Database of Precedents

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.2 Designing methodologies fit for purpose
Keywords	student involvement; public information on criteria used
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The review report noted that ASIIN’s certification committee did not currently include a student member. The Register Committee therefore considered that the involvement of stakeholders in the design and decision-making process was not fully ensured as required by the standard. The review report noted that only criteria that comply with the ESG can be chosen for evaluations (type 1). The report, however, noted that this was not made clear to the public. The Register Committee further noted that it was not explained in detail how this is verified by ASIIN. The Committee therefore considered that the requirement of external quality assurance processes being defined and designed to ensure their fitness for purpose was not complied with as regards evaluations. The Register Committee was able to verify that a student member was appointed to the certification committee, as noted in ASIIN's additional representation. The Register Committee further noted that ASIIN had clarified in its public information that the criteria in type-1 evaluations, including those of third parties, must be compatible with the ESG.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	inconsistency in implementation of the process; unclear definition for cases where there is no site visit.
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review report noted that on-site visits are not mandatory in evaluations (type 1) and recommends that ASIIN should establish clear principles to state in which cases on-site visits are not necessary. Given the current absence of such principles, the Register Committee considered that ASIIN did not comply with the requirement to normally include a site visit. In its additional representation, ASIIN specified that site visits were a mandatory element in all type-1 evaluations. While the Register Committee welcomed the clarification, it underlined that the clear implementation in practice cannot be assessed at this stage; it should thus be subject of the next external review of ASIIN. The review report further identified cases where ASIIN did not follow the principles established in its own policy regarding the use of evaluation results for programme accreditation. The Register Committee took note of ASIIN’s statement on the report, which confirms that fact but does not include an explanation or rationale for departing from the policy. The Register Committee therefore considered that ASIIN did not implement its own processes consistently in all areas. Despite the fact that ASIIN stated in its additional representation that this was “one case among hundreds of procedures” and announced that it was planning to amend its own policy to the effect that a prior evaluation result could be used, provided is is not older than 2 years, the Register Committee noted that ASIIN's current policies were not always followed in practice, even if this was so in only very few cases.”

Full decision: see agency register entry

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

“The Register Committee took note of the explanation in ASIIN's additional representation of its policy and efforts to recruit “local” students, i.e. coming from the same country as the institutions under review. The Committee noted that the participation of students nationally and internationally was increased “to practically 100%”. The Register Committee noted that there was only one case reported where no student could be recruited for the panel. The Register Committee, however, underlined that it would not be compatible with the ESG to use the policy in the sense that only a local student can be appointed. That is, if no local student can be recruited for whatever reason, ASIIN is obliged to involve a non-local student, rather than no student at all.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	No possibility to appeal in cases where the review does not end in a judgment
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The Committee noted that for the accreditation procedures the appeals procedure is regulated in the statute and in the board of complaints’ rules of procedure but that there is no clearly defined appeals procedure for evaluations and other external QA procedures not resulting in a formal decisionIn the additional representation, ASIIN explained that it had clarified that its regular complaints procedures, applicable to accreditation procedures so far, is also applied to certification procedures and in type-1 evaluation procedures. The Register Committee confirmed that this is indeed clarified in public documents.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	clear distinction between different types of activities
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“When confirming eligibility of the application, the Register Committee requested (see letter of 26/2/2016) that ASIIN demonstrates how it ensures a clear, consistent and transparent separation between activities within the scope of the ESG and others, in particular in its public communication and where similar terms are being used, such as in the case of “type 1” (ESG) and “type 2” (non-ESG) evaluations. The review panel considered that ASIIN needs to further clarify the distinction between “type 1” and “type 2” evaluations. In particular, the panel recommended that ASIIN should no longer use the term “evaluation” for type 2 evaluations, but rather define those as consultation services internally and externally. The Register Committee considered ASIIN's Statement on the review report, noting that third parties tend to use the term “evaluation” for such services. While this might well be the case, the Register Committee could not see how that would prevent ASIIN itself from avoiding the term “evaluation” in its own communication, e.g. on its website. The Register Committee further noted the Statement on the review report does not explain how ASIIN would ensure transparency and a clear distinction despite insisting on using the term “evaluation”. Having considered the additional representation, the Register Committee considered that the distinction between the two types of evaluations is now better presented on the ASIIN website. The Register Committee noted that ASIIN, however, continued to use the word “evaluation” for type-2 evaluations, against the panel's recommendation, arguing that “the term is not restricted to uses as falling under the scope of EQAR”. ASIIN was furthermore “convinced that the distinction between the two types and the fact that type 2 evaluations do not fall under the remit of the ESG, and of EQAR, is very transparent on the ASIIN website”. While the Register Committee recognised that presentation and clarity have been improved, the Committee considered that it remains to be seen whether the presentation is sufficiently clear in practice, in particular in terms of ensuring that all those evaluations that are by their nature within the scope of the ESG are carried out as type-1 evaluations and in compliance with the ESG.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	systematic approach to analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel considered that the ASIIN newsletter and the annual meetings only partially fulfil the requirements of the standard. The panel noted that the newsletters do not include an analysis of finding ascertained by ASSIIN in its own work. While the annual meetings might address the type of issues to be covered by thematic analyses, the panel noted that there was no specific documentation with summary analyses resulting from those meetings. The Register Committee took note of ASIIN's Statement on the review report and the additional representation. While referring to a number of valuable initiatives and publications, the Committee considered that many of those rather represent internal feedback mechanisms or approaches to ensure consistency in decision-making. While some of ASIIN's newsletters and publications contain elements of thematic analyses, there are currently no regular published analyses which fully respond to the requirements of this standard.The Register Committee further underlined that the standard is not entirely new, but succeeded the standard “system-wide analyses” of the ESG 2005, which, despite its name, applied to all registered agencies already in the past.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Formalisation and efectiveness of Internal quality management system
Panel conclusion	Partial compliance
Clarification request(s)	Coordinator (04/07/2025)
RC decision	Compliance

