Database of Precedents

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	coverage of ESG Part1
Panel conclusion	Compliance
Clarification request(s)	Panel (10/02/2023)
RC decision	Compliance

“11. The Register Committee noted that a protocol for the assessment of transnational education in the Netherlands (NL) came into effect in

2018. The Committee however could not find any information on whether NVAO-NL has addressed the standards of ESG Part 1 (ESG 1.1-ESG 1.10) in its new protocol and has therefore sought further clarification from the panel.

12. The panel explained (see clarification letter) that a transnational education programme may be provided on the condition that the programme abroad is equal to the one accredited in the Netherlands. This may only concern programmes that have already been accredited in the Netherlands. Given this condition, the review panel explained that the study programmes abroad follow the same accreditation protocol as the programmes accredited in the Netherlands.

13. The Register Committee understands that ESG Part 1 has been verified by the panel for the renewed 2018 NVAO-NL assessment framework and noted that a clear link between the institution’s internal and the NVAO’s external quality assurance procedures was ensured.

14. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standards 2.1.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	2.5 Criteria for outcomes
Keywords	deviation from the outcome of a panel’s report
Panel conclusion	Compliance
Clarification request(s)	Panel (10/02/2023)
RC decision	Compliance

“15. The Register Committee noted that NVAO-NL may modify a recommendation for a positive outcome in a panel report, although it has never so far questioned this. The Committee was unclear on the situations that may lead to a deviation from the outcome of a panel’s report and whether such deviations are documented.

16. In its clarification response (of 10/02/2023) the review panel explained that NVAO-NL may occasionally seek additional information from panels and in a limited number of cases, and after due deliberation may expand conditions or deviate in a minor sense from the panel’s advice. Such changes may be done by NVAO-NL to reduce the subjectivity of reports and ensure the consistency of recommendations as well as of the final outcome. Deviations from the final recommendation of the panel have not happened yet, but according to the agency’s procedure these changes are documented in the final published decision by NVAO-NL.

17. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standard 2.5.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	2.6 Reporting
Keywords	readability of reports, delay in publication
Panel conclusion	Compliance
Clarification request(s)	Panel (10/02/2023)
RC decision	Compliance

“18. In its previous renewal decision, the Register Committee stressed the delay in NVAO’s publication of reports and noted issues related to the readability of reports.

19. The panel’s findings show that NVAO has since its last review introduced instructions and templates for reporting and that the readability of submitted initial assessment reports is also checked by NVAO. The panel further confirmed that the publication of reports was done without any more significant delays, but suggested setting up an automatic uploading system of NVAO-NL reports (as it is done for NVAO-FL).

20. The Register Committee welcomed the improvements in the agency’s reporting and concurred with the panel’s conclusion that NVAO now complies with the standard 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	separation between activities that are within and outside the scope of the ESG
Panel conclusion	Compliance
Clarification request(s)	Panel (10/02/2023)
RC decision	Compliance

“21. In its Terms of Reference for the review the Register Committee asked the panel to consider how the agency clearly separates between activities that are within and outside the scope of the ESG, in particular considering the ‘Assessment of Quality Agreements in the Netherlands’ and the ‘Assessment of the quality of Training Schools’. While the panel concludes that there is a clear separation between NVAO’s activities within and outside the scope of the ESG, the Committee could not find the argumentation to support the panel’s conclusion and has therefore sought further information.

22. In its response (see minuted conversation), the panel explained that the separation between the agency’s activities that are within and outside the scope of the ESG did not pose any concern.

23. Considering the Assessment of quality agreements in the Netherlands the panel stated that the activity does not address the teaching and learning aspects within higher education and that the focus of the assessment is on how institutions (plan to) spend the so-called study advance grants. The panel added that the agency’s protocol or description does not misrepresent the activity in any way (i.e. referring to ESG or EQAR registration).

24. Considering the evaluation procedure for teacher training schools, the panel clarified that the activity does not address or evaluate the teaching and learning in higher education, but it assesses the collaboration between schools for primary and secondary education and institutions for teacher training.

25. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standard 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	2.5 Criteria for outcomes
Keywords	lack of consistency, unclear understanding of multi-level compliance scale
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8.The panel considered that SKVC's criteria are lacking clarity, especially with regard to the exact understanding of the 5-level scale used by SKVC. The panel recommended developing guidelines for interpretation of each level to enhance consistency of their use.

