Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in agency’s decision making
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (06/05/2025)
RC decision	Partial compliance

“There is a lack of student representation. Students are neither involved in the governing body nor in the bodies that review and design the agency’s procedures or take decisions on the adoption of such procedures (Governing and Advisory Board). The agency stated (in its Statement to the Review Report) that the Student Board is an Advisory Body and that students can contribute in that capacity to the governance and work of the agency. The Committee underlined the limited involvement of students in the agency’s governance and work. While the legislation does not prescribe their involvement in the agency’s Board of Directors, ACSUCYL may nevertheless improve its consultation process and also request a change of its current legal framework.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.3 Independence
Keywords	Organisational independence; Appointment of the members by minister
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“In terms of organisational independence, the evidence presented by the panel shows that members of the Governing Board are appointed by the regional minister responsible for universities and that the Governing Board has a strong representation of its regional Government, including the Chairperson. The agency is largely dependent on the regional Government also for the approvals and hiring of new staff and the annual approval of its budget. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/11/2020
Standard	2.6 Reporting
Keywords	Quality of reporting
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Considering the quality of reports, the Committee considered the panel’s assessments that BAC’s reports “still fail to completely meet the expectations of this standard as they are not yet ‘full’ reports” (Review report p. 40)

24. The panel further pointed out that the reports provide limited qualitative insight and there was no evidence of how the Accreditation Committee was able to consider the effectiveness of a higher education institution’s internal quality assurance process. In its additional representation BAC stated that it is in the process of addressing the shortcomings of its reporting format and that it is committed to publishing the negative outcomes of its reviews While the Register Committee acknowledged agency’s progress towards more qualitative reportin,, the Committee noted that a full redraft of BAC’s reporting template is only expected to be completed in the following years”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/11/2020
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to thematic analysis; Quality of analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel found that BAC’s thematic review report provided a limited analysis, and was rather descriptive by simply summarising the content of inspection reports. Overall, the review panel felt there were still significant weaknesses in BAC’s approach to thematic analysis. In its additional representation, BAC agreed with the assessment of the panel and committed to prepare more meaningful thematic analysis that will serve to improve key areas related to the agency’s work by January 2021.While the Register Committee acknowledged the agency’s work towards improving its thematic analysis, the Committee remarked that such changes have not yet been implemented.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.1 Consideration of internal quality assurance
Keywords	Part 1 insufficiently covered; Lack of clear guidance what should be evaluated by experts
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Reviewing each of the agency’s procedures individually the review panel showed that the independent evaluation procedure (international accreditation of educational programmes) does not sufficiently cover aspects related to ESG Part 1, concerning student- centred learning and teaching, the system for consideration of students’ appeals and complaints.In its additional representation the agency stated that new indicators have been added covering these matters and provided a full self-assessment with the mapping of its criteria to the ESG. In case of professional-public accreditations the panel was not able to gather conclusive evidence about what criteria are checked by the expert panel in these reviews. Following the analysis of AKKORK’s own standards and their correlation with ESG (according to the agency’s additional information) the Register Committee took note of the mapping and revisions, but could not conclude whether all concerns of the panel have been addressed. The Committee further underlined that the revised criteria still had to be officially approved, tested and implemented by AKKORK in its professional-public accreditation procedures. The Register Committee noted that experts do not have clear guidelines on what they are expected to evaluate and how to refer back to the agency’s own criteria. In its additional representation AKKORK provided its revised guidelines (as of 30/01/2020) describing its procedures and the assessment criteria that experts are expected to follow. The Register Committee welcomed the revised version of the guidelines, but noted that its use and implementation has yet to be reviewed by an external review panel. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.2 Designing methodologies fit for purpose
Keywords	Clarity of activities; lack of stakeholder involvement in the development of methodologies and criteria;
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Considering the design of AKKORK’s methodology of external QA procedures, the panel noted that the aims of the different activities were not clearly differentiated and that there were inconsistencies between the different language versions of the AKKORK ‘s website (English and Russian). In its additional representation the agency responded that it has made revisions to the information on its website. While the Register Committee could verify the publication of the procedures, the Committee further noted that the agency also has ‘on offer’ the activity quality assurance of educational programmes on the level of higher education and remains to demonstrate that the activity has been defined and designed to achieve the objectives set for it, as required by the standard. The panel further commented on the lack of involvement of external stakeholders, apart from the representatives from its own bodies, in the design and continuous improvement of the offered procedures. The agency commented in its additional representation that it has developed a Regulation on collaboration with partners designed to be implemented in AKKORK’s daily routine. The Register Committee welcomed the thorough work in the development of a cooperation regulation with stakeholders, but could not confirm that the Regulation is already in effect as no evidence of the stakeholders' engagement was provided for in the recent substantive changes introduced by the agency. ”

