Database of Precedents
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3.3 Independence – ANECA – Compliance (2018) Organisational independence
ANECA
Application Renewal Review Full, coordinated by ENQA Decision of 11/09/2018 Standard 3.3 Independence Keywords Organisational independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that since its last evaluation, ANECA has strengthened its independence i.e. becoming an autonomous public body, ensuring a more balanced representations in its Governing Council, appointing of its own director and operating with full fiscal autonomy. The Register Committee further noted that “the operation of ANECA’s policies and procedures surrounding the design, implementation and reporting on all the evaluation processes takes place in a fully independent and autonomous manner” (Review report, p. 26).”
Full decision: see agency register entry
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2.3 Implementing processes – HAKA – Compliance (2018) Consistency and transparency in decision making
HAKA
Application Renewal Review Full, coordinated by ENQA Decision of 13/06/2018 Standard 2.3 Implementing processes Keywords Consistency and transparency in decision making Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “ Having evaluated the procedures for decision making by Quality Assessment Council for Higher Education (HEQAC), the panel concluded that the standard for consistency and transparency in decision-making has received considerable attention and improvement since the last review.”
Full decision: see agency register entry
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2.4 Peer-review experts – SKVC – Compliance (2017) Involvement of students in external review process
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.4 Peer-review experts Keywords Involvement of students in external review process Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its decision of inclusion, the Register Committee flagged the involvement of students in all external review expert groups.The panel’s findings showed that students participate in all SKVC’s expert teams for all types of evaluations, whether in Lithuania or abroad. In its interviews the panel also learned that students were not always involved equally in the external review process, an issue that was mostly depended on the chair of the team (Review report pg. 36).The Register Committee noted that SKVC involved students in all its reviews and has therefore addressed the flag. he Committee nevertheless underlined the panel’s recommendation that SKVC could play a more supportive role in ensuring that students participate as equal members in all panels.”
Full decision: see agency register entry
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2.5 Criteria for outcomes – SKVC – Compliance (2017) decision making
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.5 Criteria for outcomes Keywords decision making Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “In its decision of inclusion, the Register Committee flagged the decision-making processes of the agency for accreditation and the practice in which accreditation decisions are taken by a single person (the Director).The panel noted that accreditation decisions are taken by the SKVC director upon advice of one of the two advisory commissions. In the view of the panel the role of the advisory commission should be limited to checking the reliability of the outcomes of the evaluation, leaving the final decision to the director to avoid unnecessary costly and complicated processes.The Committee nevertheless underlined the panel’s recommendation concerning the improvement of the agency’s criteria for programme accreditation with more elaborate definitions of its scores.”
Full decision: see agency register entry
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2.6 Reporting – SKVC – Compliance (2017) Publication of reports
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.6 Reporting Keywords Publication of reports Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its decision of inclusion, the Register Committee flagged the publication of reports corresponding to applications by new programmes and new licensing requests. The panel’s finding show that the evaluation reports for programme and institutional evaluations are published and accessible on the SKVC website, including the accreditation decisions (p. 40).”
Full decision: see agency register entry
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2.7 Complaints and appeals – SKVC – Partial compliance (2017) Absence of a complaints procedure
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.7 Complaints and appeals Keywords Absence of a complaints procedure Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “While the Register Committee noted that appeals’ procedures are well defined, accessible and handled adequately, the Register Committee noted that SKVC’s methodologies and principles do not cover complaints.The panel did not find how higher education institutions can raise issues of concerns or how they are handled by SKVC in a professional and consistent manner.The Committee underlined the recommendation of the panel for the development of a specific complaints procedure that should be made easily accessible to higher education institutions.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – SKVC – Compliance (2017) Separation of external QA and consultancy activities
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 3.1 Activities, policy and processes for quality assurance Keywords Separation of external QA and consultancy activities Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that SKVC provides consulting to both the government and higher education institutions. While the panel found that SKVC’s methodologies and guidelines clearly delineate its tasks and responsibilities, the panel stated that SKVC could benefit from reducing its guidance role in producing self-evaluation reports and in offering detailed and demanding rules and regulations for higher education. the Committee underlined that SKVC is expected to demonstrate a clear separation between its external quality assurance and its consulting and guidance role, in particular considering the agency’s assistance in producing self-evaluation reports. The Committee drew SKVC's attention to the guiding principles set out in Annex 5 to the Policy on the Use and Interpretation of the ESG.”
