Database of Precedents
-
3.3 Independence – AKAST – Partial compliance (2023) operational independence, decision-making
AKAST
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
-
3.4 Thematic analysis – AKAST – Partial compliance (2023) publication, analysis
AKAST
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 3.3.”
Full decision: see agency register entry
-
3.6 Internal quality assurance and professional conduct – AKAST – Partial compliance (2023) internal quality assurance, mechanisms
AKAST
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
-
2.6 Reporting – ARACIS – Partial compliance (2023) reports sometime lacking depth of analysis, expert reports not always publlshed
ARACIS
Application Renewal Review Targeted, coordinated by ENQA Decision of 12/12/2023 Standard 2.6 Reporting Keywords reports sometime lacking depth of analysis, expert reports not always publlshed Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “7. The Register Committee noted from the panel’s analysis that the central part of the agency’s reports appears to be merely a check list “occasionally lacking depth of analysis and evidence-based material”. The panel further raised concerns with regards to the accessibility of reports on the ARACIS website, which the panel found somewhat challenging to navigate.
8. The Committee further noted that in the case of doctoral study programmes, study domain accreditation and study domain authorisation ARACIS does not publish the experts’ final proposals for decision. The Committee does not understand why the final proposal for decision/expert conclusion is left out, in particular since this is included in all other external quality assurance activities of ARACIS. The Register Committee underlined that this approach affects the transparency of the agency’s decision making processes in the case of third cycle reviews.
9. The Committee also found that for some of its external QA activities the agency had changed its approach from publishing the full expert report to only publishing a short excerpt of the expert report i.e., the second cycle study domain accreditation reports only include up to a one page excerpt from the expert review report. The Register Committee underlined that it can be of public interest to know the basis on which the final reports are being developed, and that the publication (at least as annex) of the full reports is important to ensure the transparency in the decision-making of the Council.
10. Based on the above raised concerns, the Register Committee could not follow the panel’s conclusion of compliance and therefore concluded that ARACIS complies only partially with ESG 2.6.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – ARACIS – Compliance (2023) Lack of transparency in the agency’s appeals processes, accessibility of Appeals Procedure
ARACIS
Application Renewal Review Targeted, coordinated by ENQA Decision of 12/12/2023 Standard 2.7 Complaints and appeals Keywords Lack of transparency in the agency’s appeals processes, accessibility of Appeals Procedure Panel conclusion Compliance Clarification request(s) – RC decision Compliance “11. In its past decision, the Register Committee raised a concern regarding the lack of transparency in the agency’s processes concerning the members nominated to act in the Appeals Committee. The Committee also noted at that time that the appeals procedure was not easily accessible on ARACIS’s website.
12. The Register Committee noted from the analysis of the panel that ARACIS has appointed a Permanent Appeals Commission for a four-year term and published the composition of the commission. The Committee also learned that as of October 2022, ARACIS has a new, integrated and simplified Appeals and Complaints procedure that can be easily retrieved from the website1.
13. The Committee welcomed the newly updated procedure, and while noting that the procedure is rather generic in what concerns handling of complains, that it satisfies the requirements of the standard.”
Full decision: see agency register entry
-
3.6 Internal quality assurance and professional conduct – ARACIS – Compliance (2023) internal quality assurance (IQA) system not implemented
ARACIS
Application Renewal Review Targeted, coordinated by ENQA Decision of 12/12/2023 Standard 3.6 Internal quality assurance and professional conduct Keywords internal quality assurance (IQA) system not implemented Panel conclusion Compliance Clarification request(s) – RC decision Compliance “15. In its past decision the Register Committee found that the internal quality assurance (IQA) system had not been implemented at that time. In particular it found that the IQA had yet to prove its role in supporting the internal activity of its speciality commissions and in providing the agency with a sound basis for reviewing and improving the effectiveness with which it works.
16. The Register Committee noted from the detailed analysis of the review repot that ARACIS has set up a functional internal QA system including relevant documentation, structures and personnel. Having considered the evidence presented, the Committee can follow the panel’s conclusion that ARACIS now complies with the requirements of standard 3.6.”
Full decision: see agency register entry
-
2.6 Reporting – SAAHE – Compliance (2023) publication of reports
SAAHE
Application Initial Review Full, coordinated by ENQA Decision of 12/12/2023 Standard 2.6 Reporting Keywords publication of reports Panel conclusion Partial compliance Clarification request(s) Agency (28/11/2023)
RC decision Compliance “9. The panel reported that it could not identify any clear links where the decisions and the evaluation reports of the review panels are being published on the agency’s website.
10. The Register Committee sought further clarification from the agency (see minuted clarification) in order to understand the agency’s practice regarding the publication of reports and decision.
11. The agency explained (and presented) how the reports are being published on its website i.e. via links within a document uploaded on its website each time a new report is finalised. SAAHE further explained that the agency also publishes, the applications and self-assessment reports of higher education institutions undergoing review procedures. The agency is aware that the current way of publishing reports and decision is not ideal but explained that it was hesitant in making any changes during its review process.
12. The Register Committee sought further clarification on the lack of published reports in 2022 and
2023.
13. The agency explained that following a change in legislation, in 2021, all higher education institutions are required to undergo institutional accreditation and had to apply for such a review by the end of
2022. The agency clarified that while all 33 higher education institutions are have applied for an institutional accreditation, at the moment no procedure has yet been finalised. A pending decision by SAAHE’s Executive Board is expected in February
2024. (see minuted clarification)
14. Having considered the report and the clarification by the agency, the Committee concluded that despite the difficulty in accessing the links of published reports, that SAAHE has been publishing full reports and decisions on its website. The Register Committee underlined the recommendation by the panel to ensure the publishing of reports and decisions in a more accessible and informative way than the current practice.
15. The Register Committee noted that the agency is expected to inform the Register once it has concluded its first institutional accreditation procedure.
16. Having considered the review report and the clarification by the agency, the Register Committee was unable to concur with the panel’s judgement of partial compliance, and concluded that SAAHE complies with ESG 2.6.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – SAAHE – Partial compliance (2023) student, stakeholder involvement
SAAHE
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
-
3.3 Independence – SAAHE – Partial compliance (2023) ministry involvement, organisational independence
SAAHE
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
-
2.4 Peer-review experts – QAA – Compliance (2023) Involvement of students in review panels
QAA
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
-
2.5 Criteria for outcomes – QAA – Partial compliance (2023) lack of a body to ensure consistency of outcomes
QAA
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
-
3.1 Activities, policy and processes for quality assurance – QAA – Partial compliance (2023) presentation of activities within and outside the scope of the ESG
QAA
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
-
3.4 Thematic analysis – QAA – Partial compliance (2023) the geographical coverage of thematic analysis
QAA
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 Partial 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
-
2.1 Consideration of internal quality assurance – ECTE – Partial compliance (2023) Coverage of ESG Part 1, issues re descriptors for alternative providers
ECTE
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
-
3.1 Activities, policy and processes for quality assurance – ECTE – Compliance (2023) Distinction between HEIs and alternative providers/ Stakeholder involvement in governance
ECTE
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
-
3.3 Independence – ECTE – Partial compliance (2023) Appointment process for accreditation body
ECTE
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
-
2.1 Consideration of internal quality assurance – NOKUT – Partial compliance (2023) Insufficient coverage of ESG 2.1
NOKUT
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
-
2.7 Complaints and appeals – NOKUT – Partial compliance (2023) Lack of formal complaints procedure
NOKUT
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
-
3.3 Independence – THEQC – Partial compliance (2023) Infringement of the operational independence
THEQC
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
-
2.5 Criteria for outcomes – EAEVE – Partial compliance (2023) Inconsistent application of criteria
EAEVE
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
-
3.1 Activities, policy and processes for quality assurance – EAEVE – Partial compliance (2023) Involvement of stakeholders
EAEVE
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
-
2.4 Peer-review experts – NEAA – Partial compliance (2023) training, training of experts
NEAA
Application Renewal Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 2.4 Peer-review experts Keywords training, training of experts Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “8. The Register Committee noted from the panel’s analysis that the trainings of experts have been reduced to only a briefing session taking place before the site visit. The panel’s analysis further show that the last training organised by NEAA took place in 2018 (before the Covid-19 pandemic).
9. The Register Committee underlined that the agency is expected to ensure that experts have the appropriate skills and competences to carry out external reviews and that such skills and competences are acquired through regular (periodic) trainings organised by the agency.
10. In its representation, NEAA provided information that it has started intensively working on preparation and implementation of several trainings focused on specific standards and criteria. NEAA also informed that future training sessions will be included in its Action Plan.
11. The Register Committee welcomed the steps taken by NEAA to address the earlier concerns, but noted that the Committee could not verify whether these training activities will ensure that all members of a panel will be systematically trained prior to undertaking an external quality assurance procedure. The Committee noted that these will remain to be determined in NEAA’s next external review.
12. The Register Committee therefore remained unable to concur with the panel’s conclusion, but considered that NEAA complies only partially with ESG 2.4.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – NEAA – Compliance (2023) appeals and complaints, committee
NEAA
Application Renewal Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 2.7 Complaints and appeals Keywords appeals and complaints, committee Panel conclusion Compliance Clarification request(s) – RC decision Compliance “13. In its initial application for inclusion the Register Committee raised concerns regarding the lack of an internal appeals system within the agency.
14. The Register Committee noted that since the last external review of NEAA, nothing has changed in relation to the possibilities for higher education institutions to make an appeals with the agency.
15. The Register Committee further noted, that NEAA does not have its own appeals process nor a separate body in considering appeals and that the only existing appeals procedures are outside of NEAA’s remit, defined by law and under the legal competency of the Bulgarian courts.
16. The Committee considered that external quality assurance processes should always include an internal possibility to appeal within the responsible body that carried out the review itself.
17. In its representation the agency provided full documentation on its new internal provisions for complaints and appeals and for the functioning of its body the Complaints and Appeals Committee. The Committee noted that the new body is a standing committee within the agency, fully operative with permanent members and clear provisions outlined in the Statutes of the Complaints and Appeals Committee.
18. Having been able to verify that the agency provides both internal processes for complaints and appeals, the Register Committee finds that the initial concerns have been addressed. The Register Committee therefore concluded that NEAA now complies with ESG 2.7.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – NEAA – Partial compliance (2023) stakeholders, stakeholders involvement, Accreditation Council
NEAA
Application Renewal Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 3.1 Activities, policy and processes for quality assurance Keywords stakeholders, stakeholders involvement, Accreditation Council Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “19. In its last decision, the Register Committee noted that the composition of NEAA’s Accreditation Council (AC) is dominated by representatives of the academia and that there is a lack of stakeholder involvement with no student or labour market/employment representatives involved in the work and governance of NEAA.
20. The Register Committee noted that while NEAA expanded the direct participation of stakeholders in its work i.e., including representatives of students and employers in the Expert Groups and the Standing Committees, that the composition of the Accreditation Council (AC) is still limited to only representatives of the academic community.
21. Despite the improvements done by NEAA in the involvement of stakeholders’ in some of its processes and bodies, the Register Committee considered the lack of stakeholder involvement (as per the requirement of the standard) in the core governance body of NEAA as of crucial importance.
22. The Committee further emphasised the recommendation of the panel to ensure the inclusion of a representative of students and employers/industry in the AC, including a representative of students (preferably with a legal background) in NEAA’s Ethics Committee.
23. In its representation, the agency provided information on the actions taken toward the government and parliament around the need for legislative changes. The Committee took note and welcomed the positive developments towards the involvement of stakeholders in the Accreditation Council, however at the time of the Register Committee’s consideration, no changes have happened, nor a clear timeline for such changes has been provided.
