Database of Precedents
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2.7 Complaints and appeals – CYQAA – Partial compliance (2024) appeals procedure, appeals committee
CYQAA
Application Renewal Review Full, coordinated by ENQA Decision of 04/04/2024 Standard 2.7 Complaints and appeals Keywords appeals procedure, appeals committee Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “7. In the decision on the for inclusion of CYQAA on the register (of 2019-11- 05), the Register Committee raised concerns regarding the shortcomings of the appeal procedure regarding the independence of the processes and the lack of clearly defined and formal complaints procedure.
8. From the external review report, the Register Committee learned that the Complains Policy is well established and higher education institutions
have already used the possibility to submit a complaint (18 until the time of the external review).
9. The Register Committee further learned that CYQAA has revised its Appeals Procedure and now sets Advisory Committee of Experts (ACE) - groups of experts that examine and give opinion on the grounds for appeals to CYQAA’s Council. Despite the updated policy, the Council still holds the powers to make the final decision whether there are grounds for an appeal and can dismiss or uphold the appeal.
10. Furthermore, the Committee noted that the current Appeal Procedure is not entirely clear as it may suggest that an ACE is appointed for each appeal that is allowed for consideration by the Council, whereas in practice it is set only when the Council proposes to reject an appeal and needs advice from external experts.
11. The Register Committee welcomed (changes made related to the complaints procedure) and found the earlier concerns related to the complaints procedure addressed. The Committee, however, found that CYQAA is yet to demonstrate an independent functioning of the Appeals
Procedure, where the final decision is not with CYQAA’s Council. Having in mind the shortcomings related to the Appeals Procedure, the Register
Committee concurred with the panel conclusion that CYQAA only partially complies with ESG 2.7.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – CYQAA – Partial compliance (2024) strategic plan, stakeholder, stakeholders involvement
CYQAA
Application Renewal Review Full, coordinated by ENQA Decision of 04/04/2024 Standard 3.1 Activities, policy and processes for quality assurance Keywords strategic plan, stakeholder, stakeholders involvement Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “12. The Register Committee noted the concerns raised by the panel that CYQAA’s Strategic Plan (2020-2025) is rather generic, with no specific
activities and clear timeframes. Furthermore, the Committee noted that the panel did not see any evidence of public, annual corporate or activity plan than operationalise the Strategic Plan.
13. The Register Committee understood by the panels analysis, that the agency involves representatives from both public and private universities, students and regulated professions. However, as underlined by the panel, the involvement of private higher education institutions and many public and private colleges and their students is very limited and CYQAA should further widen their engagement in its governance and evaluation processes.
14. Considering the lack of comprehensive and rather generic Strategic Plan and the shortcomings in the involvement of stakeholders from all
higher education institutions, public and private colleges, the Register Committee concurred with the panel and found that CYQAA only partially
complies with ESG 3.1.”
Full decision: see agency register entry
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3.3 Independence – CYQAA – Partial compliance (2024) operational independence, methodologies
CYQAA
Application Renewal Review Full, coordinated by ENQA Decision of 04/04/2024 Standard 3.3 Independence Keywords operational independence, methodologies Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “15. In the decision for inclusion of CYQAA on EQAR (of 2019-11-05), the Committee raised concerns regarding the shortcomings related to the
operational independence of CYQAA and the close interlinkage between the agency and the responsible ministry.
16. Despite some progress being made by consultation with key stakeholders on the appointment of Council members and the Minister, the Register Committee noted that the Council members are still appointed by the Council of Ministers, upon recommendation by the Minister responsible for higher education.
17. The Register Committee took note of the panel’s concerns regarding the operational independence of the agency, The Committee understood that CYQAA cannot hire its own staff and is fully relying on secondments from the central Government and the Ministry of Education, Sport and Youth.
18. The Register Committee further noted, as underlined by the panel, that despite being fully independent in defining its evaluation methodologies, CYQAA is still challenged by the limits set in the provisions of the national legislation regarding engaging stakeholders in the development of methodologies (see issue raised under ESG 2.2 in the external review report).