Full decision: see agency register entry
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3.5 Resources – SKVC – Partial compliance (2017) financial sustainability
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 3.5 Resources Keywords financial sustainability Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “In its decision of inclusion, the Register Committee flagged the financial arrangements and sustainability of SKVC’s overall activity.The panel’s analysis showed that these concerns remain due to a wavering financial situation and decrease of project funds.The Register Committee noted the panel’s analysis that the financial arrangements remain uncertain and have not been adequately addressed within a realistic financial plan”
Full decision: see agency register entry
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2.5 Criteria for outcomes – NVAO – Compliance (2017) decision making
NVAO
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.5 Criteria for outcomes Keywords decision making Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “In its last renewal decision (of 1/12/2012), the Register Committee flagged for attention the criteria for outcomes on the accreditation of existing programmes and in particular the consistency of decisions based on reviews undertaken by different agencies.The panel stated that NVAO has taken a number of steps to improve the decision-making process and found that there has been good progress in clarifying criteria for outcomes. The panel further underlined the difficulty of grading outcomes from insufficient to excellent on which further reflection by NVAO will be needed.”
Full decision: see agency register entry
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2.6 Reporting – NVAO – Partial compliance (2017) Readability and publication of reports
NVAO
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.6 Reporting Keywords Readability and publication of reports Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee flagged for attention the readability of NVAO’s published reports considering its defined target audience (decision of renewal of 1/12/2012).The panel’s analysis show that NVAO does not have specific guidelines for organizing the content of the report. Whilst these reports can be considered clear by an expert readership, readability is generally hindered by the heterogeneity of style, which is less “user friendly” to a large public, in particular by students and employers.The Committee underlined the recommendation of the panel that NVAO should analyse the actual and potential readership of its reports and their needs, and to develop new means to reach its target readership among students and employers.The panel also noted that at least 10 percent of the reports and decisions made in 2016 were not publicly available. The agency explained that the publication of reports was delayed due to a temporary lack of personnel and that this issue has been fixed. ”
Full decision: see agency register entry
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2.7 Complaints and appeals – NVAO – Compliance (2017) Absence of a formal complaints procedures
NVAO
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.7 Complaints and appeals Keywords Absence of a formal complaints procedures Panel conclusion Partial compliance Clarification request(s) Panel (04/05/2025)
RC decision Compliance “In its analysis the panel found that the procedures on appeals against decisions are well designed but noted that the agency “lacked a solid and formal comprehensive complaints procedure, even if some elements of complaints-handling are there and informal handling of complaints by NVAO normally suffices”.The Register Committee sought further clarification from the panel concerning the extent to which the ability of NVAO to handle complaints might be affected.The panel explained in its response letter that the comments to NVAO were intended to highlight that the complaints procedure could be more clearly defined and communicated. The panel also learned that NVAO took the panel’s recommendation following the review and developed a comprehensive complaints procedure.The panel confirmed that NVAO’s regulations on governing principles include indications to both complaints and “remarks”. Stakeholders, such as panel members, staff or students, may report to NVAO matters arising during the assessment process that could affect the independence of the assessment.The Register Committee noted that NVAO’s system of appeals is well developed and that the review panel was satisfied with NVAO’s processes for handling complaints.”
