Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	mentorship programme, participation of students, stakeholder consultation in the design of methodologies
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (09/10/2020)
RC decision	Partial compliance

“ Considering the mentorship programme run by the agency, the Register Committee noted the panel's concerns related to the possible conflict of interest of such experts providing support to institutions.

Considering THEQC’ shifts towards institutional accreditation and the panels’ recommendation to ensure that any conflict of interest is avoided in this new activity, the Committee asked the agency whether it has kept or discontinued its mentorship programme.

The agency explained that the mentorship programme was a feature of the Institutional External Evaluation Programme (IEEP) and that THEQC continues to carry out evaluations for higher education institutions that have been newly established or have no graduate students. The agency added that it has launched a new call for mentors in 2020, and that those mentors are requested to declare possible interest when assigned to an institution, and to sign a Code of Ethics as well. The Committee further noted the panel’s concerns regarding the design of methodologies and other related documents, which are only discussed by the Council with no further consultation being carried out with THEQC’s stakeholders. The agency did not comment on this issue in its additional representation. The panel's analysis further shows that the participation of students is limited compared to that of other Council members, as no student was included in any of the Council’s commissions. In its additional representation, THEQC stated that students now actively participate in two additional committees.The Register Committee welcomed the clarification and steps taken to prevent conflict of interest in its mentorship programme and nomination of students in the agency’s governance. The Committee, however, underlined that the effectiveness of stakeholder involvement in the agency’s governance and work has yet to be fully reviewed in practice, in particular with regards to stakeholder consultation in the design of methodologies. The Committee therefore considered that THEQC complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ASIIN
Decision of	28/06/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	scope of the ESG, alternative providers, transparency of provider status, use of Bachelor and Master by alternative providers, need for clear distinction
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Partial compliance

“39. The ESG cover “higher education in its broadest sense, including that which is not part of a programme leading to a formal degree”. The ESG do not specifically limit what "higher education" means and explicitly include education that does not lead to a "formal degree".

40. The Register Committee therefore considers that the scope of the ESG needs to be determined by the quality and level of the education provided, not the legal status of the provider. That is, if an alternative provider offers learning opportunities with learning outcomes at higher education level, as defined by the QF-EHEA descriptors (see discussion under 2.1 above), the ESG can be considered applicable as a framework for the provider's quality assurance. [...]

42. In general, the ESG are underpinned by an expectation of utmost transparency; in turn, information that could be misleading, in particular for (potential) students, should be avoided. EQAR's Policy on the Use and Interpretation further specifies that the Register Committee should be guided by EQAR’s overall mission of ensuring transparency and trust when applying the standards.

43. Under ESG 3.1 it is expected that quality assurance agencies distinguish clearly and transparently between their external QA within the scope of the ESG and other activities. In line with the overall goal of transparency, the Register Committee applies the same principle to different types of accredited providers with a clearly different status and formal recognition; a lack of transparency about the status of different providers would bear the risk of confusing potential students as well as others, and might raise false expectations as to the status and recognition of credentials earned from those providers.

44. The guidelines to ESG 3.6 further reflect the expectation that an agency “establish the status and recognition of the institutions with which it conducts external quality assurance”. In view of the overarching goal of transparency, the Register Committee expects that agencies not only establish, but also make clear publicly the status of the different types of providers they work with.

45. In the interest of avoiding confusion and upholding the credibility of the education system, the Register Committee thus expects that the difference between formally recognised higher education institutions, awarding formally (nationally) recognised qualifications, and alternative providers must be absolutely clear for stakeholders and the general public.

46. The possible “dichotomy of national versus international, professional accreditation”, referred to by the panel in its clarification, cannot be a reason to accept unclarity or confusion about a provider's formal status. The Committee would consider it incompatible with the principles of the ESG if international, professional accreditation were to contribute to such unclarity or confusion. [...]

