Database of Precedents

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.4 Peer-review experts
Keywords	Training of experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. The Register Committee understood that the panels involve students and other stakeholders on equal bases. Furthermore, the Committee learned that despite the regular (online) trainings offered by the agency, very few people have enrolled for this online trainings.

14. The Register Committee therefore followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should find ways into making training opportunities more attractive for the reviewers to attend.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.7 Complaints and appeals
Keywords	Definition of terms; Complaints; Appeals
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. The Register Committee noted that the Complaints and Appeals Policy is detailed, covering the potential causes for a complaint or an appeal and it is easily accessible on the agency’s website. However, the Committee noted the panel’s concerns on the need to clarify the terms ‘complaints’ and ‘appeals’.

16. The Committee, therefore, followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should clarify what is meant by the terms ‘complaints’ and ‘appeals’ in all its documents, including the name of the ‘Complaints Commission’.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Student involvement in governance
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. In its last decision for renewal of registration on EQAR (of 2019-11-05), evalag was found to be partially compliant with the standard as it had no clear overarching strategy, bringing together planning, budgeting and risk assessment. Furthermore, the main decision-making body, the Foundation Board, did not included a student member.

18. From the review report and the panel’s analysis the Register Committee noted that the main shortcomings identified in the previous decision were only minimally improved i.e., the statutory changes in order to involve student member in the Foundation Board, limits their involvement only in specific cases ( “If international standards in the field of study and teaching are dealt with, a student member may be called upon as a permanent or temporary, non-voting guest.”)

19. Furthermore, the Committee understood that evalag, at the time of the review, worked on a new overarching strategy bringing together planning, budgeting and risk assessment, however this strategy was to be approved only in July 2024.

20. Considering the minimal improvements made since the last decision, the Register Committee could not follow the panel’s judgement of compliance and found that evalag complies only partially with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.4 Thematic analysis
Keywords	Inactivity in thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“21. The Register Committee understood by the panel’s analysis that the agency, since the last review, produced two publication named “Thematic analysis 2018 to mid-2021” and “Thematic Analysis mid 2021 to mid 2023”. However, as noted by the panel “these significantly digressed from the previous approach and in the eyes of the panel could not be taken as reports that describe and analyse the general findings of evalag’s external quality assurance activities as established by the standard. These reports give merely an overview of the most important projects, publications and events in the period under study, more like an annual report.”

22. The Register Committee, could concur with the panel analysis and underlined the panel’s recommendation that the agency should resume the work on thematic analysis, which was abandoned after 2018, particularly in light of the severe changes in the ‘German system’.

23. The Register Committee therefore concurred with the panel that evalag complies only partially with the standard.

24. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	appeals procedure, appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. In the decision on the for inclusion of CYQAA on the register (of 2019-11- 05), the Register Committee raised concerns regarding the shortcomings of the appeal procedure regarding the independence of the processes and the lack of clearly defined and formal complaints procedure.

8. From the external review report, the Register Committee learned that the Complains Policy is well established and higher education institutions have already used the possibility to submit a complaint (18 until the time of the external review).

9. The Register Committee further learned that CYQAA has revised its Appeals Procedure and now sets Advisory Committee of Experts (ACE) - groups of experts that examine and give opinion on the grounds for appeals to CYQAA’s Council. Despite the updated policy, the Council still holds the powers to make the final decision whether there are grounds for an appeal and can dismiss or uphold the appeal.

10. Furthermore, the Committee noted that the current Appeal Procedure is not entirely clear as it may suggest that an ACE is appointed for each appeal that is allowed for consideration by the Council, whereas in practice it is set only when the Council proposes to reject an appeal and needs advice from external experts.

11. The Register Committee welcomed (changes made related to the complaints procedure) and found the earlier concerns related to the complaints procedure addressed. The Committee, however, found that CYQAA is yet to demonstrate an independent functioning of the Appeals Procedure, where the final decision is not with CYQAA’s Council. Having in mind the shortcomings related to the Appeals Procedure, the Register Committee concurred with the panel conclusion that CYQAA only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategic plan, stakeholder, stakeholders involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The Register Committee noted the concerns raised by the panel that CYQAA’s Strategic Plan (2020-2025) is rather generic, with no specific

activities and clear timeframes. Furthermore, the Committee noted that the panel did not see any evidence of public, annual corporate or activity plan than operationalise the Strategic Plan.

13. The Register Committee understood by the panels analysis, that the agency involves representatives from both public and private universities, students and regulated professions. However, as underlined by the panel, the involvement of private higher education institutions and many public and private colleges and their students is very limited and CYQAA should further widen their engagement in its governance and evaluation processes.

14. Considering the lack of comprehensive and rather generic Strategic Plan and the shortcomings in the involvement of stakeholders from all

higher education institutions, public and private colleges, the Register Committee concurred with the panel and found that CYQAA only partially

complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	operational independence, methodologies
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. In the decision for inclusion of CYQAA on EQAR (of 2019-11-05), the Committee raised concerns regarding the shortcomings related to the operational independence of CYQAA and the close interlinkage between the agency and the responsible ministry.

