Database of Precedents

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	3.3 Independence
Keywords	Organisational (of the accreditation committee and executive board from the founding organisation) and operational independence
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (20/04/2025)
RC decision	Non-compliance

“The panel’s findings show that, under canon law, AKAST is subject to the vigilance of the German Bishops’ Conference. The Bishops' Conference influence extends to giving consent for the admission of members of the association, the consent for the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and 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. AKAST is also financed by an annual grant from the Association of German Dioceses (VDD), the legal entity for the German Bishops’ Conference. The panel explained that the German Bishop Conference member serves within the Accreditation Committee “in more moderatorial and advisory capacity” (review report p. 19) and that the elected Accreditation Committee members, permanent guests and experts involved in reviews are all requested to sign a declaration of no-conflict-of interest. The agency also added that the involvement of the German Bishops’ Conference in the decision-making process “helps ensure that there is no conflict between accreditation decisions and the subsequent ecclesiastical approval required under canon law” (self evaluation report p. 15). While the Register Committee considered it usual and acceptable for the Bishops' Conference, as the main founder and hence key stakeholder of the agency, to be involved, the Register Committee underlined that the requirement of independence should be understood to the effect that the new organisation, once it has been founded, should be able to function independently as required by the standard. 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), in contrast with the understanding of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. The Register Committee added that the accreditation decision by AKAST and the ecclesiastical approval required under cannon law are the purview of two different entities, and could be therefore considered independently from each other. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.3 Implementing processes
Keywords	new accreditation programm, follow-up process not yet defined.
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (09/10/2020)
RC decision	Compliance

“Compliance Compliance While the Register Committee noted – from the agency’s statement to the review report – that THEQC had introduced the new maturity levels for internal QA systems, the Committee was unclear whether any changes were made to the agency’s follow-up processes and has therefore sought further clarification from the agency.The agency explained in its clarification letter that an Institutional Follow-up Program (IFuP) was initiated at the beginning of 2020 and it is carried out for all institutions that have passed through an initial institutional external evaluation. The follow-up team performs a preliminary check of the institutional self-evaluation reports, performance indicators and other additional documents followed by a one-day online site-visit, which results in an Institutional Follow-up Report (IFuR) published by THEQC.

The Committee further noted that THEQC has only just initiated the Institutional Accreditation Programme (IAP); the follow-up process for this procedure has not yet been defined. new accreditation programm, follow-up process not yet defined.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.4 Peer-review experts
Keywords	student involvement
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (09/10/2020) Panel (25/10/2020)
RC decision	Compliance

“ the Register Committee noted that students were not always listed among the peer-review experts. The Register Committee has therefore asked the panel whether it was aware of such exceptions and whether it was given any explanation.

The panel explained that the involvement of students was piloted only in 2018 and that it became part of THEQC’s procedure in the academic year 2019-20 (following the set-up of the agency’s Student Commission in October 2019). The panel was assured by those that it spoke to, including the student representatives, that it was now THEQC’s policy to include students on all review panels.

The Register Committee welcomed the panel’s explanation, but noted that students were not listed among the peer-review team members in a number of evaluations carried out in 2019 (e.g. Alanya University, Atashehir University, Şırnak University, Hakari University, Ataşehir Adıgüzel Meslek Yüksek Okulu, Muş Alparslan).”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.6 Reporting
Keywords	delay in the publication of reports, inconsistency in the content of reports
Panel conclusion	Partial compliance
Clarification request(s)	Agency (09/10/2020)
RC decision	Partial compliance

“THEQC stated that it had completed only one Institutional Accreditation Program (IAP) by the end of 2020 and that the agency would begin to publish IAP reports by February

2021. As of March 2021, the Register Committee could not verify the publication of any Institutional Accreditation Program report, in particular not the report from the procedure finalised in

2020. Considering the consistency of institutional external evaluation reports (ISER and IFR) the panel formed the view that this was not systematically ensured. While the agency has taken in the recommendation of the panel to include the maturity level grades as part of these reports (see also under ESG 2.5), the Committee underlined the panel’s recommendation on the need to also introduce mechanisms to ensure consistency not only for the structure of the reports but also of the depth the reports provide. In its additional representation the agency stated that an analysis was performed on its rubric assessment approach, but that the analysis was not finalised in time for its site-visit. THEQC added that a consistency and usefulness analysis was also carried out with different stakeholders on its rubric reporting approach. The Committee welcomed the analyses carried out by the agency, but considered that the panel’s concerns have not been addressed since the analyses did not address the content of the reports. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.7 Complaints and appeals
Keywords	Implementation of an appeals process and information about the appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ The Register Committee noted from the panel’s analysis that the agency’s appeals and complaints processes were not clearly defined. The panel stressed that as the agency moves towards an institutional accreditation process, it will need to reevaluate its current processes for both complaints and appeals.

