Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.4 Peer-review experts
Keywords	involvement of students in ex-ante reviews, weak experts' training
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Since the last review. MAB had not included student reviewers in its ex ante programme evaluations. Also, the panel noted that the trainings for the ex – ante procedures are absent and insufficient”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	Lack of publishing full reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“A consolidated report is published along with the Board’s decision, while the expert review reports are not published,

The agency planned to make these reports public too, but the Committee could not verify without panel insight whether this has been materialised after the site visit.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	strong involvement of the Government in selection of members of some the agency's bodies, lack of clear procedures for selection and dismissal of Board members, lack of safeguarding mechanisms
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“increased involvement of the Government in the selection of the Board members, lack of clear

procedures for the selection and dismissal of Board members and lack of mechanisms safeguarding the agency from the Government’s interference in its work, as well as recent changes for increasing of the role of the Government and the ministry responsible for higher education in selecting and electing key positions and governing bodies”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	implementation of all standards of ESG Part 1 in practice
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“the agency, even though it has formally addressed the ESG Part 1 in its standards, it lacked the practical

implementation in all of its reviews. In particular, comprehensive analysis of higher education institutions’

compliance with ESG 1.1, ESG 1.4, ESG 1.6, ESG 1.7 and ESG 1.9 was lacking in (most of) the reports.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.2 Designing methodologies fit for purpose
Keywords	weak involvement of stakeholders in developing methodologies
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“in practice there is an absence of systematic approaches to involving broader stakeholders in the

developing, updating and reviewing of its methodologies. For example, the Expert Councils, which should act as advisory boards for the development of the methodologies, are not fully embedded in the agency’s consultations and

improvement processes. The councils do not include students”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.5 Criteria for outcomes
Keywords	lack of consistency in the implementation of agency's criteria
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Non-compliance

“Several major inconsistencies were noted by the pane;: (1) the

pre – defined judgements levels were not used by the experts – rather

various judgement terminology was applied in different reports; (2) while

agency’s methodologies have long list of assessment criteria per standard,

they were not addressed in full leading to reports covering different topics;

(3) thorough analysis and evidence were rarely present in the final reports

leading to arbitrary judgements.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	dominant role of the Director, lack of independent stakeholder consisted governing body
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Committee found that in the present arrangements the founder has a dominant figure in the work of the agency. His/her

position could endanger the organisational and the operational independence of IKCA, especially in the absence of an independent

stakeholder governing body. The Committee found also that further clarity is needed in the selection processes of its different bodies.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“IKCA explained that since the site visit in

2022, the agency initiated and published several thematic analyses. The

agency also updated its Development Strategy to accommodate topics for

future analysis. The Committee analysed further the published research on

IKCA’s website and concluded that not all of the work can be classified as

thematic analysis as understood by the ESG. In addition, it found that the

enlisted topics are more of broad ideas rather than concrete research

questions.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Closed PDCA cycle
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The agency is yet to demonstrate how it employs the feedback gathered through its internal

quality assurance feedback mechanisms to improve its work. In this sense, further panel insight is expected to demonstrate whether and how the agency translates this feedback into the work performed by its own staff, the members of the different bodies etc.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	Insufficient coverage of ESG 2.1
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Looking at systemic level, the

different regulations touch upon the three particular standards of Part 1 of the ESG. However, the full coverage of all the standards of Part 1 is still not ensured through agency’s own criteria. Partial coverage of aspects through national legislation does not substitute coverage through external QA procedures and coverage of the ESG part 1 by higher education institutions’ internal QA is a prerequisite for EQA being able to assess their implementation”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of formal complaints procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Partially compliant with the standard due to the lack of formal complaints’ procedure– the higher education institutions could express their dissatisfaction with the process only informally throughout the review process. The agency is yet to establish a clear

complaints procedure that is known by higher education institutions”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ENQA
Decision of	03/03/2023
Standard	3.3 Independence
Keywords	Infringement of the operational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Dependency of the agency on staff paid by higher education institutions”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.5 Criteria for outcomes
Keywords	Inconsistent application of criteria
Panel conclusion	Compliance
Clarification request(s)	Agency (18/07/2023)
RC decision	Partial compliance

