Database of Precedents

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

“The appeals process remains to be led by an external body. The agency is not handling any formal complains or appeals itself.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Weak involvement of stakeholders in the governance of the agency
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (28/09/2021)
RC decision	Partial compliance

“AI has no advisory or governing board, nor any other strategical decision making body (hence lacks stakeholder involvement in the governance of the agency).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/10/2021
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Informal approach to IQA; Not addressing flags from previous review
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“AI has adopted an overall framework for internal QA, which is publicly available. The panel, however, found that agency’s approach to internal QA is often informal and flexible. This was reflected in the self-evaluation report,

which the panel found to be lacking self-reflexivity and deeper analysis of agency’s internal needs. The Register Committee noted that the agency has not addressed the issues that led to a partially compliant conclusion in the

previous decision for renewal of registration (namely ESG 2.7 and ESG 3.1).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/07/2021
Standard	2.1 Consideration of internal quality assurance
Keywords	Incomplete coverage of Part 1 of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that AAQ does not cover ESG 1.3 (Student-centred

learning, teaching and assessment) and covers ESG 1.2 (Design and

approval of programme) only partially in the criteria for institutional

accreditation. These standards are only fully covered in programme accreditation,

which is voluntary except for health professions. As institutional

accreditation is the core activity of the agency and the only mandatory

external quality assurance for all Swiss institutions, it should assure full

coverage of ESG Part 1 by itself.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/07/2021
Standard	2.2 Designing methodologies fit for purpose
Keywords	Using feedback for improving methodologies
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee welcomed the diverse methods used by the agency

for gathering feedback from different stakeholders, but could

not confirm that the reflections are efficiently and systematically used in the

improvement of the activities. The findings indicate that the

feedback is only sporadically used in the improvement of the agency’s

external QA activities.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/07/2021
Standard	2.6 Reporting
Keywords	Publication of reports depends on the agreement with the HEIs; Lack of publication of negative reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel pointed out that publication of AAQ’s reports is subjected to contract between the agency and the university. Such arrangements

primarily derive from the legal framework in Switzerland, which does not prescribe obligatory publication of reports. In practice, the agency has so far published all reports that led to a positive decision. The Register Committee learned that the agency has not published any

negative decisions on its website. In addition, the panel noted that on systemic level, there was no intention for discussing this matter further, and publishing of the reports with a negative outcome was not on the political agenda of the stakeholders.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	2.1 Consideration of internal quality assurance
Keywords	Narrow focus in addressing Part 1 of the ESG
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The panel stated that requirements of ESG Part 1 are reflected in AKAST’s own guidelines for institutional evaluation and that the new review criteria to be applied by AKAST for accreditation of canonical study programmes in Germany follows the ESG. The Register Committee found the review panel’s analysis brief and lacking in analysis. However the Committee took note of the “equivalence” table” provided by the agency, mapping how ESG 1.1 to 1.10 are addressed in the agency’s programme accreditation procedures and found that standards are addressed implicitly, with a limited coverage, in particular with regards to ESG 1.1, ESG 1.3 and ESG 1.4.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	2.2 Designing methodologies fit for purpose
Keywords	stakeholder involvement in the development of methodology
Panel conclusion	Full compliance
Clarification request(s)	Panel (02/05/2025)
RC decision	Compliance

“The Register Committee was unclear how the agency has developed its accreditation criteria and whether stakeholders were involved in the design of AKAST methodologies and has therefore asked the panel for further clarifications. The panel explained that Germany’s new legal framework defines the procedures for QA agencies carrying out their accreditations within Germany and that the German Accreditation Council (GAC) is entrusted with overseeing this process. The GAC has issued reporting templates and defined the structure of review reports as well as self-evaluation reports for higher education institutions, following the criteria established in the Specimen Degree, which follow the ESG.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	2.6 Reporting
Keywords	publication of negative reports
Panel conclusion	Full compliance
Clarification request(s)	Panel (02/05/2025)
RC decision	Compliance

