Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Inadequate appeals process
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel noted that – while being clearly defined and published – “the process of appeals established by ANQA cannot be considered an appeal, but a second opportunity giving the institution time to improve its situation and then undergo one more evaluation and receive a new decision in a short period of time”. The Register Committee concurred with the panel that the ANQA process differs substantially from the common understanding of an “appeal” and considered that it was doubtful whether the process was fit to address the type of issues it is expected to address, i.e. “adversely assessed criteria and/or alleged procedural violations against the institution”. The Register Committee considered that the standard does not prescribe a specific appeals procedure and that the review report identified serious shortcomings in the appeals procedure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	cosultancy/training to HEIs
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In connection with ANQA's budget, the panel noted that ANQA is carrying out consultancy activities on a minor scale. As it was not specifically analysed in the report, the Register Committee sought clarification from the panel on potential conflicts of interest arising from consultancy work. The Register Committee understood from the panel's response that ANQA provides collective training opportunities to Armenian higher education institutions, but does not render services to individual institutions, and that, therefore, there is no specific potential for conflicts of interest.The Register Committee, however, underlined that in case ANQA provides consultancy to individual institutions in the future it would have to implement appropriate policies to prevent that ANQA accredits the same institution to which it rendered consultancy services.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.3 Independence
Keywords	operational independence
Panel conclusion	Full compliance
Clarification request(s)	Panel (11/07/2025)
RC decision	Compliance

“The Register Committee sought and received clarification from the panel as regards ANQA's independence in defining its own procedures and methods. The Committee appreciated the panel's explanation as to how ANQA developed its Manual independently.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to system-wide analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ In its decision for inclusion, the Register Committee flagged QANU’s systematic approach to system-wide analyses. While QANU has not produced thematic analysis in its strict sense, the panel noted that the agency published reports at the request of research universities and state of the art reports for programmes that are assessed in clusters. The panel noted that QANU did not have a systematic approach towards producing thematic analysis and that the agency views this activity to remain mainly in the responsibility of NVAO. In its additional representation, QANU's underlined that its core activity is to conduct assessments, and due to its limited size, financial resources and scope QANU’s ability to conduct thematic analyses in a systematic way was limited. The Board of QANU had nevertheless considered the recommendations of the panel and stated that it would adapt its approach to thematic analysis.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	follow up procedure for programmes accredited without condition
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In the review report (p. 28) the panel stated that if a programme is accredited with conditions, the programme is expected to submit an interim report on how it has fulfilled these conditions. The Register Committee was unclear if a follow-up is also implemented for programmes accredited without conditions and have therefore requested the panel to clarify this matter.The panel (response letter of 28/05/2017) stated that higher education institutions are expected to inform FINEEC of significant changes related to their programme organisation, implementation and development. The panel found no other evidence of a follow-procedure that would apply to programmes accredited without conditions. The Register Committee considered the design of the follow-up of programmes accredited without conditions to be minimal but nevertheless appropriate.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Limited scope of the appeals system