Full decision: see agency register entry
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2.5 Criteria for outcomes – AQAS – Compliance (2017) Publishing of the criteria for international institutional accreditation
AQAS
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 2.5 Criteria for outcomes Keywords Publishing of the criteria for international institutional accreditation Panel conclusion Partial compliance Clarification request(s) Panel (04/05/2025)
RC decision Compliance “The review panel noted that AQAS's criteria for international institutional accreditation were not published at the time of the review. The Register Committee took note of AQAS' statement on the review report and that AQAS now published the criteria for international institutional accreditation on its website. The Register Committee further noted that AQAS published the criteria without the additional “indicators”, which illustrates what is covered by a criterion. The Committee sought and received clarification by the review panel as to whether it considered publication without the “indicators” as sufficient. The Register Committee took note of the explanation that due to plagiarism and copyright infringements experienced in the past, AQAS published the criteria without additional, detailed material, while the “indicators” were made available to institutions applying for accreditation.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – AQAS – Partial compliance (2017) distinction between accreditation and consultation not fully publicly documented
AQAS
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 3.1 Activities, policy and processes for quality assurance Keywords distinction between accreditation and consultation not fully publicly documented Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “When confirming eligibility of the application, the Register Committee requested AQAS to clarify the relation between AQAS e.V. and AQAS ARCH, as well as the separation of external quality assurance procedures from consultancy services. The Register Committee took note of the clarification that AQAS ARCH did not engage in any activities within the scope of the ESG, but was engaging only in consultancy and project work, and welcomed the clarity provided. The Register Committee further welcomed AQAS' clear statement that it agreed “that the work of an accreditation agency in a particular procedure, be it programme or institutional accreditation, is incompatible with a preceding (or current) consultancy at the same university” and that “this incompatibility naturally includes organisations which are connected operationally with the agency” (statement on the review report); consequently, “AQAS e.V. cannot accredit the same organisation that received consultancy services through AQAS ARCH GmbH” (idem). The review panel, however, noted that these principles do not seem to be clearly documented in a published official policy document of AQAS and thus recommended that “AQAS should, in form of the formal resolution, define the distinction between accreditation and consultation, between ESG and non-ESG activities and between AQAS and AQAS ARCH” (review report, p. 12).
The Register Committee concluded that AQAS was able to explain that it appropriately separates its different areas of activity, while the details and consequences of this separation are not yet fully publicly documented.”
Full decision: see agency register entry
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3.4 Thematic analysis – AQAS – Partial compliance (2017) systematic approach to analyses and publishing
AQAS
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 3.4 Thematic analysis Keywords systematic approach to analyses and publishing Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “When AQAS last had its registration renewed, the publication of thematic analyses was flagged. Considering the review report, the Register Committee concluded that AQAS carried out a number of relevant internal analyses and produced relevant reports, e.g. the overarching report produced based on its accreditations in Moldova. These were, however, carried out on an ad-hoc basis, internal and not published as required by the standard. In its statement on the review report, AQAS explained that it had published a first set of thematic analyses on its website. While the Register Committee welcomed the efforts taken to date, it was not yet possible to conclude whether thematic analyses are produced regularly.”
Full decision: see agency register entry
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2.6 Reporting – AQU – Partial compliance (2017) Publication of ex-ante reports with negative decision
AQU
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.6 Reporting Keywords Publication of ex-ante reports with negative decision Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “In its last renewal decision (of 1/12/2012), the Register Committee flagged for attention AQU’s policy of not publishing negative validation reports, as well as the readability of reports for their target audience, in particular students and potential students.The Register Committee noted that AQU has made efforts to offer consistent, structured, and helpful reports of its quality assurance activities to a larger public through a number of portals with outcomes translated in Spanish and English.The Register Committee further noted that AQU publishes all reports except those from ex-ante evaluations that result in a negative accreditation decision.AQU explained that publishing these reports would have a negative impact on universities and society. In its statement to the review report, AQU further added that, since these programmes can not be offered by universities, it would be confusing for readers to find information on a course that will never exist.The Register Committee considered the agency’s explanations, but underlined that according to its Policy on the Use and Interpretation of the ESG (p. 7) all reports should be published, including any formal decisions based on these reports, irrespective of the outcomes of such reports.While the Register Committee acknowledged AQU’s efforts to improve the readability and accessibility of reports for its target audience the Committee concluded that the flag has only been partially addressed, since AQU still does not publish all reports. ”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – AQU – Compliance (2017) Separation of QA and consultancy activities
AQU
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 3.1 Activities, policy and processes for quality assurance Keywords Separation of QA and consultancy activities Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that AQU carried out one training activity in
2011. The review panel found that such activities should be considered as consultancy /support activities and that they should be differentiated more cautiously from the quality assurance activities which are provided by AQU Catalunya. (Review report, pg. 18).The Register Committee concurred with the panel that such consultancy activities should be clearly separated from external QA activities, in particular when those activities are carried out for the same higher education institution. The Committee drew AQU's attention to the guiding principles set out in Annex 5 to the Policy on the Use and Interpretation of the ESG and underlined that AQU is expected to make a substantive change report should it resume the same or similar consultancy-type activities offered to higher education institution.”
