Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student, stakeholder involvement
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee noted the panel’s concerns in terms of a lack of student perspective in the Executive Board of the agency. While the agency has two nominated student representatives in the Executive Board, neither one is a student or a recent graduate of a higher education institution.

18. Furthermore, the Committee noted the unrealistic requirements for one of the two student representatives to hold a third-level university degree and have at least 15 years of academic or professional experience.

19. Considering the lack of diverse stakeholder representation within the governance of the agency i.e., the limiting conditions in allowing the representation of a student or employer perspective the Register Committee could not follow the panel’s judgement of compliance and found that SAAHE complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	ministry involvement, organisational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The Register Committee noted the panel’s analysis that the members of the Executive Board, of the Board of Appeal, the agency’s auditor and the Head of Office are all appointed by the Ministry (following a public selection procedure).

21. The Committee further noted the panel’s concerns regarding a high involvement of the minister in oversight of the agency i.e, in appointing the Chair of the Executive Board, in maintaining authority to dismiss the Chair and all members of the Executive Board (if there are any infringements of legislation or internal rules of the agency).

22. Taking into consideration the panel’s analysis, the Register Committee expressed its concern that the organisational independence of the agency is constrained by its close link and dependency on the Ministry. The Committee underlined the panel’s recommendation to ensure that the agency becomes fully independent and is able to act autonomously without any influence from the Ministry or other authorities. The Register Committee concurred with the panel that SAAHE complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.4 Peer-review experts
Keywords	Involvement of students in review panels
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“11. The Register Committee already noted in its change report decision (of 2022-10-28) that QAA has changed its policy since the last review and addressed the concerns raised as regards to student involvement in review panels.

12. The Committee was reassured by the panel’s analysis that showed that QAA ensures there is always a student included in its panels for all of the activities under review, except for follow-up visits. The Register Committee understands that follow-up visits are part of an external QA activity, and not a separate activity on its own and therefore finds this approach acceptable.

13. The Register Committee therefore finds the earlier issues addressed and concur with the panel’s recommendation that QAA should extend its pool of international reviewers in light of its own increasing rate of international reviews.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.5 Criteria for outcomes
Keywords	lack of a body to ensure consistency of outcomes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“14. The Register Committee understood from the review panel’s analysis that there is no independent commission that reviews and checks all reports and their application across the agency, which may question whether criteria are being applied uniformly.

15. The Register Committee concurs with the panel’s recommendation that QAA should strongly reflect on its approach to ensuring the consistency of outcomes including the potential need to establish an independent commission that validates reports and makes the final decision.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	presentation of activities within and outside the scope of the ESG
Panel conclusion	Compliance
Clarification request(s)	Panel (03/10/2023)
RC decision	Partial compliance

“17. The Register Committee noted the following concerns with the way QAA has separated its consultancy and related activities from its external QA activities within the scope of the ESG. In particular the Register Committee remained in doubt whether:

• readers (at least lay readers) are able to distinguish whether the reviews carried out in Albania (with the national QA body) fall within the scope of QAA's registration on EQAR, as they were not officially certified as in line with the ESG and

• how the agency ensures a clear communication and separation of the QE-TNE activity from QAA’s activities within the scope of the ESG, given that the activity can be easily misconstrued as an ESG activity (see change report of 2023-02-13).

18. The Register Committee noted that these concerns have not been addressed in the self-evaluation and external review report and therefore the Committee sought further clarifications from the panel to clarify how are the services rendered by QAA itself (internationally or domestically) separated from QAA’s regular ‘ESG activities’.

19. The panel explained (see minuted call of 2023-10-03) that in its understanding the QE-TNE activity is outside the scope of the ESG and thus outside the scope of the review. While the panel did bring this matter up during its discussion with the agency, the panel was reassured by the agency that this activity is not within the scope of the review. The panel was also unaware of the concerns raised by the Register Committee with regards to the consultancy activity carried out by the agency in Albania.

