Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.7 Complaints and appeals
Keywords	Clarification whether the agency addressed complaints and appeals within the same procedure
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted the agency's argument that there was no requirement for an appeals procedure in its case “as IEP evaluations do not result in decisions”. Based on the analysis of the panel, the Register Committee, however, understood and concurs with the panel that IEP's ‘substantive’ complaints are, in fact, appeals in the ESG terminology: they enable the institution to “questions the formal outcomes of the process” (in this case, the evaluation report), where it can “demonstrate that the outcome is not based on sound evidence” (see guidelines to standard 2.7), which IEP’s complaints policy translates to erroneous judgments, erroneous assumption of non-existent factors as facts, failure in exploring relevant facts, and ignoring or misjudging factual base.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.2 Official status
Keywords	agency’s formal recognition
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that IEP itself does not have separate legal personality and therefore it is represented by EUA in all legal and contractual matters. The Committee acknowledged that the recognition of IEP as a quality assurance agency by public authorities is demonstrated by the numerous contracts that IEP (represented by EUA) signed with national authorities for conducting evaluations, or by the selection of IEP as an evaluating body through a public procurement procedure. [...] The Register Committee interprets the requirement of formal recognition in a broad sense and therefore concurred with the panel's conclusion that IEP complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.3 Independence
Keywords	Organisational independence: appointment of the director by the mother organisation, support in terms of pyscial infrastructure, including human and financial ressources
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“While IEP’s Steering Committee has full responsibility for the development of strategies and policies, the Register Committee noted that the Steering Committee ensure the strategic development of the IEP in the context of EUA’s development priorities. Moreover, EUA provides the overall support, including physical infrastructure and financial management through separate accounts; both entities have a shared staff and EUA appoints the Director of the IEP Secretariat. Despite the panel’s view that no benefits would come from legally separating the two entities, the Register Committee considered that IEP continues to be part of EUA and, as such, its organisational independence continues to be constrained by the close link and dependency in both legal and practical terms, even if less so than at the time of the previous review. The Committee concurred with the panel's analysis that IEP operates and undertakes its evaluations independently and that the Steering Committee has full responsibilities for the operations of IEP and its evaluation results. The Committee thus considered that the constrained organisational independence bears a residual risk of a perceived lack of independence, elements of which should be closely considered in IEP’s next renewal of inclusion.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	2.1 Consideration of internal quality assurance
Keywords	Alignment of PKA standards not sufficiently ensured against Part 1 of the ESG
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel noted that criteria for programme evaluation are in line with Part 1 of the ESG. However, the panel expressed concerns with the opinion giving process as the alignment with some standards of the ESG (i.e. 1.2, 1.4) was much weaker or some standards (i.e. ESG 1.7, 1.8 and 1.9) were not specifically represented within PKA’s methodology for this procedure. The agency explained in its statement to the review report that PKA has requested the Minister to extend the scope of information on the proposed regulation in the opinion giving process for study programme, and that the request was accepted in September

2018. PKA further detailed in its Substantive Change Report the new criteria adopted in December 2018 for granting permission to provide a degree programme. The Register Committee took note of the detailed criteria and confirmed that the new assessment framework addresses the standards from Part 1 ofthe ESG more comprehensively. In light of the enacted changes, the Register Committee concluded that PKA now complies with standard 2.1.”

Full decision: see agency register entry

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

“The panel’s findings show that in the opinion-giving process students are not involved as members of review panels. Opinions are prepared by members of relevant Sections or PKA experts, following which the Presidium prepares a resolution that is forwarded to the Minister and highereducation institutions. The panel noted that students are to a certain extent involved as members of the Presidium of PKA. In its statement to the review report PKA acknowledged its shortcomingregarding the student involvement in the opinion giving processes and decided to set up a team of student experts to issue opinions on applications.The Register Committee welcomed PKA’s intention but found that the composition of the relevant sections and experts panels is still unchanged. The Committee further underlined that students are normally expected to beinvolved as part of the peer-review expert groups and to contribute as equal partners. As the current arrangement of PKA could not yet be reviewed by an external panel the Committee was unable to conclude whether the way students are involved meets the requirements of the standard. Register Committee therefore concurred with the review panel’s view and concluded that PKA complies only partially with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	2.6 Reporting
Keywords	Publication of reports for opinion-giving process
Panel conclusion	Partial compliance
Clarification request(s)	Agency (21/05/2019)
RC decision	Partial compliance