48. The Register Committee noted that a number of alternative providers accredited by ECTE used the terms “Bachelor” or “Master” for their education offer. The QF-EHEA employs these terms for officially recognised degrees. In the vast majority of EHEA jurisdictions, these terms are legally protected, similar to terms such as "university", "university college" or "higher education institution". Equally, in the public eye these terms are understood as implying formal recognition as a higher education institution.

49. The Register Committee therefore considers that the use of these terms by alternative providers is not acceptable unless it can be explicitly demonstrated that an alternative provider may legally use those terms.

50. ECTE's standards specified that “Programmes that are not recognized by national authorities should ensure that the qualification nomenclature that is used is appropriate and not in breach of protected terminology” (B.2.1, p. 27) and further that “If the qualification is not recognised by competent national authorities, this should be specified.” (B.5.1, p. 39)

51. It remained unclear to the Committee how stringently these provisions were verified or enforced in practice. In its response to the clarification request, the panel did not provide any further details. Given that the terms “Bachelor” and “Master” are typically legally protected, neither the fact that “ECTE's international experts from the field [...] are checking compliance with professional standards” (clarification by the panel) nor the fact that some of “ECTE’s members cannot or do not want to obtain a national recognition” (idem) give clear reassurance that the institutions in question use those terms legally.

52. The Register Committee considered that the unrestricted use by ECTE of the terms “Bachelor” and “Master” for alternative providers significantly reduced transparency and blurred, rather than clarified these providers' status. [...]

55. The fact that the majority of ECTE-accredited providers are alternative providers underpins the importance of ensuring that not only ECTE's own communication is clear, but also that ECTE ensures – through its respective standards and their stringent application – that the accredited providers themselves live up to the same level of clarity about their status.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	conflict of interest in review processes
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (24/10/2020)
RC decision	Compliance

“The Register Committee noted that MusiQuE has since its last review created a permanent student seat on its Board (as of November 2017). While the Register Committee welcomed this change, the Committee further underlined the review panel's recommendation on the need for a more diverse range of stakeholders to be involved in the governance and work of the agenc. The Register Committee sought clarification from the panel whether it had considered the risk that the critical friend reviews could have a supporting or consulting role, which could lead to the quality enhancement review issuing judgments on matters that MusiQuE's critical friends have assisted to develop or implement. The panel was asked how it satisfied itself that MusiQuE prevents such potential conflicts of interest.The panel explained that it considered the critical friend review as a first phase of the Quality Enhancement review. The panel argued that this process did not result in conflicts of interest as the MusiQuE processes were similar to other processes where institutions are required to follow-up on previous peer reviews and consider inputs from stakeholders”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of QA and consultancy activities
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that the agency put in place a policy regarding the separation of the agency’s consultancy and assessment activities which dictates that if a project coordinator is involved in providing consultancy services to a higher education institution, he/she is not allowed to act as a secretary in an assessment procedure for a period of at least five years. The panel further commented that QANU’s management have shown high awareness of of the need to avoid conflicts of interest and to ensure QANU’s independence in its activities. With regards to the stakeholder involvement in the governance and work of the agency, the panel found that QANU has formalised the involvement of students in the Board of the agency following its change in Statutes. While the Register Committee welcomed the involvement of students, the Committee further underlined the panel’s recommendation of ensuring a broader stakeholder involvement in the agency’s governing structure. In view of the changes introduced by the agency the Register Committee was able to follow the panel’s conclusion that QANU complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in agency’s decision making
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Partial compliance

“There is a lack of student representation. Students are neither involved in the governing body nor in the bodies that review and design the agency’s procedures or take decisions on the adoption of such procedures (Governing and Advisory Board). The agency stated (in its Statement to the Review Report) that the Student Board is an Advisory Body and that students can contribute in that capacity to the governance and work of the agency. The Committee underlined the limited involvement of students in the agency’s governance and work. While the legislation does not prescribe their involvement in the agency’s Board of Directors, ACSUCYL may nevertheless improve its consultation process and also request a change of its current legal framework.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Mission implementation in daily work; Clear distinction between activities; Stakeholders’ involvement; Involvement of students
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its analysis the panel commented that it was unclear which is the body in the agency responsible for developing a strategy, how AKKORK’s procedures are developed and what types of activities and services the agency is offering. Furthermore the panel could not find any clear evidence on how the agency’s mission is translated into the daily work of the agency. The panel also noted that AKKORK’s actual structure and relations between its governing bodies were different to the ones presented in the last version of the statutes, adopted in