“As not all reports were published on the agency’s website, the Register Committee was unclear whether the agency publishes all its review reports, including those with a negative result. The panel explained that while AKAST has not published reports right from the beginning of its activities, that the agency has been making available the review reports following the implementation of the new legal framework in Germany. As GAC has assumed the task of keeping a central register for all accreditation records, all the reports by AKAST will be made available in its register (including negative and older accreditations). The panel further added that at the time of the review, AKAST had not taken any negative accreditation decisions, and if it were to do so in the future, AKAST would have to publish it.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Impartiality in handling appeals (independence of the Appeals Committee). Coverage of all EQA activities by the appeals procedure
Panel conclusion	Full compliance
Clarification request(s)	Agency (02/05/2025)
RC decision	Partial compliance

“The Register Committee underlined that the current arrangements does not ensure an impartial process in AKAST’s approach of handling appeals, since the appeals are considered by the same committee that also takes the accreditation decisions and nominates the review panel members for the review. The Register Committee further noted that the appeals and complaints procedure only cover issues concerning two of AKAST’s activities and it does not address the agency’s peer institutional evaluation procedures. While AKAST has not yet carried out any such evaluation, the Register Committee underlines that, since the activity is on offer, the agency is expected to ensure that all corresponding procedures will be adequately updated, including the agency’s appeals and complaints procedure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	3.3 Independence
Keywords	Organisational (of the accreditation committee and executive board from the founding organisation) and operational independence
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (02/05/2025)
RC decision	Non-compliance

“The panel’s findings show that, under canon law, AKAST is subject to the vigilance of the German Bishops’ Conference. The Bishops' Conference influence extends to giving consent for the admission of members of the association, the consent for the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and 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. AKAST is also financed by an annual grant from the Association of German Dioceses (VDD), the legal entity for the German Bishops’ Conference. The panel explained that the German Bishop Conference member serves within the Accreditation Committee “in more moderatorial and advisory capacity” (review report p. 19) and that the elected Accreditation Committee members, permanent guests and experts involved in reviews are all requested to sign a declaration of no-conflict-of interest. The agency also added that the involvement of the German Bishops’ Conference in the decision-making process “helps ensure that there is no conflict between accreditation decisions and the subsequent ecclesiastical approval required under canon law” (self evaluation report p. 15). While the Register Committee considered it usual and acceptable for the Bishops' Conference, as the main founder and hence key stakeholder of the agency, to be involved, the Register Committee underlined that the requirement of independence should be understood to the effect that the new organisation, once it has been founded, should be able to function independently as required by the standard. 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), in contrast with the understanding of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. The Register Committee added that the accreditation decision by AKAST and the ecclesiastical approval required under cannon law are the purview of two different entities, and could be therefore considered independently from each other. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.3 Implementing processes
Keywords	new accreditation programm, follow-up process not yet defined.
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (09/10/2020)
RC decision	Compliance

“Compliance Compliance While the Register Committee noted – from the agency’s statement to the review report – that THEQC had introduced the new maturity levels for internal QA systems, the Committee was unclear whether any changes were made to the agency’s follow-up processes and has therefore sought further clarification from the agency.The agency explained in its clarification letter that an Institutional Follow-up Program (IFuP) was initiated at the beginning of 2020 and it is carried out for all institutions that have passed through an initial institutional external evaluation. The follow-up team performs a preliminary check of the institutional self-evaluation reports, performance indicators and other additional documents followed by a one-day online site-visit, which results in an Institutional Follow-up Report (IFuR) published by THEQC.

The Committee further noted that THEQC has only just initiated the Institutional Accreditation Programme (IAP); the follow-up process for this procedure has not yet been defined. new accreditation programm, follow-up process not yet defined.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.4 Peer-review experts
Keywords	student involvement
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (09/10/2020) Panel (25/10/2020)
RC decision	Compliance

“ the Register Committee noted that students were not always listed among the peer-review experts. The Register Committee has therefore asked the panel whether it was aware of such exceptions and whether it was given any explanation.

The panel explained that the involvement of students was piloted only in 2018 and that it became part of THEQC’s procedure in the academic year 2019-20 (following the set-up of the agency’s Student Commission in October 2019). The panel was assured by those that it spoke to, including the student representatives, that it was now THEQC’s policy to include students on all review panels.