“The current set up brings confusion not only for the higher education institutions, but also for the

agency itself. The Committee found that agency’s criteria are not always applied consistently in the reviews and this leads to different standards being covered in the reports. During the clarification call, the agency explained that the SOP 2023 will be stabile - only reviewed and amended after 3 years again. The Committee welcomed these changes but found that the agency still enables usage of different SOPs – a practice that can lead to different outcomes and inconsistencies in the conclusions of its reports. This is especially problematic considering the regulatory function of the agency’s reviews for veterinary education.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of stakeholders
Panel conclusion	Compliance
Clarification request(s)	Agency (18/07/2023)
RC decision	Partial compliance

“The Committee was displeased to learn that EAEVE has not involved students and other stakeholders in the decision-making bodies since its registration on EQAR in

2017. While the Committee understood that involvingstudents from a narrow scientific field in the work of the agency could be a challenging task, it found that EAEVE could have found alternatives since its registration (e.g. establish stronger ties with stakeholders associations and or/create incentives for motivating other stakeholders to participate in the work of the agency, expand the involvement of students from closely related scientific fields etc.). The Committee found that the agency’s involvement of stakeholders, including students, in its governance and work is insufficient.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.4 Peer-review experts
Keywords	training, training of experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. The Register Committee noted from the panel’s analysis that the trainings of experts have been reduced to only a briefing session taking place before the site visit. The panel’s analysis further show that the last training organised by NEAA took place in 2018 (before the Covid-19 pandemic).

9. The Register Committee underlined that the agency is expected to ensure that experts have the appropriate skills and competences to carry out external reviews and that such skills and competences are acquired through regular (periodic) trainings organised by the agency.

10. In its representation, NEAA provided information that it has started intensively working on preparation and implementation of several trainings focused on specific standards and criteria. NEAA also informed that future training sessions will be included in its Action Plan.

11. The Register Committee welcomed the steps taken by NEAA to address the earlier concerns, but noted that the Committee could not verify whether these training activities will ensure that all members of a panel will be systematically trained prior to undertaking an external quality assurance procedure. The Committee noted that these will remain to be determined in NEAA’s next external review.

12. The Register Committee therefore remained unable to concur with the panel’s conclusion, but considered that NEAA complies only partially with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.7 Complaints and appeals
Keywords	appeals and complaints, committee
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its initial application for inclusion the Register Committee raised concerns regarding the lack of an internal appeals system within the agency.

14. The Register Committee noted that since the last external review of NEAA, nothing has changed in relation to the possibilities for higher education institutions to make an appeals with the agency.

15. The Register Committee further noted, that NEAA does not have its own appeals process nor a separate body in considering appeals and that the only existing appeals procedures are outside of NEAA’s remit, defined by law and under the legal competency of the Bulgarian courts.

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

17. In its representation the agency provided full documentation on its new internal provisions for complaints and appeals and for the functioning of its body the Complaints and Appeals Committee. The Committee noted that the new body is a standing committee within the agency, fully operative with permanent members and clear provisions outlined in the Statutes of the Complaints and Appeals Committee.

18. Having been able to verify that the agency provides both internal processes for complaints and appeals, the Register Committee finds that the initial concerns have been addressed. The Register Committee therefore concluded that NEAA now complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholders, stakeholders involvement, Accreditation Council
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“19. In its last decision, the Register Committee noted that the composition of NEAA’s Accreditation Council (AC) is dominated by representatives of the academia and that there is a lack of stakeholder involvement with no student or labour market/employment representatives involved in the work and governance of NEAA.

20. The Register Committee noted that while NEAA expanded the direct participation of stakeholders in its work i.e., including representatives of students and employers in the Expert Groups and the Standing Committees, that the composition of the Accreditation Council (AC) is still limited to only representatives of the academic community.