“In its additional representation, ASIIN noted that it had formalised its internal quality management system and fully implemented its new QM manual. The Register Committee sought and received clarification from the German Accreditation Council (GAC), as the coordinator of the external review of ASIIN. GAC confirmed that it had assessed the implementation of ASIIN's QM structure as part of assessing fulfilment of a condition. In doing so, GAC found that the QM system was appropriately formalised and implemented effectively.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.1 Consideration of internal quality assurance
Keywords	Alignment of the ECCE’s criteria with the ESG Part 1
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (04/07/2025)
RC decision	Compliance

“The Register Committee further noted that the standards have not been amended following publication of the revised ESG and that no specific mapping or analysis was carried out on how ECCE’s criteria and procedures address ESG Part 1. Based on its own analysis and interviews carried out, the panel concluded that Part 1 of the ESG was “transversally” reflected within ECCE’s standards. The Register Committee requested the panel to further elaborate on this matter. In its response letter (of 15/11/2016) the panel stated that the focus of the analysis was the link between external and internal QA and that this was well established. The panel further added that “whilst it could not be demonstrated on a one to one basis that the standards 1.1 - 10 were addressed, the panel satisfied itself that the link existed”. In the additional representation, ECCE provided a mapping of the link between the ESG Part 1 and its own standards. The Register Committee considered the mapping and noted that standards 1.1 – 1.10 are addressed in the agency's criteria and processes for institutions/programmes.”

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	Independence of the review panels
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel stated that the agency’s conflict of interest procedure has not been addressed since the agency’s initial review. The analysis of the panel showed that ECCE’s procedure lack clear criteria with regards to areas of possible conflict of interest and that this has led to unsatisfactory choices of experts in a number of reviews carried out by ECCE. The panel further expressed concern regarding the presence of an evaluation secretary from ECCE’s staff within each expert panel. In its additional representation ECCE stated that it has nominated two non-chiropractic experts to evaluation panels and that it has de-centralised the secretary function, so that there is a separate secretary for each review. The Register Committee noted that ECCE has made steps to address the independence of its review panels. ”

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	consistency and clarity of the criteria
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel’s analysis showed that the agency’s criteria are unclear with regard to the period of institutional accreditation. The accreditation is given for a period of up to five years, but there is no specification in which cases the accreditation period will be shorter than five years. In its clarification to the additional representation (letter of 02/05/2017) ECCE stated that it had developed a “Compliance Table” and a list of the critical standards to assist panels as well as institutions to understand the expectation of each standard. ECCE expects to formally adopt this practice at their general meeting in November

2017. While the Register Committee acknowledge ECCE’s plans of a new set of criteria to ensure consistency and clarity in the application of criteria, the Committee noted that the agency has neither published the ‘Compliance Table’ nor formalised this practice.”

