Database of Precedents

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

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.3 Implementing processes
Keywords	follow-up with limited value added, no students interviewed in site visits
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Partial compliance

“18. The panel noted that HCERES programme evaluation panels do not meet with students during review visits. The panel discussed the new follow-up process introduced for institutional evaluation only, but noted that some questions remained regarding the added value given that there is no analysis or feedback in direct response to follow-up reports.

19. The panel considered that HCERES made improvements since the last review, as site visits were not carried out for programme evaluations at all previously and given there was no follow-up process previously.

20. While the Register Committee acknowledged that significant progress has been made, it did not consider that HCERES complies with the standard yet in light of the limited added value of the follow-up process and the fact that students are not interviewed during site visits. The Committee therefore did not concur with the panel, but concluded that HCERES remains partially compliant with ESG 2.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.7 Complaints and appeals
Keywords	Board member in appeals committee, independence of decisions on appeals
Panel conclusion	Full compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Compliance

“28. In the last renewal of registration, HCERES was found to be only partially compliant with the standard since its appeals and complaints processes were only just set up and not yet reviewed by an external panel; a specific concern was whether the decision-making on appeals was fully independent from those in charge of the appealed report/decision.

29. The panel considered that HCERES' appeals and complaints processes were clearly defined and communicated. The panel noted that HCERES had not received appeals or complaints since 2016.

30. The panel clarified that it considered the appeals committee's composition suitable. While HCERES Board members indeed serve on the appeals committee, the Board does adopt neither evaluation reports nor accreditation decisions. In addition, one external expert is part of the committee.

31. The Register Committee agreed that the appeals committee was sufficiently independent given that the HCERES Board does not adopt the reports or decisions that are being appealed. The Committee therefore concurred with the panel's conclusion that HCERES complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	3.4 Thematic analysis
Keywords	separate research or bilbiometric analyses do not qualify as thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“38. The panel considered that HCERES' recent activities have been focused on research and bibliometric analysis; analyses drawing on the results of evaluations within the scope of the ESG have not been produced regularly since the summary reports that HCERES/AERES used to produce following earlier evaluation campaigns.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	3.6 Internal quality assurance and professional conduct
Keywords	feedback system not fully integrated, regression since last review
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“40. The panel noted that the representatives of institutions and reviewers gave different opinions on the possibilities for feedback.

41. The Register Committee agreed with the panel's analysis that this indicates that the feedback system might not yet be fully implemented and that there was a need to systematise and make more coherent the available feedback instruments.

42. The Register Committee further noted that the only partial compliance with ESG 2.1 and 3.4 is a regression since the last review and thus does not reflect positively on the agency's internal quality assurance arrangements.

43. In light of these reservations the Committee was unable to concur with the panel's conclusion, but considered that HCERES only partially complied with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee learned that IQAA now publishes in full the decisions from institutional and programme accreditations, including the

negative ones. Even though the bulk of reports is public, this is not the case for all of them - the reports from the initial accreditation and the post-accreditation monitoring are still not published.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.4 Thematic analysis
Keywords	Consistent publication of thematic analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that IQAA has published several thematic analyses since the last review. The panel, however, could not see

