Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“At the time of the site visit the

agency’s website was under development, and the access to all reports was

not possible. The Committee noted that the website was still not upgraded

and fully functional at the time of taking the decision - almost one year after

the panel’s visit. This circumstance prevented the Committee from verifying

whether all the reports are publicly available. The Committee

concurred with panel’s conclusion of partial compliance.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.3 Independence
Keywords	Operational independence; Independence of formal outcomes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Committee learned that both the president and the vice president

of KAZSEE have voting rights in the two bodies in which they are members

of, i.e. the Accreditation Council and the Supervisory Board. In panel’s view

the “mixture of roles [of the President and the vice President] could make

the [decision making] system vulnerable”. The Committee could follow panel’s reasoning that the current

arrangements could pose threat for the operational independence and the

independence of formal outcomes.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.4 Thematic analysis
Keywords	Performing thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The agency does reports covering different

topics – however they are mostly related to projects, rather than findings

from the external quality assurance activities. The panel further highlighted

that the agency is aware of the importance of collecting and analysing data

from the review processes for its own development purposes, but also for

contributing to the system level policies. The Committee acknowledged that while the thematic analyses are

not taking place in a systemic and formal manner, KAZSEE is a relatively

new agency that demonstrates interest to further formalise the processes

for producing thematic analyses.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.6 Reporting
Keywords	ex-post accreditation, Technical Committee, experts reports
Panel conclusion	Compliance
Clarification request(s)	Panel (13/02/2023)
RC decision	Partial compliance

“10. The Register Committee noted that the responsibility for the preparation of the external review reports for the monitoring and ex-post accreditation of study programmes is with the Technical Committees.

11. The Register Committee noted that the experts’ site-visit reports were not part of the final external review report and they were only available for the analysis of the Technical Committees. The Register Committee could not understand why the experts reports (in the case of the monitoring and ex-post accreditation of study programmes) is not published as well and therefore asked the panel for further clarification.

12. The panel explained (see minuted clarification 2023-02-13) that the practice of having a committee develop these reports is common among all Spanish QA agencies and it ensures the consistency of reports.

13. The Register Committee further asked the panel to clarify the forms of factual and non-factual allegations made by institutions on the reports of the Technical Committees. The panel explained (see minuted clarification) that the allegations have always been focused on the technical part of the reports (factual comments). However, the panel added that the agency should clearly differentiate within its procedure that the allegations deal only with factual errors and do not address diverging views and opinions on the statements and assessments taken in the report.

14. While the Register Committee welcomed the use of a Technical Committee to ensure consistency, the Register Committee could not follow the reasoning of not including or separately publishing such reports (i.e. as an annex). The Register Committee underlined that it can be of interest for the public to know the basis on which the final reports are being developed. In particular, such information is important to ensure the transparency in the Technical Committee’s decision making.

15. The Register Committee therefore could not follow the panel’s conclusion on the compliance with the standard, but concluded that ACCUEE complies only partially with ESG 2.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.7 Complaints and appeals
Keywords	allegations, appeals, complaints
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. The Register Committee noted that the agency defines three different processes for allegations, appeals and complaints.

17. The allegations (considered as a form of feedback opportunity for the institutions) are dealt with by the Technical Committees, who is also responsible for drafting the reports (see also under ESG 2.6).

18. The appeals and complaints procedures are defined by law and are under the legal competency of the Canary government.

19. The Committee noted, that ACCUEE’s appeals and complaints policies are limited as the agency does not have its own appeals and complaints processes or a separate body in considering complaints or appeals.

20. The Committee considered that external quality assurance processes should always include an internal possibility to appeal and complain with the responsible body that carried out the review itself.

21. The Register Committee noted that ACCUEE intends to appoint an independent and permanent body, Guarantee Commission that will consider all appeals and complaints related to all procedures that are in the scope of the ESG.

22. The Register Committee welcomed ACCUE’s intention to set up a separate body to handle appeals and complaints, but the Committee underlined that such changes are yet to be implemented and to be reviewed. The Register Committee therefore concurred with the panel that ACCUEE only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	3.3 Independence
Keywords	regional government representation, Governing Board, Technical Committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. In regards to organisational independence, the Register Committee noted that the Governing Board, the body responsible for the approval of accreditation methodologies and criteria, has a strong regional government representation, with one third of the members nominated by the regional ministry The Committee further noted that the regional ministry is also responsible in appointing the president and vice-president of the Governing Board.

24. The Committee further noted that the regional government directly appoints the Director of the agency. The Committee found this problematic given the Director’s responsibility in ensuring the independent operations of the agency and in chairing all of the agency’s Technical Committees for ex-post accreditation of study programmes.

25. The Committee further noted that the agency is limited in its recruitment processes as this responsibility lies with the regional government (review report, p. 27).

