Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.7 Complaints and appeals
Keywords	No formal complaints procedure; Advisory role of appeals commitee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“UKÄ has no formal complaints procedure in place (p. 34), even though the panel was confident that any issues stakeholders have, related to the work of the agency, are taken up by UKÄ. The report further discussed the advisory role of the appeals committee and the panel was concerned that this approach, paired with the fact that the committee cannot make recommendations how to correct potential errors, could undermine the authority of the appeals committee.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	Organizational independence; Lack of formal mechanisms for tackling conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (15/03/2021)
RC decision	Partial compliance

“Concerns about the Government's control of all major appointments remain. In particular, the way in which the Director General is selected has not been made fully transparent and it remained unclear whether the involvement of stakeholders in appointing the Advisory Board is secured in official documents. Moreover, the potential conflict of interest that the Director General could come across in their daily operations does not seem to be fully addressed through formal means by the agency.”

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 planning and work overload; Staff overturn
Panel conclusion	Full compliance
Clarification request(s)	Panel (15/03/2021)
RC decision	Compliance

“The review panel noted the continuously high workload and turnover of staff. It further elaborated that the staff and the management had different positions in regards to the reasons (p. 19). The review panel informed the Register Committee about several measures that the agency plans to introduce, including replacing site visits by online interviews and deploying a single expert panel to several institutions. The panel considered that these were welcome measures that enhance UKÄ's activities and their efficiency. The panel saw that some improvements have already taken place, resulting in decreased staff overturn.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	2.7 Complaints and appeals
Keywords	Scope of the appeals system, clarity, independent decision making body
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that MusiQuE’s appeals procedure only applies to the reviews that result in an accreditation decision, but does not cover the agency’s enhancement type of reviews. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the enhancement reports, these should equally be subject to appeal in line with the standard. During its site-visit the panel further learned that it is not always clear to stakeholders involved how a complaint will be approached and how exactly are responsibilities defined. The Register Committee noted that MusiQuE has an Appeals’ Committee, formed of one standing member and one individual appointed in response to each specific appeal. The panel remarked that the Board of MusiQuE is the decision-making body responsible for endorsing the judgement of the review team and also the body nominating the members of the Appeals’ Committee, which may raise a concern of potential conflict of interest. The Register Committee therefore underlined the panel’s recommendation of reviewing the procedure for appeals in order to guarantee a fair decision making and avoid such potential conflicts of interest. Considering the several above-mentioned issues the Register Committee could not follow the panel’s conclusion of (substantial) compliance but considered that MusiQuE complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	conflict of interest in review processes
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (24/10/2020)
RC decision	Compliance

“The Register Committee noted that MusiQuE has since its last review created a permanent student seat on its Board (as of November 2017). While the Register Committee welcomed this change, the Committee further underlined the review panel's recommendation on the need for a more diverse range of stakeholders to be involved in the governance and work of the agenc. The Register Committee sought clarification from the panel whether it had considered the risk that the critical friend reviews could have a supporting or consulting role, which could lead to the quality enhancement review issuing judgments on matters that MusiQuE's critical friends have assisted to develop or implement. The panel was asked how it satisfied itself that MusiQuE prevents such potential conflicts of interest.The panel explained that it considered the critical friend review as a first phase of the Quality Enhancement review. The panel argued that this process did not result in conflicts of interest as the MusiQuE processes were similar to other processes where institutions are required to follow-up on previous peer reviews and consider inputs from stakeholders”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.3 Independence
Keywords	nomination and dismissal of the Board members of the organisation
Panel conclusion	Full compliance
Clarification request(s)	Panel (24/10/2020)
RC decision	Compliance

“The panel noted that since its last review the MusiQuE Board now makes the final decision on its own composition. Considering the changed arrangements, the Register Committee was unclear how the members of the MusiQuE Board could be dismissed and if so on what ground. The Committee has therefore sought further clarifications from the pane. In its response, the panel explained that the absence of an external body to appoint or dismiss Board members was something specific to the legal form of a Foundation in Belgium. The panel further referred to the agency’s statutes, which provide the possible reasons/circumstances for the ending of the mandate of one board membe. The Committee noted that the panel found the current organisational arrangement to be adequate in guaranteeing the independence of the Board and its members in the context of an international quality assurance agency.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.5 Resources
Keywords	financial sustainability (relience on its founding organisation)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last review the Register Committee noted that MusiQuE did not have sufficient firm agreements with higher education institutions to achieve financial self-sustainability and thus concluded on partially compliance. The Register Committee learned that since its last review, MusiQuE has managed to expand its activities, and to increase its annual income from its reviews and other activities substantially. MusiQuE's has also reduced its reliance on the Association Européenne des Conservatoire (AEC)’s financial support, who has been covering a high proportion of its staff costs. The Committee welcomed these positive developments and concurred with the panel's conclusion that MusiQuE complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	publication of critical friend reviews
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel reported that MusiQuE has recently introduced critical friend reviews as a modified version of MusiQuE’s quality enhancement reviews. The new addition includes annual visits by ‘critical friends’ to various departments and programmes which result in specific reports; these feed into the agency’s self-evaluation and final quality enhancement review report.

