Database of Precedents
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3.6 Internal quality assurance and professional conduct – SQAA – Partial compliance (2019) Effectiveness of agency’s IQA
SQAA
Application Renewal Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 3.6 Internal quality assurance and professional conduct Keywords Effectiveness of agency’s IQA Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “When admitting SQAA to the Register, the Committee noted the 2013 panel's recommendation that SQAA systematise its internal quality assurance processes. According to the panel's report, SQAA has further systematised its internal quality assurance system.The Register Committee, however, also noted the review panel's critical appraisal of SQAA's interaction with the different stakeholders from different types of higher education institutions, and the question raised whether its quality policy was shared by all stakeholders. ”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – NOKUT – Partial compliance (2018) Insufficiently addressing ESG Part 1 in cyclical audits
NOKUT
Application Renewal Review Full, coordinated by ENQA Decision of 06/12/2018 Standard 2.1 Consideration of internal quality assurance Keywords Insufficiently addressing ESG Part 1 in cyclical audits Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “ The Committee, however, noted that the cyclical audit does not include consideration of ESG 1.3, 1.4 and 1.5, as indicated by the panel's comments[...]. While NOKUT stated that these standards were anyway checked in the programme or institutional accreditation, the Committee considered that universities – once they obtained self-accrediting power – only undergo cyclical audits. As a result, these standards were not regularly considered for universities.”
Full decision: see agency register entry
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2.3 Implementing processes – NOKUT – Compliance (2018) light systematic follow-up approach (compliant)
NOKUT
Application Renewal Review Full, coordinated by ENQA Decision of 06/12/2018 Standard 2.3 Implementing processes Keywords light systematic follow-up approach (compliant) Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The panel noted that “actions taken by the institutions after the audit are not checked comprehensively”. While the panel noted that NOKUT provided an avenue for follow-up through seminars and conferences organised to discuss the audit findings and recommendation, it did consider those to be a systematic follow-up and noted that “the institutions do not feel obliged to implement the recommendations received”. The Register Committee considered that a very “light” approach to follow-up can be appropriate for (purely improvement-oriented) recommendations from an audit with an unconditionally positive outcome. Moreover, it considered that it was in the nature of a recommendation that there is no obligation to implement it.”
Full decision: see agency register entry
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2.4 Peer-review experts – NOKUT – Partial compliance (2018) student involvement in pilot procedures
NOKUT
Application Renewal Review Full, coordinated by ENQA Decision of 06/12/2018 Standard 2.4 Peer-review experts Keywords student involvement in pilot procedures Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that there was no systematic inclusion of students in all expert groups for initial, paper-based accreditation as yet, but that the inclusion of students in these expert groups was currently piloted.[…] the Register Committee concluded that the flag has only been partially addressed so far, pending the pilot advancing to become a full regular part of the process.. The Committee further noted that there were no students included in the panel for the pilot on Combined Education and Research Evaluations, but appreciated that the panel was confident that students would be involved in case this activity became permanent.”
Full decision: see agency register entry
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2.7 Complaints and appeals – NOKUT – Partial compliance (2018) Absence of a formal complaints procedure
NOKUT
Application Renewal Review Full, coordinated by ENQA Decision of 06/12/2018 Standard 2.7 Complaints and appeals Keywords Absence of a formal complaints procedure Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted the panel's analysis that the complaints procedure “is less clearly defined”. While the Committee acknowledged that the prevailing culture of dialogue meant that institutions were aware of their opportunities to voice complaints, it considered that the possibility to complain and the related procedures should be explicitly spelled out, e.g. in the relevant guides for institutions, as required by the standard.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AIC – Partial compliance (2018) Functioning of the appeals processes; no possibility to appeal with the body that carried out the review
AIC
Application Initial Review Full, coordinated by ENQA Decision of 06/12/2018 Standard 2.7 Complaints and appeals Keywords Functioning of the appeals processes; no possibility to appeal with the body that carried out the review Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that higher education institutions can file appeals for the decision taken by the AIC committees on the accreditation of study directions (CAS) and the licensing of study programmes (CLSP). In such cases the chairperson of the agency’s board reviews the conclusions of the Appeals Committee and takes the final decision on the appeal (review report p. 57). The Committee found that as long as the final decision may be changed by the chairperson of AIC, the integrity of the appeals process might be affected. In case of the institutional accreditations carried out by AIC, the Register Committee noted that appeals can be filed only against the Ministry of Education and Science’s (MoES) decision, in a court of law, following the Latvian Administrative Procedure and not against AIC‘s report and review processes. The Register Committee considered that external quality assurance processes should always include an internal possibility to appeal with the responsible body that carried out the review itself.”