19. Following the panel’s analysis, the Register Committee expressed its concerns that the operational independence of CYQAA remains constrained by the close link and dependence on the Ministry of Education, Sport and Youth regarding the appointment of the Council members, hiring of staff and engaging stakeholders in the development of methodologies. Therefore, the Register Committee concurred with the panel conclusion, and found that CYQAA remains to be partially compliant with ESG 3.3.”
Full decision: see agency register entry
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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 3.4.”
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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2.3 Implementing processes – PKA – Compliance (2024) follow-up, online procedures,
PKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 04/04/2024 Standard 2.3 Implementing processes Keywords follow-up, online procedures, Panel conclusion Partial compliance Clarification request(s) Panel (04/10/2023)
RC decision Compliance “12. The Register Committee noted that PKA does not have separate follow-up mechanisms in place, but that they are part of the re-accreditation process i.e., after a conditional two year period (or longer depending on the length of the study cycle) the agency monitors the implementation of recommendations, while in case of a six year accreditation cycle, the agency monitors if the recommendations for improving the quality of education are addressed.
13. The Register Committee finds this approach completely reasonable and in line with the requirement of the standard
14. The Register Committee noted that all of PKA’s evaluation procedures (with some exceptions) are being carried out remotely. In its clarification call the review panel explained that PKA is following clear regulations regarding its remote procedures, regulations that have been updated following wide consultations with the sector. The panel was reassured with PKA’s approach in its online accreditation procedure i.e., PKA carries out observations of classes, institutions are asked to provide a video of the learning facilities and during the remote visit PKA experts also meet with different stakeholders to verify the facts in the review report.
15. The Register Committee further noted concerns from the review panel’s analysis regarding the factual accuracy-check of review reports, as this practice was not clear for those the review panel interviewed. The Register Committee however noted that the possibility for the higher education institution to comment on the assessment report is given to all higher education institutions (as confirmed by the panel) and that this is part of the procedure of the agency in the consideration of the report. The Register Committee nevertheless underlines the panel’s recommendation to further clarify the stage of factual accuracy check in PKA’s procedures.
16. Having considered the clarification of the panel and PKA’s statement to the review report, the Register Committee could not concur with the review panel’s decision of partial compliance, and found that the agency is in fact compliant with ESG 2.3.”
Full decision: see agency register entry
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2.4 Peer-review experts – PKA – Compliance (2024) students
PKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 04/04/2024 Standard 2.4 Peer-review experts Keywords students Panel conclusion Compliance Clarification request(s) – RC decision Compliance “17. In its past decision, the Register Committee noted PKA’s intention to ensure students are part of the peer-review expert groups in the opinion-giving process and to contribute as equal partners.
18. In its 2023 review report, the panel noted improvements related to the wider engagement of different stakeholders’ groups. In the case of opinion-giving procedure, panels are now composed of members of relevant sections or experts appointed from the academic teachers expert group and a student.
19. The Register Committee thus concluded that the agency has addressed the issues raised in the previous report and therefore can follow the panel’s judgment of compliance.”
Full decision: see agency register entry
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2.6 Reporting – PKA – Partial compliance (2024) publication of reports
PKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 04/04/2024 Standard 2.6 Reporting Keywords publication of reports Panel conclusion Compliance Clarification request(s) Panel (04/10/2023)
RC decision Partial compliance “20. In the past decision, the Register Committee noted that reports of its initial (ex-ante) programme evaluation/opinion-giving process were not published. In its recent review, the panel confirmed that all “expert reports and resolutions of the opinion giving process are now published and available on PKA’s website”.
21. While the Committee noted that PKA has published all decisions from the initial (ex-ante) programme evaluation/opinion-giving process, the Register Committee however found that such decisions did (in particular after July 2020) not include full reports. Given the missing number of a large number of full reports the Register Committee sought further clarifications from the review panel. The panel explained that they understood there was a delay in the publication of reports but that the statutory requirement is for PKA to publish all reports. This reassured the panel that the earlier concern regarding the publication of reports was resolved.