any formal plan for drafting and publishing these analyses.The Committee considered that despite the absence of a more formal planning the agency has developed a practice and demonstrated a clear vision for conducting analyses based on its EQA processes.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.1 Consideration of internal quality assurance
Keywords	How ESG Part 1 is embedded in subject-specific label reviews
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its Change Report Decision of 02/11/2020, the Register Committee requested that the next external review of ASIIN considers how the agency ensures sufficient coverage of ESG Part 1 in its combined (“piggybacking”) procedures (ESG 2.1). The agency explained that ESG Part 1 is embedded as a standard procedure in every external QA activity carried out (Self Evaluation Report p. 35). Having considered how ESG Part 1 is mapped against ASIIN’s seals while also including the standards of the German Accreditation Council, the panel was convinced of the coverage and link to ESG Part 1 in all its activities. The documents confirmed that all subject-specific label requirements are assessed in addition to ASIIN's generic standards for degree programmes, which incorporate ESG Part 1. The panel also underlined that SAR templates for each review method were structured to follow ESG Part 1. The Register Committee was therefore satisfied that ESG Part 1 is sufficiently addressed in ASIIN’s combined (“piggybacking”) procedures.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.3 Implementing processes
Keywords	Implementation of procedures and transparency of CBQA procedures
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last review the Register Committee noted that ASIIN's policies were not always followed in practice, i.e. use of on-site visits in evaluations and use of evaluation results in programme accreditations. In its current review, the panel stated that it did not find any evidence of deviations from the prescribed procedures and that policies are implemented consistently. The panel, however, remarked that ASIIN could provide better guidance about the site visit schedule and ensure more transparency in the processing of requests deemed potentially problematic from countries of higher education institutions outside of the European Higher Education Area (see also under ESG 3.1).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.7 Complaints and appeals
Keywords	handling of appeals and complaints
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee considered the panel’s findings that show that ASIIN’s appeals and complaints processes are not well differentiated and as a result not consistently used, i.e. the institutional accreditation handbook discuss complaints procedure although what is described is the means to appeal a decision, whereas the handbooks for the programme accreditation and certification processes mention appeals procedure, the name of the Appeals/Complaints Committee appear to have four different permutation. The panel further comments on the agency’s lack of understanding of the two different concepts. In its response to the review report (19/07/2021) ASIIN’s stated that it has revised its documents and website, employing the right terminology. While the Register Committee welcomed ASIIN’s corrections, the Committee found the panel’s concerns have not been fully address, as the lack of understanding of the two concepts may affect the agency’s ability to effectively handle both appeals and complains for all its activities.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholder representation within the governance and separation of EQA within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last decision, the Register Committee noted that ASIIN continued to use the term evaluation for type 2 evaluations against the panel’s recommendation, and thus the separation between activities within the scope of the ESG and those that are carried out as type-2 evaluations remained unclear. In its review report the panel considered that the difference made by ASIIN in various documents between type 1 evaluation and type 2 evaluation sufficiently differentiated between accreditation and consultancy. The panel further noted that ASIIN had a policy not to conduct accreditation for those institutions/ programmes at which consultancy activities were carried out, and that this was adhered to in practice (p.31). The Committee therefore concluded that this shortcoming has been addressed. The Register Committee noted that ASIIN’s Board of Directors consists exclusively of representatives of member organisations/institutions of ASIIN. The involvement of a diverse set of stakeholders (including students) in the governance of the agency is, however, ensured within the technical committees, Accreditation Commission and Certification Commission. Considering ASIIN’s expansion of its external QA activities to other areas the panel underlined that ASIIN should rethink its current structure and broaden its competences (p.16). The panel recommended a stronger involvement of the Board of Directors in the strategic direction of the agency and the monitoring of its strategic goals, while at the same time expanding its membership to also include external stakeholders (including a student member). The Committee underlined that recommendation of the panel.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.3 Independence
Keywords	Integrity/conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that the members of ASIIN’s technical committees can simultaneously hold the position of an external reviewer for ASIIN’s review panels, which would put them in a conflict of interest when discussing the reports prepared by the same panel they were members of.

23. Considering the panel’s concern of a potential conflict of interest resulting from this arrangement, the Committee concluded in its initial decision that ASIIN complied only partially with ESG 3.3.

24. In its Appeal of 20/01/2022, ASIIN challenged the Committee’s conclusion and judgment arguing that the independent decision making of its Technical Committee was not compromised. The agency made the case that the involvement of active experts as members within ASIIN’s 14 Technical Committees ensured a consistent application of procedures and criteria in the preparation of accreditation reports. ASIIN further explained that ASIIN’s Technical Committees did not have any decision-making power as regards the accreditation decision. Moreover, the experts involved in the procedure would regularly abstain.

25. The Committee welcomed the abstention of the Technical Committee members, but could not determine if the practice of abstention was institutionalised in ASIIN’s procedure.

26. The Register Committee further underlined that the integrity of the review process could be better safeguarded by ensuring that members of the Technical Committees would not partake at all (i.e. by leaving the room) when their report is considered by the Technical Committee.