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	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“In its decision of inclusion, the Register Committee noted that AKKORK’s follow-up procedures were not consistently implemented for all off the agency’s external quality assurance activities and therefore flagged this matter for future attention. In its 2019 review report, the panel showed that AKKORK had taken steps to address its flag by including follow-up processes as part of its contracts with higher education institutions. The panel found that - while follow-ups are not part of all contracts signed with the reviewed institutions, that they are nevertheless carried out after a conditional accreditation. The panel further underlined a number of shortcomings related to AKKORK’s independent accreditation reviews at institutional level and AKKORK’s IQAS procedures. Since these procedures are no longer on offer by AKKORK, the Register Committee found that the panel’s concerns were therefore addressed”

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; Mismatch between number of experts enlisted in the reports and number of experts required according to agency’s review methodology; Unavailability of some reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged AKKORK’s involvement of students in its previous decision of inclusion. The panel received confirmations during its multiple interviews that all of AKKORK’s peer review expert groups now included a student member.

The panel’s findings nevertheless show inconsistencies in the number of experts, listed by AKKORK in its published reports and the number of experts expected to be involved according to AKKORK’s own methodology. In particular, the review panel expressed concerns about the use of single experts for professional-public accreditations, although it was told that not all panel members were in fact listed in the prepared reports. The panel therefore concluded that while the formal procedure in the composition of review panel was met on paper, the practice differed. The Register Committee noted from AKKORK’s additional representation that its procedures are published, but noted that the above raised concerns were not addressed and remain unresolved. The Register Committee noted from the statement by the agency - in its further information on the report and additional representation - that the links have been checked and all review panel members are now listed in the published reports. Following a check of the agency’s website, the Register Committee found that a number of reports still have broken links (see the agency’s Register of programmes, under the Russian version of its website). ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.5 Criteria for outcomes
Keywords	publication of procedures; Criteria are not applied consistently; Lack of consistency in decision making
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of inclusion, the Register Committee flagged AKKORK’s publication of detailed criteria for all its procedures. In its additional representation AKKORK stated that the detailed procedures and criteria for decisions have now been published. The Register Committee could verify that that the criteria are now published. The panel learned that in many cases experts relied on their personal review experience, rather than following AKKORK’s guidelines and methodology, and that AKKORK’s criteria were not applied consistently in the agency’s decision making. According to AKKORK’s revised Guidelines for Reviewers on Conducting External Evaluation of Education Quality and Quality Assurance at Programme level (adopted as of 30/01/2020), experts are expected to follow a clear methodology in their evaluation, and not their personal review experience. In its additional information to the review report, AKKORK stated that its decision-making criteria had been checked for consistency following its external review. The agency further provided a mapping of the scale for its decision making on programme accreditation ”

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 all reports
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its previous decision of inclusion, the Register Committee flagged AKKORK’s practice of ensuring the consistent publication of all external evaluation reports. In its additional information and additional representation to the review report the agency claimed that all its review reports and decisions were now published on its website, including the reports from its professional-public accreditation activity. The Register Committee could verify that with a few exceptions all of these reports are now published by the agency on its website i.e. links included under the Russian version of its agency’s website under Register of programmes. ”

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
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that appeals procedures are published together with every procedure on the agency’s website, except the independent accreditation at the institutional level. To date AKKORK has only received a complaint, but no appeals. The panel’s analysis show that AKKORK’s Appeals Committee involves members of the International Accreditation Council, the same body that is involved in the accreditation decision-making process in addition to the members of its Supervisory Board. The Register Committee underlined that in such cases the impartiality of the decision making in considering appeals is not ensured. In its further information to the review report, AKKORK stated that its regulation on appeals have been updated and that its new appeals body, appointed by AKKORK’s Supervisory Board, includes members from the agency’s partner organisations. In its additional representation the agency has further provided a link to its revised regulation on appeals. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Mission implementation in daily work; Clear distinction between activities; Stakeholders’ involvement; Involvement of students
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its analysis the panel commented that it was unclear which is the body in the agency responsible for developing a strategy, how AKKORK’s procedures are developed and what types of activities and services the agency is offering. Furthermore the panel could not find any clear evidence on how the agency’s mission is translated into the daily work of the agency. The panel also noted that AKKORK’s actual structure and relations between its governing bodies were different to the ones presented in the last version of the statutes, adopted in