26. Given the close link to the regional government, the Committee shares the panel’s view that ACCUEE should (in consultation with the regional Government) amend the current processes regarding the appointment of the Director as well as the legal frameworks definition on the composition and the proportion of governmental members in the Governing Board and ensure the recruitment processes are under the competency of the agency.

27. The Register Committee welcomed ACCUEE’s plans for addressing the panel’s concerns, but the Committee underlined that these changes are yet to be fully enacted. The Register Committee therefore concurred with the panel that ACCUEE only partially complies with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.3 Implementing processes
Keywords	study programme groups
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee found the difference between the initial and re-assessments of study programme groups on the one hand and the phasing out of assessments of study programme groups on the other hand not to be completely clear.

The agency explained (see clarification of 2023-06-06) that the initial and re-assessment procedures remain compulsory for the opening of any new study programme groups. For existing study programme groups that have gone successfully through multiple assessment processes, the assessments of individual study programme groups are being phased out for a sample of these programmes, within the new model for institutional accreditations.

Having considered the agency’s explanation and the implementation of the new procedures, the Register Committee concurs with the panel’s conclusion of compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	3.5 Resources
Keywords	state budget
Panel conclusion	Full compliance
Clarification request(s)	Agency (06/06/2023)
RC decision	Compliance

“The Register Committee noted that the proportion of HAKA’s activities financed through state budget has been decreasing. This is caused by the fact that HAKA has taken on activities for other education levels/types not falling under the ESG, which are financed through projects.

The Register Committee understood from the agency’s clarification (see minuted response of 2023-06-06) that the financial concerns do not affect the agency’s ability to carry out its regular external QA activities.

The Register Committee therefore concluded that the agency continues to comply with ESG 3.5.”

Full decision: see agency register entry

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	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.4 Peer-review experts
Keywords	Student involvement in panels
Panel conclusion	Non-compliance
Clarification request(s)	Agency (14/02/2023)
RC decision	Partial compliance

“Further efforts made by the

agency to engage students in the review panels - in particular

students have participated in the first reviews by the time the Register Committee analysed the application. While the panel’s

conclusion of non-compliance did reflect accurately the situation at the

February 2022’s site visit, the Committee concluded that the agency is now

partially compliant with the standard. The Committee, however, underlined

that further evidence of the actual involvement of the students in the panels

will be needed and has to be thoroughly analysed in the next review of HAHE”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.7 Complaints and appeals
Keywords	Independence of the appeal's body
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel argued that there was “no avenue available to have an

external review of a decision” and noted the “absence of external

adjudication in the mechanism used”. The Register Committee expects that

an appeal is considered by another body than the one whose

decision/report is appealed (see interpretation 13 of the ESG); this will

nevertheless normally be a body of the agency, as the standard requires an

internal appeals process (see also interpretation 12 of the ESG). As the

HAHE appeals committee consists of different persons than the (current)

EAC, this requirement is formally fulfilled, even if HAHE may reconsider the

practice of appointing only retired EAC members when it reviews its

appeals procedures as recommended by the panel, Further, the fact that the appeals' committee makes a recommendation to the

EAC is compatible with EQAR's expectations (see interpretation 14 of the

ESG).”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	3.4 Thematic analysis
Keywords	Content of the thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“From several Annual reports of the agency from recent years, the Committee learned that the agency provides key figures on its work, but

also provides an in-depth overview of the compliance levels per standard in the undertaken accreditation procedures, summarises the good practices and obstacles observed in HEIs, and presents the most common recommendations by the panels.Following this, the Register Committee found that the current practice fulfils the minimum ESG criteria”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	2.5 Criteria for outcomes
Keywords	Methodology and criteria for the different re-accreditation period inconsistent
Panel conclusion	Compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“12. The Committee noted from the panel’s report that it is now clear what level of compliance a programme must achieve to receive the full 8-year accreditation period. At the same time, the definition of shorter accreditation periods remained unclear: the panel also confirmed in its clarification that there are no specific criteria or guidelines that determine by how much the period gets shortened.

13. In its additional representation the agency explained its methodology and criteria for the different re-accreditation period. While the Register Committee found a clear reasoning in the agency’s response, the Committee could not understand why the cited information (i.e. table and explanation provided) was not integrated in the agency’s procedures i.e., Accreditation Procedures and Standards. In particular, the Committee found the provided information on the length of the accreditation cycle i.e., of five years, to be completely missing from the agency’s procedure for re-accreditation (see Accreditation Procedures and Standards 5.3 – November 2019 Section 3.2.4.2.1).

14. Given the inconsistencies in the agency’s explanations and the presentation of ECTE’s criteria in its own procedures, the Register Committee was not persuaded that the agency ensured a consistent application of its criteria in its decision making.

15. The Committee also considered that this issue was amplified by the fact that there is no decision document (see also ESG 2.6), i.e., the Quality Assurance & Accreditation Committee’s (QAAC’s) considerations and argumentation on why a certain length of accreditation period was decided are currently not recorded in any public document.