2013. While stakeholders are part of AKKORK’s multiple bodies, the panel noted that their involvement could be broadened. In particular, the panel recommended that students be involved also in other bodies than the Advisory Council, where only representatives from professional organisations and higher education institutions are present. The Register Committee noted from the additional information that AKKORK has updated its mission statement and detailed its objectives and main activities on its website. The agency further stated that a new Strategic plan 2020-2024 has been approved by the Supervisory Board and that its Financial Plan also have been updated. The Register Committee could also verify that the new Strategic Plan has been adopted by the Supervisory Board at its meeting on December

2019. While the Committee welcomed the steps taken by the agency to address the panel’s concerns, the Committee further considers that these changes still have to be fully implemented and externally reviewed by a panel, i.e. showing evidence of a robust yearly work planning, implementation of the strategic plan. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholders’ involvement; Involvement of students; Lack of strategical planning
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted the panel’s concerns in terms of the agency’s engagement with stakeholders. While the agency has strong connections with universities, the relationship with student representatives, and other civic and social groups is very weak. This lack of engagement is reflected in both the composition, working arrangements and internal interaction of the agency’s committees. The Register Committee considered the agency’s explanation that the current regulation of its statutes limit the involvement of students, but the Register Committee underlined that stakeholder involvement such as students is a key requirement of the standard. the agency lacked a strategic focus and that there was no evidence of governance level oversight of strategic planning or review by AAC-DEVA. In its additional representation the agency reported that steps have been already made to ensure the presence of students and professionals in all evaluation committees for ex-ante verification, modification and accreditation renewal. The agency stated that it intends to further strengthen the role of the Technical Committee for Evaluation and Accreditation (CTEyA) by incorporating professionals and by increasing the number of students. Considering the lack of a strategic focus and governance oversight, the agency added that its new Strategic Plan for 2021-2026 is in preparation and that it will reflect the engagement of stakeholders and the different levels of strategic governance. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of student in evalag’s governing structure, and overarching strategy
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel found that evalag had no clear overarching strategy, bringing together planning, budgeting and risk assessment. The review panel noted stakeholders are formally involved in evalag’s governance through the Foundation Board, while the Board does not include a student member. Stakeholders are further involved in evalag’s work through participation in workshops and similar activities. The panel recommended that a student be appointed to the Foundation Board.Considering the concerns re. the lack of an overarching strategy and that one important stakeholder group is not represented in evalag’s governing structure, the Register Committee was unable to concur with the panel’s conclusion of substantial compliance, but considered that evalag only partially complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in the governance
Panel conclusion	Full compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Compliance

“The Register Committee noted that the legal regulation over CTI’s governing structure limits the involvement of students in the agency’s formal bodies. The Committee has asked the panel to clarify whether the agency has taken any steps towards changing its legal framework and involving students in its governance. In its clarification response the panel emphasised the positive collaboration and involvement of students in the work of CTI but also admitted that students are not involved in the final decision making processes of CTI. The panel noted that students participated in the work of CTI as part of review panels, meetings and training activities along with CTI members and that the student union is consulted in the revision of CTI’s frameworks and guidelines. The panel argued that the involvement in CTI’s ‘committee’ would be very time consuming, as members fulfil the equivalent of one fourth to one half of a full time position and that in practice this would not lead to a significant increase in students participation. The panel concluded therefore that, given the reactions of all stakeholders, including the students, CTI was in (full) compliance with ESG 3.1. Given that CTI in practice ensures the regular consultation of students, considering that students did not request to be represented in the CTI’s Commission and due to their limited capacity to meet the expected workload, the Register Committee was therefore able to concur with the panel’s conclusion that CTI complies with the standard. The Committee further concurs with the panel’s remarks that students (and international experts) can add value to the governance of CTI, even though their expected overall workload for CTI could be more limited. The Register Committee also underlined the recommendation of the panel to recognise the official status of students in CTI’s governance. The Committee added, that in order to allow for the possibility of students’ involvement in the governance of CTI, a change in the legislative restrictions should be considered.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clear distinction between activities within and outside of the scope of the ESG
Panel conclusion	Full compliance
Clarification request(s)	Panel (21/10/2019)
RC decision	Compliance