21. Despite the improvements done by NEAA in the involvement of stakeholders’ in some of its processes and bodies, the Register Committee considered the lack of stakeholder involvement (as per the requirement of the standard) in the core governance body of NEAA as of crucial importance.

22. The Committee further emphasised the recommendation of the panel to ensure the inclusion of a representative of students and employers/industry in the AC, including a representative of students (preferably with a legal background) in NEAA’s Ethics Committee.

23. In its representation, the agency provided information on the actions taken toward the government and parliament around the need for legislative changes. The Committee took note and welcomed the positive developments towards the involvement of stakeholders in the Accreditation Council, however at the time of the Register Committee’s consideration, no changes have happened, nor a clear timeline for such changes has been provided.

24. The Register Committee acknowledge that although NEAA has taken all possible actions to improve the involvement of stakeholders within relevant normative documents, the fact remains that the level of compliance is negatively impacted by the regulatory framework within which NEAA operates.

25. The Register Committee therefore concurs with the panel that NEAA complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.5 Resources
Keywords	resources, financial independance
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“26. The panel noted that the main challenge for NEAA remains the fact that it cannot manage its own finances in a manner that will enable NEAA to ensure the best quality of its activities. Even if the majority of the funding comes from its external quality assurance activities i.e., mostly accreditation fees, due to the strict regulations and rules defined on national level, NEAA cannot access these revenues. The Committee concurs with the panel that this could have a negative impact on the sustainability and the quality of its processes.

27. The panel underlined that despite the improvements and increase of staff members since its last review, from 8 to 19 staff members, NEAA still had a high number of vacant positions.

28. The Committee emphasised the panel’s recommendations on the need for the agency to pursue with the Ministry changes in its financial management and to continue the recruitment of new staff to ensure optimal workload and implementation of external QA processes on time.

29. In its representation, NEAA reported of a further increase in its staff (i.e., from 19 to 23 employees), with recruitment for some of these positions currently underway. The Committee noted that the agency has taken active steps addressing specific proposals to increase pay rates to the Ministry of Education, the Ministry of Finance and the Prime Ministers office. Similar efforts are directed towards the Council of Rectors. Further, the agency stated that there are constant efforts made towards the responsible national authorities with a request to increase the budget of the agency.

30. The Register Committee welcomed the actions taken by NEAA. The Register Committee, however, noted that despite the improvements in NEAA’s permanent staff, the agency’s financial independence, due to external factors, remains constrained, and while the limitations in resources may not pose an immediate concern as to the sustainability of the agency, it may negatively impact the scope and quality of the activities undertaken by NEAA.

31. The Register Committee therefore concurred with the panel’s conclusion that NEAA complies only partially with ESG 3.5.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal, internal QA system,
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“32. The panel noted that NEAA started developing its internal quality assurance system introducing, some new mechanisms and procedures. However, the panel underlined that the elements of the procedures are fragmented and not fully structured, integrated and connected in a systematic way. The panel also noted the lack of transparency of the mechanisms and their results.

33. Despite NEAA’s efforts to develop its own internal quality assurance system, the Register Committee found that the process is still in a developmental phase. The Committee underlines the panel’s recommendation that all the elements of the internal QA system needs to be better connected, regularly implemented with the involvement of all internal and external stakeholders.

34. In its representation, NEAA informed that in 2023, the agency undertook an internal audit to identify the weaknesses and bottlenecks in its own internal processes and review procedures. The agency also provided details of the internal audit process and the series of recommendations that were outlined to correct the issues. NEAA further stated that necessary measures are being implemented to improve the functioning of the agency.

35. While the Register Committee welcomed the steps taken by NEAA, the Committee underlined that the issues outlined before remain to be considered and reviewed by an external review panel to determine the improvement in the functioning of NEAA’s internal QA system.

36. The Register Committee therefore concurred with the panel’s conclusion that NEAA only partially complies with ESG 3.6.”

Full decision: see agency register entry

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