Database of Precedents

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.3 Independence
Keywords	Independence of formal outcomes
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (07/12/2021)
RC decision	Compliance

“In its past review the Register Committee noted that AKAST was subject to the vigilance of the German Bishops’ Conference and that its influence extended to giving consent for the admission of members of the association and the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and the Board, and the approval of each of the accreditation decision by the member of the Commission for Science and Arts (Commission VIII) of the German Bishops’ Conference. Due to these interlinkages, the Register Committee concluded (see decision of 30/11/2019) that AKAST did not comply with ESG 3.3. The Register Committee in particular found the requirement that each accreditation decision requires the consent of the representative of the German Bishops’ Conference (member of the Accreditation Committee) to be in contrast with the requirement of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.4 Thematic analysis
Keywords	Lack of development in preparing thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. The panel notes that AKAST reliably contributes the experience gained from its own quality assurance procedures to the regular evaluation of the Key Points and that the agency is documenting the results of its ongoing student survey on its website.

18. The Register Committee welcomes AKAST’s plan to further develop a thematic analysis after an appropriate number of programme accreditation procedures have been completed, but underlined that such an analysis has not been finalised.

19. Considering the limited development of thematic analysis, the Register Committee can follow the review panel conclusion that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.2 Designing methodologies fit for purpose
Keywords	no ownership or full responsibility resting with a single actor, consequences for improvement
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Compliance

“9. The panel noted that no actor had ownership or full responsibility for the entire accreditation system and process, since the specimen decree appoints specific responsibilities to both GAC and the agencies.

10. The Register Committee sought further clarification from the panel as to how that impacted continuous improvement and development. The panel noted that opportunities for improvements were discussed actively; the ongoing review of the Specimen Decree was an example of that. The panel, however, saw a lack of GAC itself assuming a more proactive, coordinating role and taking responsibility for the system as a whole; this would be reasonable given its unique and pivotal position.

11. The Register Committee concluded that continuous improvement seems to be ensured despite the distributed responsibilities and thus concurred with the panel's conclusion that GAC complies with standard 2.2; the issues related to GAC's role and strategy are considered under standard 3.1 below.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.5 Criteria for outcomes
Keywords	lack of formal mechanisms for consistency, unclear whether or not consistency improved
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The panel considered critically the lack of formal mechanisms to ensure a consistent understanding and application of the criteria (e.g. guidelines, interpretations or a precedent database made available by GAC).

13. The panel was unable to draw a conclusion whether the post-2018 system – with decisions made by GAC, including the practice to change conditions deviating from the proposal by the expert panels – actually delivered a higher degree of consistency or not.

14. The panel further noted that the current organisation of the Council's work included the risk that analysis of cases might often be “monopolised” in the hands of a single (academic) Council member, while some other Council members are currently not participating in the preparatory work as rapporteurs.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategy not reflecting agency's central role, lack of broad discussions with stakeholders
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Partial compliance

“16. The panel considered that the lack of involvement of stakeholders beyond those individuals who are members of the agency bodies themselves might lead to a lack of critical distance. The panel thus saw a need for more and broader stakeholder feedback, and recommended more regular dialogues with stakeholder organisations on strategic and policy matters.

17. The panel further considered that GAC's strategic planning did not sufficiently reflect its central, pivotal role in the accreditation system (see also the comments under ESG 2.2 above). The panel saw a strong need for a broader discussion with agencies and all stakeholders on GAC’s role in the system and its strategy. In particular in view of the upcoming revision of the

Specimen Decree, the panel found such a discussion was urgent to define a strategy that describes clearly the role GAC plans to assume in the system and its mid-term priorities.