Full decision: see agency register entry
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3.3 Independence – AQU – Partial compliance (2017) organisational independence (overlap in the composition of the agency’s different bodies)
AQU
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 3.3 Independence Keywords organisational independence (overlap in the composition of the agency’s different bodies) Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee flagged for attention the independence of AQU from both government and higher education institutions. The panel found that the new legal framework (AQU Catalunya Bill adopted in 2015) has increased the agency's independence, whereby the government is no longer directly involved in the appointment of senior staff members in the agency.In its statement to the review report, the agency explained that the representation of higher education institutions was in line with existing legislation and that the role of the Governing Board is separated from the committees dealing with evaluation results. The agency further emphasised that the current composition does not allow for a partisan decision to be made by any stakeholder group and argued that the panel's concerns were based on conjecture and not evidence.The Register Committee noted the review panel’s concerns with regard to the lack of a clear separation between the composition of subject-specific committees and review panels that implement and monitor the procedures, which might create unwanted and unintended interference between the different roles. AQU stressed in its statement to the review report that this practice in fact ensures greater consistency in the application of the review criteria and since the decisions are made collectively the agency considers there is no undue influence.The Register Committee noted the agency’s clarifications. While it found that the flag on the independence of the Governing Board was largely addressed, the Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies.”
Full decision: see agency register entry
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2.5 Criteria for outcomes – FIBAA – Compliance (2017) lack of transparency in criteria for awarding the premium seal
FIBAA
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 2.5 Criteria for outcomes Keywords lack of transparency in criteria for awarding the premium seal Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “In the decision of renewal of FIBAA’s registration, the Register Committee flagged for attention the lack of transparency in the agency’s criteria for awarding the “FIBAA Premium” seal to accredited programmes.The panel noted that FIBAA has made improvements to the transparency of its procedure, including to the criteria for awarding the premium seal. The panel, however, underlined that the weighing of the criteria is not sufficiently transparent as this information it is not made accessible for external parties (in particular to higher education institutions).
In its statement to the review report the agency stated that weighing for the criteria for awarding the premium seal (along with the other criteria) are published on the homepage of FIBAA. The Register Committee was able to verify this information and therefore concluded that the agency has addressed the flag. ”
Full decision: see agency register entry
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2.6 Reporting – FIBAA – Partial compliance (2017) Inconsistency in preparation of reports; publication of programme accreditation reports
FIBAA
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 2.6 Reporting Keywords Inconsistency in preparation of reports; publication of programme accreditation reports Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The panel noted that the practice of sending review reports to higher education institutions for approval after decisions have been made should be reconsidered as this is not standard practice. To ensure consistency in the preparation of reports, the panel underlined the need for clearer manuals. The panel also referred to the results of an analysis carried out by the Accreditation Council, which showed that a number of programme accreditation reports have not been published by FIBAA. The Register Committee noted the intention of FIBAA to improve its practice of publishing reports and considered that improvements have not yet been externally reviewed.”
Full decision: see agency register entry
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2.7 Complaints and appeals – FIBAA – Partial compliance (2017) Lack of impartiality in the appeals process; lack of clear complaints procedures.
FIBAA
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 2.7 Complaints and appeals Keywords Lack of impartiality in the appeals process; lack of clear complaints procedures. Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The panel learned from its discussion with the agency that higher education institutions can point out faults in the procedure of the review in their statement to the review report. While higher education institutions are given the possibility to make a statement on the review report the panel underlined that there was not a clear indication on whether higher education institutions can issue a complaint regarding the course of the procedure. In its statement on the review report the agency stated the appeal procedure has been published on its website and also included in its quality management handbook. According to the procedure, once the appeal is lodged by a higher education institution it will be passed on – after consultation with the review panel – to the responsible Committee who can decide on whether to allow the appeal to go forth. In case this is granted the appeal will be submitted to the FIBAA Appeal’s Committee for examination. The Register Committee considered that the current procedure, whereby the Committee that issued the initial decision decides on whether the appeal of that institution will be passed to the Appeals Committee, might affect the impartiality of the process. The Register Committee further found the procedure to be documented only rudimentarily, with little or no explanation on the issues that could be raised under the appeal, no provision on the expected timeline to process a complaint, publication policy etc.”
Full decision: see agency register entry