“When A3ES applied for renewal, the Register Committee stated in its Eligibility Confirmation that the external review report should address how the agency clearly separates activities outside the scope of the ESG from activities within the scope of the ESG. As the report did not address the issueof clear separation of these activities, the Register Committee sought clarification from the panel. The panel clarified that A3ES' consultancy activities are not provided to universities or colleges, but solely focused on advising the national authorities or organisations on the design of national quality assurance policies, criteria and processes. Having considered the panel’s clarification, the Register Committee concurred with the panel that these activities are clearly separated from activities within the scope of the ESG by their very nature, and do not bear the potential for unclarity or conflict of interest that services rendered to higher education institutions do. The Committee therefore concurred with the panel's conclusion that A3ES complies with the standard”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of activities within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (20/02/2020)
RC decision	Compliance

“The Register Committee found the presentation of the accreditation of post-graduate programmes in medicine and healthcare inconsistent with the presentation of the activity on ANVUR’s website, where the activity was described together with ANVUR’s accreditation of PhDs programmes, as an accreditation activity under the responsibility of ANVUR. The Committee therefore underlined the panel’s remarks (letter of 22/10/2019) that in order to avoid misunderstandings, ANVUR should make a clearer description of its different activities on its website. In its additional representation ANVUR presented the clear distinction of its activities, which was published on its website. ANVUR created separate pages which clarifies transparently the activities within and outside the scope of the ESG. As the issue of a clear separation of external QA activities within and outside the scope of the ESG was addressed, the Register Committee was able to conclude that ANVUR now complies with the ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clasification of Titulos propios
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (20/05/2019)
RC decision	Partial compliance

“The Register Committee sought and received clarification regarding the evaluation of “títulos propios”. Unibasq clarified that these activities were not listed in its application for renewal of registration because Unibasq “realized that it was more a consultancy activity as Unibasq just provides an external expert report” and thus did not consider them as activities within the scope of ESG.In support of its classification, Unibasq stated that it acted only as a subcontractor to the UPV/EHU and had no own responsibility for the review process or the outcomes. The Register Committee also noted that Unibasq does not provide “accreditation” of ‘títulos propios”, contrary to what was published by UPV/EHU. Unibasq, however, stated on its website that it “will evaluate and certificate” those degrees.Unibasq further noted that the misunderstandings were caused by a discrepancy between the internal regulations of the UPV/EHU and the public information on their website, stating that some programmes are accredited by Unibasq.Having considered Unibasq's response, the Register Committee accepted that the evaluation of “títulos propios” may be classified as consultancy service performed by Unibasq to UPV/EHU. The Register Committee further considered how Unibasq ensured a clear distinction from its external quality assurance activities within the scope of the ESG (see EQAR Policy on the Use and Interpretation of the ESG, standard 3.1 and Annex 5). The Committee noted that such a clear distinction was particularly crucial in this case, given that the terminology and the characteristic of the activity caused an actual risk of confusion with ESG activities.The Register Committee concluded that the presentation on Unibasq's website was misleading and did not ensure clarity as to the different nature of these evaluations; it thus considered that Unibasq did not comply with the standard.In its additional representation, Unibasq stated that it held specific meetings with the UPV/EHU, sent a formal letter regarding this issue and elaborated a new agreement with the UPV/EHU, which was approved by Unibasq’s Governing Council. As stated in the agreement, the evaluations of “Títulos propios” are consultancy activities which cannot be represented as ”Accredited, validated or reviewed by Unibasq”. In addition, Unibasq removed from its website the information that could have been misleading about “títulos propios” previously. The Committee, however, noted that UPV/EHU continues to refer to an “external report” by Unibasq in its advertisement of “títulos propios”.The Register Committee welcomed Unibasq's steps that were taken to clarifythe status of this activity and to avoid further misinterpretations. At the sametime, the Register Committee considered that it cannot be fully determined at this stage whether the new communication is fully clear to all stakeholders and avoids any misrepresentation; this should thus be analysedin the next external review of Unibasq.The Register Committee remained unable to concur with the panel's conclusion of compliance but concluded that Unibasq now complies partially with standard 3.1”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ECA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of external QA and consultancy activities
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (19/11/2018)
RC decision	Partial compliance