The Committee further noted that the agency does not have a designated body to handle appeals, but that they are considered by the Council in consultation with the IEE Commission. In its additional representation, THEQC explained that it has developed and integrated the complaints process into its Feedback Management System. The Register Committee was able to verify that the new complaints process and form is easily accessible on THEQC’s website. With a view to appeals, the Register Committee welcomed the decision to establish a distinct Appeals Committee to handle appeals and took note of THEQC’s newly developed Directive of Complaints and Appeals. The Committee, however, noted that the Appeals Committee is not part of THEQC’s organisational chart and that no information is provided on the members of the Appeals Committee. The Register Committee asked the agency to elaborate on whether any other provisions have been added to its Complaints and Appeals regulation. The agency clarified in its response letter that the latest version of the Rules of Procedure of the Appeals Committee dated 19/05/2021was now in use and published on the agency’s website (only available in German) which include minor updates. The Register Committee noted that the additions to the updated procedure are in line with the expectation of the standard.”

Full decision: see agency register entry

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 ENQA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	Organisational and operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that THEQC’s operational independence is affected by the key role played by experts and consultants, who serve as the agency's professional staff but remain employed and on the payroll of higher education institutions. The analysis of the panel showed that the current organisational structure of the agency affects the independence of its operations and formal outcomes since there is a potential for conflicts of interest to arise regarding the different roles played by the Councils’ members. The agency responded in its statement to the review report that THEQC had increased the number of permanent employees (4 new full-time employees started working for the Council in 2020). The agency also stated that its organisation structure was defined by law, but it had nevertheless conveyed the recommendation related to THEQC’s organizational structure to the relevant authorities. In its additional representation the agency added that as of January 2021, the number of THEQC employees had further increased and that the duties and responsibilities of the Council members had been reframed. While the Register Committee noticed the increase in the number of permanent staff, the Committee considered that the agency is still relying to a large extent (14 of 35 staff members) on experts and consultants that are at the same time on the payroll of higher education institutions. This could constitute a conflict of interest for obvious reasons. The Committee thus concluded that the panel’s concerns related to THEQC's operational independence have not been fully addressed”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.5 Resources
Keywords	Human resources
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“According to the panel’s analysis the allocation of the budget has not been made considering the agency’s real financial needs and its Strategic Plan for 2019-2023. The panel further expressed concern regarding the sustainability of agency’s processes as they do not rely on permanent professional staff, but almost entirely on the ‘voluntary’ nature of the work of evaluators and staff seconded to the agency. In its statement to the review report THEQC responded that it had made its budget plan within the scope of Strategic Planning in Public Institutions, following the Law on Public Finance Management and Control (No. 5018). The agency added that the strategic plan also includes a budget, which can be provided at request. In its additional representation the agency explained that the number of its permanent employees increased from 10 to 21 in over a year an a half. While the agency still has 14 staff members seconded and paid by higher education institution, the Committee concluded that human resources are nevertheless sufficient to allow THEQC to carry out its activities within the scope and in line with the ESG. Considering the additional representation and the changes to THEQC’s staffing the Register Committee concluded that THEQC now complies with ESG 3.5.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Effectiveness of the internal QA system
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted THEQC’s recent development of an internal quality assurance system, in line with the results of the Plan-Do-Check-Act methodology and the 2019-2023 Strategic Plan. While the panel commended the use of platforms and on-line tools for the implementation of the internal quality assurance system and the dissemination of relevant information, the panel found a number of issues that remained to be addressed in order for the quality assurance system to foster continuous improvement: existing confusion amongst experts, consultants and staff regarding their responsibilities in internal quality assurance matters, the lack of any corrective measure if an evaluation team were to fail to complete its task with the production of a satisfactory report. THEQC explained in its additional representation that it had prepared a chart clarifying the roles of staff, council and commission representatives (see Annex 9). THEQC further added that higher education institutions have a chance to comment on factual issues before reports are finalised, which then have to be addressed by the review panel. The Register Committee welcomed the clarification provided but underlined that the effectiveness of THEQC’s internal quality assurance system to foster continuous improvement in its processes is still to be reviewed in practice as the current improvements are not a result of the agency’ internal QA system but a result of an external feedback. The Register Committee further considered that the internal QA system should be designed so as to further support the successful implementation of the agency’s activities in particular considering THEQ’s newly launched Institutional Accreditation Programme (IAP).”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.3 Implementing processes
Keywords	Lack of on site visits; Lack of interviews with stakeholders
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (15/03/2021)
RC decision	Partial compliance