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	Functioning of the appeals process
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“With a view to ECCE’s complaints and appeals processes, institutions held the view that there was little point pursuing a complaint or appeal as the only restitution available was annulment of the whole accreditation process. The panel formed the view that ECCE’s current appeals’ procedure required updating and further improvement to meet the expectations of the standard. In its clarification to its additional representation (letter of 02/05/2017) ECCE responded that it had since the review, resolved one appeal situation (in favour of the institution) and that the agency is currently taking steps to revise its Appeals and Complaints processes.While the Register Committee noted the agency’s intention to revise its complaints and appeals processes, the Committee considered that this has not yet taken place...”

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	Strategic plan, involvement of students in the governance structures
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that, while the goals and objectives of ECCE are clearly described, ‘the strategic planning work seems to be underdeveloped and lagging behind ‘and ‘there is no clear evidence of robust yearly work planning and how it ties to the long or medium term strategies’ (review report, p. 56). The panel further stated that stakeholder involvement has not been fully ensured and especially recommended the involvement of students in the governance structures of ECCE. In its additional representation ECCE submitted a revised Strategic Plan (dated November 2016) with ‘indicators of success’. The agency also added that a student will be included in its Commission of Accreditation with effect from ECCE’s general meeting in November

2017. While the Register Committee took note of the revised strategic plan and the intention to improve student involvement into the governance of ECCE, the Committee considers that these changes still have to be enacted and externally reviewed by a panel (i.e. showing evidence of a robust yearly work planning, adoption of a strategic plan)”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.3 Independence
Keywords	Lack of experts from the field; organisational and operational independence
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Due to the small chiropractic community, the review team noted that experts from the field may lack independence. While this issue was highlighted in ECCE’s previous external review, the panel noted that the situation remained unchanged. The panel further stated that the move of experts and committee members within ECCE’s different organisational structures (panel experts, the Commission on Accreditation, Quality Assurance Committee, Executive) may pose questions to the effective independence of the agency. In its additional representation the agency stated that two additional experts from outside the chiropractic field were nominated and that the position of ‘Evaluation Team Secretary’ was replaced with newly appointed panel members. The agency also added that a list of conditions was prepared to be integrated as part of its conflict of interest statement. The Register Committee acknowledged the intention of ECCE to eliminate possible conflict of interest within its accreditation procedures and to improve its organisational and operational independence. Based on the evidence provided, the Committee could not yet verify that ECCE has addressed the earlier mentioned concerns (no clear explanation of conflict of interest for members of CoA, QAC or the Executive) and the nomination of two non-chiropractic experts is not yet enacted, since it has to be voted on at the General Meeting of ECCE in November.”

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 plan for thematic analysis;
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of inclusion the Register the Committee noted that attention should be given to whether ECCE publishes regularly and systematically overarching analyses from its accreditation activity. The review panel’s finding showed that ECCE had not undertaken an analysis into its external quality assurance activities although the agency had committed to a series of research of pedagogic papers in its Draft Strategic Plan 2016-2020. The Register Committee underlined the view of the panel that while the need to undertake such analysis had increased (as a result of the rise in the number of reviews) that ECCE lacked the human resources and capacity to undertake such a structured analysis. In its additional representation ECCE provided three research papers co-authored by one of the accreditation committee members that were used to update ECCE standards. The agency also stated that the newly hired consultant will be expected to perform specific research on the internal activities of the organisation. While the Register Committee noted that resources were allocated into the development of thematic analysis, the Committee could not conclude that ECCE’s research papers describe and analyse the general findings of the agency’s activities nor that ECCE has developed a plan to ensure that thematic analysis will be regularly undertaken.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.5 Resources
Keywords	financial sustainability
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel noted that ECCE’s level of financing was not fully ensured to professionally run external QA and make possible the further development of the organisation. In its additional representation (of 27/03/2017) ECCE informed that the membership fees of the agency have increased, that allowed the agency to improve its financial resources and employ a quality assurance consultant.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
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