“33. The panel considered that it was “clear from EQ-Arts procedures and documentation, and confirmed during the site-visit – and, importantly, ‘ethos’ - [...] that those involved in any consultation activities cannot be involved in any assessment/ reviews nor in the making of any accreditation decisions nor involved in any related appeals procedures” (letter by the panel).

34. In its additional representation, EQ-Arts elaborated on the nature of its enhancement-oriented reviews and formal assessments, respectively. The Register Committee, however, underlined that the question related to the clear separation between consultancy activities, i.e. activities outside the scope of the ESG, and either of the two types of reviews (enhancement- oriented and formal assessment) offered by EQ-Arts. While it might be regarded more crucial for formal assessments, the Register Committee underlined that safeguards should be in place to avoid conflicts of interest in both types of reviews.

35. Having considered the panel's clarification and EQ-Arts' additional representation, the Committee remained unable to identify a specific provision in EQ-Arts’ suite of documents that rules out the possibility of reviewing an institution or programme that was previously consulted by EQ- Arts.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/03/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clear separation of reviews and consultancy carried out for higher education institutions.
Panel conclusion	Full compliance
Clarification request(s)	Agency (31/01/2019) Panel (05/11/2018)
RC decision	Partial compliance

“The Register Committee sought clarification from the panel regarding the separation of reviews and consultancy to higher education institutions, including both services rendered by QAA itself (internationally) or through its subsidiary QAAE (domestically). The Committee took note of the various measures and policies the panel referred to. The Committee also noted the clarification that “no evidence was found which would bring any doubt about the proper separation between [of] consulting units and undertaking reviews”. The Register Committee considered QAA's activities in Albania, which QAA described as a capacity-building activity that involved the support of the Albanian Ministry of Education Sport and the Albanian national QA agency (initially PAAHE, later APAAL, now ASCAL) in (1) developing review materials, (2) training reviewers and (3) conducting the reviews of all Albanian higher education institutions. […] The Register Committee thus considered how QAA ensured a clear distinction of such work from its external quality assurance activities (see EQAR Policy on the Use and Interpretation of the ESG, standard 3.1 and Annex 5). In doing so, the Committee considered that also an uninformed reader needs to be able to distinguish the reviews in Albania from review reports (co-)owned by QAA, and thus not falling within the scope of QAA's registration on EQAR and not officially certified as in line with the ESG. While the final paragraph of the section “About this review” indeed states that QAA “provided expert support” in producing the report, the initial paragraph states that “Institutional Review is a peer-review process with each review team composed of a mix of UK reviewers appointed by QAA and Albanian reviewers appointed by the Albanian Public Accreditation Agency for Higher Education (APAAL)”. Considering the entire text, the Register Committee remained in doubt whether readers (at least lay readers) are able to clearly recognise the substantially different roles of QAA and ASCAL in the process, with QAA being “just” a consultant and ASCAL having full and sole ownership of and responsibility for the report.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategic plan, stakeholder involvement in the governance of the agency
Panel conclusion	Partial compliance
Clarification request(s)	Panel (26/02/2021)
RC decision	Compliance

“With regards to the agency’s vision mission and strategy, the panel stated that ARACIS “does not have a strategic plan that spans several years and does not appear to set targets for itself against which its Council and others can measure the Agency’s performance” (Review report p. 17).