20. The Register Committee could not establish how the agency ensures a clear separation between ESG-type external quality assurance activities especially in cases where such a risk has been previously noted. The Committee therefore could not follow the panel’s judgment of compliance and found that QAA complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.4 Thematic analysis
Keywords	the geographical coverage of thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“21. The Register Committee noted that QAA carries out systematic thematic analysis within Scotland, sector-wide analysis in Wales, while UK-wide QAA has only carried out “The Quality Assurance of Alternative Providers: A Retrospective View”.

22. The Committee finds that the current activity is sufficient in its understanding and interpretation of the standard and therefore could not follow the panel’s judgment of partial compliance and concluded that QAA complies with ESG 3.4.

23. The Register Committee nevertheless underlines the panel’s recommendation that QAA should develop a clearer plan for thematic analyses for all of its external QA activities in all nations of the UK and publish them on its website.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ASIIN
Decision of	30/06/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	Coverage of ESG Part 1, issues re descriptors for alternative providers
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“11. ECTE was found to be non-compliant with ESG 2.1 following its initial review (see report of 2021-08-06) and the following Register Committee decision of 2022-06-28.

12. The Register Committee’s first concern was whether all ESG Part 1 were clearly enshrined in the ECTE standards for their new integrated review, covering both institutional and programme accreditation.

13. In its focused review, the panel analysed and confirmed that the integrated standards “cover all ESG I criteria”, based also on an analysis of the five accreditation procedures that took place since January 2022; these procedures featured programmes of various levels, profiles and types of providers. The Register Committee therefore found the issue addressed.

14. The Register Committee’s second concern was whether qualifications awarded by alternative providers refer to the correct level of the QF-EHEA.

15. The Register Committee found that the review panel's analysis was very generic containing no specific insights or findings on whether the concern was addressed. In particular, the Committee was not persuaded by the statement that ECTE Standards and Guidelines apply “uniformly to all ECTE programme levels (here 5-7), all types of providers (Higher Education Institutions as well as Alternative Providers) and all programme orientations (research and practice-oriented programmes)” given the fact that the learning outcomes in the Certification Framework differ between levels.

16. In its addendum to the report (submitted May 2, 2023) the panel clarified that all programmes accredited by the ECTE are classified as higher education and match the QF-EHEA descriptors, including practice-oriented programmes. The panel further explained that their formulation “of uniformly applied” meant to emphasise the use of one framework for different levels, in the way that programmes use one framework for evaluating different levels of programmes.

17. The Register Committee further found it hard to understand why the panel did not discuss the change of ECTE’s descriptors given the significant reduction in its detail and specificity. The Committee thus requested a comprehensive assessment on how ECTE’s subject-specific descriptors are considered in its new Certification Framework and on how the broad QF-EHEA descriptors themselves has impacted ECTE’s accreditation in practice.

18. The panel explained that they have not been aware of a different version of ECTE Certification Framework (earlier version published in 2019, analysed version published in September 2022)1, and thus only commented on the latest version.

19. In the view of the panel, ECTE’s documentation is consistently clear in requiring the application of ECTE standard B.2.1 (that concerns the application of QF-EHEA).

20. In its addendum to the report, the panel further provided an analysis of 16 reviews covering Short Cycle, First Cycle and Second Cycle qualifications delivered by alternative providers. The panel’s finding show that alternative providers have been specifically asked to link the learning outcomes of their programmes to the Dublin Descriptors and the associated higher education cycle.

21. The panel also checked whether ECTE evaluates the qualifications awarded by alternative providers at the correct QF-EHEA level and whether the intended learning outcomes and qualifications were in conformity with nationally agreed standards for theological education.

22. Following the consideration of the additional documentation, the Register Committee could follow the panel’s conclusion that ECTE is, in practice, examining whether qualifications at different levels match the QF-EHEA level.