Full decision: see agency register entry
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2.2 Designing methodologies fit for purpose – NEAA – Compliance (2018) flexibility of the accreditaiton system
NEAA
Application Initial Review Full, coordinated by ENQA Decision of 13/06/2018 Standard 2.2 Designing methodologies fit for purpose Keywords flexibility of the accreditaiton system Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “While concurring with the panel's conclusion that NEAA complies with the standard, the Register Committee underlined the suggestion by the panel that NEAA should explore ways to make the accreditation system more flexible.”
Full decision: see agency register entry
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2.4 Peer-review experts – NEAA – Compliance (2018) Nomination of students in expert panels
NEAA
Application Initial Review Full, coordinated by ENQA Decision of 13/06/2018 Standard 2.4 Peer-review experts Keywords Nomination of students in expert panels Panel conclusion Substantial compliance Clarification request(s) Panel (30/05/2018)
RC decision Compliance “The Register Committee, however, noted that there might remain a residual risk of influence as long as higher education institutions could de facto exercise a veto right in the nomination of students to the NEAA pool of experts. While not impeding the agency's compliance with the standard (nor with standard 3.3) the Register Committee consider that NEAA should be mindful of that issue (also in regard to operational independence under standard 3.3).”
Full decision: see agency register entry
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2.6 Reporting – NEAA – Partial compliance (2018) Publication of full reports
NEAA
Application Initial Review Full, coordinated by ENQA Decision of 13/06/2018 Standard 2.6 Reporting Keywords Publication of full reports Panel conclusion Substantial compliance Clarification request(s) Panel (30/05/2018)
RC decision Partial compliance “The review panel noted that the expert groups' (EG) reports were “reflected” in the standing committee (SC) reports, but were not published as such. The panel clarified that the practice reflected NEAA's “division of labour”, that there was no substantial difference between the EG and SC reports, and that the SC was not able to include in its report “other findings than those of the EG”. […]In its statement on the review report, NEAA noted that it was now publishing the full EG reports. This could, however, not be verified by the Register Committee as the reports are only available on the Bulgarian version of NEAA's website.”
Full decision: see agency register entry
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2.7 Complaints and appeals – NEAA – Partial compliance (2018) Availability of appeals & clarify in the role of the 'Appeals Committee'
NEAA
Application Initial Review Full, coordinated by ENQA Decision of 13/06/2018 Standard 2.7 Complaints and appeals Keywords Availability of appeals & clarify in the role of the 'Appeals Committee' Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that NEAA established an Appeals Committee that can make recommendations to the Accreditation Council (AC), but no binding decisions. The review panel, however, considered that the type of issues handled by that committee were complaints rather than appeals.The Register Committee concurs with the panel that the ESG should not be interpreted as requiring the establishment of more than one appeal systems. The Register Committee considers that the wording of the standard suggests an internal system, set up and operated by the agency. The Register Committee considers as the key requirement of the standard that the outcomes of external quality assurance are open to appeal. Furthermore, the possibility to appeal needs to be clearly defined and communicated to the institutions concerned, cover the possible grounds for appeal indicated in the guidelines and be effective and efficient in practice.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – NEAA – Partial compliance (2018) Stakeholder involvement in the governance and work of the agency
NEAA
Application Initial Review Full, coordinated by ENQA Decision of 13/06/2018 Standard 3.1 Activities, policy and processes for quality assurance Keywords Stakeholder involvement in the governance and work of the agency Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “While the panel noted that a broader stakeholder involvement would require a change of the law on higher education and might have further implications for the overall functioning of the agency, the Register Committee underlined that the unbalanced composition of NEAA's governing bodies was already flagged as a matter requiring attention when NEAA was first admitted to the Register in 2009”
Full decision: see agency register entry
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2.2 Designing methodologies fit for purpose – MAB – Compliance (2019) fitness for purpose of doctoral schools EQA
MAB
Application Initial Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 2.2 Designing methodologies fit for purpose Keywords fitness for purpose of doctoral schools EQA Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “Considering the fitness for purpose of external QA processes, the Register Committee noted the panel’s concerns with the effectiveness of the practice of evaluating doctoral schools every six months. In its additional representation HAC explained that the biannual checking of compliance with criteria for doctoral programmes has now been discontinued and that a new approach and criteria have been developed, which are expected to be finalised in autumn.”