18. While the Register Committee appreciates that GAC has begun to plan a strategy process (see statement on the report), it considered that the panel's analysis under this standard points to important issues in GAC's governance and engagement with stakeholders; these are particularly important in light of GAC's pivotal role in the German system.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.4 Thematic analysis
Keywords	relevance of topics, nature of topics to qualify, regularity and frequency of analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“20. The panel discussed the analyses produced by GAC on various topics, with the most recent ones focusing on conditions imposed on higher education institutions/programmes in decisions by the agencies and by GAC, published in 2018 and 2020 respectively. While the panel questioned whether this was “a crucial topic in the development of the HE system”, the Register Committee considered that such an analysis is certainly based on the general findings of GAC's external quality assurance activities and thus meets the expectation of the standard. Moreover, while the panel did not specifically indicate whether stakeholders found the topic relevant, an analysis of conditions might show how the accreditation criteria resonate with the sector and indicate topics that are typically challenging for institutions and programmes, and hence be relevant beyond GAC.

21. Given the role of GAC as the central body of the German accreditation system, the panel considered that the current publishing rate (one paper per year) was “insufficient”. As the standard remains completely open as to the frequency of analysis, the Register Committee found it an overly strict interpretation of the standard to influence the compliance level on that basis; the remark should rather be seen as a recommendation to publish more analyses.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.5 Resources
Keywords	shortage of staff positions addressed
Panel conclusion	Partial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Compliance

“24. The review panel noted a lack of human resources at GAC's disposal, leading to staff having to prioritise initial accreditation in their work, with reaccreditation procedures taking longer than they should in turn.

25. In its comments on the review report, GAC informed EQAR that a staff increase by 9.25 FTE was now confirmed.

26. The Register Committee sought clarification from the panel on the resources in light of this increase. The Committee understood that this staff increase would address the resourcing in quantitative terms, but that the positive impact of this would remain limited as long as the reservations about the organisation of the Council's work remain, as noted under ESG 2.5.

27. In light of the staff increase, the Register Committee considered that GAC now complies with standard 3.5, while noting that the serious concerns stated under standard 2.5 relate to the question whether GAC effectively deploys its resources, especially in terms of organising the Council's work.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.1 Consideration of internal quality assurance
Keywords	lack of coverage for certain ESG Part 1 standards in international programme accreditation
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Partial compliance

“9. The review report showed that several standards of ESG Part 1 (1.1, 1.4, 1.6, 1.7, 1.9, 1.10) are not addressed in (international) programme accreditation. While HCERES explained to the panel that they adapt their standards according to the foreign context, this creates a situation where a study programme might be accredited by HCERES without having been assessed against the full ESG Part 1.

10. The panel considered that (international) programme accreditations are small in number compared to (national) programme evaluations and other activities of HCERES. The Register Committee, however, considered that the issue at hand is not an occasional or statistical error, but a structural and systemic deficiency for an entire external quality assurance activity of HCERES.

11. As a programme accredited by HCERES will be regarded as ESG-aligned by the public, confirmed by the entry of those programmes in DEQAR, the lack of full ESG Part 1 coverage represents a substantial shortcoming. The Register Committee was therefore unable to concur with the panel's conclusion that HCERES complies with the standard, but concluded that HCERES only partially complies with ESG 2.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.3 Implementing processes
Keywords	follow-up with limited value added, no students interviewed in site visits
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Partial compliance

“18. The panel noted that HCERES programme evaluation panels do not meet with students during review visits. The panel discussed the new follow-up process introduced for institutional evaluation only, but noted that some questions remained regarding the added value given that there is no analysis or feedback in direct response to follow-up reports.

19. The panel considered that HCERES made improvements since the last review, as site visits were not carried out for programme evaluations at all previously and given there was no follow-up process previously.

20. While the Register Committee acknowledged that significant progress has been made, it did not consider that HCERES complies with the standard yet in light of the limited added value of the follow-up process and the fact that students are not interviewed during site visits. The Committee therefore did not concur with the panel, but concluded that HCERES remains partially compliant with ESG 2.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.7 Complaints and appeals
Keywords	Board member in appeals committee, independence of decisions on appeals
Panel conclusion	Full compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Compliance

“28. In the last renewal of registration, HCERES was found to be only partially compliant with the standard since its appeals and complaints processes were only just set up and not yet reviewed by an external panel; a specific concern was whether the decision-making on appeals was fully independent from those in charge of the appealed report/decision.

