and good operating practices

For education providers, the current regulatory environment requires structured organisational clarity. A compliant and robust model typically includes:

• an internal staff member formally designated as official liaison with MFHEA;
• clearly documented internal governance and quality assurance structures;
• external advisory support, where appropriate, operating within a defined technical remit.

The use of an external External Quality Advisor can significantly enhance procedural robustness, audit preparation and regulatory alignment, provided that the boundaries of representation and accountability remain unambiguous.

This balanced configuration allows institutions to demonstrate genuine internal capacity while benefiting from specialised regulatory expertise.

Final thoughts

Strengthening internal institutional capacity is fully compatible with the use of external expertise, provided that roles and responsibilities are clearly articulated and transparently applied.

Institutional accountability, knowledge and formal representation must remain internal. At the same time, structured technical advisory support can play an important role in ensuring that institutions approach MFHEA procedures with clarity, coherence and regulatory awareness.

For providers navigating accreditation, reaccreditation or EQA audits, the key challenge is not whether to rely on internal or external resources, but how to integrate both within a compliant and well-governed organisational model aligned with MFHEA expectations.

Institutions seeking structured regulatory support, while maintaining full internal accountability, may contact Malta Quality Education for tailored advisory assistance in its capacity as External Quality Advisor.