Full decision: see agency register entry
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2.4 Peer-review experts – MAB – Partial compliance (2019) student involvement in ex-ante procedures
MAB
Application Initial Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 2.4 Peer-review experts Keywords student involvement in ex-ante procedures Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that students are not involved in ex-ante accreditation of new institutions, the accreditation of doctoral schools and in the initial evaluation of programmes. The Register Committee agrees with the panel’s reasoning that the anonymity of experts in ex-ante evaluations precludes evaluators for becoming answerable for their decisions.[...] The agency also stated that the practice of maintaining the anonymity of experts will be changed following the Board’s decision (of February 2019). Regarding the involvement of students in the ex ante evaluations, the agency argued that students are involved in the decision-making process, as members of the expert committees where findings are discussed and that all eight expert committees now involve a student. In the view of the agency ex-ante evaluations call for an academic judgement as the focus is on academic content. The Register Committee welcomed HAC’s decision to lift the anonymity of experts (in case of ex-ante procedures) and acknowledged HAC’s intention to address the involvement of students in its follow-up report to the coordinator. The Committee nevertheless noted that such changes are yet to take place, and underlined that students should be appropriately involved in all peer expert groups, including the ex-ante evaluation stage as per the requirement of the standard.”
Full decision: see agency register entry
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2.7 Complaints and appeals – MAB – Partial compliance (2019) Absence of a formal complaints procedure
MAB
Application Initial Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 2.7 Complaints and appeals Keywords Absence of a formal complaints procedure Panel conclusion Substantial compliance Clarification request(s) Panel (20/11/2018)
RC decision Partial compliance “The Register Committee noted that the agency does not have a clear, structured and effective complaints process. In its self-evaluation report the agency acknowledged that complaints reach HAC by letter, mail or telephone enquiries, and are handled on a case by case basis. HAC also explained that in practice complaints (referring to the evaluation process) may be also considered as part of the appeals heard by the Board of Appeals, but they are mostly considered through the agency informal processes. The Register Committee considered HAC’s explanation that in case of a positive result of an evaluation complaints cannot be lodged, but underlined that any individual or organisation should nevertheless have the possibility to bring to the attention of HAC substantiated concerns about the evaluation process or conduct of review experts in line with a formal complaints policy.
In its additional representation the agency acknowledged that it has not introduced a separate process for complaints but that it is currently in the process of changing its regulation to implement a formal complaints procedure.”
Full decision: see agency register entry
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3.3 Independence – MAB – Partial compliance (2019) Organisational independence: selection and dismissal of the agency’s board members
MAB
Application Initial Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 3.3 Independence Keywords Organisational independence: selection and dismissal of the agency’s board members Panel conclusion Full compliance Clarification request(s) Panel (20/11/2018)
RC decision Partial compliance “The Register Committee learned from HAC’s self-evaluation report and the review panel’s analysis that the President of HAC’s Board is chosen from among the Board members by the Minister in agreement with the Hungarian Academy of Sciences. The Committee also noted that nine of the 20 HAC Board members are nominated by the Ministry of Human Resources and that the Minister has the authority to recall members of the HAC Board. [...] The panel stated that it is not aware of a published set of criteria for the selection and appointment of Board members and that it was assured by the ministry that a priority is put on nominating experienced and senior academics to the Board. The panel further added that possible reasons for the dismissal of the members of the HAC Board might be for inappropriate, unprofessional or illegal behaviour, although a specific list of admissible reasons did not exist. The agency further argued that the legality of HAC’s activities is overseen by the minister (Art 71/a) and thus the only case where the government may interfere in the agency’s operations are in cases where the law is breached. Dismissal of Board members is, according to the agency, also based on legal grounds, as legislation requires that the Minister state its reasons for such an action. The agency also admits that while the legal framework may seem to leave open the challenge to its (organisational) independence this has not been the case in practice.[…] The Committee noted that the agency’s explanations did not change the fact that there is a lack of clear safeguards to prevent possible (even if unlikely based on experience to date) interference in the activity of the agency or in the dismissal of its Board members. The Register Committee underlined the importance of ensuring not just a balanced representation in the nominated delegates to the Board but also of formal mechanisms and regulations to safeguard its organisational independence.. ”
Full decision: see agency register entry
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3.4 Thematic analysis – MAB – Partial compliance (2019) Use and regular publication of thematic analysis
MAB
Application Initial Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 3.4 Thematic analysis Keywords Use and regular publication of thematic analysis Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “While evidence of thematic analysis can be found within the programme accreditation reports, annual reports and other publications of the staff on the "activities, trends and outlook" of the HAC (SAR 41), the panel found that HAC’s level of activity in thematic analysis is limited and insufficiently developed. In its additional representation the agency stated that a thematic overview and analysis on ESG compliance from its most recent institutional accreditation round was presented during a recent event and it will be published by HAC. Further thematic analysis are planned for
2019. The Committee acknowledged the agency’s recent activity, however as it stands the agency’s progress is modest. The Committee underlines the review panel’s recommendation of ensuring the regular publication of thematic work and making use of such analysis more widely.”