29. The panel considered that HCERES' appeals and complaints processes were clearly defined and communicated. The panel noted that HCERES had not received appeals or complaints since 2016.

30. The panel clarified that it considered the appeals committee's composition suitable. While HCERES Board members indeed serve on the appeals committee, the Board does adopt neither evaluation reports nor accreditation decisions. In addition, one external expert is part of the committee.

31. The Register Committee agreed that the appeals committee was sufficiently independent given that the HCERES Board does not adopt the reports or decisions that are being appealed. The Committee therefore concurred with the panel's conclusion that HCERES complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	3.4 Thematic analysis
Keywords	separate research or bilbiometric analyses do not qualify as thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“38. The panel considered that HCERES' recent activities have been focused on research and bibliometric analysis; analyses drawing on the results of evaluations within the scope of the ESG have not been produced regularly since the summary reports that HCERES/AERES used to produce following earlier evaluation campaigns.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	3.6 Internal quality assurance and professional conduct
Keywords	feedback system not fully integrated, regression since last review
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“40. The panel noted that the representatives of institutions and reviewers gave different opinions on the possibilities for feedback.

41. The Register Committee agreed with the panel's analysis that this indicates that the feedback system might not yet be fully implemented and that there was a need to systematise and make more coherent the available feedback instruments.

42. The Register Committee further noted that the only partial compliance with ESG 2.1 and 3.4 is a regression since the last review and thus does not reflect positively on the agency's internal quality assurance arrangements.

43. In light of these reservations the Committee was unable to concur with the panel's conclusion, but considered that HCERES only partially complied with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee learned that IQAA now publishes in full the decisions from institutional and programme accreditations, including the

negative ones. Even though the bulk of reports is public, this is not the case for all of them - the reports from the initial accreditation and the post-accreditation monitoring are still not published.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.4 Thematic analysis
Keywords	Consistent publication of thematic analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that IQAA has published several thematic analyses since the last review. The panel, however, could not see

any formal plan for drafting and publishing these analyses.The Committee considered that despite the absence of a more formal planning the agency has developed a practice and demonstrated a clear vision for conducting analyses based on its EQA processes.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.1 Consideration of internal quality assurance
Keywords	How ESG Part 1 is embedded in subject-specific label reviews
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its Change Report Decision of 02/11/2020, the Register Committee requested that the next external review of ASIIN considers how the agency ensures sufficient coverage of ESG Part 1 in its combined (“piggybacking”) procedures (ESG 2.1). The agency explained that ESG Part 1 is embedded as a standard procedure in every external QA activity carried out (Self Evaluation Report p. 35). Having considered how ESG Part 1 is mapped against ASIIN’s seals while also including the standards of the German Accreditation Council, the panel was convinced of the coverage and link to ESG Part 1 in all its activities. The documents confirmed that all subject-specific label requirements are assessed in addition to ASIIN's generic standards for degree programmes, which incorporate ESG Part 1. The panel also underlined that SAR templates for each review method were structured to follow ESG Part 1. The Register Committee was therefore satisfied that ESG Part 1 is sufficiently addressed in ASIIN’s combined (“piggybacking”) procedures.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.3 Implementing processes
Keywords	Implementation of procedures and transparency of CBQA procedures
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last review the Register Committee noted that ASIIN's policies were not always followed in practice, i.e. use of on-site visits in evaluations and use of evaluation results in programme accreditations. In its current review, the panel stated that it did not find any evidence of deviations from the prescribed procedures and that policies are implemented consistently. The panel, however, remarked that ASIIN could provide better guidance about the site visit schedule and ensure more transparency in the processing of requests deemed potentially problematic from countries of higher education institutions outside of the European Higher Education Area (see also under ESG 3.1).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.7 Complaints and appeals
Keywords	handling of appeals and complaints
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee considered the panel’s findings that show that ASIIN’s appeals and complaints processes are not well differentiated and as a result not consistently used, i.e. the institutional accreditation handbook discuss complaints procedure although what is described is the means to appeal a decision, whereas the handbooks for the programme accreditation and certification processes mention appeals procedure, the name of the Appeals/Complaints Committee appear to have four different permutation. The panel further comments on the agency’s lack of understanding of the two different concepts. In its response to the review report (19/07/2021) ASIIN’s stated that it has revised its documents and website, employing the right terminology. While the Register Committee welcomed ASIIN’s corrections, the Committee found the panel’s concerns have not been fully address, as the lack of understanding of the two concepts may affect the agency’s ability to effectively handle both appeals and complains for all its activities.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholder representation within the governance and separation of EQA within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last decision, the Register Committee noted that ASIIN continued to use the term evaluation for type 2 evaluations against the panel’s recommendation, and thus the separation between activities within the scope of the ESG and those that are carried out as type-2 evaluations remained unclear. In its review report the panel considered that the difference made by ASIIN in various documents between type 1 evaluation and type 2 evaluation sufficiently differentiated between accreditation and consultancy. The panel further noted that ASIIN had a policy not to conduct accreditation for those institutions/ programmes at which consultancy activities were carried out, and that this was adhered to in practice (p.31). The Committee therefore concluded that this shortcoming has been addressed. The Register Committee noted that ASIIN’s Board of Directors consists exclusively of representatives of member organisations/institutions of ASIIN. The involvement of a diverse set of stakeholders (including students) in the governance of the agency is, however, ensured within the technical committees, Accreditation Commission and Certification Commission. Considering ASIIN’s expansion of its external QA activities to other areas the panel underlined that ASIIN should rethink its current structure and broaden its competences (p.16). The panel recommended a stronger involvement of the Board of Directors in the strategic direction of the agency and the monitoring of its strategic goals, while at the same time expanding its membership to also include external stakeholders (including a student member). The Committee underlined that recommendation of the panel.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.3 Independence
Keywords	Integrity/conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that the members of ASIIN’s technical committees can simultaneously hold the position of an external reviewer for ASIIN’s review panels, which would put them in a conflict of interest when discussing the reports prepared by the same panel they were members of.