The Register Committee welcomed the panel’s explanation, but noted that students were not listed among the peer-review team members in a number of evaluations carried out in 2019 (e.g. Alanya University, Atashehir University, Şırnak University, Hakari University, Ataşehir Adıgüzel Meslek Yüksek Okulu, Muş Alparslan).”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.6 Reporting
Keywords	delay in the publication of reports, inconsistency in the content of reports
Panel conclusion	Partial compliance
Clarification request(s)	Agency (09/10/2020)
RC decision	Partial compliance

“THEQC stated that it had completed only one Institutional Accreditation Program (IAP) by the end of 2020 and that the agency would begin to publish IAP reports by February

2021. As of March 2021, the Register Committee could not verify the publication of any Institutional Accreditation Program report, in particular not the report from the procedure finalised in

2020. Considering the consistency of institutional external evaluation reports (ISER and IFR) the panel formed the view that this was not systematically ensured. While the agency has taken in the recommendation of the panel to include the maturity level grades as part of these reports (see also under ESG 2.5), the Committee underlined the panel’s recommendation on the need to also introduce mechanisms to ensure consistency not only for the structure of the reports but also of the depth the reports provide. In its additional representation the agency stated that an analysis was performed on its rubric assessment approach, but that the analysis was not finalised in time for its site-visit. THEQC added that a consistency and usefulness analysis was also carried out with different stakeholders on its rubric reporting approach. The Committee welcomed the analyses carried out by the agency, but considered that the panel’s concerns have not been addressed since the analyses did not address the content of the reports. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.7 Complaints and appeals
Keywords	Implementation of an appeals process and information about the appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ The Register Committee noted from the panel’s analysis that the agency’s appeals and complaints processes were not clearly defined. The panel stressed that as the agency moves towards an institutional accreditation process, it will need to reevaluate its current processes for both complaints and appeals.

The Committee further noted that the agency does not have a designated body to handle appeals, but that they are considered by the Council in consultation with the IEE Commission. In its additional representation, THEQC explained that it has developed and integrated the complaints process into its Feedback Management System. The Register Committee was able to verify that the new complaints process and form is easily accessible on THEQC’s website. With a view to appeals, the Register Committee welcomed the decision to establish a distinct Appeals Committee to handle appeals and took note of THEQC’s newly developed Directive of Complaints and Appeals. The Committee, however, noted that the Appeals Committee is not part of THEQC’s organisational chart and that no information is provided on the members of the Appeals Committee. The Register Committee asked the agency to elaborate on whether any other provisions have been added to its Complaints and Appeals regulation. The agency clarified in its response letter that the latest version of the Rules of Procedure of the Appeals Committee dated 19/05/2021was now in use and published on the agency’s website (only available in German) which include minor updates. The Register Committee noted that the additions to the updated procedure are in line with the expectation of the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	mentorship programme, participation of students, stakeholder consultation in the design of methodologies
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (09/10/2020)
RC decision	Partial compliance

“ Considering the mentorship programme run by the agency, the Register Committee noted the panel's concerns related to the possible conflict of interest of such experts providing support to institutions.

Considering THEQC’ shifts towards institutional accreditation and the panels’ recommendation to ensure that any conflict of interest is avoided in this new activity, the Committee asked the agency whether it has kept or discontinued its mentorship programme.