24. The Register Committee acknowledge that although NEAA has taken all possible actions to improve the involvement of stakeholders within relevant normative documents, the fact remains that the level of compliance is negatively impacted by the regulatory framework within which NEAA operates.
25. The Register Committee therefore concurs with the panel that NEAA complies only partially with ESG 3.1.”
Full decision: see agency register entry
-
3.5 Resources – NEAA – Partial compliance (2023) resources, financial independance
NEAA
Application Renewal Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 3.5 Resources Keywords resources, financial independance Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “26. The panel noted that the main challenge for NEAA remains the fact that it cannot manage its own finances in a manner that will enable NEAA to ensure the best quality of its activities. Even if the majority of the funding comes from its external quality assurance activities i.e., mostly accreditation fees, due to the strict regulations and rules defined on national level, NEAA cannot access these revenues. The Committee concurs with the panel that this could have a negative impact on the sustainability and the quality of its processes.
27. The panel underlined that despite the improvements and increase of staff members since its last review, from 8 to 19 staff members, NEAA still had a high number of vacant positions.
28. The Committee emphasised the panel’s recommendations on the need for the agency to pursue with the Ministry changes in its financial management and to continue the recruitment of new staff to ensure optimal workload and implementation of external QA processes on time.
29. In its representation, NEAA reported of a further increase in its staff (i.e., from 19 to 23 employees), with recruitment for some of these positions currently underway. The Committee noted that the agency has taken active steps addressing specific proposals to increase pay rates to the Ministry of Education, the Ministry of Finance and the Prime Ministers office. Similar efforts are directed towards the Council of Rectors. Further, the agency stated that there are constant efforts made towards the responsible national authorities with a request to increase the budget of the agency.
30. The Register Committee welcomed the actions taken by NEAA. The Register Committee, however, noted that despite the improvements in NEAA’s permanent staff, the agency’s financial independence, due to external factors, remains constrained, and while the limitations in resources may not pose an immediate concern as to the sustainability of the agency, it may negatively impact the scope and quality of the activities undertaken by NEAA.
31. The Register Committee therefore concurred with the panel’s conclusion that NEAA complies only partially with ESG 3.5.”
Full decision: see agency register entry
-
3.6 Internal quality assurance and professional conduct – NEAA – Partial compliance (2023) internal, internal QA system,
NEAA
Application Renewal Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 3.6 Internal quality assurance and professional conduct Keywords internal, internal QA system, Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “32. The panel noted that NEAA started developing its internal quality assurance system introducing, some new mechanisms and procedures. However, the panel underlined that the elements of the procedures are fragmented and not fully structured, integrated and connected in a systematic way. The panel also noted the lack of transparency of the mechanisms and their results.
33. Despite NEAA’s efforts to develop its own internal quality assurance system, the Register Committee found that the process is still in a developmental phase. The Committee underlines the panel’s recommendation that all the elements of the internal QA system needs to be better connected, regularly implemented with the involvement of all internal and external stakeholders.
34. In its representation, NEAA informed that in 2023, the agency undertook an internal audit to identify the weaknesses and bottlenecks in its own internal processes and review procedures. The agency also provided details of the internal audit process and the series of recommendations that were outlined to correct the issues. NEAA further stated that necessary measures are being implemented to improve the functioning of the agency.
35. While the Register Committee welcomed the steps taken by NEAA, the Committee underlined that the issues outlined before remain to be considered and reviewed by an external review panel to determine the improvement in the functioning of NEAA’s internal QA system.
36. The Register Committee therefore concurred with the panel’s conclusion that NEAA only partially complies with ESG 3.6.”
Full decision: see agency register entry
-
2.6 Reporting – KAZSEE – Partial compliance (2023) Publication of reports
KAZSEE
Application Initial Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 2.6 Reporting Keywords Publication of reports Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “At the time of the site visit the
agency’s website was under development, and the access to all reports was
not possible. The Committee noted that the website was still not upgraded
and fully functional at the time of taking the decision - almost one year after
the panel’s visit. This circumstance prevented the Committee from verifying
whether all the reports are publicly available. The Committee
concurred with panel’s conclusion of partial compliance.”
Full decision: see agency register entry
-
3.3 Independence – KAZSEE – Partial compliance (2023) Operational independence; Independence of formal outcomes
KAZSEE
Application Initial Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 3.3 Independence Keywords Operational independence; Independence of formal outcomes Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Committee learned that both the president and the vice president
of KAZSEE have voting rights in the two bodies in which they are members
of, i.e. the Accreditation Council and the Supervisory Board. In panel’s view
the “mixture of roles [of the President and the vice President] could make
the [decision making] system vulnerable”. The Committee could follow panel’s reasoning that the current
arrangements could pose threat for the operational independence and the
independence of formal outcomes.”
Full decision: see agency register entry
-
3.4 Thematic analysis – KAZSEE – Partial compliance (2023) Performing thematic analysis
KAZSEE
Application Initial Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 3.4 Thematic analysis Keywords Performing thematic analysis Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The agency does reports covering different
topics – however they are mostly related to projects, rather than findings
from the external quality assurance activities. The panel further highlighted
that the agency is aware of the importance of collecting and analysing data
from the review processes for its own development purposes, but also for
contributing to the system level policies. The Committee acknowledged that while the thematic analyses are
not taking place in a systemic and formal manner, KAZSEE is a relatively
new agency that demonstrates interest to further formalise the processes
for producing thematic analyses.”
Full decision: see agency register entry
-
2.6 Reporting – ACCUEE – Partial compliance (2023) ex-post accreditation, Technical Committee, experts reports
ACCUEE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 2.6 Reporting Keywords ex-post accreditation, Technical Committee, experts reports Panel conclusion Compliance Clarification request(s) Panel (13/02/2023)
RC decision Partial compliance “10. The Register Committee noted that the responsibility for the preparation of the external review reports for the monitoring and ex-post accreditation of study programmes is with the Technical Committees.
11. The Register Committee noted that the experts’ site-visit reports were not part of the final external review report and they were only available for the analysis of the Technical Committees. The Register Committee could not understand why the experts reports (in the case of the monitoring and ex-post accreditation of study programmes) is not published as well and therefore asked the panel for further clarification.
12. The panel explained (see minuted clarification 2023-02-13) that the practice of having a committee develop these reports is common among all Spanish QA agencies and it ensures the consistency of reports.
13. The Register Committee further asked the panel to clarify the forms of factual and non-factual allegations made by institutions on the reports of the Technical Committees. The panel explained (see minuted clarification) that the allegations have always been focused on the technical part of the reports (factual comments). However, the panel added that the agency should clearly differentiate within its procedure that the allegations deal only with factual errors and do not address diverging views and opinions on the statements and assessments taken in the report.
14. While the Register Committee welcomed the use of a Technical Committee to ensure consistency, the Register Committee could not follow the reasoning of not including or separately publishing such reports (i.e. as an annex). The Register Committee underlined that it can be of interest for the public to know the basis on which the final reports are being developed. In particular, such information is important to ensure the transparency in the Technical Committee’s decision making.
15. The Register Committee therefore could not follow the panel’s conclusion on the compliance with the standard, but concluded that ACCUEE complies only partially with ESG 2.6.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – ACCUEE – Partial compliance (2023) allegations, appeals, complaints
ACCUEE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 2.7 Complaints and appeals Keywords allegations, appeals, complaints Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “16. The Register Committee noted that the agency defines three different processes for allegations, appeals and complaints.
17. The allegations (considered as a form of feedback opportunity for the institutions) are dealt with by the Technical Committees, who is also responsible for drafting the reports (see also under ESG 2.6).
18. The appeals and complaints procedures are defined by law and are under the legal competency of the Canary government.
19. The Committee noted, that ACCUEE’s appeals and complaints policies are limited as the agency does not have its own appeals and complaints processes or a separate body in considering complaints or appeals.
20. The Committee considered that external quality assurance processes should always include an internal possibility to appeal and complain with the responsible body that carried out the review itself.
21. The Register Committee noted that ACCUEE intends to appoint an independent and permanent body, Guarantee Commission that will consider all appeals and complaints related to all procedures that are in the scope of the ESG.
22. The Register Committee welcomed ACCUE’s intention to set up a separate body to handle appeals and complaints, but the Committee underlined that such changes are yet to be implemented and to be reviewed. The Register Committee therefore concurred with the panel that ACCUEE only partially complies with ESG 2.7.”
Full decision: see agency register entry
-
3.3 Independence – ACCUEE – Partial compliance (2023) regional government representation, Governing Board, Technical Committee
ACCUEE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords regional government representation, Governing Board, Technical Committee Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “23. In regards to organisational independence, the Register Committee noted that the Governing Board, the body responsible for the approval of accreditation methodologies and criteria, has a strong regional government representation, with one third of the members nominated by the regional ministry The Committee further noted that the regional ministry is also responsible in appointing the president and vice-president of the Governing Board.
24. The Committee further noted that the regional government directly appoints the Director of the agency. The Committee found this problematic given the Director’s responsibility in ensuring the independent operations of the agency and in chairing all of the agency’s Technical Committees for ex-post accreditation of study programmes.
25. The Committee further noted that the agency is limited in its recruitment processes as this responsibility lies with the regional government (review report, p. 27).
26. Given the close link to the regional government, the Committee shares the panel’s view that ACCUEE should (in consultation with the regional Government) amend the current processes regarding the appointment of the Director as well as the legal frameworks definition on the composition and the proportion of governmental members in the Governing Board and ensure the recruitment processes are under the competency of the agency.
27. The Register Committee welcomed ACCUEE’s plans for addressing the panel’s concerns, but the Committee underlined that these changes are yet to be fully enacted. The Register Committee therefore concurred with the panel that ACCUEE only partially complies with ESG 3.3.”
Full decision: see agency register entry
-
2.3 Implementing processes – HAKA – Compliance (2023) study programme groups
HAKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 30/06/2023 Standard 2.3 Implementing processes Keywords study programme groups Panel conclusion Compliance Clarification request(s) – RC decision Compliance “The Register Committee found the difference between the initial and re-assessments of study programme groups on the one hand and the phasing out of assessments of study programme groups on the other hand not to be completely clear.
The agency explained (see clarification of 2023-06-06) that the initial and re-assessment procedures remain compulsory for the opening of any new study programme groups. For existing study programme groups that have gone successfully through multiple assessment processes, the assessments of individual study programme groups are being phased out for a sample of these programmes, within the new model for institutional accreditations.
Having considered the agency’s explanation and the implementation of the new procedures, the Register Committee concurs with the panel’s conclusion of compliance.”
Full decision: see agency register entry
-
3.5 Resources – HAKA – Compliance (2023) state budget
HAKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 30/06/2023 Standard 3.5 Resources Keywords state budget Panel conclusion Full compliance Clarification request(s) Agency (06/06/2023)
RC decision Compliance “The Register Committee noted that the proportion of HAKA’s activities financed through state budget has been decreasing. This is caused by the fact that HAKA has taken on activities for other education levels/types not falling under the ESG, which are financed through projects.
The Register Committee understood from the agency’s clarification (see minuted response of 2023-06-06) that the financial concerns do not affect the agency’s ability to carry out its regular external QA activities.
The Register Committee therefore concluded that the agency continues to comply with ESG 3.5.”