23. Considering the panel’s concern of a potential conflict of interest resulting from this arrangement, the Committee concluded in its initial decision that ASIIN complied only partially with ESG 3.3.

24. In its Appeal of 20/01/2022, ASIIN challenged the Committee’s conclusion and judgment arguing that the independent decision making of its Technical Committee was not compromised. The agency made the case that the involvement of active experts as members within ASIIN’s 14 Technical Committees ensured a consistent application of procedures and criteria in the preparation of accreditation reports. ASIIN further explained that ASIIN’s Technical Committees did not have any decision-making power as regards the accreditation decision. Moreover, the experts involved in the procedure would regularly abstain.

25. The Committee welcomed the abstention of the Technical Committee members, but could not determine if the practice of abstention was institutionalised in ASIIN’s procedure.

26. The Register Committee further underlined that the integrity of the review process could be better safeguarded by ensuring that members of the Technical Committees would not partake at all (i.e. by leaving the room) when their report is considered by the Technical Committee.

27. Having weighed the limited role of the Technical Committee in ASIIN’s decision making process and the fact that its members abstain from decision-making in such cases where they were involved as reviewers, the Register Committee concluded that ASIIN’s independent decision-making is not compromised and thus found that the requirement of the standard is met. The Committee therefore concurred that the agency complies with ESG 3.3”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.4 Thematic analysis
Keywords	thematic analysis conducted on a regular basis
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last renewal of registration on EQAR, the Register Committee noted that ASIIN only partially fulfilled the requirement of the standard, since ASIIN did not conduct such analysis on a regular basis and the prepared analysis and studies contained only elements of what is understood as thematic analysis. In its current review report, the panel commends ASIIN for its efforts in regularly developing thematic analysis through its impact studies which provide significant insights on the agency’s external QA activities. While the panel finds that ASIIN could improve the dissemination of its impact studies among stakeholders, the panel is satisfied that the requirement of the standard is met. Having addressed the earlier concerns in its compliance with ESG 3.4, the Register Committee concurred with the panel’s conclusion that ASIIN now complies with the standard.”

Full decision: see agency register entry