The Register Committee noted that the agency does not publish the specific reports resulting from the critical friend review, neither separately nor together with the final quality enhancement review report. The Committee has therefore asked the panel to clarify its stance on this practice considering the requirement of the standard 2.6.

In its clarification letter, the Panel explained that the critical friend review report was one element of the review process and one of the documents informing the quality enhancement review report. The panel did not find it necessary to publish the outcomes of critical friend reviews as maintaining the report in confidence gave the “critical friends” the liberty to be more straightforward and explicit.

The Register Committe, underlined that the agency is expected to publish full reports prepared by the experts. In the Committee's understanding, these need to cover the full evidence reviewed and the full analysis made. Hence, where several reports are produced within one procedure, such as the critical friend reports, all reports should be published.

The Register Committee added that it would be sufficient to publish the critical friend reports together with the final external review report, rather than separately.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.4 Peer-review experts
Keywords	Student involvement in panels
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that QANU has, since its last review, taken steps towards the inclusion of students in the assessment of research units/PhD programmes. QANU agreed with VSNU, KNAW and KWO (the organisations who developed the Standard Evaluation Protocol for these assessments) to include students on the experts panels in the form of a pilotscheme, starting in

2019. The Register Committee found that QANU has so far finalised one assessment of a research unit/PhD programme in 2019 (report published as of 15 March 2019), but that the expert panel for that review did not include a student.While the Register Committee recognised and welcomed the clear stepstaken by QANU so far, it considered that the involvement of students on research unit/PhD assessment panels is so far at the stage of a pilot and notyet implemented in practice. The Committee was therefore unable to concur with panel’s conclusion of (substantially) compliant but found that QANU stillcomplies only partially with ESG 2.4. The Register Committee further underlined the review panel’s recommendation to ensure that students become a constituent element of the research units/PhD programme assessments panels. The Committee further added that students involvement should not be limited to the assessment of specific aspects, but that they are to be fully involved along all expert panel members.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.7 Complaints and appeals
Keywords	Absence of the body responsible for handling complaints (established in renewal)
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that QANU has revised its complaints and appeals procedure and established an independent committee to consider its appeals.The panel noted that institutions can now submit an appeal against all external quality assurance activities of QANU and the decisions are taken by an Appeals Committee, instead of QANU’s director.The panel’s analysis further show that QANU offers the possibility to institutions to express their dissatisfaction about the conduct of the external quality assurance activity carried out by QANU or misbehaviour of people acting on behalf of the agency. The agency has also established different processes in the handling of complaints i.e. if a complaint refers to the behaviour of a staff member of QANU this is processed by the director; if a complaint is about the director of the agency, the complaint is processed by the chair of the Board etc.Having considered the changes put in place by QANU since its last external review, the Register Committee was able to follow the panel’s judgement that QANU now complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of QA and consultancy activities
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that the agency put in place a policy regarding the separation of the agency’s consultancy and assessment activities which dictates that if a project coordinator is involved in providing consultancy services to a higher education institution, he/she is not allowed to act as a secretary in an assessment procedure for a period of at least five years. The panel further commented that QANU’s management have shown high awareness of of the need to avoid conflicts of interest and to ensure QANU’s independence in its activities. With regards to the stakeholder involvement in the governance and work of the agency, the panel found that QANU has formalised the involvement of students in the Board of the agency following its change in Statutes. While the Register Committee welcomed the involvement of students, the Committee further underlined the panel’s recommendation of ensuring a broader stakeholder involvement in the agency’s governing structure. In view of the changes introduced by the agency the Register Committee was able to follow the panel’s conclusion that QANU complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.4 Thematic analysis
Keywords	Introduced policy for thematic analysis
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that QANU approved a new policy for thematic analysis in October 2018, which defines explicit aims and objectives for various analysis. The panel stressed that QANU acknowledged its responsibility for producing thematic analysis as a way of contributing to the further development of the university research sector in the Netherlands. The panel further added that QANU has demonstrated capacity to use the experiences it gathered, to reflect on them, to share them and to publish outcomes through thematic analysis. Following the evidence and analysis provided by the panel, the Register Committee concurred with the panel’s conclusion that QANU now complies with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Internal quality policy
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“ The panel confirmed that the agency had some procedures and processes in place aiming to support, reflect and improve its own day-to-day operations (i.e. Quick Reference Guide, annual reports, bi-weekly staff briefings, evaluation of assessments). The panel found that QANU did not have an internal quality assurance policy or an integrated quality management system (related to i.e. human resources, briefing of panels, collegial feedback on draft reports). In its additional representation the agency argued that the necessary components of a quality policy are in place and described briefly in QANU’s Quick Reference Guide. In terms of a cohesive and integrated quality plan the agency stated that it had started developing such a plan that will be an integration of the processes and procedures QANU has in place. Given the commendations by the panel on the internal quality assurance processes, e.g. good procedure for monitoring and improving the quality of the staff, good quality of assessment reports, QANU stated it did not understand the Committee’s conclusion of partial compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.6 Reporting
Keywords	Lack of public reports for evaluations of new institutions (authorisation)
Panel conclusion	Full compliance
Clarification request(s)	Agency (03/05/2025)
RC decision	Partial compliance

“The panel noted that the assessment of institutions' programmes development plans is “a procedure to authorise their operation” (under ESG 2.3) and that the resulting reports "'are all issued on demand from universities and are not published' because programmes have not started yet” (under ESG 2.6).