“In the previous decision of renewal the Register Committee flagged for attention PKA’s publication of reports of its ex-ante evaluations. The panel’s findings show that while the reports for programme accreditation and resolutions are published the reports and resolutions of the opinion-giving process are however not published online.PKA explained in its statement to the review report that all reports have been published since October

2018. The Register Committee noted that according to the information published by PKA on its website some of the reports of its opinion-giving process are not published and has therefore asked the agency to clarify the delay and timeline of their expected publication.In its clarification letter, the agency explained that the publication of resolutions before 2018 are delayed due to the changes in the legal framework and due to the requirements of the European Unions’ General Data Protection Regulation adopted in

2018. This required changes in PKA’s internal reporting templates and procedures.PKA added that legal grounds for publishing opinion-giving resolutions and reviews was established with its Statute as approved in 2018, but explained that this regulation does not apply retroactively.Having considered the additional clarifications given by the agency, the Register Committee noted that PKA would, however, be able to publish already prepared reports from 2016 and

2017. As this issue was already flagged in PKA’s last application, the Register Committee therefore concurred with the review panel’s conclusion that PKA complies only partially with the standard, pending the publication of the remaining reports.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	clarification of external QA carried abroad
Panel conclusion	Full compliance
Clarification request(s)	Agency (21/05/2019)
RC decision	Compliance

“In its confirmation of eligibility, the Register Committee noted that PKA is expected to also address activities carried out by the agency abroad i.e. in Lithuania. As it was unclear on whether such activities were addressed in the external review of PKA, the Committee asked PKA for further clarifications. PKA explained that the external QA activities carried out in Lithuania only extended to one foreign branch of a Polish higher education institution and that the procedures and criteria used were identical with those applied in the case of national HE providers.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.5 Resources
Keywords	human resources
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its analysis, the review panel commented that, while the situation of resources is acceptable in the short to medium term, some of PKA’s activities “cannot be addressed appropriately due to the lack of resources”. The Panel further expressed concerns with regards to the high turnover of the Bureau staff, who perform the functions of secretaries for the sections Committee. The Register Committee further underlined the review panel’s recommendations on the need to increase the agency’s capacity to perform thematic analysis. The Register Committee was therefore unable to follow the panel’s conclusion of (substantially) compliant but concluded that PKA complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.1 Consideration of internal quality assurance
Keywords	Aspects of ESG 1.1 – 1.10 insuficiently covered.
Panel conclusion	Partial compliance
Clarification request(s)	Panel (20/02/2020)
RC decision	Partial compliance

“The panel noted that ANVUR fully integrates Part 1 of the ESG in AVA procedures, but that AFAM and PhD accreditation procedures cover only some aspects of ESG 1.1 – 1.10. In its additional representation ANVUR explained that AFAM and PhD accreditation procedures are limited in scope due to the existing Italian legal framework. ANVUR further added that it had already taken steps to integrate aspects of ESG 1.1 - 1.10 in these procedures by revising its own methodologies and guidelines for AFAM procedures and by testing its new preliminary evaluation protocol for PhD Programmes during two institutional visits. The Register Committee welcomed that ANVUR has intensified its dialogue with the relevant Ministry in order to review the appropriate regulations for its AFAM and PhD procedures, but considered that the changes have not yet been enacted and the agency has thus not yet fully addressed its compliance with ESG 2.1 in practice.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.4 Peer-review experts
Keywords	lack of student experts in some review panels
Panel conclusion	Partial compliance
Clarification request(s)	Panel (20/02/2020)
RC decision	Partial compliance

“In its additional representation ANVUR acknowledged the lack of student experts in review panels, and referred to the involvement of students in the internal consultation process on new study programmes. ANVUR added that starting from November 2019, the agency has included (PhD) students in the evaluation groups for PhD programmes at two institutions. The agency also presented its plans to involve students in the AFAM’s external reviews, starting with a pilot project during