23. Considering the effectiveness of how ECTE addresses these standards within its review reports (B2.1 and B5.1), the Committee found there’s a wide variation in the level of detail and specificity, that may hinder the successful application and interpretation. The Committee thus found that this concern was only partially addressed.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ASIIN
Decision of	30/06/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between HEIs and alternative providers/ Stakeholder involvement in governance
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“28. The Register Committee found ECTE to be only partially compliant with the standard (see decision of 2022-06-28), given the lack of a clear and transparent distinction made between officially-recognised higher education institutions (HEIs) and alternative providers (APs).

29. The panel analysed ECTE’s comprehensive measures introduced and how they have been implemented by both ECTE itself and the accredited providers.

30. The Register Committee commended ECTE for the steps taken and concurred with the panel that these address the earlier mentioned issues.

31. The Register Committee considered that the panel's concerns regarding the Accreditation Commission's (AC) dominance by staff and the lack of other stakeholder representation (e.g. students and business) are an issue related to the requirement of stakeholder participation in ESG 3.1 rather than related to ESG 3.3.

32. The Committee took note of ECTE’s immediate steps to ensure the appointment of stakeholder members (see ECTE statement of 2022-12-21). The Committee further considered the analysis provided by the panel in its addendum to the review report, on the new composition of the Accreditation Commission, that now ensures a broader stakeholder representation.

33. Given that the issues related to the involvement of stakeholders' perspectives on the AC was addressed, Register Committee was now able to concur with the panel's conclusion of compliance.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ASIIN
Decision of	30/06/2023
Standard	3.3 Independence
Keywords	Appointment process for accreditation body
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Partial compliance

“34. The Register Committee considered ECTE partially compliant with the standards 3.3 (see decision of 2022-06-28), due to concerns with regard to ECTE’s structure, the composition and overlapping functions of the ECTE Council and the possible conflict of interest in the role of some staff members; while steps to resolve this were taken, these had not been analysed by an external review panel.

35. The Register Committee took note that the new governance structure of ECTE separates the governance role of the Council from the accreditation decision-making role of the Accreditation Commission (AC) and that members of the committee hold no other positions within ECTE. The Committee further noted that ECTE has put additional measures in place to remove all staff representation from the Accreditation Commission.

36. The Committee however maintained that the practice whereby the Accreditation Commission nominates candidates for the same body is problematic in terms of ensuring the agency’s operational independence. Even if the candidates are nominated by the Board, the Register Committee found this approach may lead to conflict of interest scenarios and can affect the agency’s operational independent and fair selection process.

37. The Register Committee also found the appointment period of the AC confusing and ill-designed as it did not provide a limited term or a clear period for the mandate of the Commission i.e. ‘members of the Accreditation Commission are appointed by the Board for a period of two-four years, re-appointments are possible.

38. Given the above mentioned issues, the Register Committee found ECTE to be partially compliant with the standard as established previously.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	coverege of ESG Part 1
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. The Register Committee follows the panel’s analysis regarding the requirement of a public quality assurance policy (ESG 1.1), explicitly in the Inclusion of a licensed study programme on the accreditation form of a study field and the Accreditation of foreign study programmes frameworks. The Register Committee noted that AIC has yet to fully take up the national qualification framework (ESG 1.2) in each assessment framework, focussing more on assessment policies in all assessment frameworks, including a focus on student-centred assessment (ESG 1.3), and adding reference to public information (ESG 1.8) in the Inclusion of a licensed study programme on the accreditation form of a study field framework.

11. After consideration of the additional representation by AIC regarding the points addressed in the panel review report and the Register Committee decisions, the Register Committee concluded that even when considering that different procedures could be considered as a package, there are missing elements with regards to standards 1.1, 1.2, 1.3 and 1.8 in the QA model of the agency.

