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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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