“absence of any standard framework or guidance as to the use of site visits or interviews in thematic evaluations, makes it unclear whether the agency has sufficient approaches to validate the evidences provided by HEIsin this activity. In addition, the panel's report touched only briefly on the suitability of online interviews instead of regular site visits in the activities program evaluation and appraisal of applications for degree-awarding powers.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.7 Complaints and appeals
Keywords	No formal complaints procedure; Advisory role of appeals commitee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“UKÄ has no formal complaints procedure in place (p. 34), even though the panel was confident that any issues stakeholders have, related to the work of the agency, are taken up by UKÄ. The report further discussed the advisory role of the appeals committee and the panel was concerned that this approach, paired with the fact that the committee cannot make recommendations how to correct potential errors, could undermine the authority of the appeals committee.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	Organizational independence; Lack of formal mechanisms for tackling conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (15/03/2021)
RC decision	Partial compliance

“Concerns about the Government's control of all major appointments remain. In particular, the way in which the Director General is selected has not been made fully transparent and it remained unclear whether the involvement of stakeholders in appointing the Advisory Board is secured in official documents. Moreover, the potential conflict of interest that the Director General could come across in their daily operations does not seem to be fully addressed through formal means by the agency.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.5 Resources
Keywords	Human resources planning and work overload; Staff overturn
Panel conclusion	Full compliance
Clarification request(s)	Panel (15/03/2021)
RC decision	Compliance

“The review panel noted the continuously high workload and turnover of staff. It further elaborated that the staff and the management had different positions in regards to the reasons (p. 19). The review panel informed the Register Committee about several measures that the agency plans to introduce, including replacing site visits by online interviews and deploying a single expert panel to several institutions. The panel considered that these were welcome measures that enhance UKÄ's activities and their efficiency. The panel saw that some improvements have already taken place, resulting in decreased staff overturn.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	2.7 Complaints and appeals
Keywords	Scope of the appeals system, clarity, independent decision making body
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that MusiQuE’s appeals procedure only applies to the reviews that result in an accreditation decision, but does not cover the agency’s enhancement type of reviews. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the enhancement reports, these should equally be subject to appeal in line with the standard. During its site-visit the panel further learned that it is not always clear to stakeholders involved how a complaint will be approached and how exactly are responsibilities defined. The Register Committee noted that MusiQuE has an Appeals’ Committee, formed of one standing member and one individual appointed in response to each specific appeal. The panel remarked that the Board of MusiQuE is the decision-making body responsible for endorsing the judgement of the review team and also the body nominating the members of the Appeals’ Committee, which may raise a concern of potential conflict of interest. The Register Committee therefore underlined the panel’s recommendation of reviewing the procedure for appeals in order to guarantee a fair decision making and avoid such potential conflicts of interest. Considering the several above-mentioned issues the Register Committee could not follow the panel’s conclusion of (substantial) compliance but considered that MusiQuE complies only partially with ESG 2.7.”