2020. ANVUR further stated that starting in 2021 the fees will be aligned between the faculty panel members and student panel members. The Register Committee considered that if student experts have an equal role in panels there is no ground for paying them differently, and welcomed ANVUR's commitment to change its practice in that regard. The Register Committee underlined that the consultation of student representatives in the institutions' internal preparation processes for new study programmes cannot replace the requirement of the standard, i.e. that students are part of ANVUR's expert groups.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.6 Reporting
Keywords	Publication of sysntetic reports for its main EQA
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ANVUR only publishes synthetic reports, resulting from its AVA system reviews, while the experts’ full reports from its other external QA activities have not been made available to the general public. The Register Committee underlined that while higher education institutions may decide to publish the reports on their own website, that ANVUR is expected to publish itself the full reports by the experts and that it should make its reports and decisions clear and easily accessible to the academic community, external partners and other interested individuals. In its additional representation, ANVUR stated that the new AVA guidelines would address the issue of the publication of full reports and final decisions. As from the second round of the institutional accreditations in 2021, ANVUR would publish its full AVA reports; the same would apply to reports resulting from its other activities. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.7 Complaints and appeals
Keywords	Implementation of an appeals process and independent appeals body.
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (13/07/2025) Panel (20/02/2020)
RC decision	Partial compliance

“The panel noted in the review report that a clear and transparent formal complaints procedure within ANVUR was not yet fully developed. The panel also noted that there was no specific appeals committee, but that the Governing Board fulfilled both the role of the accreditation body and that of the re-examination body. The Register Committee further noted that the agency has no clear processes in handling complaints (EER, p. 51-52). In light of these concerns and the panel’s conclusion of compliance, the Register Committee sought further clarifications. The panel responded that the spirit of the standard was followed in practice, although the clarity and transparency of appeals processes could be further improved. In its response letter, ANVUR explained that its Governing Board had now approved the establishment of a separate Appeals’ Committee, which will include a member from ANVUR’s Governing Board, one member appointed by the Board of Rectors of Italian Universities and one member from the National Authority for anti-corruption, transparency and public procurement (ANAC).”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of activities within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (20/02/2020)
RC decision	Compliance

“The Register Committee found the presentation of the accreditation of post-graduate programmes in medicine and healthcare inconsistent with the presentation of the activity on ANVUR’s website, where the activity was described together with ANVUR’s accreditation of PhDs programmes, as an accreditation activity under the responsibility of ANVUR. The Committee therefore underlined the panel’s remarks (letter of 22/10/2019) that in order to avoid misunderstandings, ANVUR should make a clearer description of its different activities on its website. In its additional representation ANVUR presented the clear distinction of its activities, which was published on its website. ANVUR created separate pages which clarifies transparently the activities within and outside the scope of the ESG. As the issue of a clear separation of external QA activities within and outside the scope of the ESG was addressed, the Register Committee was able to conclude that ANVUR now complies with the ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.3 Implementing processes
Keywords	strengthening follow-up procedures for voluntary international reviews
Panel conclusion	Full compliance
Clarification request(s)	Agency (20/05/2019)
RC decision	Compliance

“The external review panel noted that for (voluntary) international accreditation procedures “the full responsibility to request any kind of follow-up lies in the hands of the institution”.The Register Committee considered the clarification by Unibasq that it follows up programmes' improvement plans in its international quality assurance activities, which is mentioned in the relevant protocol. Having considered Unibasq's clarification, the Register Committee was ableto concur with the panel's conclusion of compliance.The Register Committee, however, encouraged Unibasq to look into possibilities to strengthen its follow-up procedure for (voluntary) international reviews, and to clarify the expectation towards HEIs regarding the follow-up.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.4 Peer-review experts
Keywords	Involvement of students in review committees
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the previous review this standard was flagged due to the fact that the regular involvement of students on all review committees was yet to become practice.The Committee noted that steps have been taken in order to ensure regular involvement of students. Participation of students in evaluation procedures isguaranteed by the Basque Country Act 13/2012.The Register Committee therefore concluded that the flag has been addressed and concurred with the panel's conclusion that Unibasq (substantially) complies with the standard”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In the last review of the agency the Register Committee flagged for attention the publication of reports for evaluation of study programmes and monitoring reports of study programmes, which then were only communicated to the interested party.The review panel found that Unibasq published all reports, except for the ex-ante accreditation reports on programmes that have not been successful.In its additional representation Unibasq confirmed that it does not publish reports for the from ex-ante accreditation, arguing that it would be confusingfor readers to find information on a study programme that will never exist. Unibasq did not express any intention to change this practice in future.The Register Committee underlined that all reports should be published as required by the standard. The Committee underlined that even if a study programme will not be offered 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 same programme applies for accreditation by another agency, which needs to be able to find out that it was earlier denied accreditation by another agency.As the flag was largely, but not fully, addressed the Register Committee did not concur with the review panel’s conclusion of compliance, but concluded that Unibasq still complies only partially with ESG 2.6”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.7 Complaints and appeals
Keywords	unclear process for handling complaints
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In order to improve the appeals procedure, the former Ethics Committee became the Ethics and Guarantees Committee, which was composed of members who play an active role within the agency. The review panel noted that the composition of the Committee was limiting its independence. The Register Committee underlined the recommendation of the panel that the Ethics and Guarantees Committee be composed of members who are independent from the agency and the Basque higher education system. In its additional representation, Unibasq stated that the composition of the Committee had been changed. The new Ethics and Guarantees Code, which was approved by Unibasq’s Governing Council, established that the Committee is now composed of experts from outside the Basque University System, who moreover cannot be part of any other Unibasq body or committee. The Register Committee was able to see the new composition on Unibasq’s website. Furthermore, while the panel confirmed that Unibasq has developed a clear appeals processes, it referred to “a more general procedure for the reception and handling of complaints and suggestion”, but did not analyse that in detail. In its additional representation, Unibasq did not comment further on the complaints procedure. Given the unclear process for handling complaints, the Register Committee remained unable to concur with the review panel’s conclusion of compliance, but concluded that Unibasq complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clasification of Titulos propios
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (20/05/2019)
RC decision	Partial compliance