22. Given that PKA has not published all reports from its opinion giving process, the Register Committee found that the earlier concern has not been addressed.
23. In its representation, PKA provided information on the planned changes in its provisions to ensure publishing all reports from its opinion-giving processes. PKA explained that it would be possible to publish all reports from its opinion giving process without the need to wait for information from the Minister regarding their final decision through these changes.
24. Furthermore, in its additional documentation provided on 2024-03-28 PKA informed of its statutory changes where the planned changes have been done.
25. The Register Committee welcomed the actions taken by PKA. However, these changes in the provisions remain to be considered and reviewed by an external review panel to determine whether the changes have been properly implemented.
26. The Register Committee therefore could not concur with the review panel’s conclusion, and found that PKA complies only partially with ESG 2.6.”
Full decision: see agency register entry
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3.3 Independence – PKA – Partial compliance (2024) organisational independence, minstry,
PKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 04/04/2024 Standard 3.3 Independence Keywords organisational independence, minstry, Panel conclusion Partial compliance Clarification request(s) Panel (04/10/2023)
RC decision Partial compliance “27. In its decision of the Substantive change report decision (of 28-06-2022) the Register Committee concluded that the dismissal of the President casts serious doubts on whether PKA remains able to “act autonomously” and to assume “full responsibility for [its] operations”, as required by ESG standard 3.3.
28. The Register Committee considered that the law and regulations on PKA provided insufficient safeguards against an infringement on the agency's independence by allowing for such a decision to be taken discretionary by the Minister. The Committee found that its earlier conclusion that PKA complies with ESG 3.3 might have been flawed, and based on a positive external review report that did not allay such concerns.
29. In its current review the panel confirmed the concerns of the Register Committee i.e., the panel “could not gauge the extent to which the looming possibility of dismissal without reason may affect the behaviour and performance of the President…”. The panel also noted that there are no clear rules and procedures for the dismissal of PKA’s President, thus the Minister can continue to use discretionary power to dismiss the President of PKA.
30. Following the review panel’s recommendation, the President of PKA submitted a letter, dated August 2, 2023, to the Minister of Education and Science, articulating the recommendations delineated in the ENQA’s review report. In its response letter (Annex 1 of Statement), the Minister showed readiness for a discussion that would determine the criteria for dismissing the PKA President.
31. The Register Committee considered that the Minister was willing to recommend a change in the Law and that would remove the question mark over the independence of PKA (as noted in the Review Report and PKA’s Statement to the Review Report). The Committee nevertheless found that since its Change Report (of 2022-06-28) and the review panel’s review report of June 2023, no change or new evidence in the form of a policy, protocol, procedure or similar, specifying reasons/rationale for the dismissal of the President regulating the Minister’s discretionary power was developed and adopted.
32. The Committee further noted existing possible conflict of interest in PKA’s decision making bodies (see further under ESG 3.6), which raises concerns related to the integrity and independence of the agency’s formal outcomes.
33. The Register Committee finds the above issues of significance given the powers conferred in the position of the PKA’s President (expressed mainly in article 7, 8, 9 & 11a of PKA Statutes) and the controlling stake laid in the hands of the Minister, who has already employed its discretionary power to dismiss the President of PKA at any point (see Change Report Decision of 2022-10-25).
34. In its additional representation, the agency provided a declaration from the new Minister of Science of Poland, where he shows willingness to initiate an amendment on the provisions of the Act of Higher Education and Science in order to limit the Minister’s powers and remove their right to dismiss the President of PKA. Furthermore, the declaration states that the proposed amendment it would empower PKA to be responsible for the dismissal of the President.
35. The declaration of the Minister also informed the Register Committee, that until the legislative framework is changed, he shall introduce an internal procedure in case the President needs to be dismissed, in order to eliminate any further doubts of the Register Committee.