The agency explained that the mentorship programme was a feature of the Institutional External Evaluation Programme (IEEP) and that THEQC continues to carry out evaluations for higher education institutions that have been newly established or have no graduate students. The agency added that it has launched a new call for mentors in 2020, and that those mentors are requested to declare possible interest when assigned to an institution, and to sign a Code of Ethics as well. The Committee further noted the panel’s concerns regarding the design of methodologies and other related documents, which are only discussed by the Council with no further consultation being carried out with THEQC’s stakeholders. The agency did not comment on this issue in its additional representation. The panel's analysis further shows that the participation of students is limited compared to that of other Council members, as no student was included in any of the Council’s commissions. In its additional representation, THEQC stated that students now actively participate in two additional committees.The Register Committee welcomed the clarification and steps taken to prevent conflict of interest in its mentorship programme and nomination of students in the agency’s governance. The Committee, however, underlined that the effectiveness of stakeholder involvement in the agency’s governance and work has yet to be fully reviewed in practice, in particular with regards to stakeholder consultation in the design of methodologies. The Committee therefore considered that THEQC complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	Organisational and operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that THEQC’s operational independence is affected by the key role played by experts and consultants, who serve as the agency's professional staff but remain employed and on the payroll of higher education institutions. The analysis of the panel showed that the current organisational structure of the agency affects the independence of its operations and formal outcomes since there is a potential for conflicts of interest to arise regarding the different roles played by the Councils’ members. The agency responded in its statement to the review report that THEQC had increased the number of permanent employees (4 new full-time employees started working for the Council in 2020). The agency also stated that its organisation structure was defined by law, but it had nevertheless conveyed the recommendation related to THEQC’s organizational structure to the relevant authorities. In its additional representation the agency added that as of January 2021, the number of THEQC employees had further increased and that the duties and responsibilities of the Council members had been reframed. While the Register Committee noticed the increase in the number of permanent staff, the Committee considered that the agency is still relying to a large extent (14 of 35 staff members) on experts and consultants that are at the same time on the payroll of higher education institutions. This could constitute a conflict of interest for obvious reasons. The Committee thus concluded that the panel’s concerns related to THEQC's operational independence have not been fully addressed”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.5 Resources
Keywords	Human resources
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“According to the panel’s analysis the allocation of the budget has not been made considering the agency’s real financial needs and its Strategic Plan for 2019-2023. The panel further expressed concern regarding the sustainability of agency’s processes as they do not rely on permanent professional staff, but almost entirely on the ‘voluntary’ nature of the work of evaluators and staff seconded to the agency. In its statement to the review report THEQC responded that it had made its budget plan within the scope of Strategic Planning in Public Institutions, following the Law on Public Finance Management and Control (No. 5018). The agency added that the strategic plan also includes a budget, which can be provided at request. In its additional representation the agency explained that the number of its permanent employees increased from 10 to 21 in over a year an a half. While the agency still has 14 staff members seconded and paid by higher education institution, the Committee concluded that human resources are nevertheless sufficient to allow THEQC to carry out its activities within the scope and in line with the ESG. Considering the additional representation and the changes to THEQC’s staffing the Register Committee concluded that THEQC now complies with ESG 3.5.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Effectiveness of the internal QA system
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted THEQC’s recent development of an internal quality assurance system, in line with the results of the Plan-Do-Check-Act methodology and the 2019-2023 Strategic Plan. While the panel commended the use of platforms and on-line tools for the implementation of the internal quality assurance system and the dissemination of relevant information, the panel found a number of issues that remained to be addressed in order for the quality assurance system to foster continuous improvement: existing confusion amongst experts, consultants and staff regarding their responsibilities in internal quality assurance matters, the lack of any corrective measure if an evaluation team were to fail to complete its task with the production of a satisfactory report. THEQC explained in its additional representation that it had prepared a chart clarifying the roles of staff, council and commission representatives (see Annex 9). THEQC further added that higher education institutions have a chance to comment on factual issues before reports are finalised, which then have to be addressed by the review panel. The Register Committee welcomed the clarification provided but underlined that the effectiveness of THEQC’s internal quality assurance system to foster continuous improvement in its processes is still to be reviewed in practice as the current improvements are not a result of the agency’ internal QA system but a result of an external feedback. The Register Committee further considered that the internal QA system should be designed so as to further support the successful implementation of the agency’s activities in particular considering THEQ’s newly launched Institutional Accreditation Programme (IAP).”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.3 Implementing processes
Keywords	Lack of on site visits; Lack of interviews with stakeholders
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (15/03/2021)
RC decision	Partial compliance

“absence of any standard framework or guidance as to the use of site visits or interviews in thematic evaluations, makes it unclear whether the agency has sufficient approaches to validate the evidences provided by HEIsin this activity. In addition, the panel's report touched only briefly on the suitability of online interviews instead of regular site visits in the activities program evaluation and appraisal of applications for degree-awarding powers.”

Full decision: see agency register entry