16. Despite some progress being made by consultation with key stakeholders on the appointment of Council members and the Minister, the Register Committee noted that the Council members are still appointed by the Council of Ministers, upon recommendation by the Minister responsible for higher education.

17. The Register Committee took note of the panel’s concerns regarding the operational independence of the agency, The Committee understood that CYQAA cannot hire its own staff and is fully relying on secondments from the central Government and the Ministry of Education, Sport and Youth.

18. The Register Committee further noted, as underlined by the panel, that despite being fully independent in defining its evaluation methodologies, CYQAA is still challenged by the limits set in the provisions of the national legislation regarding engaging stakeholders in the development of methodologies (see issue raised under ESG 2.2 in the external review report).

19. Following the panel’s analysis, the Register Committee expressed its concerns that the operational independence of CYQAA remains constrained by the close link and dependence on the Ministry of Education, Sport and Youth regarding the appointment of the Council members, hiring of staff and engaging stakeholders in the development of methodologies. Therefore, the Register Committee concurred with the panel conclusion, and found that CYQAA remains to be partially compliant with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.5 Criteria for outcomes
Keywords	Inconsistent use of tools for decision making; Consistency in the interpretation of the agency’s criteria
Panel conclusion	Partial compliance
Clarification request(s)	Panel (28/05/2024)
RC decision	Partial compliance

“The Register Committee learned that, out of 24 applications concluded between

2022 and 2024, the final conclusions on the standards differed from those

proposed by the panels in four cases – three of which occurred in

2024. This

trend resulted in either more or less favourable outcomes for the concerned

higher education institutions.The Committee could not understand, without a panel insight, whether

the increased discrepancy between the panels’ and the Authorisation

Council’s conclusions occurring after the site visit (2023-11-05) steams from

the (im)proper use of the tools for consistent application of agency’s criteria

or other external factors (see more in ESG 3.3)”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	High level of involvement of the Government of Georgia in the selection of candidates for several leadership and managerial positions in the agency
Panel conclusion	Partial compliance
Clarification request(s)	Panel (28/05/2024)
RC decision	Non-compliance

“The Register Committee found that the agency remains having weak

organisational independence as the government persists having strong involvement in the appointment of several NCEQE’s bodies. The Committee found that further panel insight should asses whether the Government’s significant involvement in the agency’s operations affects the notable staff overturn (i.e. the operational independence) and the final conclusions of the accreditation decisions (i.e. the independence of formal outcomes).”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision for renewal of registration on EQAR (of 2020-03-16), the Register Committee found that AHPGS only partially fulfilled the requirements of the standard, as the ESG Part 1 was not properly addressed in their external reviews outside Germany.

9. The Committee understood that in order to address these issues, AHPGS revised its handbooks for reviews abroad. Nevertheless, the Committee understood by the analysis of the panel, that the Handbook for Institutional Evaluations does not address standards 1.7, 1.8 and 1.9 sufficiently.

10. Furthermore, the Committee understood from the analysis of the panel, that programme accreditation reports were in line with ESG Part 1, except one which did not follow AHPGS’s own criteria in full.

11. In a statement of the report (of 2024-05-17), AHPGS explained that in order to address the shortcomings underlined by the panel, it revised its handbooks for programme and institutional accreditation outside Germany.

12. The Committee welcomed the changes made by AHPGS. The Committee was, however, unable to conclude whether the adopted changes are implemented in practice without further panel insight and therefore they remain to be reviewed within the next external review of the agency. The Register Committee, therefore, concurred with the panel’s conclusion and found that the agency remains partially compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.4 Peer-review experts
Keywords	Training of experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its previous decision of registration on EQAR (of 2020-03-16), the Register Committee found AHPGS to be partially compliant with the standard due to ambiguity in whether the agency ensured that all experts received training. Additionally, the criteria and process for recruiting reviewers were not clear.

14. From the report, the Register Committee learned that the training process has been improved, and ensures inclusivity and accessibility for all experts. Furthermore, as underlined by the panel, the format was made more adaptable and personalised.

15. Following the improvements made by the agency, the Committee was able to follow the panel’s conclusion that the agency now complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.4 Thematic analysis
Keywords	Thematic analysis
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“16. In its previous decision of registration on EQAR (of 2020-03-16), the Register Committee found the agency to be partially compliant with the standard, as the publications prepared by the agency did not analyse the outcomes of the review processes.

17. Based on the analysis of the review panel, the Register Committee understood that, since its last review in 2020, the agency published several thematic analyses. Conducting additional studies is also now part of the agency’s strategic documents.

18. The Register Committee was able to follow panel’s conclusion that AHPGS is now compliant with the standard. The Committee, further highlighted the panel’s recommendation that the agency should secure adequate dissemination of its thematic analysis, keeping in mind the various target audiences.

19. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“8. From the report, the Register Committee learned that in case of the activities leading to an accreditation of German higher education institutions, there is a (theoretical) possibility that an institution may not forward the report to the German Accreditation Council (GAC); hence the report may not be published.