Full decision: see agency register entry
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3.6 Internal quality assurance and professional conduct – MAB – Compliance (2019) Implementation of the processes for external feedback mechanism
MAB
Application Initial Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 3.6 Internal quality assurance and professional conduct Keywords Implementation of the processes for external feedback mechanism Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “The Register Committee noted from the review panel’s analysis that [...] internal and external feedback mechanisms are not entirely in place within the agency and the processes for examining data and collecting feedback are not systematic and formalised (Review Report p. 30). In its additional representation, HAC explained that internal quality assurance practices that are in place i.e. internal regulations for professional conduct and integrity, code of ethics, by-laws laying down the responsibilities for all activities of external members and staff, handbook for programme officers etc. The agency added that the surveys carried out with evaluated institutions were discussed in staff meetings and by the HAC Board and actions have been taken to improve procedures. The Register Committee further took note that HAC’s Quality Assurance and Development Committee has scheduled further activities to revise and develop surveys on accreditation procedures.”
Full decision: see agency register entry
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2.4 Peer-review experts – QAA – Partial compliance (2019) infrequent involvement of students in some procedures
QAA
Application Renewal Review Full, coordinated by ENQA Decision of 15/03/2019 Standard 2.4 Peer-review experts Keywords infrequent involvement of students in some procedures Panel conclusion Substantial compliance Clarification request(s) Panel (05/11/2018)
RC decision Partial compliance “The involvement of student reviewers in reviews for Degree-Awarding Powers (DAP) was flagged when QAA was admitted to the Register. The Committee noted that student reviewers now take part in these reviews […]. The panel's report, however, suggested that the standard was not fully met, as there were no student review panel members in some of QAA's review methods. The Register Committee sought clarification from the panel in that regard. The Committee noted that students are not on the review teams for General Osteopathic Council reviews (GosC); and it could not be established how frequently students are on the panels for Higher Education Review (Alternative Providers) or Transnational Education review (TNE).”
Full decision: see agency register entry
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2.6 Reporting – QAA – Compliance (2019) publication of reports and publication of the experts involved
QAA
Application Renewal Review Full, coordinated by ENQA Decision of 15/03/2019 Standard 2.6 Reporting Keywords publication of reports and publication of the experts involved Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The publication of review reports regarding Degree-Awarding Powers (DAP) was flagged for attention when QAA was admitted to the Register. The Register Committee welcomed that regulations were changed to the effect that such reports are now published [...] the Register Committee noted that the composition of the panels for TNE review is not mentioned in the published report. The Committee therefore drew attention to the guidelines to ESG 2.6, which suggest that the members of the review panel should be listed in the review report.”
Full decision: see agency register entry
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2.7 Complaints and appeals – QAA – Compliance (2019) No possibility to appeal in cases where the review does not end in a judgment
QAA
Application Renewal Review Full, coordinated by ENQA Decision of 15/03/2019 Standard 2.7 Complaints and appeals Keywords No possibility to appeal in cases where the review does not end in a judgment Panel conclusion Full compliance Clarification request(s) Panel (05/11/2018)
RC decision Compliance “The Committee noted that appeals are only possible in those review methods that result in a formal judgement on some type of scale, but not for methods that results in a report alone; the panel considered a complaints process sufficient in those cases. The Register Committee concurred with the panel's conclusion that QAA complies with the standard, considering that the current wording of the EQAR Policy on the Use and Interpretation of the ESG might be understood in that way. The Committee, however, underlined that also a report without a formal summarising judgement or decision contains (published) judgements about an institution. In the interest of full accountability these should thus in principle be open to appeal, too.”
Full decision: see agency register entry