9.The Committee understood that the current situation as described and analysed by the panel might lead to a lack of consistency.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	2.7 Complaints and appeals
Keywords	lack of internal appeals process for HEIs in exile
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. The Register Committee shared the panel's reservations that the inability for higher education institutions in exile to use SKVC's internal appeals process is a shortcoming.

14. Given that this only concerns one single institution at the moment and no accreditation has taken place so far, the Committee, however, did not consider this shortcoming material enough to influence the conclusion per this standard and concurred with the panel's conclusion that SKVC complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	3.3 Independence
Keywords	involvement of ministry in accreditation of HEIs in exile
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. The review panel noted some concerns about the process of ex-post accreditation of higher education institutions in exile, especially given the direct involvement of the Ministry of Foreign Affairs in the evaluation, i.e. certain standards being assessed by the Ministry instead of the panel of experts.

16. The Register Committee considered that the rationale might lie in the obvious political and diplomatic dimensions involved and that this might justify distributed responsibilities in principle. The Committee, however, considered that it must be transparent to the public what is an assessment made by SKVC and its independent expert panels, and what part of the assessment is made by the Ministry, potentially taking into account political considerations. The Committee recommends that SKVC and the Ministry explore how to disentangle political/diplomatic considerations and quality assessments fully, e.g. by having the Ministry make a separate assessment and decision either preceding SKVC's quality assessment, or following a decision by SKVC.

17. Given the rare occurrence of these procedures and the brief analysis by the panel on the matter, the Register Committee was unable to draw a definitive conclusion; the independence and transparency in these procedures should thus receive close attention in SKVC's next review.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	3.5 Resources
Keywords	reliance on temporary funding sources, state budget allocations insufficient
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The panel discussed SKVC funding, relying on sources from several channels. In particular, SKVC's activities still partly depended on EU structural funds, which are temporary by nature. The panel further noted that the funding from Lithuania's state budget seemed to be insufficient to support the agency's activities sustainably.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	2.1 Consideration of internal quality assurance
Keywords	how ESG 1.9 is addressed in AQU’s activities
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that in the implementation of ESG 1.9 the review panel considered how AQU’s different activities address the cyclicity of external reviews. The Committee, however, underlined that the focus of the standard is on the monitoring and periodical review of programmes as part of the institutions internal QA, ensuring that objectives set for the programmes are achieved and that monitoring processes lead to the continuous improvement of the programme.

Given that the Register Committee was unable to draw a definitive conclusion on how ESG 1.9 is addressed in AQU’s activities, the issue should thus receive close attention in AQU’s next review.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	2.6 Reporting
Keywords	publication of reports from ex-ante accreditation
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous renewal decision, the Register Committee noted that AQU publishes all reports except those from ex-ante evaluations that result in a negative accreditation decision. The review panel reports that AQU now publishes all review reports, independent of their outcome. The Committee also noted that reports with a negative ex-ante accreditation outcome are released with an initial page warning that the degree will not be taught. While the practice of publishing ex-ante reports with a negative outcome was originally met with unease by the institutions whose study programme was rejected, there now is an agreement within AQU on the value of ensuring accountability and trust in the whole system. In relation to the AQU reports for the ex-ante accreditation of short learning programmes (SLP) and micro-credentials, the Committee noted that the agency struggles in scaling the demands of accrediting such programmes, in particular ensuring the proportionate length and detail in its reporting. The Committee underlined the panel’s suggestion on expanding the level of detail and analysis in reports for SLPs to facilitate the usability by various stakeholders and to reflect the detailed evaluation work of the experts. Having considered the change in practice in the publication of negative ex-ante reports, the Register Committee concurred with the panel’s conclusion that AQU now complies with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	3.3 Independence
Keywords	composition of governing bodies; independence of the appeals process; financial independence
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision the Register Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies. The review panel found that AQU has separated the membership of its strategic and oversight bodies from its specific commissions and review panels. The Register Committee welcomed these changes, including the appointment of two non-local members to the Appeals Committee, but noted that the Chair of the Appeals Committee is a member of the Governing Board. While the role of the members in the Governing Board is limited to the strategic decision-making and management of the organisation, the Register Committee found that the involvement of a representative of the Board (in particular as a Chair) in the Appeals Committee might put undue pressure in the discussion and decision-making of the Appeals Committee. The Register Committee nevertheless agreed that the Appeals Committee was sufficiently independent given that the AQU’s Governing Board does not adopt the reports or decisions that are being appealed. The Register Committee further noted that AQU’s funding comes primarily from the Government of Catalonia (about 90% of the agency’s budget) and is allocated on an annual basis. The Committee welcomed AQU’s plans to move to a four-year contract with the Government of Catalonia, which could further improve its operational independence. Considered the steps taken to separate the membership of the agency’s strategic and oversight bodies, the Register Committee could follow the panel’s conclusion that AQU now complies with the standard ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee and limited coverage of appeals
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (07/12/2021)
RC decision	Compliance