Full decision: see agency register entry
-
2.1 Consideration of internal quality assurance – NVAO – Compliance (2023) coverage of ESG Part1
NVAO
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.1 Consideration of internal quality assurance Keywords coverage of ESG Part1 Panel conclusion Compliance Clarification request(s) Panel (10/02/2023)
RC decision Compliance “11. The Register Committee noted that a protocol for the assessment of transnational education in the Netherlands (NL) came into effect in
2018. The Committee however could not find any information on whether NVAO-NL has addressed the standards of ESG Part 1 (ESG 1.1-ESG 1.10) in its new protocol and has therefore sought further clarification from the panel.
12. The panel explained (see clarification letter) that a transnational education programme may be provided on the condition that the programme abroad is equal to the one accredited in the Netherlands. This may only concern programmes that have already been accredited in the Netherlands. Given this condition, the review panel explained that the study programmes abroad follow the same accreditation protocol as the programmes accredited in the Netherlands.
13. The Register Committee understands that ESG Part 1 has been verified by the panel for the renewed 2018 NVAO-NL assessment framework and noted that a clear link between the institution’s internal and the NVAO’s external quality assurance procedures was ensured.
14. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standards 2.1.”
Full decision: see agency register entry
-
2.5 Criteria for outcomes – NVAO – Compliance (2023) deviation from the outcome of a panel’s report
NVAO
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.5 Criteria for outcomes Keywords deviation from the outcome of a panel’s report Panel conclusion Compliance Clarification request(s) Panel (10/02/2023)
RC decision Compliance “15. The Register Committee noted that NVAO-NL may modify a recommendation for a positive outcome in a panel report, although it has never so far questioned this. The Committee was unclear on the situations that may lead to a deviation from the outcome of a panel’s report and whether such deviations are documented.
16. In its clarification response (of 10/02/2023) the review panel explained that NVAO-NL may occasionally seek additional information from panels and in a limited number of cases, and after due deliberation may expand conditions or deviate in a minor sense from the panel’s advice. Such changes may be done by NVAO-NL to reduce the subjectivity of reports and ensure the consistency of recommendations as well as of the final outcome. Deviations from the final recommendation of the panel have not happened yet, but according to the agency’s procedure these changes are documented in the final published decision by NVAO-NL.
17. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standard 2.5.”
Full decision: see agency register entry
-
2.6 Reporting – NVAO – Compliance (2023) readability of reports, delay in publication
NVAO
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.6 Reporting Keywords readability of reports, delay in publication Panel conclusion Compliance Clarification request(s) Panel (10/02/2023)
RC decision Compliance “18. In its previous renewal decision, the Register Committee stressed the delay in NVAO’s publication of reports and noted issues related to the readability of reports.
19. The panel’s findings show that NVAO has since its last review introduced instructions and templates for reporting and that the readability of submitted initial assessment reports is also checked by NVAO. The panel further confirmed that the publication of reports was done without any more significant delays, but suggested setting up an automatic uploading system of NVAO-NL reports (as it is done for NVAO-FL).
20. The Register Committee welcomed the improvements in the agency’s reporting and concurred with the panel’s conclusion that NVAO now complies with the standard 2.6.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – NVAO – Compliance (2023) separation between activities that are within and outside the scope of the ESG
NVAO
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 3.1 Activities, policy and processes for quality assurance Keywords separation between activities that are within and outside the scope of the ESG Panel conclusion Compliance Clarification request(s) Panel (10/02/2023)
RC decision Compliance “21. In its Terms of Reference for the review the Register Committee asked the panel to consider how the agency clearly separates between activities that are within and outside the scope of the ESG, in particular considering the ‘Assessment of Quality Agreements in the Netherlands’ and the ‘Assessment of the quality of Training Schools’. While the panel concludes that there is a clear separation between NVAO’s activities within and outside the scope of the ESG, the Committee could not find the argumentation to support the panel’s conclusion and has therefore sought further information.
22. In its response (see minuted conversation), the panel explained that the separation between the agency’s activities that are within and outside the scope of the ESG did not pose any concern.
23. Considering the Assessment of quality agreements in the Netherlands the panel stated that the activity does not address the teaching and learning aspects within higher education and that the focus of the assessment is on how institutions (plan to) spend the so-called study advance grants. The panel added that the agency’s protocol or description does not misrepresent the activity in any way (i.e. referring to ESG or EQAR registration).
24. Considering the evaluation procedure for teacher training schools, the panel clarified that the activity does not address or evaluate the teaching and learning in higher education, but it assesses the collaboration between schools for primary and secondary education and institutions for teacher training.
25. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standard 3.1.”
Full decision: see agency register entry
-
2.4 Peer-review experts – HAHE – Partial compliance (2023) Student involvement in panels
HAHE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 2.4 Peer-review experts Keywords Student involvement in panels Panel conclusion Non-compliance Clarification request(s) Agency (14/02/2023)
RC decision Partial compliance “Further efforts made by the
agency to engage students in the review panels - in particular
students have participated in the first reviews by the time the Register Committee analysed the application. While the panel’s
conclusion of non-compliance did reflect accurately the situation at the
February 2022’s site visit, the Committee concluded that the agency is now
partially compliant with the standard. The Committee, however, underlined
that further evidence of the actual involvement of the students in the panels
will be needed and has to be thoroughly analysed in the next review of HAHE”
Full decision: see agency register entry
-
2.7 Complaints and appeals – HAHE – Compliance (2023) Independence of the appeal's body
HAHE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 2.7 Complaints and appeals Keywords Independence of the appeal's body Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The panel argued that there was “no avenue available to have an
external review of a decision” and noted the “absence of external
adjudication in the mechanism used”. The Register Committee expects that
an appeal is considered by another body than the one whose
decision/report is appealed (see interpretation 13 of the ESG); this will
nevertheless normally be a body of the agency, as the standard requires an
internal appeals process (see also interpretation 12 of the ESG). As the
HAHE appeals committee consists of different persons than the (current)
EAC, this requirement is formally fulfilled, even if HAHE may reconsider the
practice of appointing only retired EAC members when it reviews its
appeals procedures as recommended by the panel, Further, the fact that the appeals' committee makes a recommendation to the
EAC is compatible with EQAR's expectations (see interpretation 14 of the
ESG).”
Full decision: see agency register entry
-
3.4 Thematic analysis – HAHE – Compliance (2023) Content of the thematic analysis
HAHE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.4 Thematic analysis Keywords Content of the thematic analysis Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “From several Annual reports of the agency from recent years, the Committee learned that the agency provides key figures on its work, but
also provides an in-depth overview of the compliance levels per standard in the undertaken accreditation procedures, summarises the good practices and obstacles observed in HEIs, and presents the most common recommendations by the panels.Following this, the Register Committee found that the current practice fulfils the minimum ESG criteria”
Full decision: see agency register entry
-
2.5 Criteria for outcomes – ECCE – Partial compliance (2023) Methodology and criteria for the different re-accreditation period inconsistent
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 2.5 Criteria for outcomes Keywords Methodology and criteria for the different re-accreditation period inconsistent Panel conclusion Compliance Clarification request(s) Panel (15/02/2023)
RC decision Partial compliance “12. The Committee noted from the panel’s report that it is now clear what level of compliance a programme must achieve to receive the full 8-year accreditation period. At the same time, the definition of shorter accreditation periods remained unclear: the panel also confirmed in its clarification that there are no specific criteria or guidelines that determine by how much the period gets shortened.
13. In its additional representation the agency explained its methodology and criteria for the different re-accreditation period. While the Register Committee found a clear reasoning in the agency’s response, the Committee could not understand why the cited information (i.e. table and explanation provided) was not integrated in the agency’s procedures i.e., Accreditation Procedures and Standards. In particular, the Committee found the provided information on the length of the accreditation cycle i.e., of five years, to be completely missing from the agency’s procedure for re-accreditation (see Accreditation Procedures and Standards 5.3 – November 2019 Section 3.2.4.2.1).
14. Given the inconsistencies in the agency’s explanations and the presentation of ECTE’s criteria in its own procedures, the Register Committee was not persuaded that the agency ensured a consistent application of its criteria in its decision making.
15. The Committee also considered that this issue was amplified by the fact that there is no decision document (see also ESG 2.6), i.e., the Quality Assurance & Accreditation Committee’s (QAAC’s) considerations and argumentation on why a certain length of accreditation period was decided are currently not recorded in any public document.
16. The Register Committee thus remained unable to concur with the panel’s conclusion, but considered that ECCE only partially complied with the standard.”
Full decision: see agency register entry
-
2.6 Reporting – ECCE – Partial compliance (2023) Publication of Accreditation Decisions
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 2.6 Reporting Keywords Publication of Accreditation Decisions Panel conclusion Compliance Clarification request(s) Panel (15/02/2023)
RC decision Partial compliance “17. The Register Committee noted that the decisions of the Quality Assurance & Accreditation Committee’s (QAAC) are published only in the form of the accreditation period being presented on the web page listing accredited programmes (https://cce-europe.org/index.php/accredited-institutions.html). The list contains links to the expert review reports, but not to the QAAC decision as a separate document or similar.
18. The standard requires that “if the agency takes any formal decision based on the reports, the decision should be published together with the report”.The Register Committee assumed that a written record of the QAAC decision presumably exists in some form, either as a document sent to the accredited programme or as section in the QAAC minutes. The review panel clarified that it was not aware of the QAAC decision being available a separate document.
19. In its additional representation the agency stated that what is published on its website i.e., the dates of when the institution was first accredited, the most recent decision and the date of when the accreditation runs out represent, next to the generic statement on its website - that a programme meets ECCE’s criteria and standards for accredited status - represents its decision.
20. The Register Committee underlined that the standard aims to ensure reliable documentation and transparency of the agency's outcomes and the mere publication of the date of the accreditation does not suffice.
21. The Committee further disagrees with the agency’s claim that its objection are technical in nature. The Committee emphasised that QAAC decisions are not recorded in writing at all (beyond the dates cited on the web page) and that ECCE does not provide any information to the public on e.g., when such a decision was taken, the basis of QAAC’s decision making, the rationale for QAAC in agreeing/disagreeing with the findings of the panel or any recording of a possible conflict of interests with the institution applying for ECCE accreditation.
22. The Register Committee therefore could not concur with the panel’s conclusion that ECCE complies with the standard, but found ECCE to be only partially compliant.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – ECCE – Partial compliance (2023) no possibility to appeal the formal decisions
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 2.7 Complaints and appeals Keywords no possibility to appeal the formal decisions Panel conclusion Partial compliance Clarification request(s) Panel (15/02/2023)
RC decision Partial compliance “23. The panel raised concerns about the slight unclarity and overlap between the “appeals and complaints procedure” and the separate “complaints procedure”. Even though the wording is unusual, the Register Committee considered that both appeals and complaints, as understood in the ESG, are generally possible.
24. The Committee obtained clarification by the panel on the composition of the Appeals Committee. Even though the members are different from the QAAC, the Committee shares the panel’s concern that all but one come from the rather small chiropractic community.
25. The Register Committee’s further noted that there is no possibility to appeal the formal decision by the QAAC, only the expert report. The Committee regarded this as problematic given that the QAAC alone decides on the accreditation term.
26. In its additional representation the agency explained that the judgement itself of the QAAC cannot be appealed solely on the basis of disagreement with the decision, but can be made based on incorrect procedures, or if it was executed in an unfair and discriminatory manner. The Committee thus understood that while ECCE makes possible appeals based on procedural error, errors of fact, mitigating circumstances where material was not available at the time and for situation where members of QAAC or ECCE behaved in a discriminatory or unprofessional manner, the agency does not allow for an appeal of QAAC’s judgement itself. The Committee thus finds that the appeals process is limited, given that the reviewed higher education institution may not challenge based on e.g., criteria that may have not been correctly applied or disagreements in how standards were interpreted by QAAC.