36. The Register Committee welcomed the proposed changes by PKA and the Polish Ministry of Science. Nevertheless, the presented changes have not been implemented in practice yet and at the moment are promises that have yet to be implemented. Therefore, once adopted it remains to be considered and reviewed by an external review panel to determine whether the changes have been properly implemented.
37. The Register Committee therefore concurs with the panel that PKA complies only partially with ESG 3.3. The agency is expected to submit a Substantive Change Report informing the Register Committee once the changes have been made.”
Full decision: see agency register entry
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3.5 Resources – PKA – Compliance (2024) resources
PKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 04/04/2024 Standard 3.5 Resources Keywords resources Panel conclusion Compliance Clarification request(s) – RC decision Compliance “38. In its past review, the Register Committee noted concerns related to the lack of resources, the high turnover of the Bureau staff and the agency’s capacity to perform thematic analysis.
39. The Register Committee noted from the findings of the latest review (review report of 2023) that the agency now benefits from an increase in support and resources, a decrease in staff turnover, an improved focus on thematic analysis and a legislative recognition for this activity. The panel also found that staff, managers and stakeholders were satisfied with the current resources of the agency.
40. Based on the findings of the review panel, the Register Committee was able to concur with the judgement of compliance with standard 3.5.”
Full decision: see agency register entry
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3.6 Internal quality assurance and professional conduct – PKA – Partial compliance (2024) internal QA,
PKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 04/04/2024 Standard 3.6 Internal quality assurance and professional conduct Keywords internal QA, Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “41. In its Change Report Decision (of 2022-11-25), the Register Committee considered the reported change on the newly established body, the Quality Council, and expressed concern with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council.
42. While the panel was unable to address concerns with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council, it noted that the PKA’s President maintains a supervisory role in the internal quality management system of the agency (by being responsible for supervision of the internal quality management system (IQMS) and in appointing a Quality Management System.
43. The Register Committee found that the current proposal for Quality Council (based on Statutes articles 11a & 15a) could have far reaching consequences, while also noting the organisational issues highlighted under ESG 3.3.
44. The Committee was also made aware of possible conflict of interest scenarios (1) where the Chairs of Section may participate in the discussion of the Presidium, even if they have been part of assessments they have previously prepared and (2) where the Chair of the Appeals Body may vote on resolutions adopted by the Presidium which may be later considered by the Appeals Body. The Register Committee found that this setup lacks the appropriate checks and balances and may affect the integrity of PKA’s activities. The Committee could not understand why PKA has not set up a system that would allow the recusal from the discussion or the possibility for restricting the participation (to no voting rights) of those that could be in a conflict of interest scenario.
45. In its additional representation, PKA informed that the responsibility for establishing the Quality Council will be with the Presidium and no longer solely with the President.
46. Furthermore, PKA committed to introduce provisions stipulating that members of the Presidium participating in programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on those procedures.
47. In its additional representation, PKA clarified that the participation and voting rights of the Chair of the Appeals Body in the Presidium is based on the provisions of the Higher Education Act and PKA’s Statutes. PKA clarified that the Chair of the Appeals Body participates only in the part of the meetings where motions for reconsideration of assessment of opinions are discussed and votes only on this matter.
48. Furthermore, PKA clarified that the Chair of the Appeals Body does not take part in the proceeding assessments of opinions that may become object of applications for reconsideration, nor do they vote on such matters.
49. In the additional documentation (of 2024-03-28), PKA reported that the following statutory changes have been made: (a) The responsibility for establishing the Quality Council will be with the Presidium rather than solely with the President; (b) The members of the Presidium participating in the programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on the decisions resulting from those procedures.
50. While the Register Committee welcomed the changes taken by PKA, it underlined that the issues outlined before remain to be addressed and subsequently to be considered and review by an external review panel in order to determine their implementation in practice.
51. The Register Committee therefore could not follow the review panel’s judgment of compliance and found that PKA 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