“The Register Committee sought and received clarification regarding the evaluation of “títulos propios”. Unibasq clarified that these activities were not listed in its application for renewal of registration because Unibasq “realized that it was more a consultancy activity as Unibasq just provides an external expert report” and thus did not consider them as activities within the scope of ESG.In support of its classification, Unibasq stated that it acted only as a subcontractor to the UPV/EHU and had no own responsibility for the review process or the outcomes. The Register Committee also noted that Unibasq does not provide “accreditation” of ‘títulos propios”, contrary to what was published by UPV/EHU. Unibasq, however, stated on its website that it “will evaluate and certificate” those degrees.Unibasq further noted that the misunderstandings were caused by a discrepancy between the internal regulations of the UPV/EHU and the public information on their website, stating that some programmes are accredited by Unibasq.Having considered Unibasq's response, the Register Committee accepted that the evaluation of “títulos propios” may be classified as consultancy service performed by Unibasq to UPV/EHU. The Register Committee further considered how Unibasq ensured a clear distinction from its external quality assurance activities within the scope of the ESG (see EQAR Policy on the Use and Interpretation of the ESG, standard 3.1 and Annex 5). The Committee noted that such a clear distinction was particularly crucial in this case, given that the terminology and the characteristic of the activity caused an actual risk of confusion with ESG activities.The Register Committee concluded that the presentation on Unibasq's website was misleading and did not ensure clarity as to the different nature of these evaluations; it thus considered that Unibasq did not comply with the standard.In its additional representation, Unibasq stated that it held specific meetings with the UPV/EHU, sent a formal letter regarding this issue and elaborated a new agreement with the UPV/EHU, which was approved by Unibasq’s Governing Council. As stated in the agreement, the evaluations of “Títulos propios” are consultancy activities which cannot be represented as ”Accredited, validated or reviewed by Unibasq”. In addition, Unibasq removed from its website the information that could have been misleading about “títulos propios” previously. The Committee, however, noted that UPV/EHU continues to refer to an “external report” by Unibasq in its advertisement of “títulos propios”.The Register Committee welcomed Unibasq's steps that were taken to clarifythe status of this activity and to avoid further misinterpretations. At the sametime, the Register Committee considered that it cannot be fully determined at this stage whether the new communication is fully clear to all stakeholders and avoids any misrepresentation; this should thus be analysedin the next external review of Unibasq.The Register Committee remained unable to concur with the panel's conclusion of compliance but concluded that Unibasq now complies partially with standard 3.1”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the previous review the panel found that Unibasq had yet to produce a system-wide analysis and there was a lack of sufficient resources which is why this standard was flagged.The panel recognised that Unibasq has made clear progress in this area in recent years. The reports that agency produces show a clear shift from the evaluation of the procedures to a genuine thematic analysis (see page 24 of the report).The Committee concluded that the flag has been addressed and concurred with the review panel’s conclusion that Unibasq complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.5 Resources
Keywords
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the last review of the agency the Register Committee expressed concern regarding Unibasq’s capacity to ensure adequate resources for the increasing number of its activities.In the meantime, the agency has received additional funds which have allowed the agency to play a very active role in the international quality assurance community. The panel commended the agency for the achievements and the active role.The Register Committee considered that the flag was addressed and therefore concurred with the panel’s conclusion that Unibasq complies with ESG 3.5.”

Full decision: see agency register entry