27. The Committee noted that the agency considered and upheld an appeal against a QAAC formal decision, but also noted that there is no public documentation on this appeal and that the agency does not have any information on its website on the composition of its Appeal’s Committee.
28. The Register Committee therefore concurred with the panel’s conclusion that ECCE only partially complies with the standard.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – ECCE – Partial compliance (2023) Involvement of student members in the governing/accreditation body
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 3.1 Activities, policy and processes for quality assurance Keywords Involvement of student members in the governing/accreditation body Panel conclusion Partial compliance Clarification request(s) Panel (15/02/2023)
RC decision Partial compliance “29. The panel clarified that ECCE had a clear strategy that guided its work; even if the official documents were sometime incoherent in wording, they were coherent in substance.
30. The panel further clarified that ECCE should have been more attentive and flexible as regards the appointment of a new student member to QAAC. The practice led to a student member being absent from QAAC for some time, which could have been avoided if ECCE had been more concerned to prevent this with priority.
31. Having considered the panel's clarification, the Register Committee was able to concur with the panel's conclusion that ECCE partially complies with the standard.
32. The review report explains that ECCE does not provide consultancy themselves but “offers the names and contact details of highly qualified independent educationalists to new chiropractic programmes to assist them with the development of their programmes” (report, p. 14).
33. While the Register Committee considered that these did not appear to be problematic, it found that this should be discussed in more detail in the next review of ECCE.”
Full decision: see agency register entry
-
3.3 Independence – ECCE – Partial compliance (2023) Overlapping responsibilities between different bodies/ Lack of diversity
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 3.3 Independence Keywords Overlapping responsibilities between different bodies/ Lack of diversity Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “34. The panel raised issues related to the high involvement of representatives of accredited institutions, amplified by the small size of the chiropractic community, as well as the overlapping responsibilities between different agency bodies. In particular, the panel regarded critically the ex-officio mutual memberships of the Executive Committee and QAAC chairperson in the respective other committee, the involvement of both bodies in the QA process and the close involvement of the QAAC in pre-screening self-evaluation reports.
35. In light of these concerns, the Register Committee concurred with the panel’s conclusion that ECCE only partially complies with the standard.”
Full decision: see agency register entry
-
2.5 Criteria for outcomes – SKVC – Partial compliance (2022) lack of consistency, unclear understanding of multi-level compliance scale
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.5 Criteria for outcomes Keywords lack of consistency, unclear understanding of multi-level compliance scale Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “8.The panel considered that SKVC's criteria are lacking clarity, especially with regard to the exact understanding of the 5-level scale used by SKVC. The panel recommended developing guidelines for interpretation of each level to enhance consistency of their use.
9.The Committee understood that the current situation as described and analysed by the panel might lead to a lack of consistency.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – SKVC – Compliance (2022) lack of internal appeals process for HEIs in exile
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.7 Complaints and appeals Keywords lack of internal appeals process for HEIs in exile Panel conclusion Compliance Clarification request(s) – RC decision Compliance “13. The Register Committee shared the panel's reservations that the inability for higher education institutions in exile to use SKVC's internal appeals process is a shortcoming.
14. Given that this only concerns one single institution at the moment and no accreditation has taken place so far, the Committee, however, did not consider this shortcoming material enough to influence the conclusion per this standard and concurred with the panel's conclusion that SKVC complies with the standard.”
Full decision: see agency register entry
-
3.3 Independence – SKVC – Compliance (2022) involvement of ministry in accreditation of HEIs in exile
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.3 Independence Keywords involvement of ministry in accreditation of HEIs in exile Panel conclusion Compliance Clarification request(s) – RC decision Compliance “15. The review panel noted some concerns about the process of ex-post accreditation of higher education institutions in exile, especially given the direct involvement of the Ministry of Foreign Affairs in the evaluation, i.e. certain standards being assessed by the Ministry instead of the panel of experts.
16. The Register Committee considered that the rationale might lie in the obvious political and diplomatic dimensions involved and that this might justify distributed responsibilities in principle. The Committee, however, considered that it must be transparent to the public what is an assessment made by SKVC and its independent expert panels, and what part of the assessment is made by the Ministry, potentially taking into account political considerations. The Committee recommends that SKVC and the Ministry explore how to disentangle political/diplomatic considerations and quality assessments fully, e.g. by having the Ministry make a separate assessment and decision either preceding SKVC's quality assessment, or following a decision by SKVC.
17. Given the rare occurrence of these procedures and the brief analysis by the panel on the matter, the Register Committee was unable to draw a definitive conclusion; the independence and transparency in these procedures should thus receive close attention in SKVC's next review.”
Full decision: see agency register entry
-
3.5 Resources – SKVC – Partial compliance (2022) reliance on temporary funding sources, state budget allocations insufficient
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.5 Resources Keywords reliance on temporary funding sources, state budget allocations insufficient Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “20. The panel discussed SKVC funding, relying on sources from several channels. In particular, SKVC's activities still partly depended on EU structural funds, which are temporary by nature. The panel further noted that the funding from Lithuania's state budget seemed to be insufficient to support the agency's activities sustainably.”
Full decision: see agency register entry
-
2.4 Peer-review experts – ANECA – Partial compliance (2023) students, panel members
ANECA
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.4 Peer-review experts Keywords students, panel members Panel conclusion Compliance Clarification request(s) Panel (17/02/2023)
RC decision Partial compliance “10. The panel noted that the internal system of the agency generally aimed to have students in every expert panel, in each of ANECA’s procedure. The panel, however, found out that the majority of AUDIT INTERNATIONAL experts panels did not include students (see clarification of 2023-02-17).
11. According to the panel, ANECA found it challenging to ensure student participation in these experts panel due to the limited availability of the students. The Committee acknowledged that recruiting student experts might be more difficult for some reviews than for others, but underlined that this challenge has to be addressed by any agency and cannot serve as a reason to carry out reviews without student panel members.
12. Given the absence of students from most expert panels for AUDIT INTERNATIONAL, the Register Committee was unable to concur with the panel’s conclusion, but concluded that ANECA only partially complies with ESG 2.4.”
Full decision: see agency register entry
-
2.6 Reporting – ANECA – Partial compliance (2023) reports, publication
ANECA
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.6 Reporting Keywords reports, publication Panel conclusion Compliance Clarification request(s) Panel (17/02/2023)
RC decision Partial compliance “14. The panel reported that all reports from programme evaluations were now published on ANECA’s website in a more extensive format; for SIC, AUDIT and AUDIT INTERNATIONAL the agency published the full expert reports.
17. The panel further explained (see clarification) that in programme evaluations the external review reports are prepared by ANECA’s Committees, based on the initial experts’ reports and following the multiple-stage process that is described in the review report. For SIC, AUDIT and AUDIT international procedures the panel noted that ANECA did not have the same practice and specific committees preparing external review reports, but instead considered the full experts’ reports as final report.
18. Having thus considered the report and the clarification, the Committee concluded that the two step approach, where the external review reports are prepared by internal specialised committees, might mean that the full content of the reports prepared by the panel would not be publicly known. Further, the Committee could not, based on the evidence provided by the panel, identify "before" and "after" examples of programme evaluation reports, and hence understand what "more extensive" might mean in practice, and was therefore unable to concur with the panel assessment of compliance.
19. The Committee therefore concluded that ANECA is not living up to the intentions of standard 2.6 which states that "full reports by the experts should be published”. Therefore, the Register Committee concluded that ANECA only partially complies with ESG 2.6.”
Full decision: see agency register entry
-
2.1 Consideration of internal quality assurance – AQU – Compliance (2022) how ESG 1.9 is addressed in AQU’s activities
AQU
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.1 Consideration of internal quality assurance Keywords how ESG 1.9 is addressed in AQU’s activities Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that in the implementation of ESG 1.9 the review panel considered how AQU’s different activities address the cyclicity of external reviews. The Committee, however, underlined that the focus of the standard is on the monitoring and periodical review of programmes as part of the institutions internal QA, ensuring that objectives set for the programmes are achieved and that monitoring processes lead to the continuous improvement of the programme.
Given that the Register Committee was unable to draw a definitive conclusion on how ESG 1.9 is addressed in AQU’s activities, the issue should thus receive close attention in AQU’s next review.”
Full decision: see agency register entry
-
2.6 Reporting – AQU – Compliance (2022) publication of reports from ex-ante accreditation
AQU
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.6 Reporting Keywords publication of reports from ex-ante accreditation Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its previous renewal decision, the Register Committee noted that AQU publishes all reports except those from ex-ante evaluations that result in a negative accreditation decision. The review panel reports that AQU now publishes all review reports, independent of their outcome. The Committee also noted that reports with a negative ex-ante accreditation outcome are released with an initial page warning that the degree will not be taught. While the practice of publishing ex-ante reports with a negative outcome was originally met with unease by the institutions whose study programme was rejected, there now is an agreement within AQU on the value of ensuring accountability and trust in the whole system. In relation to the AQU reports for the ex-ante accreditation of short learning programmes (SLP) and micro-credentials, the Committee noted that the agency struggles in scaling the demands of accrediting such programmes, in particular ensuring the proportionate length and detail in its reporting. The Committee underlined the panel’s suggestion on expanding the level of detail and analysis in reports for SLPs to facilitate the usability by various stakeholders and to reflect the detailed evaluation work of the experts. Having considered the change in practice in the publication of negative ex-ante reports, the Register Committee concurred with the panel’s conclusion that AQU now complies with ESG 2.6.”
Full decision: see agency register entry
-
3.3 Independence – AQU – Compliance (2022) composition of governing bodies; independence of the appeals process; financial independence
AQU
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.3 Independence Keywords composition of governing bodies; independence of the appeals process; financial independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its previous decision the Register Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies. The review panel found that AQU has separated the membership of its strategic and oversight bodies from its specific commissions and review panels. The Register Committee welcomed these changes, including the appointment of two non-local members to the Appeals Committee, but noted that the Chair of the Appeals Committee is a member of the Governing Board. While the role of the members in the Governing Board is limited to the strategic decision-making and management of the organisation, the Register Committee found that the involvement of a representative of the Board (in particular as a Chair) in the Appeals Committee might put undue pressure in the discussion and decision-making of the Appeals Committee. The Register Committee nevertheless agreed that the Appeals Committee was sufficiently independent given that the AQU’s Governing Board does not adopt the reports or decisions that are being appealed. The Register Committee further noted that AQU’s funding comes primarily from the Government of Catalonia (about 90% of the agency’s budget) and is allocated on an annual basis. The Committee welcomed AQU’s plans to move to a four-year contract with the Government of Catalonia, which could further improve its operational independence. Considered the steps taken to separate the membership of the agency’s strategic and oversight bodies, the Register Committee could follow the panel’s conclusion that AQU now complies with the standard ESG 3.3.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – ANQA – Partial compliance (2022) Student involvement in decision making bodies
ANQA
Application Renewal Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords Student involvement in decision making bodies Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “ANQA involves students in the review panels, but not in the body
responsible for making decisions on accreditation (i.e. the Accreditation
Council). The Committee highlighted the panel’s recommendation and
found it necessary that the agency improves the involvement of students in
the decision-making process.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – AQAS – Partial compliance (2022) Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest
AQAS
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The governing body (i.e. the Managing Board) of the agency does not involve other stakeholders than academics. The agency has not published any policy or statements in regards to the separation of its consultancy activities and preventing conflicts of interest.”