Considering the involvement of stakeholders, the Register Committee noted that this is limited to representatives of students and employers sitting in ARACIS Council and Permanent Speciality Commissions. In the view of the panel, ARACIS tended to define the term ‘stakeholder’ narrowly, confining it to students, employers and trades union representatives and the panel was not confident that ARACIS understands the need to involve stakeholders more fully in the work of the Council and the work of ARACIS.

In its additional representation, ARACIS noted that it has followed up on the recommendations of the panel and it has developed a Strategic plan for the period 2018-2021 and the operational plans for 2018 and 2019, which were approved by the ARACIS Council. The Register Committee could verify the published plans.

The agency further provided a detailed overview on how representatives of stakeholders i.e. academics, representatives of students, representatives of employers and employers’ federation, representative of trade-unions, including one representative of ESU and ENQA.- participate in the council and different commissions of ARACIS.

ARACIS further explained that it has recently approved the inclusion of representatives of employers in the permanent Speciality Commissions, with priority the Commission of Engineering Sciences that awards the EUR-ACE label, and that the selection process for new members will be soon initiated.

The agency added that it has put forward a project application for “Stakeholder Engagement in QA” under a call of the Erasmus+ programme. The project aims to promote the diversification of stakeholders' involvement in quality assurance activities across EHEA and to provide the means for making the involvement of stakeholders effective.

The Register Committee welcomed the agency’s newly adopted strategic and operational work plans and was satisfied with the level of stakeholder involvement in the work and governance of the agency.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Publication of the mission or goals of the agency, stakeholder involvement in the governance of the agency (incl students) and separation of consulting and assessment activities
Panel conclusion	Partial compliance
Clarification request(s)	Panel (17/05/2019)
RC decision	Partial compliance

“n its additional representation the agency explained that it would be unwise from a commercial point of view, as a private organisation, to publish its strategic goals. The agency stated that it has chosen a more dynamic course, so that NQA is able to adopt swiftly if/when radical changes such as the introduction of institutional accreditations in the system occur. While the Register Committee understood that publishing explicit strategic goals might not be the most favourable option for NQA, that the agency could nevertheless publicly communicate (in broader terms) its mission statement along with its goals and objectives. The agency added that its yearly management review includes strategies based on its mission statement and goals. In its additional representation NQA stated that the agency meets with a diverse group of university employees (e.g. CEO’s, quality assurance officers, management of degree programmes and teachers), the NVAO, the Inspectorate and other quality assurance agencies. NQA emphasised that the results of such meetings are translated into the work of the agency, i.e. in its strategic goals, management and review processes. The Register Committee welcomed such consultations, but underscored the ESG understanding of stakeholders, which cover all actors within an institution and therefore also students. The Committee thus underlined the panel’s recommendation to ensure stakeholder involvement by establishing regular interactions with all relevant groups of interest. Concerning the separation between NQA’s external QA activities the panel reported that one of the measures adopted by NQA was to ensure that staff members involved in assessment activities do not provide consultancy to the same institution. In most of the examples provided to the panel, the consultancy projects were completed by the Director. This was regarded by the panel as a potential problem in ensuring a clear distinction between NQA’s consultancy and external quality assurance activities. From the review panel’s analysis the Committee noted that “NQA attempts to separate as much as possible quality assurance activities from consultancy services” and that “throughout the interviews, there was no feeling of a lack of independence”. The Committee further noted that while the panel concluded the agency is “substantially compliant” re. independence, the panel found it necessary to recommend the establishment of stricter internal procedures in order to further separate consulting and assessment activities. In particular, the panel suggested to avoid performing consultancy activities to institutions NQA reviews, at least during a certain time span. This would be in line with Annex 5 of the Use and Interpretation of the ESG.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	11/09/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	separation of consultancy and EQA activities, addressing international activities as activities within the scope of the ESG
Panel conclusion	Full compliance
Clarification request(s)	Agency (31/07/2018) Panel (09/06/2018)
RC decision	Partial compliance