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (of 18/11/2010) the Register Committee flagged for attention FIN(H)EEC’s appeals procedure. The Committee noted that considerations should be given to this matter even though FIN(H)EEC’s decisions do not have a formal consequence (in terms of an institution’s license or financing), its audits result in a formal result, i.e. the report. The panel stated that audit results are considered expert opinions and according to Finnish law, appeals can be filed against administrative decisions only. The Register Committee underlined that a system for complaints and appeals should be in place irrespective of the formal status, while the status of the appeal system may be different from the common system of appeals that might be applicable to public administration. The panel explained that FINEEC has nevertheless made it possible for higher education institutions under review to request an assessment of the results of an audit or a re-audit on the grounds that the audit has not been carried out in compliance with the audit manual. Higher education institutions cannot, however, appeal the actual conclusion of the audit or accreditation team nor the decisions of the decision-making committees, a situation the panel described as “less optimal”. The panel further established that until now there was only one request to review the result of an audit, but the case was not yet decided upon by the time of the site visit. While an appeals system is established and publicly described, due to the lack of actual practice the Register Committee was so far unable to conclude whether the current system, limited in scope, was sufficient to safeguard the interest of institutions under review. The Committee noted that practical experiences with the appeals system should be addressed in the next review of FINEEC.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Scope of the thematic analysis (evaluations)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the eligibility verification (see letter to FINEEC of 12/02/2016) the Register Committee considered FINEEC’s thematic evaluations to be activities within the scope of the ESG, as far as they concern individual institutions or programmes of higher education. The Register Committee noted from the panel’s analysis that thematic evaluations have been paused after the merger of FINHEEC, and that the agency intends, according to its National Plan for Education Evaluations to reintroduce these evaluations between 2016-2019. […] the panel stated that thematic evaluations were found to be outside the scope of the ESG. The panel noted that thematic evaluations did not evaluate individual higher education institutions (or parts of them) or programmes, nor did they address the effectiveness of internal quality assurance as defined in Part 1 of the ESG. The panel, however, added that – although these evaluations are outside the scope of the ESG – the procedures and practices applied by FINEEC largely comply with the ESG. While the Register Committee concurred with the panel in that thematic evaluations in general fall outside of the scope of the ESG. The Register Committee, however, noted that at least in one particular case, i.e. the thematic evaluation of education in the maritime sector (2015-2017), FINEEC (also) addressed the quality management of individual education units and that the results of the FINEEC evaluation will serve as a basis for the International Maritime Organization (IMO) to decide on the right of the educational establishments in the maritime field to issue certificates of competency. The Register Committee concluded that thematic evaluations are within the scope of the ESG only if they apply to the three cycles described in the QF-EHEA and include formal results, statements or judgements on individual higher education institutions. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.3 Independence
Keywords	organisational independence
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its analysis, the panel discussed that the processes for the appointment of the Director and members of the Evaluation Council may be seen as political and as a potential risk in terms of FINEEC’s organisational independence. The panel thus emphasised the need for transparent procedures with clear and predetermined criteria. The Register Committee sought clarification from the panel as to how it satisfied itself that there was no undue influence in the nomination process given the current absence of a formal procedure and criteria. In its response letter, the panel stated that the need for the procedure to be transparent was brought up to underline the need to guarantee the independence of the agency and not to indicate that there was not a formal procedure in place or that it was not transparent. The panel clarified that in case of the Director, the appointment follows the procedure for the recruitment of civil servants in Finland, while in case of appointing the members of the Evaluation Council, the members are chosen from the proposals made by different stakeholder groups (from the educational sector, teacher education, research, working life and students). The Register Committee was able to verify that the documentation related to both procedure is published.In the review report the panel stated that FINEEC might in the future merge with the National Board of Education and the Centre for International Mobility (CIMO). The panel noted that this merger might affect the independence of evaluation activities as the tasks of the Board of Education are closely related to the political work of the Ministry of Education and Culture.

