Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.4 Thematic analysis
Keywords	thematic analysis
Panel conclusion	Compliance
Clarification request(s)	Agency (24/09/2024)
RC decision	Compliance

“59. The Register Committee learned from the report that the agency has conducted only one thematic analysis, focussing on only one standard from

its EQA Audit procedures carried out by the agency as of

2016.

60. The Committee learned that the agency is considering conducting a thematic analysis for the remaining ten standards. The panel, however, was

not provided with further information on the status of the development of this analysis or, in general, MFHEA’s policy on thematic analysis.

61. The Register Committee noted the agency's plans to revisit its policy and enhance its work on the thematic analysis. The Register Committee

found that these plans have yet to materialise in practice.

62. In its additional representation, the agency informed that it was in a process of conducting its latest thematic analysis and the same should be

finalised by the end of

2024.

63. The Register Committee further asked for clarification whether the work on the thematic analysis is ongoing and whether there is a clear

timeframe when the thematic analysis will be published. The agency clarified that the thematic analysis is currently being finalised and will be

published and presented to the public in December 2024 (see minuted clarification of 2024-09-24).

64. The Committee welcomed the work and progress done by the agency in producing thematic analysis and expects that MFHEA will continue

conducting thematic analysis on regular basis. Given the provided information in the additional representation and the further clarification,

the Register Committee could concur with the panel that the agency is in fact compliant with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	appeals procedure, appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. In the decision on the for inclusion of CYQAA on the register (of 2019-11- 05), the Register Committee raised concerns regarding the shortcomings of the appeal procedure regarding the independence of the processes and the lack of clearly defined and formal complaints procedure.

8. From the external review report, the Register Committee learned that the Complains Policy is well established and higher education institutions have already used the possibility to submit a complaint (18 until the time of the external review).

9. The Register Committee further learned that CYQAA has revised its Appeals Procedure and now sets Advisory Committee of Experts (ACE) - groups of experts that examine and give opinion on the grounds for appeals to CYQAA’s Council. Despite the updated policy, the Council still holds the powers to make the final decision whether there are grounds for an appeal and can dismiss or uphold the appeal.

10. Furthermore, the Committee noted that the current Appeal Procedure is not entirely clear as it may suggest that an ACE is appointed for each appeal that is allowed for consideration by the Council, whereas in practice it is set only when the Council proposes to reject an appeal and needs advice from external experts.

11. The Register Committee welcomed (changes made related to the complaints procedure) and found the earlier concerns related to the complaints procedure addressed. The Committee, however, found that CYQAA is yet to demonstrate an independent functioning of the Appeals Procedure, where the final decision is not with CYQAA’s Council. Having in mind the shortcomings related to the Appeals Procedure, the Register Committee concurred with the panel conclusion that CYQAA only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategic plan, stakeholder, stakeholders involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The Register Committee noted the concerns raised by the panel that CYQAA’s Strategic Plan (2020-2025) is rather generic, with no specific

activities and clear timeframes. Furthermore, the Committee noted that the panel did not see any evidence of public, annual corporate or activity plan than operationalise the Strategic Plan.

13. The Register Committee understood by the panels analysis, that the agency involves representatives from both public and private universities, students and regulated professions. However, as underlined by the panel, the involvement of private higher education institutions and many public and private colleges and their students is very limited and CYQAA should further widen their engagement in its governance and evaluation processes.

14. Considering the lack of comprehensive and rather generic Strategic Plan and the shortcomings in the involvement of stakeholders from all

higher education institutions, public and private colleges, the Register Committee concurred with the panel and found that CYQAA only partially

complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	operational independence, methodologies
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. In the decision for inclusion of CYQAA on EQAR (of 2019-11-05), the Committee raised concerns regarding the shortcomings related to the operational independence of CYQAA and the close interlinkage between the agency and the responsible ministry.

16. Despite some progress being made by consultation with key stakeholders on the appointment of Council members and the Minister, the Register Committee noted that the Council members are still appointed by the Council of Ministers, upon recommendation by the Minister responsible for higher education.