Full decision: see agency register entry
-
3.4 Thematic analysis – AQAS – Partial compliance (2022) Content of the thematic analysis
AQAS
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 3.4 Thematic analysis Keywords Content of the thematic analysis Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “the content of the thematic publications mainly involved reflections on the agency’s own experiences in conducting EQA rather than analysis of the results of the EQA (an analysis which could be more appropriate to serve the internal quality assurance processes, ESG 3.6). The Committee agreed with the panel’s views that the agency could improve the content of the analyses so they are more meaningful for the wider academic and QA community”
Full decision: see agency register entry
-
2.7 Complaints and appeals – AKAST – Compliance (2021) Lack of an independent appeals committee and limited coverage of appeals
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 2.7 Complaints and appeals Keywords Lack of an independent appeals committee and limited coverage of appeals Panel conclusion Substantial compliance Clarification request(s) Agency (07/12/2021)
RC decision Compliance “In its decision of rejection (of June 2020), the Register Committee noted that AKAST’s appeals and complaints procedure did not cover the peer institutional evaluation procedures and that the appeals were only considered by the same committee that also took the appealed decision. While AKAST agreed to revise its procedure and to establish a complaints committee consisting of independent members, the Register Committee remained unable to follow the panel’s judgment of compliance since the procedure was not yet in operation and the committee handling appeals has not been elected. 8. The panel notes that AKAST has now a revised complaints and appeals regulation and has elected a Complaints Committee at the AKAST General Meeting on 28/01/2021. In the description of the provisions for complaints (AKAST Complaints and Appeals Regulations as amended on 28/01/2021), the agency noted that the Complaints Committee’s statement is to be taken into account in the final decision of the Executive Board or the Accreditation Committee and that further details shall be regulated in the rules of procedure issued by the Complaints Committee and approved by the Executive Board.”
Full decision: see agency register entry
-
3.3 Independence – AKAST – Compliance (2021) Independence of formal outcomes
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 3.3 Independence Keywords Independence of formal outcomes Panel conclusion Substantial compliance Clarification request(s) Agency (07/12/2021)
RC decision Compliance “In its past review the Register Committee noted that AKAST was subject to the vigilance of the German Bishops’ Conference and that its influence extended to giving consent for the admission of members of the association and the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and the Board, and the approval of each of the accreditation decision by the member of the Commission for Science and Arts (Commission VIII) of the German Bishops’ Conference. Due to these interlinkages, the Register Committee concluded (see decision of 30/11/2019) that AKAST did not comply with ESG 3.3. The Register Committee in particular found the requirement that each accreditation decision requires the consent of the representative of the German Bishops’ Conference (member of the Accreditation Committee) to be in contrast with the requirement of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation”
Full decision: see agency register entry
-
3.4 Thematic analysis – AKAST – Partial compliance (2021) Lack of development in preparing thematic analysis
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 3.4 Thematic analysis Keywords Lack of development in preparing thematic analysis Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “7. The panel notes that AKAST reliably contributes the experience gained from its own quality assurance procedures to the regular evaluation of the Key Points and that the agency is documenting the results of its ongoing student survey on its website.
18. The Register Committee welcomes AKAST’s plan to further develop a thematic analysis after an appropriate number of programme accreditation procedures have been completed, but underlined that such an analysis has not been finalised.
19. Considering the limited development of thematic analysis, the Register Committee can follow the review panel conclusion that AKAST complies only partially with ESG 3.4.”
Full decision: see agency register entry
-
2.2 Designing methodologies fit for purpose – GAC – Compliance (2022) no ownership or full responsibility resting with a single actor, consequences for improvement
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 2.2 Designing methodologies fit for purpose Keywords no ownership or full responsibility resting with a single actor, consequences for improvement Panel conclusion Substantial compliance Clarification request(s) Panel (05/10/2022)
RC decision Compliance “9. The panel noted that no actor had ownership or full responsibility for the entire accreditation system and process, since the specimen decree appoints specific responsibilities to both GAC and the agencies.
10. The Register Committee sought further clarification from the panel as to how that impacted continuous improvement and development. The panel noted that opportunities for improvements were discussed actively; the ongoing review of the Specimen Decree was an example of that. The panel, however, saw a lack of GAC itself assuming a more proactive, coordinating role and taking responsibility for the system as a whole; this would be reasonable given its unique and pivotal position.
11. The Register Committee concluded that continuous improvement seems to be ensured despite the distributed responsibilities and thus concurred with the panel's conclusion that GAC complies with standard 2.2; the issues related to GAC's role and strategy are considered under standard 3.1 below.”
Full decision: see agency register entry
-
2.5 Criteria for outcomes – GAC – Partial compliance (2022) lack of formal mechanisms for consistency, unclear whether or not consistency improved
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 2.5 Criteria for outcomes Keywords lack of formal mechanisms for consistency, unclear whether or not consistency improved Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “12. The panel considered critically the lack of formal mechanisms to ensure a consistent understanding and application of the criteria (e.g. guidelines, interpretations or a precedent database made available by GAC).
13. The panel was unable to draw a conclusion whether the post-2018 system – with decisions made by GAC, including the practice to change conditions deviating from the proposal by the expert panels – actually delivered a higher degree of consistency or not.
14. The panel further noted that the current organisation of the Council's work included the risk that analysis of cases might often be “monopolised” in the hands of a single (academic) Council member, while some other Council members are currently not participating in the preparatory work as rapporteurs.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – GAC – Partial compliance (2022) strategy not reflecting agency's central role, lack of broad discussions with stakeholders
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords strategy not reflecting agency's central role, lack of broad discussions with stakeholders Panel conclusion Substantial compliance Clarification request(s) Panel (05/10/2022)
RC decision Partial compliance “16. The panel considered that the lack of involvement of stakeholders beyond those individuals who are members of the agency bodies themselves might lead to a lack of critical distance. The panel thus saw a need for more and broader stakeholder feedback, and recommended more regular dialogues with stakeholder organisations on strategic and policy matters.
17. The panel further considered that GAC's strategic planning did not sufficiently reflect its central, pivotal role in the accreditation system (see also the comments under ESG 2.2 above). The panel saw a strong need for a broader discussion with agencies and all stakeholders on GAC’s role in the system and its strategy. In particular in view of the upcoming revision of the
Specimen Decree, the panel found such a discussion was urgent to define a strategy that describes clearly the role GAC plans to assume in the system and its mid-term priorities.
18. While the Register Committee appreciates that GAC has begun to plan a strategy process (see statement on the report), it considered that the panel's analysis under this standard points to important issues in GAC's governance and engagement with stakeholders; these are particularly important in light of GAC's pivotal role in the German system.”
Full decision: see agency register entry
-
3.4 Thematic analysis – GAC – Compliance (2022) relevance of topics, nature of topics to qualify, regularity and frequency of analyses
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.4 Thematic analysis Keywords relevance of topics, nature of topics to qualify, regularity and frequency of analyses Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “20. The panel discussed the analyses produced by GAC on various topics, with the most recent ones focusing on conditions imposed on higher education institutions/programmes in decisions by the agencies and by GAC, published in 2018 and 2020 respectively. While the panel questioned whether this was “a crucial topic in the development of the HE system”, the Register Committee considered that such an analysis is certainly based on the general findings of GAC's external quality assurance activities and thus meets the expectation of the standard. Moreover, while the panel did not specifically indicate whether stakeholders found the topic relevant, an analysis of conditions might show how the accreditation criteria resonate with the sector and indicate topics that are typically challenging for institutions and programmes, and hence be relevant beyond GAC.
21. Given the role of GAC as the central body of the German accreditation system, the panel considered that the current publishing rate (one paper per year) was “insufficient”. As the standard remains completely open as to the frequency of analysis, the Register Committee found it an overly strict interpretation of the standard to influence the compliance level on that basis; the remark should rather be seen as a recommendation to publish more analyses.”
Full decision: see agency register entry
-
3.5 Resources – GAC – Compliance (2022) shortage of staff positions addressed
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.5 Resources Keywords shortage of staff positions addressed Panel conclusion Partial compliance Clarification request(s) Panel (05/10/2022)
RC decision Compliance “24. The review panel noted a lack of human resources at GAC's disposal, leading to staff having to prioritise initial accreditation in their work, with reaccreditation procedures taking longer than they should in turn.
25. In its comments on the review report, GAC informed EQAR that a staff increase by 9.25 FTE was now confirmed.
26. The Register Committee sought clarification from the panel on the resources in light of this increase. The Committee understood that this staff increase would address the resourcing in quantitative terms, but that the positive impact of this would remain limited as long as the reservations about the organisation of the Council's work remain, as noted under ESG 2.5.
27. In light of the staff increase, the Register Committee considered that GAC now complies with standard 3.5, while noting that the serious concerns stated under standard 2.5 relate to the question whether GAC effectively deploys its resources, especially in terms of organising the Council's work.”
Full decision: see agency register entry
-
2.1 Consideration of internal quality assurance – HCERES – Partial compliance (2022) lack of coverage for certain ESG Part 1 standards in international programme accreditation
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 2.1 Consideration of internal quality assurance Keywords lack of coverage for certain ESG Part 1 standards in international programme accreditation Panel conclusion Substantial compliance Clarification request(s) Panel (14/06/2022)
RC decision Partial compliance “9. The review report showed that several standards of ESG Part 1 (1.1, 1.4, 1.6, 1.7, 1.9, 1.10) are not addressed in (international) programme accreditation. While HCERES explained to the panel that they adapt their standards according to the foreign context, this creates a situation where a study programme might be accredited by HCERES without having been assessed against the full ESG Part 1.
10. The panel considered that (international) programme accreditations are small in number compared to (national) programme evaluations and other activities of HCERES. The Register Committee, however, considered that the issue at hand is not an occasional or statistical error, but a structural and systemic deficiency for an entire external quality assurance activity of HCERES.
11. As a programme accredited by HCERES will be regarded as ESG-aligned by the public, confirmed by the entry of those programmes in DEQAR, the lack of full ESG Part 1 coverage represents a substantial shortcoming. The Register Committee was therefore unable to concur with the panel's conclusion that HCERES complies with the standard, but concluded that HCERES only partially complies with ESG 2.1.”
Full decision: see agency register entry
-
2.3 Implementing processes – HCERES – Partial compliance (2022) follow-up with limited value added, no students interviewed in site visits
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 2.3 Implementing processes Keywords follow-up with limited value added, no students interviewed in site visits Panel conclusion Substantial compliance Clarification request(s) Panel (14/06/2022)
RC decision Partial compliance “18. The panel noted that HCERES programme evaluation panels do not meet with students during review visits. The panel discussed the new follow-up process introduced for institutional evaluation only, but noted that some questions remained regarding the added value given that there is no analysis or feedback in direct response to follow-up reports.
19. The panel considered that HCERES made improvements since the last review, as site visits were not carried out for programme evaluations at all previously and given there was no follow-up process previously.
20. While the Register Committee acknowledged that significant progress has been made, it did not consider that HCERES complies with the standard yet in light of the limited added value of the follow-up process and the fact that students are not interviewed during site visits. The Committee therefore did not concur with the panel, but concluded that HCERES remains partially compliant with ESG 2.3.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – HCERES – Compliance (2022) Board member in appeals committee, independence of decisions on appeals
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 2.7 Complaints and appeals Keywords Board member in appeals committee, independence of decisions on appeals Panel conclusion Full compliance Clarification request(s) Panel (14/06/2022)
RC decision Compliance “28. In the last renewal of registration, HCERES was found to be only partially compliant with the standard since its appeals and complaints processes were only just set up and not yet reviewed by an external panel; a specific concern was whether the decision-making on appeals was fully independent from those in charge of the appealed report/decision.