The Register Committee underlined that FINEEC is expected to submit a Substantive Change Report should its organisational status change in the future.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	Lack of thematic analyeses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While a number of thematic analyses have been published since the last external review of the agency, the panel found that the analyses have been paused since the merger of FINHEEC into FINEEC. The panel also noted that FINEEC has not yet initiated thematic analyses of the accreditations of engineering degree programmes due to the small number of finished accreditations. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	Lack of consistent follow-up procedures
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (18/05/2011) the Register Committee flagged the introduction of site visits as well as follow-up procedures undertaken by HCERES. The panel noted that since its last review HCERES did not ensure a consistent follow-up in its EQA activities due to a prolonged process of succeeding evaluations (that included the introduction of site evaluations). The agency replaced the follow-up with a progress report that higher education institutions would prepare as part of their self-evaluation so as to facilitate and speed up the process. Moreover, the panel noted that evaluations of programmes are carried out without site visits.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.4 Peer-review experts
Keywords	Lack of involvement of students
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (18/05/2011) the Register Committee flagged the participation of international experts and students. The panel noted that usually two experts are involved in the evaluation of bachelor and master programmes, and that these panels do not include students. According to the review panel, HCERES found it very hard to recruit students due to their need for extra time to carry out evaluations alongside their studies. The Register Committee further noted that in the ‘evaluation of doctoral schools’ the agency included a recent doctoral graduate rather than an actual student or doctoral candidate (p. 13 external evaluation report). The panel further noted that the involvement of students in institutional evaluations is limited to panel discussions. In its statement to the review report (of 10/03/2017) the agency, however, commented that students have the same role and responsibilities as other members of the panel in institutional evaluations. The Register Committee concluded that the agency has not addressed the flag and does not meet the requirements of standard 2.4 to involve students in all its external quality assurance activities.While considering that the failure to meet the requirement of the standard concerns a large proportion of HCERES' activity, the Register Committee noted that due to the immanent transition from programme accreditation to the evaluation of study fields, the involvement of students is to be resolved in this new setting.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	lack of consistent application of criteria for institutional evaluations; lack of criteria for evaluation of study fields
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“With regard to institutional evaluations the panel noted that the application of criteria for outcomes leaves too much room for interpretation and therefore undermines the consistent application of criteria. Considering the agency’s transitioning to evaluation of study fields the review panel further highlighted the need for development of criteria for the outcomes of subject level evaluations.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Conflict of interest of the body responsible for handling complaint/appeals
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged in its decision of initial inclusion the procedure for complaints and appeals. While recognising the agency's efforts in developing regulations for appeals and complaints, the panel found that the current system does not clarify who is the responsible party (ministry or agency) in handling complaints and recommended a coordination with the responsible ministry. In its statement to the review report (of 20/03/2017) the agency stated that it cannot interfere in the decision-making process of the ministry and that coordinating a complaints procedure with the ministry would affect its independence and confuse its role. HCERES further explained that in case of a complaint that concerns evaluation reports, the case would be handled by the agency, and in case the issue concerns a contract or decision of the ministry, the case will be handled by the ministry. In its Substantive Change Report (of 23/02/2017) HCERES described further updates to its appeals system that was adopted in October 2016, i.e. after the review panel’s visit in June

2016. The agency reported that eight new members have been appointed to the Appeals’ Commission who would address complaints concerning all activities of HCERES. The Commission will consider issues regarding the implementation or findings of an evaluation, the selection of experts, the decision of the accreditation commission and the decisions to validate other bodies’ evaluation procedure. The Register Committee noted that the majority of members in the Appeals’ Committee are also members of HCERES’s other bodies responsible for parts of the evaluation procedure (i.e. Board, evaluation departments) and might thus have a conflict of interest in handling complaints.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.2 Designing methodologies fit for purpose
Keywords	overlaping and duplication of processess
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its decision to admit ASHE to the Register, the Register Committee had flagged the need to review ASHE's different processes with a view to avoiding duplication. The Register Committee noted that the review panel remained concerned about different ASHE processes addressing the same or very similar issues. Moreover, the panel appeared to be concerned that the new processes for re-accreditation of doctoral programmes and the possible future processes related to the Croatian Qualifications Framework (CROQF) might even lead to further duplication.The Register Committee therefore concluded that the flag was not addressed and remains a matter deserving the urgent attention of both ASHE and the Croatian Ministry of Science and Education, being responsible for the legal framework of the external quality assurance processes implemented by ASHE.