9. The Register Committee concurred with panel’s conclusion and found the agency compliant with the standard. It, however, underlined panel’s recommendation that the agency could include a publishing clause in the contract with the higher education institution in case the report to the German Accreditation Council is not forwarded.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clarity in activities and services; Conflicts of interest
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. While the Register Committee was able to follow panel’s conclusion that AQ Austria is compliant with the standard, it highlighted the panel’s recommendation that the agency should enhance the clarity on its ESG aligned activities and consultancy services for the public and add explanation on avoiding conflicts of interest on their website.

11. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.6 Reporting
Keywords	Publication of reports with negative outcomes, publication of expert panel reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its previous decision for renewal of registration on EQAR (of 11-05- 2019), Unibasq was found to be partially compliant with the standard as it did not publish reports of its ex-ante accreditation resulting with a negative outcome. From the report, the Register Committee learned that the agency now publishes these reports too.

9. The Register Committee further learned that the preliminary and final review reports shared with the higher education institutions and the public do not include the expert panel reports; these reports are only available to the Unibasq’s Committees.

10. The Register Committee found that the agency addressed the concerns raised in its earlier decision regarding the publication of negative reports from its ex ante accreditation procedure. It, however, shared the panel’s concerns that the agency does not fully comply with this standard because of the lack of transparency regarding the expert panel reports.

11. The Register Committee therefore concurred with the panel’s conclusion and found that the agency remains partially compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	procedure for handling complaints
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard due to the unclear procedure for handling complaints. From the report, the Committee learned that Unibasq now has a well established complaints procedure noted in the agency’s regulations of the Ethics and Guarantees Committee and the Code of Ethics.

13. Following the changes made by the agency, the Committee was able to follow the panel’s conclusion that the agency complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between ESG aligned and consultancy activities
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“14. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard as it did not make a clear distinction between its ESG aligned and consultancy activities (i.e. the evaluation of “títulos propios”). At the time, the agency removed the information regarding the evaluation of “titulos proprios” from its website; the Committee, however, could not verify whether the new method of communication brought clarity for all stakeholders.

15. From the external review report, the Committee has learned that the agency “ has made...efforts to request from higher education institutions [involved in the consultancy activities] not to use misleading information on their websites and has succeeded as far as the panel could determine through an internet search”.

16. The Committee therefore followed the panel’s conclusion and found that the agency now complies with the standard. The Committee, however, shared the panel’s view that the agency could improve the distinction between these two group of activities by creating a separate section on its website where it showcases clear information to the public.

17. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	operational independence, decision-making
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision, the Register Committee noted the strong role the German Bishops’ Conference (DBK) plays in the governance of the agency.

9. Despite the changes made by the agency to further its operational independence, the Register Committee noted that DBK maintains a significant role in the organisational structure of AKAST.

10. The Committee underlined the possible influence that may be exerted by the DBK Episcopal Commissioner in the decision making of the Accreditation Committee. Although the Episcopal Commissioner is present in the Accreditation Committee (AC) of the agency in an advisory capacity, there is still the possibility of undue influence considering the fact that the Episcopal Commissioner still issues a separate consent impacting the programme.

11. Furthermore as noted by the panel, it also seems possible for the episcopal commissioner to express, even unintentionally, a preliminary opinion on particular study programmes, not necessarily based on the findings of the expert panel during the AC meeting.

12. The Committee noted the concentration of power in one place, i.e., the current Chairperson of the Executive Board of AKAST holds the position of Chair of the Accreditation Committee and Chair of the Advisory Board of AKAST. Furthermore, the DBK nominates the Chairperson of the Executive Board.

13. Considering the strong influence of one main stakeholder in the running of the agency, the Register Committee underlined the risk to the agency’s operational independence, as well as to its independent decision-making. The Register Committee therefore concurred with the panel’s view that AKAST complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.4 Thematic analysis
Keywords	publication, analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“14. In its last decision, the Register Committee welcomed AKAST plans for further development of its thematic analysis after an appropriate number of programme accreditation procedures have been carried out.

15. The Register Committee noted that while AKAST has taken some steps in preparing thematic analysis since its last review, i.e., initiating a process for evaluation of the peer review processes carried out by AKAST, since 2022 at the time of the review, no thematic analysis have been made available nor any kind of such analysis have been published.

16. Considering the limited progress made since the inclusion on the Register and the limited development of thematic analysis, the Register Committee concurred with the panel that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality assurance, mechanisms
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee, noted in the analysis by the panel the gaps and shortcomings in the implementation of the agency’s Internal Quality Assurance (IQA) Regulations.

18. Furthermore, the Committee underlined that the mechanisms for fostering continuous improvement within the agency are weak and unsustainable on the long-term, i.e., the heavy responsibility of AKAST administrator for all of the IQA processes, the lack of systematic approach in gathering feedback and lack of evidence and example of enhancement based IQA.

19. The Register Committee further noted the lack of commitment in timely addressing the issues previously noted under ESG 3.3 and ESG 3.4 which impacts the overall effectiveness of the agency’s internal quality assurance arrangements.

20. In light of these concerns, the Register Committee could not follow the panel’s judgement of compliance and found that AKAST complies only partially with ESG 3.6.”

Full decision: see agency register entry