29. The panel considered that HCERES' appeals and complaints processes were clearly defined and communicated. The panel noted that HCERES had not received appeals or complaints since 2016.
30. The panel clarified that it considered the appeals committee's composition suitable. While HCERES Board members indeed serve on the appeals committee, the Board does adopt neither evaluation reports nor accreditation decisions. In addition, one external expert is part of the committee.
31. The Register Committee agreed that the appeals committee was sufficiently independent given that the HCERES Board does not adopt the reports or decisions that are being appealed. The Committee therefore concurred with the panel's conclusion that HCERES complies with ESG 2.7.”
Full decision: see agency register entry
-
3.4 Thematic analysis – HCERES – Partial compliance (2022) separate research or bilbiometric analyses do not qualify as thematic analysis
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 3.4 Thematic analysis Keywords separate research or bilbiometric analyses do not qualify as thematic analysis Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “38. The panel considered that HCERES' recent activities have been focused on research and bibliometric analysis; analyses drawing on the results of evaluations within the scope of the ESG have not been produced regularly since the summary reports that HCERES/AERES used to produce following earlier evaluation campaigns.”
Full decision: see agency register entry
-
3.6 Internal quality assurance and professional conduct – HCERES – Partial compliance (2022) feedback system not fully integrated, regression since last review
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 3.6 Internal quality assurance and professional conduct Keywords feedback system not fully integrated, regression since last review Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “40. The panel noted that the representatives of institutions and reviewers gave different opinions on the possibilities for feedback.
41. The Register Committee agreed with the panel's analysis that this indicates that the feedback system might not yet be fully implemented and that there was a need to systematise and make more coherent the available feedback instruments.
42. The Register Committee further noted that the only partial compliance with ESG 2.1 and 3.4 is a regression since the last review and thus does not reflect positively on the agency's internal quality assurance arrangements.
43. In light of these reservations the Committee was unable to concur with the panel's conclusion, but considered that HCERES only partially complied with the standard.”
Full decision: see agency register entry
-
2.6 Reporting – IQAA – Partial compliance (2022) Publication of reports
IQAA
Application Renewal Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 2.6 Reporting Keywords Publication of reports Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee learned that IQAA now publishes in full the decisions from institutional and programme accreditations, including the
negative ones. Even though the bulk of reports is public, this is not the case for all of them - the reports from the initial accreditation and the post-accreditation monitoring are still not published.”
Full decision: see agency register entry
-
3.4 Thematic analysis – IQAA – Compliance (2022) Consistent publication of thematic analyses
IQAA
Application Renewal Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.4 Thematic analysis Keywords Consistent publication of thematic analyses Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The Register Committee learned that IQAA has published several thematic analyses since the last review. The panel, however, could not see
any formal plan for drafting and publishing these analyses.The Committee considered that despite the absence of a more formal planning the agency has developed a practice and demonstrated a clear vision for conducting analyses based on its EQA processes.”
Full decision: see agency register entry
-
2.1 Consideration of internal quality assurance – ASIIN – Compliance (2021) How ESG Part 1 is embedded in subject-specific label reviews
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 2.1 Consideration of internal quality assurance Keywords How ESG Part 1 is embedded in subject-specific label reviews Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its Change Report Decision of 02/11/2020, the Register Committee requested that the next external review of ASIIN considers how the agency ensures sufficient coverage of ESG Part 1 in its combined (“piggybacking”) procedures (ESG 2.1). The agency explained that ESG Part 1 is embedded as a standard procedure in every external QA activity carried out (Self Evaluation Report p. 35). Having considered how ESG Part 1 is mapped against ASIIN’s seals while also including the standards of the German Accreditation Council, the panel was convinced of the coverage and link to ESG Part 1 in all its activities. The documents confirmed that all subject-specific label requirements are assessed in addition to ASIIN's generic standards for degree programmes, which incorporate ESG Part 1. The panel also underlined that SAR templates for each review method were structured to follow ESG Part 1. The Register Committee was therefore satisfied that ESG Part 1 is sufficiently addressed in ASIIN’s combined (“piggybacking”) procedures.”
Full decision: see agency register entry
-
2.3 Implementing processes – ASIIN – Compliance (2021) Implementation of procedures and transparency of CBQA procedures
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 2.3 Implementing processes Keywords Implementation of procedures and transparency of CBQA procedures Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “In its last review the Register Committee noted that ASIIN's policies were not always followed in practice, i.e. use of on-site visits in evaluations and use of evaluation results in programme accreditations. In its current review, the panel stated that it did not find any evidence of deviations from the prescribed procedures and that policies are implemented consistently. The panel, however, remarked that ASIIN could provide better guidance about the site visit schedule and ensure more transparency in the processing of requests deemed potentially problematic from countries of higher education institutions outside of the European Higher Education Area (see also under ESG 3.1).”
Full decision: see agency register entry
-
2.7 Complaints and appeals – ASIIN – Partial compliance (2021) handling of appeals and complaints
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 2.7 Complaints and appeals Keywords handling of appeals and complaints Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee considered the panel’s findings that show that ASIIN’s appeals and complaints processes are not well differentiated and as a result not consistently used, i.e. the institutional accreditation handbook discuss complaints procedure although what is described is the means to appeal a decision, whereas the handbooks for the programme accreditation and certification processes mention appeals procedure, the name of the Appeals/Complaints Committee appear to have four different permutation. The panel further comments on the agency’s lack of understanding of the two different concepts. In its response to the review report (19/07/2021) ASIIN’s stated that it has revised its documents and website, employing the right terminology. While the Register Committee welcomed ASIIN’s corrections, the Committee found the panel’s concerns have not been fully address, as the lack of understanding of the two concepts may affect the agency’s ability to effectively handle both appeals and complains for all its activities.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – ASIIN – Compliance (2021) stakeholder representation within the governance and separation of EQA within and outside the scope of the ESG
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 3.1 Activities, policy and processes for quality assurance Keywords stakeholder representation within the governance and separation of EQA within and outside the scope of the ESG Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “In its last decision, the Register Committee noted that ASIIN continued to use the term evaluation for type 2 evaluations against the panel’s recommendation, and thus the separation between activities within the scope of the ESG and those that are carried out as type-2 evaluations remained unclear. In its review report the panel considered that the difference made by ASIIN in various documents between type 1 evaluation and type 2 evaluation sufficiently differentiated between accreditation and consultancy. The panel further noted that ASIIN had a policy not to conduct accreditation for those institutions/ programmes at which consultancy activities were carried out, and that this was adhered to in practice (p.31). The Committee therefore concluded that this shortcoming has been addressed. The Register Committee noted that ASIIN’s Board of Directors consists exclusively of representatives of member organisations/institutions of ASIIN. The involvement of a diverse set of stakeholders (including students) in the governance of the agency is, however, ensured within the technical committees, Accreditation Commission and Certification Commission. Considering ASIIN’s expansion of its external QA activities to other areas the panel underlined that ASIIN should rethink its current structure and broaden its competences (p.16). The panel recommended a stronger involvement of the Board of Directors in the strategic direction of the agency and the monitoring of its strategic goals, while at the same time expanding its membership to also include external stakeholders (including a student member). The Committee underlined that recommendation of the panel.”
Full decision: see agency register entry
-
3.3 Independence – ASIIN – Compliance (2021) Integrity/conflict of interest
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 3.3 Independence Keywords Integrity/conflict of interest Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that the members of ASIIN’s technical committees can simultaneously hold the position of an external reviewer for ASIIN’s review panels, which would put them in a conflict of interest when discussing the reports prepared by the same panel they were members of.
23. Considering the panel’s concern of a potential conflict of interest resulting from this arrangement, the Committee concluded in its initial decision that ASIIN complied only partially with ESG 3.3.
24. In its Appeal of 20/01/2022, ASIIN challenged the Committee’s conclusion and judgment arguing that the independent decision making of its Technical Committee was not compromised. The agency made the case that the involvement of active experts as members within ASIIN’s 14 Technical Committees ensured a consistent application of procedures and criteria in the preparation of accreditation reports. ASIIN further explained that ASIIN’s Technical Committees did not have any decision-making power as regards the accreditation decision. Moreover, the experts involved in the procedure would regularly abstain.
25. The Committee welcomed the abstention of the Technical Committee members, but could not determine if the practice of abstention was institutionalised in ASIIN’s procedure.
26. The Register Committee further underlined that the integrity of the review process could be better safeguarded by ensuring that members of the Technical Committees would not partake at all (i.e. by leaving the room) when their report is considered by the Technical Committee.
27. Having weighed the limited role of the Technical Committee in ASIIN’s decision making process and the fact that its members abstain from decision-making in such cases where they were involved as reviewers, the Register Committee concluded that ASIIN’s independent decision-making is not compromised and thus found that the requirement of the standard is met. The Committee therefore concurred that the agency complies with ESG 3.3”
Full decision: see agency register entry
-
3.4 Thematic analysis – ASIIN – Compliance (2021) thematic analysis conducted on a regular basis
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 3.4 Thematic analysis Keywords thematic analysis conducted on a regular basis Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “In its last renewal of registration on EQAR, the Register Committee noted that ASIIN only partially fulfilled the requirement of the standard, since ASIIN did not conduct such analysis on a regular basis and the prepared analysis and studies contained only elements of what is understood as thematic analysis. In its current review report, the panel commends ASIIN for its efforts in regularly developing thematic analysis through its impact studies which provide significant insights on the agency’s external QA activities. While the panel finds that ASIIN could improve the dissemination of its impact studies among stakeholders, the panel is satisfied that the requirement of the standard is met. Having addressed the earlier concerns in its compliance with ESG 3.4, the Register Committee concurred with the panel’s conclusion that ASIIN now complies with the standard.”
Full decision: see agency register entry
-
2.4 Peer-review experts – EQ-Arts – Compliance (2021) student involvement
EQ-Arts
Application Initial Review Focused, coordinated by ECA Decision of 18/03/2021 Standard 2.4 Peer-review experts Keywords student involvement Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “9. The review panel's report contained no analysis of the factors that led to that departure from EQ-Arts' own policies, but confirmed that all reviews since December 2018 have included students (8 reviews in 2019 and 1 in 2020); the panel further elaborated on EQ-Arts approach to recruiting and training experts.”
Full decision: see agency register entry
-
2.5 Criteria for outcomes – EQ-Arts – Compliance (2021) consistency of decisions
EQ-Arts
Application Initial Review Focused, coordinated by ECA Decision of 18/03/2021 Standard 2.5 Criteria for outcomes Keywords consistency of decisions Panel conclusion Substantial compliance Clarification request(s) Panel (16/03/2021)
RC decision Compliance “12. The panel was convinced that EQ-Arts had “developed a sound approach to guarantee fair and transparent decisions and judgments”; it noted that consistency was ensured by a template with guidelines, the executive officer supporting each expert team and the Board considering each report.
13. [...] In its response, the panel elaborated on the measures taken to ensure consistency and how reviewers are being familiarised with them in EQ-Arts' trainings. The panel explained how it triangulated the information received from the reviewers, the reviewed institutions and the EQ-Arts Board. The panel confirmed that there was a “consistent understanding of procedure and process”. Based on the increased amount of activities, the panel was satisfied that EQ-Arts criteria were applied consistently, irrespective of whether the process leads to a formal decision by the Board.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – EQ-Arts – Compliance (2021) Separation of external QA and consultancy activities; possible conflicts between different types of reviews
EQ-Arts
Application Initial Review Focused, coordinated by ECA Decision of 18/03/2021 Standard 3.1 Activities, policy and processes for quality assurance Keywords Separation of external QA and consultancy activities; possible conflicts between different types of reviews Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “16. [...] The report noted that it would be against EQ-Arts' principles to engage in paid consultancy work (p. 31), this was now explicitly ruled out in the Governance Framework.