The Register Committee concluded that all processes deployed by ASHE in themselves are fit for purpose and were developed in line with the standard, while the overlap and duplication identified by the panel is primarily the result of the typology of external quality assurance processes prescribed by law, the Register Committee was nevertheless able to concur with the panel's conclusion that ASHE complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	lack of transparency in criteria; inconsistency in the application of critera; insufficient documentation for interpretation of criteria
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel identified that some policies that affect ASHE's decision-making are not fully transparent and known by the stakeholders concerned. The panel further referred to some inconsistency in the application of ASHE's criteria and an insufficiency of the reference documents that panels use to interpret the criteria.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Publication of reports of initial accreditation
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision to admit ASHE to the Register, the Register Committee had flagged the accessibility and readability of ASHE reports. The Committee noted that ASHE took several steps to enhance the accessibility and readability of its report during the past five years, including the publication of summary reports. The Register Committee therefore concluded that the flag has been addressed. The review panel noted that reports of initial accreditation procedures are not published. The review panel considered that these reports “serve as a base for the ministerial decision to admit the HEI or programme to be established and that therefore these reports do not carry information directly addressed to the general public” (report p. 40) and that in case of a negative decision “the HEI or programme concerned will not be launched and so there is no tangible public interest in reading these reports” (idem). The Register Committee, however, considered that the standard clearly requires the publication of all external quality assurance reports. Even if the reports' addressee is the ministry, there is a clear public interest in the basis of ministerial decisions being public and transparent.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Absence of appeals procedure for initial accreditation and inadequate body to address the appeal.
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel considered that the body deciding on appeals should not be identical to the body that made the decision being appealed, but identified an overlap in the case of ASHE. It further noted that there is no appeals procedure (internal to ASHE) for initial accreditation, but only a possibility to appeal decisions in a court.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.1 Consideration of internal quality assurance
Keywords	Addressing the effectiveness of internal QA
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that the decision-making procedure of the Accreditation Council does not give any special consideration to the effectiveness of internal quality assurance process e.g. by linking the varying progress made by institutions in the development of IQA to the three possible final outcomes. While the panel found that IQAA’s approach reflects the early stages of its development, the panel recommended a stronger focus on the effectiveness of internal quality assurance in IQAA’s accreditation methodology as well as a refining of accreditation standards on student-centred learning (ESG 1.3) so that they give more consideration to how the concept is translated into pedagogical approaches and assessment practices; and more consideration to the primary responsibility of institutions for quality in its interpretation (ESG 1.9). The RC noticed shortcomings in addressing the effectiveness of internal QA processes in its institutional and specialised accreditation procedure and the need for a refining of its standards,”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.2 Designing methodologies fit for purpose
Keywords	fitness for purpose of IQA’s methodology
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Considering the fitness for purpose of the agency’s metholodogy, the panel identified a number of shortcomings i.e. lack of a regular review of the agency’s methodology, blurring of boundaries between the agency’s different functions (such as the preliminary review processes and the post-accreditation monitoring process).

In the analysis the panel further underlined the need to shift the responsibility for quality from the agency towards the institution and that the current procedures might be impeding such development. While the Register Committee considered the agency’s statement to the review report, noting the phasing out of preliminary reviews and the clarification regarding post-accreditation reviews, the Committee concluded that the achieved fitness for purpose of IQA’s methodology needs to be externally reviewed.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	difference in reports regarding recommendations and level of compliance/Inconsistencies between the provisions for programme accreditation and institutional accreditation,
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted some inconsistencies between the provisions for programme accreditation and institutional accreditation, i.e. the IQAA Accreditation Council can only modify the points awarded for decisions in case of programme accreditation but not for institutional accreditation. The panel further noted that it is not always clear how the number and weight of recommendations is linked to the compliance levels of each standard i.e. some reports may include recommendations or critical comments, while other reports do not although in both cases the standard is considered ‘fully compliant’. The panel considered this was a result of the fact that the guidelines for experts are not sufficiently precise. The panel recommended a revision of the agency’s decision-making algorithm, in particular a clarification of the minimum requirements to be fulfilled by higher education institutions and the acceptable shortcomings for each of the four levels of compliance within IQAA’s accreditation standards.”

Full decision: see agency register entry