Database of Precedents
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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