“In its decision of rejection (of June 2020), the Register Committee noted that AKAST’s appeals and complaints procedure did not cover the peer institutional evaluation procedures and that the appeals were only considered by the same committee that also took the appealed decision. While AKAST agreed to revise its procedure and to establish a complaints committee consisting of independent members, the Register Committee remained unable to follow the panel’s judgment of compliance since the procedure was not yet in operation and the committee handling appeals has not been elected. 8. The panel notes that AKAST has now a revised complaints and appeals regulation and has elected a Complaints Committee at the AKAST General Meeting on 28/01/2021. In the description of the provisions for complaints (AKAST Complaints and Appeals Regulations as amended on 28/01/2021), the agency noted that the Complaints Committee’s statement is to be taken into account in the final decision of the Executive Board or the Accreditation Committee and that further details shall be regulated in the rules of procedure issued by the Complaints Committee and approved by the Executive Board.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.3 Independence
Keywords	Independence of formal outcomes
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (07/12/2021)
RC decision	Compliance

“In its past review the Register Committee noted that AKAST was subject to the vigilance of the German Bishops’ Conference and that its influence extended to giving consent for the admission of members of the association and the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and the Board, and the approval of each of the accreditation decision by the member of the Commission for Science and Arts (Commission VIII) of the German Bishops’ Conference. Due to these interlinkages, the Register Committee concluded (see decision of 30/11/2019) that AKAST did not comply with ESG 3.3. The Register Committee in particular found the requirement that each accreditation decision requires the consent of the representative of the German Bishops’ Conference (member of the Accreditation Committee) to be in contrast with the requirement of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.4 Thematic analysis
Keywords	Lack of development in preparing thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. The panel notes that AKAST reliably contributes the experience gained from its own quality assurance procedures to the regular evaluation of the Key Points and that the agency is documenting the results of its ongoing student survey on its website.

18. The Register Committee welcomes AKAST’s plan to further develop a thematic analysis after an appropriate number of programme accreditation procedures have been completed, but underlined that such an analysis has not been finalised.

19. Considering the limited development of thematic analysis, the Register Committee can follow the review panel conclusion that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.2 Designing methodologies fit for purpose
Keywords	no ownership or full responsibility resting with a single actor, consequences for improvement
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Compliance

“9. The panel noted that no actor had ownership or full responsibility for the entire accreditation system and process, since the specimen decree appoints specific responsibilities to both GAC and the agencies.

10. The Register Committee sought further clarification from the panel as to how that impacted continuous improvement and development. The panel noted that opportunities for improvements were discussed actively; the ongoing review of the Specimen Decree was an example of that. The panel, however, saw a lack of GAC itself assuming a more proactive, coordinating role and taking responsibility for the system as a whole; this would be reasonable given its unique and pivotal position.

11. The Register Committee concluded that continuous improvement seems to be ensured despite the distributed responsibilities and thus concurred with the panel's conclusion that GAC complies with standard 2.2; the issues related to GAC's role and strategy are considered under standard 3.1 below.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.5 Criteria for outcomes
Keywords	lack of formal mechanisms for consistency, unclear whether or not consistency improved
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The panel considered critically the lack of formal mechanisms to ensure a consistent understanding and application of the criteria (e.g. guidelines, interpretations or a precedent database made available by GAC).

13. The panel was unable to draw a conclusion whether the post-2018 system – with decisions made by GAC, including the practice to change conditions deviating from the proposal by the expert panels – actually delivered a higher degree of consistency or not.