17. The Register Committee took note of the panel’s concerns regarding the operational independence of the agency, The Committee understood that CYQAA cannot hire its own staff and is fully relying on secondments from the central Government and the Ministry of Education, Sport and Youth.

18. The Register Committee further noted, as underlined by the panel, that despite being fully independent in defining its evaluation methodologies, CYQAA is still challenged by the limits set in the provisions of the national legislation regarding engaging stakeholders in the development of methodologies (see issue raised under ESG 2.2 in the external review report).

19. Following the panel’s analysis, the Register Committee expressed its concerns that the operational independence of CYQAA remains constrained by the close link and dependence on the Ministry of Education, Sport and Youth regarding the appointment of the Council members, hiring of staff and engaging stakeholders in the development of methodologies. Therefore, the Register Committee concurred with the panel conclusion, and found that CYQAA remains to be partially compliant with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.5 Criteria for outcomes
Keywords	Inconsistent use of tools for decision making; Consistency in the interpretation of the agency’s criteria
Panel conclusion	Partial compliance
Clarification request(s)	Panel (28/05/2024)
RC decision	Partial compliance

“The Register Committee learned that, out of 24 applications concluded between

2022 and 2024, the final conclusions on the standards differed from those

proposed by the panels in four cases – three of which occurred in

2024. This

trend resulted in either more or less favourable outcomes for the concerned

higher education institutions.The Committee could not understand, without a panel insight, whether

the increased discrepancy between the panels’ and the Authorisation

Council’s conclusions occurring after the site visit (2023-11-05) steams from

the (im)proper use of the tools for consistent application of agency’s criteria

or other external factors (see more in ESG 3.3)”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	High level of involvement of the Government of Georgia in the selection of candidates for several leadership and managerial positions in the agency
Panel conclusion	Partial compliance
Clarification request(s)	Panel (28/05/2024)
RC decision	Non-compliance

“The Register Committee found that the agency remains having weak

organisational independence as the government persists having strong involvement in the appointment of several NCEQE’s bodies. The Committee found that further panel insight should asses whether the Government’s significant involvement in the agency’s operations affects the notable staff overturn (i.e. the operational independence) and the final conclusions of the accreditation decisions (i.e. the independence of formal outcomes).”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision for renewal of registration on EQAR (of 2020-03-16), the Register Committee found that AHPGS only partially fulfilled the requirements of the standard, as the ESG Part 1 was not properly addressed in their external reviews outside Germany.

9. The Committee understood that in order to address these issues, AHPGS revised its handbooks for reviews abroad. Nevertheless, the Committee understood by the analysis of the panel, that the Handbook for Institutional Evaluations does not address standards 1.7, 1.8 and 1.9 sufficiently.

10. Furthermore, the Committee understood from the analysis of the panel, that programme accreditation reports were in line with ESG Part 1, except one which did not follow AHPGS’s own criteria in full.

11. In a statement of the report (of 2024-05-17), AHPGS explained that in order to address the shortcomings underlined by the panel, it revised its handbooks for programme and institutional accreditation outside Germany.

12. The Committee welcomed the changes made by AHPGS. The Committee was, however, unable to conclude whether the adopted changes are implemented in practice without further panel insight and therefore they remain to be reviewed within the next external review of the agency. The Register Committee, therefore, concurred with the panel’s conclusion and found that the agency remains partially compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.4 Peer-review experts
Keywords	Training of experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its previous decision of registration on EQAR (of 2020-03-16), the Register Committee found AHPGS to be partially compliant with the standard due to ambiguity in whether the agency ensured that all experts received training. Additionally, the criteria and process for recruiting reviewers were not clear.

14. From the report, the Register Committee learned that the training process has been improved, and ensures inclusivity and accessibility for all experts. Furthermore, as underlined by the panel, the format was made more adaptable and personalised.