17. The Register Committee considered that the issue has been addressed for consultancy in the classical meaning, i.e. paid services provided to institutions. The Committee therefore now concurred with the panel's conclusion that EQ-Arts complies with the standard.
18. The Register Committee nevertheless underlined that EQ-Arts needs to be mindful for all other current or future activities with individual higher education institutions – whether paid or unpaid – if they could be regarded as compromising its ability to make an independent assessment of that institution later on and, if so, to make adequate provisions to rule out carrying out a review of that institution.
19. In addition, the next external review of EQ-Arts should analyse whether any risk lies in the fact that the same higher education institutions might undergo an enhancement review first and request a formal assessment later, depending on whether such patterns occur in practice.”
Full decision: see agency register entry
-
3.3 Independence – EQ-Arts – Compliance (2021) nomination of the Board members
EQ-Arts
Application Initial Review Focused, coordinated by ECA Decision of 18/03/2021 Standard 3.3 Independence Keywords nomination of the Board members Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “21. The review panel noted that EQ-Arts' statutes were reviewed in order to reorganise its Board and allow for the inclusion of students. Moreover, the Board and Executive Group were merged. The Governance Framework defined the composition and responsibilities of the Board, as well as the criteria for Board membership (p.34).
22. The panel reported that a call for Board members was issued in May 2020 and addressed to relevant subject-specific stakeholder organisations; on that basis, the Board members were selected.
23. The Register Committee considered that the new arrangements improved transparency and therefore concurred with the panel's conclusion that EQ-Arts complies with the standard.
24. The Committee was unable to verify whether the nomination arrangements apply only to initial nominations or also to re-appointments. In the interest of assuring a regular link with the sector, the Committee encouraged EQ-Arts to ask for nominations also for re-appointments.”
Full decision: see agency register entry
-
3.5 Resources – EQ-Arts – Partial compliance (2021) volatile resources
EQ-Arts
Application Initial Review Focused, coordinated by ECA Decision of 18/03/2021 Standard 3.5 Resources Keywords volatile resources Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “28. The 2018 external review discussed that EQ-Arts' financial situation was volatile. While the resources were sufficient to sustain the (currently) small number of reviews, the medium-term perspective was not clear.
29. The panel reported that staff increased to 1.3 FTE in 2019, then fell to 0.5 FTE as result of the Covid-19 pandemic and a drop in activities.
30. While the panel found that the “agile and collaborative approach” assured that workload could be handled, the Register Committee considered that the resources of EQ-Arts remain highly volatile; this has not changed since the initial review.”
Full decision: see agency register entry
-
2.4 Peer-review experts – ECAQA – Partial compliance (2023) Lack of meaningful involvement of students in panels
ECAQA
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 2.4 Peer-review experts Keywords Lack of meaningful involvement of students in panels Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “ECAQA involves a variety of stakeholders in the composition of panels, including students. The Committee learned that, in practice, the student reviewers were not always offered the training provided for the other panel members – such conditions made their involvement in some of the reviews nominal in the panel's view.The Register Committee found that despite the formal involvement, ECAQA's approach did not ensure meaningful participation of students in all review panels”
Full decision: see agency register entry
-
3.3 Independence – ECAQA – Partial compliance (2023) Infringement of the organizational independence
ECAQA
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords Infringement of the organizational independence Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “The Committee could not verify how the agency ensures its independence from its founder and found the distribution of power among stakeholders in the governing of the agency unequal. The Committee noted that the current arrangements include the possibility of
the founder or the Director General exercising their controlling stake in several regards, causing a substantial risk of an infringement on the
independence of the agency (see also interpretation 18).”
Full decision: see agency register entry
-
2.4 Peer-review experts – FIBAA – Partial compliance (2022) training of experts & pool of experts limited
FIBAA
Application Renewal Review Full, coordinated by ENQA Decision of 07/02/2022 Standard 2.4 Peer-review experts Keywords training of experts & pool of experts limited Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The panel noted that FIBAA uses several videos and Power Point presentations to provide training for the experts, but critically remarked that there is not a face-to-face training and no clear obligation for experts to undertake such a training (or supervision on it) prior to an accreditation or certification procedure. The training is done on a voluntary basis. The review panel also underlined that the training materials for the English-speaking experts may not be as comprehensive as those received by German-speaking experts.
In its analysis the review panel also noted that the number of international experts in the pool of experts to be rather limited given FIBAA’s international profile and that there is minimal rotation and renewal among the experts.
Considering the above mentioned shortcomings, the Register Committee cannot follow the panel’s conclusion on (substantially) compliant but finds that FIBAA complies only partially with ESG 2.4.”
Full decision: see agency register entry
-
2.6 Reporting – FIBAA – Compliance (2022) publication of all reports
FIBAA
Application Renewal Review Full, coordinated by ENQA Decision of 07/02/2022 Standard 2.6 Reporting Keywords publication of all reports Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “14. In its last decision, the Register Committee noted that a number of programme accreditation reports have not been published by FIBAA and concluded that the agency at that time complied only partially with ESG 2.6. In response to the recommendation made in the previous review, the Register Committee learned that FIBAA is now publishing both the positive and negative reports on accreditation and certification processes from national as well as international activities, on its website.
15. The Register Committee therefore agreed with the panel’s conclusion, that FIBAA complies with standard 2.6.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – FIBAA – Partial compliance (2022) Rudimentary nature of appeals procedure
FIBAA
Application Renewal Review Full, coordinated by ENQA Decision of 07/02/2022 Standard 2.7 Complaints and appeals Keywords Rudimentary nature of appeals procedure Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “16. In its last decision, the Register Committee underlined the panel’s observation that there is no clear indication on whether higher education institutions can issue a complaint regarding the course of the procedure. The Committee also remarked at that the appeals procedure is documented only rudimentarily, with little or no explanation on the issues that could be raised under the appeal, no provision on the expected timeline to process a complaint, publication policy etc.
17. In its review report, the panel stated that higher education institutions may submit complaints about the conduct of the process writing an email to FIBAA and that FIBAA has established a procedure for appeals.
18. The Register Committee learned that FIBAA’s appeals procedure only applies to the procedures where the agency is awarding its seal and it does not cover the reviews where GAC is the decision-making body. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the reports prepared for the GAC, these should equally be subject to appeal in line with the standard.
19. The Register Committee further noted that FIBAA’s appeals procedure date back to December 2016, and has not been updated since the agency’s last review. The Committee found it surprising that the review panel has not addressed any of the issues the Committee raised in its last decision regarding the rudimentary nature of FIBAA’s appeals procedure and only commented on the wording of the process for complaints and appeals (that should be clarified).
20. In light of the above observations the Register Committee cannot follow the panel’s judgement of (substantially) compliant, but find that FIBAA complies only partially with the standard.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – FIBAA – Partial compliance (2022) student involvement in governance, lack of periodic and multi-annual Strategic Plan, a clear distinction between external quality assurance and its other fields of work
FIBAA
Application Renewal Review Full, coordinated by ENQA Decision of 07/02/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords student involvement in governance, lack of periodic and multi-annual Strategic Plan, a clear distinction between external quality assurance and its other fields of work Panel conclusion Substantial compliance Clarification request(s) Agency (05/05/2024)
RC decision Partial compliance “21. The panel found that in general stakeholders are involved in the work of the agency, but commented that there is no student representative on the Foundation Council and that FIBAA should consider broadening its stakeholders to include, for example, members of committees from outside of FIBAA’s circle of ‘customers’.
22. The panel also remarked that FIBAA does not have a periodic and multi-annual Strategic Plan but that the strategic goals are considered during the Council’s last meeting in the year. The review panel noted that the consideration of strategic matters takes place as and when necessary, but still in a highly informal process. The Committee concurs with the view of the panel that the current strategic planning process, should be further developed to ensure that it also considers the medium to long term future of the agency.
23. While the review panel confirmed that FIBAA has in place a strict separation between its consultancy services and external QA activities within the scope of the ESG, the Register Committee noted that this separation was not clear in the case of FIBAA’s Evaluation Procedures According to Individual Objectives (see also point 5 above).
24. The Committee underlined that agencies are expected to take appropriate precautions to prevent any conflicts of interest arising from the consultancy activities they carry out, as indicated in Annex 2 to the EQAR Policy on the Use and Interpretation of the ESG.
25. Considering the shortcomings of involving students in FIBAA’s governance and the lack of a comprehensive Strategic Plan and the separation of consultancy and external QA procedures, the Committee cannot follow the panel’s conclusion of (substantial) compliance but finds that FIBAA complies only partially with standard 3.1.”
Full decision: see agency register entry
-
3.4 Thematic analysis – FIBAA – Partial compliance (2022) structured approach in carrying out of thematic analysis, limited work carried out
FIBAA
Application Renewal Review Full, coordinated by ENQA Decision of 07/02/2022 Standard 3.4 Thematic analysis Keywords structured approach in carrying out of thematic analysis, limited work carried out Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “26. The panel critically remarked that FIBAA does not seem to collect in a systematic way information on programmes and institutions and that the agency does not produce an overview of the outcomes of it external QA activities.
27. The panel also noted that workshops on topics related to quality assurance and resulting studies are mainly organised by FIBAA Consult. While the panel is of the view that FIBAA should reconsider the assignment of such activities to FIBAA Consult, the Register Committee disagrees and underlines that the standard does not limit the carrying out of thematic analysis by a unit of the agency or the possibility to subcontract this work to an external body.
28. The Register Committee however agrees with the panel’s conclusion that FIBAA should ensure a structured approach and allocate more resources to the planning and carrying out of thematic analysis on a systematic basis.
29. Considering the limited work in producing thematic analysis, the Committee concurs with the panel’s conclusion that FIBAA complies only partially with ESG 3.4.”
Full decision: see agency register entry
-
2.1 Consideration of internal quality assurance – ECTE – Non-compliance (2022) scope of the ESG, EQF level 5/short cycle, partial qualifications, alternative providers, QF-EHEA as decisive reference point
ECTE
Application Initial Review Full, coordinated by ASIIN Decision of 28/06/2022 Standard 2.1 Consideration of internal quality assurance Keywords scope of the ESG, EQF level 5/short cycle, partial qualifications, alternative providers, QF-EHEA as decisive reference point Panel conclusion Non-compliance Clarification request(s) Panel (05/05/2024)
RC decision Non-compliance “10. The external review panel noted that ECTE accredits institutions and programmes which belong to the “category of post-secondary courses/programmes” and which – in the panel's view – “are not covered by the ESG”. In particular, the panel refers to programmes such as Certificates1 in Theology, Diploma2 in Theology or the Postgraduate Certificate3 in Theology according to Appendix A of ECTE's Standards and Guidelines (see p. 15 of the review report).
11. In its response to EQAR's clarification request, the panel noted that it was “obvious for the panel that both the ESG and EQAR registration only cover formal tertiary education at bachelor and master level (levels 6 and 7 EQF)”4.
12. ECTE – in its standards – portrayed a “Certificate” as a partial qualification at/within EQF level 5 and a “Diploma” as a short-cycle, EQF level 5 qualification. In principle, short-cycle qualifications at EQF level 5 can be considered as part of the QF-EHEA. Moreover, the ESG generally cover higher education in its broadest sense and can also be applied to provision that is not part of a programme leading to a formal degree. [...]