12. Therefore the Register Committee agrees with the argumentation of the panel and judgement of the standard only as partial compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.3 Implementing processes
Keywords	inconsistencies in the implementation
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. The Register Committee noted that there are inconsistencies in the implementation of the processes. The Register Committee underlines the panel’s recommendation that the agency should clearly communicate on the valid reasons behind multiple inputs to its accreditation process and decisions, by publishing them on the website as noted also in its Substantive Change Report Decision of 15 October 2021.

14. The Register Committee further noted the concerns raised by the review panel concerning the lack of relevant criteria and information integrated in AIC’s guidebook from the Law on Higher Education and Cabinet Regulations, as well as the updating of assessment methodologies, frameworks and the guidelines for institutions, as well as experts.

15. From the additional representation by the agency, the Register Committee understood that, when considering that different procedures would be considered as a package the Methodology for organising the assessment of higher education institutions and colleges could be seen as a follow-up procedure for the one-off procedure Accreditation of higher education institutions. While the panel noted that the agency is preparing a cyclical institutional accreditation, the Committee reiterates the need for clear follow-up measures.

16. The Register Committee concluded that AIC complies with ESG 2.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.4 Peer-review experts
Keywords	student in panel
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee stressed in its Substantive Change Report Decision of 2021-10-22 that the group of experts in the inclusion of licenced study programme on the accreditation of study field procedure, does not include a student. While the Committee understands that this procedure was created as a temporary and short-term solution in order to close possible gaps in the accreditation periods of programmes (until the next re-accreditation of the corresponding study field), the Committee could not follow the agency’s decision of not involving students, as per the requirement of the standard 2.4.

18. The Register Committee further noted from the review panel’s report that the agency has not resolved this issue and sustained its position that two experts should be sufficient in this procedure.

19. Considering AIC’s statement to the report that, the Register Committee understood that AIC is applying the national framework. The Committee however underlined that it is AIC’s responsibility to ensure ESG compliance with all standards and that it has taken measures to ensure the involvement of students in all procedures.

20. The Register Committee underlines the panel’s recommendation to include student-members in all procedures involving external experts, in particular in the procedures for Inclusion of a licensed study programme in the accreditation form of study field.

21. In its additional representation, AIC explained that the inclusion of licenced study programme on the accreditation of study field procedure is not a stand-alone procedure, but a temporary measure while the new quality assurance system from 2025 will include students in all procedures. The Register Committee however noted that students are at the time not included in this procedure, as the new system is not implemented yet. The Register Committee underlined the expectation of the standard, that

students should be involved in all QA processes.

22. The Register Committee concurs with the panel that AIC complies only partially with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	publication of decisions
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. The panel’s analysis shows that AIC does publish full reports of the experts panels for its procedures ‘Accreditation of higher education institution’, ‘Assessment and accreditation of a study field’, ‘Licensing of study programme’ and ‘Accreditation of study programmes abroad’.

24. The Register Committee further noted however, that these published reports and the decision letter do not reflect the additional elements which have been provided and taken into consideration after the site visit nor the additional tasks given to the higher education institution.

25. The Register Committee could not find any new supporting evidence to AIC’s position in the additional representation. Both from the panel’s report and the AIC website, it was clear that only the duration of accreditation terms is published, while the full decisions are not published together with the reports.

26. The Register Committee therefore concludes that there is no sufficient transparency in AIC’s reporting processes and therefore concurs with the panel’s conclusion of partial compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	appeals procedure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“27. The Register Committee noted in its past decision that the chairperson of the agency’s board takes the final decision on the appeal and reviews the conclusions of the Appeals Committee. The Register Committee found this may affect the integrity of the appeals process. Additionally, the Register Committee found that higher education institutions do not have the possibility in case of institutional accreditation to appeal the report with AIC (only with ministry).

28. In the Substantive Change Report (of 2022-03-15), AIC elaborated further on the modalities for potential appeals against accreditation decisions regarding the Accreditation of foreign study programmes. The explanations, however, left open how such appeals would be considered.