15. Following the improvements made by the agency, the Committee was able to follow the panel’s conclusion that the agency now complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.4 Thematic analysis
Keywords	Thematic analysis
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“16. In its previous decision of registration on EQAR (of 2020-03-16), the Register Committee found the agency to be partially compliant with the standard, as the publications prepared by the agency did not analyse the outcomes of the review processes.

17. Based on the analysis of the review panel, the Register Committee understood that, since its last review in 2020, the agency published several thematic analyses. Conducting additional studies is also now part of the agency’s strategic documents.

18. The Register Committee was able to follow panel’s conclusion that AHPGS is now compliant with the standard. The Committee, further highlighted the panel’s recommendation that the agency should secure adequate dissemination of its thematic analysis, keeping in mind the various target audiences.

19. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“8. From the report, the Register Committee learned that in case of the activities leading to an accreditation of German higher education institutions, there is a (theoretical) possibility that an institution may not forward the report to the German Accreditation Council (GAC); hence the report may not be published.

9. The Register Committee concurred with panel’s conclusion and found the agency compliant with the standard. It, however, underlined panel’s recommendation that the agency could include a publishing clause in the contract with the higher education institution in case the report to the German Accreditation Council is not forwarded.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clarity in activities and services; Conflicts of interest
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. While the Register Committee was able to follow panel’s conclusion that AQ Austria is compliant with the standard, it highlighted the panel’s recommendation that the agency should enhance the clarity on its ESG aligned activities and consultancy services for the public and add explanation on avoiding conflicts of interest on their website.

11. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.6 Reporting
Keywords	Publication of reports with negative outcomes, publication of expert panel reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its previous decision for renewal of registration on EQAR (of 11-05- 2019), Unibasq was found to be partially compliant with the standard as it did not publish reports of its ex-ante accreditation resulting with a negative outcome. From the report, the Register Committee learned that the agency now publishes these reports too.

9. The Register Committee further learned that the preliminary and final review reports shared with the higher education institutions and the public do not include the expert panel reports; these reports are only available to the Unibasq’s Committees.

10. The Register Committee found that the agency addressed the concerns raised in its earlier decision regarding the publication of negative reports from its ex ante accreditation procedure. It, however, shared the panel’s concerns that the agency does not fully comply with this standard because of the lack of transparency regarding the expert panel reports.

11. The Register Committee therefore concurred with the panel’s conclusion and found that the agency remains partially compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	procedure for handling complaints
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard due to the unclear procedure for handling complaints. From the report, the Committee learned that Unibasq now has a well established complaints procedure noted in the agency’s regulations of the Ethics and Guarantees Committee and the Code of Ethics.

13. Following the changes made by the agency, the Committee was able to follow the panel’s conclusion that the agency complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between ESG aligned and consultancy activities
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“14. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard as it did not make a clear distinction between its ESG aligned and consultancy activities (i.e. the evaluation of “títulos propios”). At the time, the agency removed the information regarding the evaluation of “titulos proprios” from its website; the Committee, however, could not verify whether the new method of communication brought clarity for all stakeholders.

15. From the external review report, the Committee has learned that the agency “ has made...efforts to request from higher education institutions [involved in the consultancy activities] not to use misleading information on their websites and has succeeded as far as the panel could determine through an internet search”.

16. The Committee therefore followed the panel’s conclusion and found that the agency now complies with the standard. The Committee, however, shared the panel’s view that the agency could improve the distinction between these two group of activities by creating a separate section on its website where it showcases clear information to the public.

17. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	operational independence, decision-making
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision, the Register Committee noted the strong role the German Bishops’ Conference (DBK) plays in the governance of the agency.

9. Despite the changes made by the agency to further its operational independence, the Register Committee noted that DBK maintains a significant role in the organisational structure of AKAST.

10. The Committee underlined the possible influence that may be exerted by the DBK Episcopal Commissioner in the decision making of the Accreditation Committee. Although the Episcopal Commissioner is present in the Accreditation Committee (AC) of the agency in an advisory capacity, there is still the possibility of undue influence considering the fact that the Episcopal Commissioner still issues a separate consent impacting the programme.