2013. While stakeholders are part of AKKORK’s multiple bodies, the panel noted that their involvement could be broadened. In particular, the panel recommended that students be involved also in other bodies than the Advisory Council, where only representatives from professional organisations and higher education institutions are present. The Register Committee noted from the additional information that AKKORK has updated its mission statement and detailed its objectives and main activities on its website. The agency further stated that a new Strategic plan 2020-2024 has been approved by the Supervisory Board and that its Financial Plan also have been updated. The Register Committee could also verify that the new Strategic Plan has been adopted by the Supervisory Board at its meeting on December

2019. While the Committee welcomed the steps taken by the agency to address the panel’s concerns, the Committee further considers that these changes still have to be fully implemented and externally reviewed by a panel, i.e. showing evidence of a robust yearly work planning, implementation of the strategic plan. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to thematic analysis; Absence of regular analysis;
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that the agency has produced two analyses since its last review in 2014, both written in Russian but only published on the English version of AKKORK’s website. According to the panel, the last publication, however, does not meet the requirements of a thematic analysis. In particular, the panel noted the great qualitative difference between the publications, indicating a missing systematic approach to the publication of thematic analysis. The Register Committee underlines the panel’s recommendation that the agency should establish a clear process to address all of its activities in thematic analyses. ”

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	Lack of sufficient and fit for purpose IQA processes; Inconsistency of presentation of internal structures;
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that while the responsibilities in internal quality assurance are defined in the ‘AKKORK Internal Regulations’, the main tool of the agency for internal quality assurance of its activities are the regular staff meetings. The panel’s analysis showed a number of concerns related to the agency’s internal workings, i.e. inconsistencies in the information presented on the agency’s website, the information regarding the publication of the reports or information available on external QA activities on the Russian and English parts of the website; inconsistency in the presentation of the agency’s organizational chart in ‘AKKORK Internal Regulations’ and the structure outlined in the review report, etc.. Considering the above examples, the panel considered that not all outcomes of the agency’s work, especially not the production of documentation, are covered by the existing QA cycles. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.4 Peer-review experts
Keywords	learners in non-traditional higher education provision
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (06/05/2025)
RC decision	Compliance

“While the panel underlined the different status of "listeners", as opposed to “students”, who enrol into these programmes, the Register Committee considered that the institutions and programmes in question were part of the higher education system and their accreditation thus within the scope of the ESG; this was also NCPA's own assessment at eligibility stage.

While the panel considered that, in light of the small number of these accreditations, a stricter judgement had “overstretched” the relevance of the matter, the Register Committee considered that this was not only a matter of numbers. The practice at the time of review meant that two types of accreditations did not fully comply with the standard.

In its additional representation, NCPA explained that it had revised the corresponding regulations and now required the presence of a “listener” (i.e. a student/learner enrolled in a further professional education programme, see above) on the expert panels. [...]

The Register Committee therefore considered that the issue has been addressed and was now able to concur with the panel’s conclusion that NCPA complies with the standard.

”

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	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that AAC-DEVA publishes the full reports of its external reviews, except those with a negative result of its (ex-ante) verification programme. While the review panel found the agency’s explanations – that it is not necessary to publish information about study programmes that are not going to be offered – reasonable, the Register Committee underlined that it can be of interest for the public to know which concepts were denied accreditation and why. In particular, such information is important if the institutions applies for accreditation of the same programme with another quality assurance agency, which needs to be able to find out that it was earlier denied accreditation by AAC-DEVA. In its additional representation the agency stated that it is committed to transparency, but that the publication of the ex ante reports would create confusion among students and might create prejudice against the concerned university. AAC-DEVA added that that the current legal framework in Spain does not allow ex-ante accreditation to be carried out by a different QA agency and that the universities are required to wait at least two years before resubmitting the programme for the ex-ante verification. The Committee however could not follow the agency’s reasoning for not publishing reports where the agency takes a negative decision since such reports have been published in the past by registered agencies (in other regions of Spain and elsewhere), without the risk of confusion. The reputation of a higher education institutions should not be affected by an ex-ante negative report more than the publication of any other report with a negative outcome. The Register Committee added that the higher education institution could always have the option to withdraw the proposal of a study programme before a decision by AAC-DEVA is taken, so as to avoid any public decision from being taken. The Register Committee underlined that the standard requirement is clear, and does not include exceptions in regards to the publication of reports for any form of finalised external QA procedure. ”