The standard requires that all reports be published for all external quality assurance activities. Based on the information in the report the Register Committee understood that the assessment of institutions' programmes development plans is part of an authorisation process in which institutions are assessed against preset criteria, and thus should be considered a quality assurance process. Unlike for consultancy services or similar, which would be outside the scope of the ESG, the Register Committee therefore considered that the standard applies here.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.4 Thematic analysis
Keywords	absence of regular analysis based on agency’s findings
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel specifically recommended that the agency “publishes reports of thematic analysis every year”. While the standard requires that such analyses be published "regularly”, it does not impose a specific cycle.

The Register Committee therefore underlined that this recommendation should rather be considered a suggestion.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	not clear how agency ensures ESG compliance when using non-registered QAAs’ results
Panel conclusion	Full compliance
Clarification request(s)	Panel (03/05/2025)
RC decision	Partial compliance

“The panel pointed out that it was “assured by the agency that the same criteria and guidelines were applied”. The panel noted it had discussed the issue with the madri+d Accreditation Commission, which “confirmed its focus on being assured that meeting the ESG standards are a key focus of such accreditations”.

The external review report and the panel’s clarification did not refer to any evidence or further details to support this assurance. The Register Committee noted that at least two actual cases (accreditation based on ABET accreditation, https://data.deqar.eu/report/8971/ and https://data.deqar.eu/report/9129/) raised concerns insofar as the ABET reports, forming the basis for these decisions, are not published as required in ESG 2.6.

The rather generic statements, combined with these two examples, did not demonstrate sufficiently how ESG compliance is assured for reports by other, non-registered agencies. The Register Committee was therefore unable to concur with the panel's conclusion, but considered that madri+d only partially complied with standard 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.3 Implementing processes
Keywords	Lack follow-up procedures
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“ In its previous decision of inclusion (05/06/2015) the Register Committee flagged for attention whether follow-up procedures were introduced for degree assessments between the first ex-post accreditation and consecutive periodic re-accreditations. ACSUCYL has since its last review introduced a new system of annual follow-up procedures. The panel also confirmed that it was convinced that the follow-up procedures are well and consistently implemented. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.4 Peer-review experts
Keywords	student involvement
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (03/05/2025)
RC decision	Compliance

“The review panel noted that “when the nature of the assessment in question so requires, every effort is made to include non-academic experts [...] as well as students who are experienced in quality assessment in higher education“ (ERR, p. 39). As the Register Committee found the analysis unclear as to whether students are consistently involved in all ACSUCYL’s review panels, the Committee asked the panel for further clarifications. The panel explained that all evaluation procedures within the scope of the ESG include one student member. The panel further added that students are regarded as equal members of peer review expert panels.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.6 Reporting
Keywords	publication of negative reports
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (03/05/2025)
RC decision	Compliance

“While ACSUCYL publishes the results of its external evaluations, the Register Committee was unclear on whether the agency also makes public the assessment reports with a negative result. The Register Committee therefore sought further clarification from the panel. In its clarification response, the panel stated that according to ACSUCYL’s handbook, the assessment reports are published once the University Council, the body responsible for taking the formal decision concerning verification and modification of curricula takes its decision. The panel added that it does not have any indication to show that negative reports of this activity are not published (in case a decision is taken).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee; Clarification of appeals’ procedure
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision for renewal, the Register Committee flagged for attention the appeals system, as the panel recommended that ACSUCYL should revise its appeals system so that a separate committee handles appeals. The external review panel confirmed in its external evaluation report that ACSUCYL established an independent body, the Guarantees Commission, that is responsible for examining appeals or complaints in areas where the agency is competent. For procedures where the final decision belongs to the University Council or Regional Ministry (i.e. verification/modification, accreditation renewal, evaluation to create, recognize, modify or withdraw university centres), the appeal is considered by the corresponding decision making body. ACSUCYL provides input into the consideration of these cases, but it does not decide. Within ACSUCYL, the request will be sent to the Guarantees Commission, which consults the relevant Assessment Commission, before preparing an answer. If the appeal is granted, ACSUCYL will be requested to review its earlier conclusion. The Register Committee underlined that ACSUCYL’s complaints policy should communicate better that higher education institutions have the possibility to raise matters about the conduct of the process or those carrying it out (i.e. complaints in the understanding of the ESG), even in such procedures where the final decision is taken by other bodies.”

Full decision: see agency register entry