11. Furthermore as noted by the panel, it also seems possible for the episcopal commissioner to express, even unintentionally, a preliminary opinion on particular study programmes, not necessarily based on the findings of the expert panel during the AC meeting.

12. The Committee noted the concentration of power in one place, i.e., the current Chairperson of the Executive Board of AKAST holds the position of Chair of the Accreditation Committee and Chair of the Advisory Board of AKAST. Furthermore, the DBK nominates the Chairperson of the Executive Board.

13. Considering the strong influence of one main stakeholder in the running of the agency, the Register Committee underlined the risk to the agency’s operational independence, as well as to its independent decision-making. The Register Committee therefore concurred with the panel’s view that AKAST complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.4 Thematic analysis
Keywords	publication, analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“14. In its last decision, the Register Committee welcomed AKAST plans for further development of its thematic analysis after an appropriate number of programme accreditation procedures have been carried out.

15. The Register Committee noted that while AKAST has taken some steps in preparing thematic analysis since its last review, i.e., initiating a process for evaluation of the peer review processes carried out by AKAST, since 2022 at the time of the review, no thematic analysis have been made available nor any kind of such analysis have been published.

16. Considering the limited progress made since the inclusion on the Register and the limited development of thematic analysis, the Register Committee concurred with the panel that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality assurance, mechanisms
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee, noted in the analysis by the panel the gaps and shortcomings in the implementation of the agency’s Internal Quality Assurance (IQA) Regulations.

18. Furthermore, the Committee underlined that the mechanisms for fostering continuous improvement within the agency are weak and unsustainable on the long-term, i.e., the heavy responsibility of AKAST administrator for all of the IQA processes, the lack of systematic approach in gathering feedback and lack of evidence and example of enhancement based IQA.

19. The Register Committee further noted the lack of commitment in timely addressing the issues previously noted under ESG 3.3 and ESG 3.4 which impacts the overall effectiveness of the agency’s internal quality assurance arrangements.

20. In light of these concerns, the Register Committee could not follow the panel’s judgement of compliance and found that AKAST complies only partially with ESG 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“7. The review report showed that the coverage of the particular standards is ensured with guiding questions for institutions and for review teams. However, the evaluation reports are still not checked with a specific focus on how ESG is covered by the IEP Secretariat.

8. While the Register Committee concurred with the panel’s judgement and found the agency to be compliant with the standard, it highlighted the panel’s recommendation on importance of systematic signposting of ESG Part 1 criteria in the evaluation reports.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.3 Implementing processes
Keywords	Implementing processes
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“9. In the last review, the agency was found to be partially compliant with the standard as the follow-up model did not ensure a consistent follow-up for all evaluated higher education institutions.

10. The Register Committee noted from the panel’s analysis IEP’s efforts in addressing the shortcomings with the standards. Furthermore, the Committee noted that IEP took further measures to increase the rate of submission of follow-up reports by evaluated higher education institutions. .

11. The Register Committee therefore concurred with the panel's conclusion that IEP complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	Organisational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In the previous renewal decision of IEP’s registration, the Register Committee noted that the agency’s organisational independence still continued to be compelled by the close link with the EUA.

13. The Register Committee understood that IEP has taken further steps to address the flagged issues raised in the previous decision. The Committee notes the panel’s analysis and the conclusion that while the EUA is providing resources to IEP, it does not have any role in the decision making processes within the IEP. Furthermore, the Committee notes that in order to better distinguish between EUA and the separate activities undertaken by the IEP, the agency has developed a new website and a distinguishable new corporate identity.

14. Furthermore, the Register Committee took note of the agency’s revised Terms of Reference in order to show the Steering Committee’s full ownership of the development and operation of the IEP.

15. The Register Committee therefore concurred with the panel's conclusion that IEP complies with the standard. The Committee, however, shared the panel’s view that the agency should make publicly visible the IEP Terms of Reference and other official documents that state the organisational independence of IEP from EUA.”

Full decision: see agency register entry