You need to be sure he is really bending his planeline and swinging inside out or if he is simply swinging on a flatter plane angle. Big difference that needs to be checked. His problems could be an issue of clubface control and not plane.
Other than video what's the easiest way to verify this? As I mentioned, I'm working on this very issue and have diagnosed it as a plane problem. The only way I know to check this without video or a plane board is to do some mirror work and some slow motion swings to see what's going on.