29. In the review report the panel explained the possibility to appeal accreditation decisions made by the agency. The panel considers that the appeals procedure which has been developed, and the Appeals Committee which has been compiled in January 2022, brought the agency’s review procedures for Latvian higher education institutions in line with the standard.

30. The Register Committee considered the statement of the agency regarding the appeals and complaints procedures and noted that the amendments to the legislation were approved and an appeal procedure including independent appeals commission, has been set and is functioning. The Register Committee welcomes the progress made, but follows the panel’s concern on the lack of the transparency of external quality assurance system, due to a lack of written procedure for hearing complaints.

31. The Register Committee underscores the panel recommendations on the publication of the procedures to follow-up complaints concerning activities of the agency in Latvia and on the development of an appeals and complaints procedure for its accreditation procedure for foreign degrees.

32. Having considered the improvements by the agency, the Register Committee noted the need to further elaborate on the procedure for complaints. The Register Committee agrees on compliance for this standard.”

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 management system, feedback mechanisms
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“33. The Register Committee understood from the panel’s analysis that AIC has set up an internal management system to support the daily work of the agency and the collection of feedback from different sources to inform improvements.

34. The Committee however noted AIC’s internal quality assurance system faces a number of issues and limitations: no major changes/ improvements can take place without government regulation or legal change; the informal nature of the feedback limits the ability of the agency to measure objectively “the outputs of the system”; no sufficient evidence that experts are getting acquainted with additional requirements or obligations set by Study Quality Commission after the accreditation procedure.

35. The Register Committee therefore finds that AIC has yet to consolidate its internal quality assurance system, including internal and external feedback mechanisms for continuous improvement.

36. 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 and therefore could not follow the panel’s conclusion, but found that AIC complies only partially with the standard 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	Insufficient coverage of ESG 2.1
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Looking at systemic level, the

different regulations touch upon the three particular standards of Part 1 of the ESG. However, the full coverage of all the standards of Part 1 is still not ensured through agency’s own criteria. Partial coverage of aspects through national legislation does not substitute coverage through external QA procedures and coverage of the ESG part 1 by higher education institutions’ internal QA is a prerequisite for EQA being able to assess their implementation”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of formal complaints procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Partially compliant with the standard due to the lack of formal complaints’ procedure– the higher education institutions could express their dissatisfaction with the process only informally throughout the review process. The agency is yet to establish a clear

complaints procedure that is known by higher education institutions”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ENQA
Decision of	03/03/2023
Standard	3.3 Independence
Keywords	Infringement of the operational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Dependency of the agency on staff paid by higher education institutions”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.5 Criteria for outcomes
Keywords	Inconsistent application of criteria
Panel conclusion	Compliance
Clarification request(s)	Agency (18/07/2023)
RC decision	Partial compliance

“The current set up brings confusion not only for the higher education institutions, but also for the

agency itself. The Committee found that agency’s criteria are not always applied consistently in the reviews and this leads to different standards being covered in the reports. During the clarification call, the agency explained that the SOP 2023 will be stabile - only reviewed and amended after 3 years again. The Committee welcomed these changes but found that the agency still enables usage of different SOPs – a practice that can lead to different outcomes and inconsistencies in the conclusions of its reports. This is especially problematic considering the regulatory function of the agency’s reviews for veterinary education.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of stakeholders
Panel conclusion	Compliance
Clarification request(s)	Agency (18/07/2023)
RC decision	Partial compliance

“The Committee was displeased to learn that EAEVE has not involved students and other stakeholders in the decision-making bodies since its registration on EQAR in

2017. While the Committee understood that involvingstudents from a narrow scientific field in the work of the agency could be a challenging task, it found that EAEVE could have found alternatives since its registration (e.g. establish stronger ties with stakeholders associations and or/create incentives for motivating other stakeholders to participate in the work of the agency, expand the involvement of students from closely related scientific fields etc.). The Committee found that the agency’s involvement of stakeholders, including students, in its governance and work is insufficient.”

Full decision: see agency register entry