14. The panel further noted that the current organisation of the Council's work included the risk that analysis of cases might often be “monopolised” in the hands of a single (academic) Council member, while some other Council members are currently not participating in the preparatory work as rapporteurs.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategy not reflecting agency's central role, lack of broad discussions with stakeholders
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Partial compliance

“16. The panel considered that the lack of involvement of stakeholders beyond those individuals who are members of the agency bodies themselves might lead to a lack of critical distance. The panel thus saw a need for more and broader stakeholder feedback, and recommended more regular dialogues with stakeholder organisations on strategic and policy matters.

17. The panel further considered that GAC's strategic planning did not sufficiently reflect its central, pivotal role in the accreditation system (see also the comments under ESG 2.2 above). The panel saw a strong need for a broader discussion with agencies and all stakeholders on GAC’s role in the system and its strategy. In particular in view of the upcoming revision of the

Specimen Decree, the panel found such a discussion was urgent to define a strategy that describes clearly the role GAC plans to assume in the system and its mid-term priorities.

18. While the Register Committee appreciates that GAC has begun to plan a strategy process (see statement on the report), it considered that the panel's analysis under this standard points to important issues in GAC's governance and engagement with stakeholders; these are particularly important in light of GAC's pivotal role in the German system.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.4 Thematic analysis
Keywords	relevance of topics, nature of topics to qualify, regularity and frequency of analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“20. The panel discussed the analyses produced by GAC on various topics, with the most recent ones focusing on conditions imposed on higher education institutions/programmes in decisions by the agencies and by GAC, published in 2018 and 2020 respectively. While the panel questioned whether this was “a crucial topic in the development of the HE system”, the Register Committee considered that such an analysis is certainly based on the general findings of GAC's external quality assurance activities and thus meets the expectation of the standard. Moreover, while the panel did not specifically indicate whether stakeholders found the topic relevant, an analysis of conditions might show how the accreditation criteria resonate with the sector and indicate topics that are typically challenging for institutions and programmes, and hence be relevant beyond GAC.

21. Given the role of GAC as the central body of the German accreditation system, the panel considered that the current publishing rate (one paper per year) was “insufficient”. As the standard remains completely open as to the frequency of analysis, the Register Committee found it an overly strict interpretation of the standard to influence the compliance level on that basis; the remark should rather be seen as a recommendation to publish more analyses.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.5 Resources
Keywords	shortage of staff positions addressed
Panel conclusion	Partial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Compliance

“24. The review panel noted a lack of human resources at GAC's disposal, leading to staff having to prioritise initial accreditation in their work, with reaccreditation procedures taking longer than they should in turn.

25. In its comments on the review report, GAC informed EQAR that a staff increase by 9.25 FTE was now confirmed.

26. The Register Committee sought clarification from the panel on the resources in light of this increase. The Committee understood that this staff increase would address the resourcing in quantitative terms, but that the positive impact of this would remain limited as long as the reservations about the organisation of the Council's work remain, as noted under ESG 2.5.

27. In light of the staff increase, the Register Committee considered that GAC now complies with standard 3.5, while noting that the serious concerns stated under standard 2.5 relate to the question whether GAC effectively deploys its resources, especially in terms of organising the Council's work.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.1 Consideration of internal quality assurance
Keywords	lack of coverage for certain ESG Part 1 standards in international programme accreditation
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Partial compliance

“9. The review report showed that several standards of ESG Part 1 (1.1, 1.4, 1.6, 1.7, 1.9, 1.10) are not addressed in (international) programme accreditation. While HCERES explained to the panel that they adapt their standards according to the foreign context, this creates a situation where a study programme might be accredited by HCERES without having been assessed against the full ESG Part 1.

10. The panel considered that (international) programme accreditations are small in number compared to (national) programme evaluations and other activities of HCERES. The Register Committee, however, considered that the issue at hand is not an occasional or statistical error, but a structural and systemic deficiency for an entire external quality assurance activity of HCERES.

11. As a programme accredited by HCERES will be regarded as ESG-aligned by the public, confirmed by the entry of those programmes in DEQAR, the lack of full ESG Part 1 coverage represents a substantial shortcoming. The Register Committee was therefore unable to concur with the panel's conclusion that HCERES complies with the standard, but concluded that HCERES only partially complies with ESG 2.1.”

Full decision: see agency register entry