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	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.3 Independence
Keywords	nomination and dismissal of the Board members of the organisation
Panel conclusion	Full compliance
Clarification request(s)	Panel (24/10/2020)
RC decision	Compliance

“The panel noted that since its last review the MusiQuE Board now makes the final decision on its own composition. Considering the changed arrangements, the Register Committee was unclear how the members of the MusiQuE Board could be dismissed and if so on what ground. The Committee has therefore sought further clarifications from the pane. In its response, the panel explained that the absence of an external body to appoint or dismiss Board members was something specific to the legal form of a Foundation in Belgium. The panel further referred to the agency’s statutes, which provide the possible reasons/circumstances for the ending of the mandate of one board membe. The Committee noted that the panel found the current organisational arrangement to be adequate in guaranteeing the independence of the Board and its members in the context of an international quality assurance agency.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.5 Resources
Keywords	financial sustainability (relience on its founding organisation)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last review the Register Committee noted that MusiQuE did not have sufficient firm agreements with higher education institutions to achieve financial self-sustainability and thus concluded on partially compliance. The Register Committee learned that since its last review, MusiQuE has managed to expand its activities, and to increase its annual income from its reviews and other activities substantially. MusiQuE's has also reduced its reliance on the Association Européenne des Conservatoire (AEC)’s financial support, who has been covering a high proportion of its staff costs. The Committee welcomed these positive developments and concurred with the panel's conclusion that MusiQuE complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	publication of critical friend reviews
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel reported that MusiQuE has recently introduced critical friend reviews as a modified version of MusiQuE’s quality enhancement reviews. The new addition includes annual visits by ‘critical friends’ to various departments and programmes which result in specific reports; these feed into the agency’s self-evaluation and final quality enhancement review report.

The Register Committee noted that the agency does not publish the specific reports resulting from the critical friend review, neither separately nor together with the final quality enhancement review report. The Committee has therefore asked the panel to clarify its stance on this practice considering the requirement of the standard 2.6.

In its clarification letter, the Panel explained that the critical friend review report was one element of the review process and one of the documents informing the quality enhancement review report. The panel did not find it necessary to publish the outcomes of critical friend reviews as maintaining the report in confidence gave the “critical friends” the liberty to be more straightforward and explicit.

The Register Committe, underlined that the agency is expected to publish full reports prepared by the experts. In the Committee's understanding, these need to cover the full evidence reviewed and the full analysis made. Hence, where several reports are produced within one procedure, such as the critical friend reports, all reports should be published.

The Register Committee added that it would be sufficient to publish the critical friend reports together with the final external review report, rather than separately.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.4 Peer-review experts
Keywords	Student involvement in panels
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that QANU has, since its last review, taken steps towards the inclusion of students in the assessment of research units/PhD programmes. QANU agreed with VSNU, KNAW and KWO (the organisations who developed the Standard Evaluation Protocol for these assessments) to include students on the experts panels in the form of a pilotscheme, starting in

2019. The Register Committee found that QANU has so far finalised one assessment of a research unit/PhD programme in 2019 (report published as of 15 March 2019), but that the expert panel for that review did not include a student.While the Register Committee recognised and welcomed the clear stepstaken by QANU so far, it considered that the involvement of students on research unit/PhD assessment panels is so far at the stage of a pilot and notyet implemented in practice. The Committee was therefore unable to concur with panel’s conclusion of (substantially) compliant but found that QANU stillcomplies only partially with ESG 2.4. The Register Committee further underlined the review panel’s recommendation to ensure that students become a constituent element of the research units/PhD programme assessments panels. The Committee further added that students involvement should not be limited to the assessment of specific aspects, but that they are to be fully involved along all expert panel members.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.7 Complaints and appeals
Keywords	Absence of the body responsible for handling complaints (established in renewal)
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that QANU has revised its complaints and appeals procedure and established an independent committee to consider its appeals.The panel noted that institutions can now submit an appeal against all external quality assurance activities of QANU and the decisions are taken by an Appeals Committee, instead of QANU’s director.The panel’s analysis further show that QANU offers the possibility to institutions to express their dissatisfaction about the conduct of the external quality assurance activity carried out by QANU or misbehaviour of people acting on behalf of the agency. The agency has also established different processes in the handling of complaints i.e. if a complaint refers to the behaviour of a staff member of QANU this is processed by the director; if a complaint is about the director of the agency, the complaint is processed by the chair of the Board etc.Having considered the changes put in place by QANU since its last external review, the Register Committee was able to follow the panel’s judgement that QANU now complies with ESG 2.7.”

Full decision: see agency register entry