16. The Register Committee thus remained unable to concur with the panel’s conclusion, but considered that ECCE only partially complied with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	2.6 Reporting
Keywords	Publication of Accreditation Decisions
Panel conclusion	Compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“17. The Register Committee noted that the decisions of the Quality Assurance & Accreditation Committee’s (QAAC) are published only in the form of the accreditation period being presented on the web page listing accredited programmes (https://cce-europe.org/index.php/accredited-institutions.html). The list contains links to the expert review reports, but not to the QAAC decision as a separate document or similar.

18. The standard requires that “if the agency takes any formal decision based on the reports, the decision should be published together with the report”.The Register Committee assumed that a written record of the QAAC decision presumably exists in some form, either as a document sent to the accredited programme or as section in the QAAC minutes. The review panel clarified that it was not aware of the QAAC decision being available a separate document.

19. In its additional representation the agency stated that what is published on its website i.e., the dates of when the institution was first accredited, the most recent decision and the date of when the accreditation runs out represent, next to the generic statement on its website - that a programme meets ECCE’s criteria and standards for accredited status - represents its decision.

20. The Register Committee underlined that the standard aims to ensure reliable documentation and transparency of the agency's outcomes and the mere publication of the date of the accreditation does not suffice.

21. The Committee further disagrees with the agency’s claim that its objection are technical in nature. The Committee emphasised that QAAC decisions are not recorded in writing at all (beyond the dates cited on the web page) and that ECCE does not provide any information to the public on e.g., when such a decision was taken, the basis of QAAC’s decision making, the rationale for QAAC in agreeing/disagreeing with the findings of the panel or any recording of a possible conflict of interests with the institution applying for ECCE accreditation.

22. The Register Committee therefore could not concur with the panel’s conclusion that ECCE complies with the standard, but found ECCE to be only partially compliant.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	no possibility to appeal the formal decisions
Panel conclusion	Partial compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“23. The panel raised concerns about the slight unclarity and overlap between the “appeals and complaints procedure” and the separate “complaints procedure”. Even though the wording is unusual, the Register Committee considered that both appeals and complaints, as understood in the ESG, are generally possible.

24. The Committee obtained clarification by the panel on the composition of the Appeals Committee. Even though the members are different from the QAAC, the Committee shares the panel’s concern that all but one come from the rather small chiropractic community.

25. The Register Committee’s further noted that there is no possibility to appeal the formal decision by the QAAC, only the expert report. The Committee regarded this as problematic given that the QAAC alone decides on the accreditation term.

26. In its additional representation the agency explained that the judgement itself of the QAAC cannot be appealed solely on the basis of disagreement with the decision, but can be made based on incorrect procedures, or if it was executed in an unfair and discriminatory manner. The Committee thus understood that while ECCE makes possible appeals based on procedural error, errors of fact, mitigating circumstances where material was not available at the time and for situation where members of QAAC or ECCE behaved in a discriminatory or unprofessional manner, the agency does not allow for an appeal of QAAC’s judgement itself. The Committee thus finds that the appeals process is limited, given that the reviewed higher education institution may not challenge based on e.g., criteria that may have not been correctly applied or disagreements in how standards were interpreted by QAAC.

27. The Committee noted that the agency considered and upheld an appeal against a QAAC formal decision, but also noted that there is no public documentation on this appeal and that the agency does not have any information on its website on the composition of its Appeal’s Committee.

28. The Register Committee therefore concurred with the panel’s conclusion that ECCE only partially complies with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of student members in the governing/accreditation body
Panel conclusion	Partial compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“29. The panel clarified that ECCE had a clear strategy that guided its work; even if the official documents were sometime incoherent in wording, they were coherent in substance.

30. The panel further clarified that ECCE should have been more attentive and flexible as regards the appointment of a new student member to QAAC. The practice led to a student member being absent from QAAC for some time, which could have been avoided if ECCE had been more concerned to prevent this with priority.

31. Having considered the panel's clarification, the Register Committee was able to concur with the panel's conclusion that ECCE partially complies with the standard.

32. The review report explains that ECCE does not provide consultancy themselves but “offers the names and contact details of highly qualified independent educationalists to new chiropractic programmes to assist them with the development of their programmes” (report, p. 14).

33. While the Register Committee considered that these did not appear to be problematic, it found that this should be discussed in more detail in the next review of ECCE.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	3.3 Independence
Keywords	Overlapping responsibilities between different bodies/ Lack of diversity
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“34. The panel raised issues related to the high involvement of representatives of accredited institutions, amplified by the small size of the chiropractic community, as well as the overlapping responsibilities between different agency bodies. In particular, the panel regarded critically the ex-officio mutual memberships of the Executive Committee and QAAC chairperson in the respective other committee, the involvement of both bodies in the QA process and the close involvement of the QAAC in pre-screening self-evaluation reports.

35. In light of these concerns, the Register Committee concurred with the panel’s conclusion that ECCE only partially complies with the standard.”

Full decision: see agency register entry