14. Given that EQF level 5 and provision outside full formal degree programmes is not per se excluded from the scope of the ESG, the Register Committee confirmed this in the tripartite Terms of Reference.
15. The Register Committee considered that the distinction made by the panel between accreditation of higher education within the scope of the ESG and “post-secondary education” outside the scope of the ESG cannot be derived from the Terms of Reference, nor from ECTE's own presentation of its work. [...]
28. In the case of an alternative provider, the quality assurance procedure carried out by an EQAR-registered agency might be the only occasion to externally verify whether the education offered by the alternative provider is indeed at higher education level in terms of its learning outcomes. Therefore, the Committee found that attention to ESG Part 1 and in particular ESG 1.2 with its requirement that the qualification resulting from a programme should refer to the correct level of the Qualifications Framework for the European Higher Education Area (QF-EHEA) are of crucial importance in the domain of alternative providers.
29. Given that ECTE accredits a large number of alternative providers (see also under ESG 3.1) the Register Committee underlined that ESG 2.1 was a particularly crucial standard; it sought to ascertain that criteria are robust, fully aligned with the QF-EHEA and applied stringently in all cases, so as to protect the label and designation of what will be perceived as “higher education”.
30. With a view to the discussion on scope above, the Register Committee understood that the review panel clearly did not confirm whether ECTE's criteria for Certificate in Theology, Diploma in Theology and Postgraduate Certificate in Theology are correctly aligned with the QF-EHEA. As noted above, the quotes provided by ECTE from its Certification Framework cannot replace an external panel's analysis of the alignment in theory and practice.
31. As the Register Committee considers the accreditation of such programmes fully pertinent to the application (see above), this necessarily leads to a conclusion of non-compliance with ESG 2.1 as well.
32. The QF-EHEA further expects that students “have demonstrated knowledge and understanding in a field of study” upon completion of their studies. In general, ECTE's standards state that “theology” was the field of study they refer to. [...]
35. ECTE generally refers to the European Qualifications Framework for Lifelong Learning (EQF) in its framework and communication. While the Register Committee saw this as a legitimate choice, the Committee underlined that the analysis and formal assessment in respect of ESG 2.1 always need to refer to the QF-EHEA descriptors as a benchmark, given that the QF-EHEA is the framework adopted by the EHEA and referred to in ESG 1.2.”
Full decision: see agency register entry
-
3.1 Activities, policy and processes for quality assurance – ECTE – Partial compliance (2022) scope of the ESG, alternative providers, transparency of provider status, use of Bachelor and Master by alternative providers, need for clear distinction
ECTE
Application Initial Review Full, coordinated by ASIIN Decision of 28/06/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords scope of the ESG, alternative providers, transparency of provider status, use of Bachelor and Master by alternative providers, need for clear distinction Panel conclusion Substantial compliance Clarification request(s) Panel (05/05/2024)
RC decision Partial compliance “39. The ESG cover “higher education in its broadest sense, including that which is not part of a programme leading to a formal degree”. The ESG do not specifically limit what "higher education" means and explicitly include education that does not lead to a "formal degree".
40. The Register Committee therefore considers that the scope of the ESG needs to be determined by the quality and level of the education provided, not the legal status of the provider. That is, if an alternative provider offers learning opportunities with learning outcomes at higher education level, as defined by the QF-EHEA descriptors (see discussion under 2.1 above), the ESG can be considered applicable as a framework for the provider's quality assurance. [...]
42. In general, the ESG are underpinned by an expectation of utmost transparency; in turn, information that could be misleading, in particular for (potential) students, should be avoided. EQAR's Policy on the Use and Interpretation further specifies that the Register Committee should be guided by EQAR’s overall mission of ensuring transparency and trust when applying the standards.
43. Under ESG 3.1 it is expected that quality assurance agencies distinguish clearly and transparently between their external QA within the scope of the ESG and other activities. In line with the overall goal of transparency, the Register Committee applies the same principle to different types of accredited providers with a clearly different status and formal recognition; a lack of transparency about the status of different providers would bear the risk of confusing potential students as well as others, and might raise false expectations as to the status and recognition of credentials earned from those providers.
44. The guidelines to ESG 3.6 further reflect the expectation that an agency “establish the status and recognition of the institutions with which it conducts external quality assurance”. In view of the overarching goal of transparency, the Register Committee expects that agencies not only establish, but also make clear publicly the status of the different types of providers they work with.
45. In the interest of avoiding confusion and upholding the credibility of the education system, the Register Committee thus expects that the difference between formally recognised higher education institutions, awarding formally (nationally) recognised qualifications, and alternative providers must be absolutely clear for stakeholders and the general public.
46. The possible “dichotomy of national versus international, professional accreditation”, referred to by the panel in its clarification, cannot be a reason to accept unclarity or confusion about a provider's formal status. The Committee would consider it incompatible with the principles of the ESG if international, professional accreditation were to contribute to such unclarity or confusion. [...]
48. The Register Committee noted that a number of alternative providers accredited by ECTE used the terms “Bachelor” or “Master” for their education offer. The QF-EHEA employs these terms for officially recognised degrees. In the vast majority of EHEA jurisdictions, these terms are legally protected, similar to terms such as "university", "university college" or "higher education institution". Equally, in the public eye these terms are understood as implying formal recognition as a higher education institution.
49. The Register Committee therefore considers that the use of these terms by alternative providers is not acceptable unless it can be explicitly demonstrated that an alternative provider may legally use those terms.
50. ECTE's standards specified that “Programmes that are not recognized by national authorities should ensure that the qualification nomenclature that is used is appropriate and not in breach of protected terminology” (B.2.1, p. 27) and further that “If the qualification is not recognised by competent national authorities, this should be specified.” (B.5.1, p. 39)
51. It remained unclear to the Committee how stringently these provisions were verified or enforced in practice. In its response to the clarification request, the panel did not provide any further details. Given that the terms “Bachelor” and “Master” are typically legally protected, neither the fact that “ECTE's international experts from the field [...] are checking compliance with professional standards” (clarification by the panel) nor the fact that some of “ECTE’s members cannot or do not want to obtain a national recognition” (idem) give clear reassurance that the institutions in question use those terms legally.
52. The Register Committee considered that the unrestricted use by ECTE of the terms “Bachelor” and “Master” for alternative providers significantly reduced transparency and blurred, rather than clarified these providers' status. [...]
55. The fact that the majority of ECTE-accredited providers are alternative providers underpins the importance of ensuring that not only ECTE's own communication is clear, but also that ECTE ensures – through its respective standards and their stringent application – that the accredited providers themselves live up to the same level of clarity about their status.”
Full decision: see agency register entry
-
2.4 Peer-review experts – ACQUIN – Partial compliance (2021) Strength of the training for reviewers
ACQUIN
Application Renewal Review Full, coordinated by ENQA Decision of 13/12/2021 Standard 2.4 Peer-review experts Keywords Strength of the training for reviewers Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The training for experts relies mainly on sending materials to the experts and their self-
preparation and group briefings at the beginning of the review”
Full decision: see agency register entry
-
2.6 Reporting – ACQUIN – Compliance (2021) Consistency in the content and publication of the reports
ACQUIN
Application Renewal Review Full, coordinated by ENQA Decision of 13/12/2021 Standard 2.6 Reporting Keywords Consistency in the content and publication of the reports Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The agency publishes its reports on the website. The panel noted that, however, the structure of the reports and their publishing was not always consistent and that for some procedures the reports included summary information only. In their response to the review report, the agency explained that it now uses a template provided by GAC which enables a better structured and
standardised reporting. The agency is currently updating its database and
tackling the technical issues leading to an inconsistent report publishing. The Register Committee found that the agency has taken concrete
steps to address the issues related to the consistent drafting and publishing of its reports”
Full decision: see agency register entry
-
3.6 Internal quality assurance and professional conduct – ACQUIN – Partial compliance (2021) Weak management of staff development and not addressing earlier flags
ACQUIN
Application Renewal Review Full, coordinated by ENQA Decision of 13/12/2021 Standard 3.6 Internal quality assurance and professional conduct Keywords Weak management of staff development and not addressing earlier flags Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “Partial compliance due the need for a more structured management of the professional development of the staff and the lack of a comprehensive response to the issues raised in the previous external reviews (i.e. instances of partial compliance from the previous renewals of the registration: the training of experts (ESG 2.4) is still weak (a concern raised in 2011) and the publication of thematic analyses (ESG 3.4) remains not systematic (a concern raised in 2016).)”
Full decision: see agency register entry
-
2.4 Peer-review experts – ZEvA – Partial compliance (2022) monitoring expert training, experts trained by other agencies
ZEvA
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 2.4 Peer-review experts Keywords monitoring expert training, experts trained by other agencies Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “19. In addition,the review panel noted that the proportion of experts who take part in training had increased, but not sufficiently in the panel's view. The panel also considered that the process for recruitment and selection of experts was largely informal.
20. The Register Committee welcomed the newly introduced systematic monitoring of experts' training and prior experience, as explained in ZEvA's representation. The Committee agreed that ZEvA may of course rely on experts who were previously trained by other agencies operating in Germany.
21. At the same time, the Committee considered that 50% was not a very ambitious goal for the share of formally trained experts. Moreover, the Committee had some doubts whether prior experience should be considered entirely equal to a formal training.
22. While the Register Committee welcomed that the involvement of students was now ensured and that ZEvA is taking steps to enhance the formal training of experts, the Committee considered that the level of formal expert training remained weak to date. The Register Committee was therefore unable to concur with the panel, but considered that ZEvA only partially complies with the standard.”
Full decision: see agency register entry
-
2.6 Reporting – ZEvA – Compliance (2022) responsibility to publish reports also when not submitted to GAC
ZEvA
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 2.6 Reporting Keywords responsibility to publish reports also when not submitted to GAC Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “23. The Register Committee concurred with the panel's conclusion that ZEvA complies with the standard; the Committee further underlined that ZEvA is responsible to ensure that all reports are ultimately published on its own website and on DEQAR, including those that are never submitted to GAC by the institution under review.”
Full decision: see agency register entry
-
2.7 Complaints and appeals – ZEvA – Partial compliance (2022) requirement that appeals can be made against any report
ZEvA
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 2.7 Complaints and appeals Keywords requirement that appeals can be made against any report Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “25. The Committee underlined that any report is a formal outcome and thus needs to be open to appeal, even if it does not result in a yes/no decision.
26. In its additional representation, ZEvA clarified matters for evaluation reports. At the same time, it remained unclear whether and how institutions can appeal accreditation reports before submitting those to GAC. Even though GAC offers an appeals possibility, presumably GAC's process cannot fully investigate matters that are rooted in the report produced outside of GAC's direct control. Moreover, it would be unreasonable that institutions are forced to first submit to GAC a report against which they have strong objections before they can appeal against that report.”
Full decision: see agency register entry
-
2.4 Peer-review experts – ACPUA – Partial compliance (2021) Involvement of students in panels
ACPUA
Application Renewal Review Full, coordinated by ENQA Decision of 15/10/2021 Standard 2.4 Peer-review experts Keywords Involvement of students in panels Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “The Register Committee learned that the absence of student
members in the panels in the two activities is due to the specificity of the
processes; the procedures focus on quantitative indicators on teaching
offering and the human, material and financial resources. The Committee, however, understood that the process goes beyond a
purely technical check of numbers, as it generally involves other experts also
making a qualitative assessment. The Committee could not agree with the
panel’s conclusion that the “student perspective could not add any value” in
those procedures and considered that the students’ views could offer an
important insight into the matters under observation in both activities”
Full decision: see agency register entry