“The panel recommended that ECCE develop a single consolidated internal quality assurance document that includes internal and external feedback mechanisms for continuous improvement. In its additional representation the agency stated that while the internal QA and professional conduct was an issue at the time of the external review ECCE had since put in place a number of measures to address these issues, i.e. a Complaints and Appeals procedures (document expected to be finalised in May 2017), questionnaires to collect feedback from ECCE committee members and is planning a study to compare its standards. Given that most of these steps are plans and their effectiveness has not yet been reviewed by an external panel, the Register Committee could not conclude that, as it stands, the agency’s internal quality assurance processes are fully sufficient to assure and enhance the quality and integrity of its activities. The Committee underlined the need for an external review of the changes to its internal quality assurance related to defining, assuring and enhancing the quality and integrity of the agency’s activities.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	2.1 Consideration of internal quality assurance
Keywords	Addressing IQA
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (04/07/2025)
RC decision	Compliance

“Given that the standards relating to design and approval of programmes (1.2), student-centred learning, teaching and assessment (1.3), student admission, progression, recognition, certification (1.4) and ongoing monitoring and periodic review of programmes (1.9) do not seem to be considered in ACPUA’s institutional-level activities (according to the table on alignment with the ESG) the Register Committee asked the panel (letter of 04/11/2016) to confirm whether they are in fact addressed within ACPUA’s programme accreditation procedures.It its response (letter of 20/11/2016) the Chair of the panel confirmed that the programme accreditation procedures (ex-ante accreditation, follow-up and ex-post accreditation) touch upon all standards of Part 1. As the review took place soon after the publication of the new ESG, the panel could not sufficiently well verify the focus on the new issues brought by ESG 2015, i.e. ESG 1.3 student-centred learning has not been explicitly stated in ACPUA’s evaluation criteria but the panel found there is significant ongoing discussion on how to best approach its inclusion. he Register Committee noted that although ACPUA performs several types of reviews in collaboration with ANECA or with other regional quality assurance agencies (i.e. DOCENTIA, AUDIT reviews) and thus it might not be in the position to modify the criteria and processes, the agency retains full responsibility for how it addresses Part 1 of the ESG in its own procedures that are carried out autonomously irrespective of whether such procedures are voluntary or obligatory in their nature”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	3.3 Independence
Keywords	Organisational independence
Panel conclusion	Full compliance
Clarification request(s)	Panel (04/07/2025)
RC decision	Compliance

“The Register Committee noted that the Board of the agency is chaired by the regional minister who is also responsible for the appointment of the Director of the organisation (following consultation with the Board of Directors).Referring to the independence of the Board the panel stated that while the Minister is the chair of this decision-making body there was no evidence of any political interference over the agency’s activities (Review Report, p.18). The Register Committee was unclear on the evidence supporting the conclusion of the panel and has therefore asked the panel to elaborate on the policies and processes which the panel considered to satisfy itself of the Board’s independence.In its clarification response (of 20/11/2016) the panel stated that the code of ethics extends also to the Board members, but that there were no specific mentions on this during the site visit. The panel satisfied itself on the separation of roles between the Board and technical committees and commented that it has been a positive step to guarantee the independence of the agency’s activities. The members of the technical committees interviewed by the panel reported that they had no political interference in their work. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach/lack of resources
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel stated that ACPUA has focused on thematic reports during its first year of existence, however the constraints on human and financial resources have hindered the agency’s activity in this area in recent years. Considering the increased number of external quality assurance activities carried out by ACPUA in recent years, the Register Committee underlined the panel’s recommendation to allocate sufficient resources to the activities supporting thematic analysis and ensure their implementation in a more systematic way”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	3.5 Resources
Keywords	financial sustainability
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that ACPUA’s main funding source comes from the regional government. The panel stated that the agency is considering possibilities to diversify its funding revenues and therefore reduce its financial dependence from the Ministry. While the panel commended the agency on the way it has dealt with its tasks considering its limited human and financial resources, it also expressed concerns regarding the agency’s ability to further sustain these efforts and ensure effectiveness in meeting its strategic goals.”

Full decision: see agency register entry