27. Having weighed the limited role of the Technical Committee in ASIIN’s decision making process and the fact that its members abstain from decision-making in such cases where they were involved as reviewers, the Register Committee concluded that ASIIN’s independent decision-making is not compromised and thus found that the requirement of the standard is met. The Committee therefore concurred that the agency complies with ESG 3.3”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.4 Thematic analysis
Keywords	thematic analysis conducted on a regular basis
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last renewal of registration on EQAR, the Register Committee noted that ASIIN only partially fulfilled the requirement of the standard, since ASIIN did not conduct such analysis on a regular basis and the prepared analysis and studies contained only elements of what is understood as thematic analysis. In its current review report, the panel commends ASIIN for its efforts in regularly developing thematic analysis through its impact studies which provide significant insights on the agency’s external QA activities. While the panel finds that ASIIN could improve the dissemination of its impact studies among stakeholders, the panel is satisfied that the requirement of the standard is met. Having addressed the earlier concerns in its compliance with ESG 3.4, the Register Committee concurred with the panel’s conclusion that ASIIN now complies with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	2.4 Peer-review experts
Keywords	student involvement
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“9. The review panel's report contained no analysis of the factors that led to that departure from EQ-Arts' own policies, but confirmed that all reviews since December 2018 have included students (8 reviews in 2019 and 1 in 2020); the panel further elaborated on EQ-Arts approach to recruiting and training experts.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	2.5 Criteria for outcomes
Keywords	consistency of decisions
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (16/03/2021)
RC decision	Compliance

“12. The panel was convinced that EQ-Arts had “developed a sound approach to guarantee fair and transparent decisions and judgments”; it noted that consistency was ensured by a template with guidelines, the executive officer supporting each expert team and the Board considering each report.

13. [...] In its response, the panel elaborated on the measures taken to ensure consistency and how reviewers are being familiarised with them in EQ-Arts' trainings. The panel explained how it triangulated the information received from the reviewers, the reviewed institutions and the EQ-Arts Board. The panel confirmed that there was a “consistent understanding of procedure and process”. Based on the increased amount of activities, the panel was satisfied that EQ-Arts criteria were applied consistently, irrespective of whether the process leads to a formal decision by the Board.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of external QA and consultancy activities; possible conflicts between different types of reviews
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“16. [...] The report noted that it would be against EQ-Arts' principles to engage in paid consultancy work (p. 31), this was now explicitly ruled out in the Governance Framework.

17. The Register Committee considered that the issue has been addressed for consultancy in the classical meaning, i.e. paid services provided to institutions. The Committee therefore now concurred with the panel's conclusion that EQ-Arts complies with the standard.

18. The Register Committee nevertheless underlined that EQ-Arts needs to be mindful for all other current or future activities with individual higher education institutions – whether paid or unpaid – if they could be regarded as compromising its ability to make an independent assessment of that institution later on and, if so, to make adequate provisions to rule out carrying out a review of that institution.

19. In addition, the next external review of EQ-Arts should analyse whether any risk lies in the fact that the same higher education institutions might undergo an enhancement review first and request a formal assessment later, depending on whether such patterns occur in practice.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	nomination of the Board members
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“21. The review panel noted that EQ-Arts' statutes were reviewed in order to reorganise its Board and allow for the inclusion of students. Moreover, the Board and Executive Group were merged. The Governance Framework defined the composition and responsibilities of the Board, as well as the criteria for Board membership (p.34).

22. The panel reported that a call for Board members was issued in May 2020 and addressed to relevant subject-specific stakeholder organisations; on that basis, the Board members were selected.

23. The Register Committee considered that the new arrangements improved transparency and therefore concurred with the panel's conclusion that EQ-Arts complies with the standard.

24. The Committee was unable to verify whether the nomination arrangements apply only to initial nominations or also to re-appointments. In the interest of assuring a regular link with the sector, the Committee encouraged EQ-Arts to ask for nominations also for re-appointments.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.5 Resources
Keywords	volatile resources
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“28. The 2018 external review discussed that EQ-Arts' financial situation was volatile. While the resources were sufficient to sustain the (currently) small number of reviews, the medium-term perspective was not clear.

29. The panel reported that staff increased to 1.3 FTE in 2019, then fell to 0.5 FTE as result of the Covid-19 pandemic and a drop in activities.

30. While the panel found that the “agile and collaborative approach” assured that workload could be handled, the Register Committee considered that the resources of EQ-Arts remain highly volatile; this has not changed since the initial review.”

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	Lack of meaningful involvement of students in panels
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“ECAQA involves a variety of stakeholders in the composition of panels, including students. The Committee learned that, in practice, the student reviewers were not always offered the training provided for the other panel members – such conditions made their involvement in some of the reviews nominal in the panel's view.The Register Committee found that despite the formal involvement, ECAQA's approach did not ensure meaningful participation of students in all review panels”

Full decision: see agency register entry

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

“The Committee could not verify how the agency ensures its independence from its founder and found the distribution of power among stakeholders in the governing of the agency unequal. The Committee noted that the current arrangements include the possibility of

the founder or the Director General exercising their controlling stake in several regards, causing a substantial risk of an infringement on the

independence of the agency (see also interpretation 18).”

Full decision: see agency register entry