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 impartial decision making → lack of an independent appeals committee
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that higher education institutions reviewed by AAC-DEVA may file an appeal before the Universities Council in case of verification/modification, accreditation renewal and institutional accreditation. If the claim is accepted, the appeal is sent to AAC-DEVA where a group of experts who have not intervened in the evaluation that led to the unfavourable decision will revise the report. The Committee underlined that AAC-DEVA’s current appeals process does not fully ensure the impartiality of decision making, as the Universities Council is both the body responsible for the accreditation decisions and the resolution of appeals after such procedures. In case of DOCENTIA, IMPLANTA and the accreditation of foreign language skills, the resolution of the appeal is with the same body who issued the initial decision. Thus the impartiality of the decision making is not fully ensured in any of the external QA activities carried out by the agency. In its additional representation the agency explained that according to the Spanish legal framework the agency cannot exclude the University Council in the consideration of the appeals procedure – in the case of verification/modification, accreditation renewal and institutional accreditation. The appeal is assessed by a commission which includes experts that have not intervened in the evaluation, and following their examination, if the appeal is ratified it will be further submitted to the corresponding evaluation body for reevaluation. The Register Committee noted that AAC-DEVA intends to establish an Appeals Committee to consider all appeals related to the evaluation of programmes. The decision of the Appeals Committee will be binding for the DEVA Director. Furthermore, while higher education institutions have been able to state their dissatisfaction with the review process i.e. by filling in an online ‘suggestions form’, AAC-DEVA lacks a formal procedure that explains what form of complaints may be submitted and considered by the agency. In its additional representation the agency stated that it has designed a specific procedure for complaints as part of its quality management system and that it has updated its online form for the submission of such complaints. The Register Committee could verify that a complaints protocol has been developed and that the modified online form allows the submission of various forms of complaints. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholders’ involvement; Involvement of students; Lack of strategical planning
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted the panel’s concerns in terms of the agency’s engagement with stakeholders. While the agency has strong connections with universities, the relationship with student representatives, and other civic and social groups is very weak. This lack of engagement is reflected in both the composition, working arrangements and internal interaction of the agency’s committees. The Register Committee considered the agency’s explanation that the current regulation of its statutes limit the involvement of students, but the Register Committee underlined that stakeholder involvement such as students is a key requirement of the standard. the agency lacked a strategic focus and that there was no evidence of governance level oversight of strategic planning or review by AAC-DEVA. In its additional representation the agency reported that steps have been already made to ensure the presence of students and professionals in all evaluation committees for ex-ante verification, modification and accreditation renewal. The agency stated that it intends to further strengthen the role of the Technical Committee for Evaluation and Accreditation (CTEyA) by incorporating professionals and by increasing the number of students. Considering the lack of a strategic focus and governance oversight, the agency added that its new Strategic Plan for 2021-2026 is in preparation and that it will reflect the engagement of stakeholders and the different levels of strategic governance. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.5 Resources
Keywords	Allocation of resources; Financial sustainability
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last decision of inclusion the Register Committee flagged AAC-DEVA’s ability to acquire and consolidate the resources required to organise site-visits as part of its periodic re-accreditation procedures. As AAC-DEVA has been able to carry out site-visits within its procedures, the flag has been addressed. The Register Committee noted that AAC-DEVA acknowledged in its SWOT analysis that it did not achieved what it aspired it set out to do in the past five years. These concerns were mainly due to the current organisational structure of the agency and lack of strategic planning which has lead to difficulties in the proper allocation of resources and development of prospective units for the full implementation of thematic analysis. In its additional representation AAC-DEVA stated that it had been able to provide all the necessary resources to set up and maintain its external QA activities and that its budget has been approved without any reductions. Concerning the problems related to the structural organisation of the agency, AAC-DEVA explained that this are addressed in the development of its Strategic Plan. ”

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	Lack of sufficient and consistent IQA processes
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its previous decision of inclusion, the Register Committee flagged the effectiveness of AAC-DEVA’s internal quality assurance arrangements. In May 2018, AAC-DEVA established an Internal Quality Assurance Commission to review its own internal quality assurance methodology, but at the time of the site-visit the agency was still reviewing its internal documentation. The panel saw insufficient evidence of a pattern of continuous improvement in the internal quality assurance of AAC-DEVA. While there has been a spur of activity in preparation for the external review the panel did not consider this was sufficient to achieve meaningful results. In its additional representation the agency reasserted its commitment for improving its internal QA system and that it was in the process of reviewing its Services Charter and setting up a web application designed to support continuous improvement and facilitate the management of the agency’s activities. ”

Full decision: see agency register entry