“The panel noted that in its understanding all international activities of ANECA were advisory in nature whereby ANECA acted essentially as a consultant/project partner and did not carry out external quality assurance activities (evaluation, accreditation, audits) abroad. The panel did not provide any further information on how the agency ensures a clear distinction between external quality assurance and its other fields of work. The agency provided a detailed report on its international activities, explained and that they follow similar procedures to that of the AUDIT and ACCREDITA evaluations carried out in Spain and confirmed they are within the scope of the ESG. Tthe Register Committee could now verify the publication of criteria for evaluation and the publication of all (summary) reports of the international activities. The Committee acknowledged the steps taken by ANECA to clarify the nature of its international activities, but noted that these activities were not considered by an external review panel (in particular in considering compliance with ESG Part 2). The Register Committee further noted that it could not analyse with full certainty how the agency separates its external QA activities within the scope of the ESG from the consultancy projects it carries out.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of external QA and consultancy activities
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that SKVC provides consulting to both the government and higher education institutions. While the panel found that SKVC’s methodologies and guidelines clearly delineate its tasks and responsibilities, the panel stated that SKVC could benefit from reducing its guidance role in producing self-evaluation reports and in offering detailed and demanding rules and regulations for higher education. the Committee underlined that SKVC is expected to demonstrate a clear separation between its external quality assurance and its consulting and guidance role, in particular considering the agency’s assistance in producing self-evaluation reports. The Committee drew SKVC's attention to the guiding principles set out in Annex 5 to the Policy on the Use and Interpretation of the ESG.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	distinction between accreditation and consultation not fully publicly documented
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“When confirming eligibility of the application, the Register Committee requested AQAS to clarify the relation between AQAS e.V. and AQAS ARCH, as well as the separation of external quality assurance procedures from consultancy services. The Register Committee took note of the clarification that AQAS ARCH did not engage in any activities within the scope of the ESG, but was engaging only in consultancy and project work, and welcomed the clarity provided. The Register Committee further welcomed AQAS' clear statement that it agreed “that the work of an accreditation agency in a particular procedure, be it programme or institutional accreditation, is incompatible with a preceding (or current) consultancy at the same university” and that “this incompatibility naturally includes organisations which are connected operationally with the agency” (statement on the review report); consequently, “AQAS e.V. cannot accredit the same organisation that received consultancy services through AQAS ARCH GmbH” (idem). The review panel, however, noted that these principles do not seem to be clearly documented in a published official policy document of AQAS and thus recommended that “AQAS should, in form of the formal resolution, define the distinction between accreditation and consultation, between ESG and non-ESG activities and between AQAS and AQAS ARCH” (review report, p. 12).

The Register Committee concluded that AQAS was able to explain that it appropriately separates its different areas of activity, while the details and consequences of this separation are not yet fully publicly documented.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of QA and consultancy activities
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that AQU carried out one training activity in

2011. The review panel found that such activities should be considered as consultancy /support activities and that they should be differentiated more cautiously from the quality assurance activities which are provided by AQU Catalunya. (Review report, pg. 18).The Register Committee concurred with the panel that such consultancy activities should be clearly separated from external QA activities, in particular when those activities are carried out for the same higher education institution. The Committee drew AQU's attention to the guiding principles set out in Annex 5 to the Policy on the Use and Interpretation of the ESG and underlined that AQU is expected to make a substantive change report should it resume the same or similar consultancy-type activities offered to higher education institution.”

Full decision: see agency register entry