Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.7 Complaints and appeals
Keywords	brief procedure for complaints and appeals
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“33. […] there was only a brief procedure for complaints and appeals, and that the process was not fully known by the universities concerned; the Appeals Committee was not yet appointed, neither another body that deals with complaints and appeals.

34. [...] a statutory change, introducing the legal basis of the Appeals Committee, had entered into force and that the Appeals Committee had subsequently been appointed.

35. Having considered the additional information, the Register Committee concurred with the review panel's conclusion that AHPGS complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	3.4 Thematic analysis
Keywords	Lack of clarity about existing activities; lack of regular analyses as described by the standard
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Partial compliance

“36. [...] the publication of assessment reports, its yearly board meeting and the publication of books/journals by AHPGS staff – did not represent thematic analyses resulting from the review processes undertaken by AHPGS. […]

38. […] The statement by AHPGS did, however, not provide details as to whether and how these are clearly based on findings from AHPGS accreditation work.

39. In its additional representation, AHPGS reiterated the view that the various past publications would not have been possible without the experience from the agency’s review processes.

40. Moreover, AHPGS provided further details on its concept and work plan of publishing two thematic analyses per year. These were developed based on decisions by its governing bodies in

2019. 41. AHPGS also pointed out that it had already published its first two thematic analyses after the external review.

42. […] The Committee considered that through the combination of past publications and the two recently published thematic analyses AHPGS showed its capacity to implement that concept.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	formalisation of QA processes
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“44. The panel analysed that AHPGS has a system describing the internal QA processes, but given the agency's small size some processes were not formalised and relied on “informal procedures and tacit knowledge”.

45. The Register Committee noted the publication of AHPGS’ comprehensive internal quality assurance reports for the years 2009-2013 and 2013-2017 on its website.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.1 Consideration of internal quality assurance
Keywords	Part 1 reflected in the agency’s external QA
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In the previous decision of renewal of IEP’s registration, the Register Committee flagged for attention the extent to which the different elements of Part 1 of the ESG were reflected in the agency’s institutional evaluation reports. The Register Committee noted the review panel findings that show that IEP amended the guidelines for institutions as well as the guidelines for evaluation teams to directly reference 2015 ESG Part 1. The panel commended IEP’s efforts to analyse reports and to provide clear guidance on implementing the ESG standard 2.1. Having considered the mapping of ESG part I and the analysis of the panel, the Register Committee concluded that the flag was addressed.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.3 Implementing processes
Keywords	Consistent follow-up
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee acknowledged the steps taken by IEP to enhance the participation in follow-up processes, but noted that the current follow-up model does not ensure for a consistent follow-up for all evaluated higher education institutions. The Committee considered that a progress report, which is a relatively light requirement, could possibly be a feasible follow-up for all evaluated institutions. The Committee took note of the panel's concern that making the requirement more stringent would pose a risk of turning progress reports into a purely formal requirement, but considered that such a risk had not necessarily to become true. Moreover, the same argument could be used against any obligatory element in quality assurance, or obligatory quality assurance as such.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.7 Complaints and appeals
Keywords	Clarification whether the agency addressed complaints and appeals within the same procedure
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted the agency's argument that there was no requirement for an appeals procedure in its case “as IEP evaluations do not result in decisions”. Based on the analysis of the panel, the Register Committee, however, understood and concurs with the panel that IEP's ‘substantive’ complaints are, in fact, appeals in the ESG terminology: they enable the institution to “questions the formal outcomes of the process” (in this case, the evaluation report), where it can “demonstrate that the outcome is not based on sound evidence” (see guidelines to standard 2.7), which IEP’s complaints policy translates to erroneous judgments, erroneous assumption of non-existent factors as facts, failure in exploring relevant facts, and ignoring or misjudging factual base.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.2 Official status
Keywords	agency’s formal recognition
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that IEP itself does not have separate legal personality and therefore it is represented by EUA in all legal and contractual matters. The Committee acknowledged that the recognition of IEP as a quality assurance agency by public authorities is demonstrated by the numerous contracts that IEP (represented by EUA) signed with national authorities for conducting evaluations, or by the selection of IEP as an evaluating body through a public procurement procedure. [...] The Register Committee interprets the requirement of formal recognition in a broad sense and therefore concurred with the panel's conclusion that IEP complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.3 Independence
Keywords	Organisational independence: appointment of the director by the mother organisation, support in terms of pyscial infrastructure, including human and financial ressources
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“While IEP’s Steering Committee has full responsibility for the development of strategies and policies, the Register Committee noted that the Steering Committee ensure the strategic development of the IEP in the context of EUA’s development priorities. Moreover, EUA provides the overall support, including physical infrastructure and financial management through separate accounts; both entities have a shared staff and EUA appoints the Director of the IEP Secretariat. Despite the panel’s view that no benefits would come from legally separating the two entities, the Register Committee considered that IEP continues to be part of EUA and, as such, its organisational independence continues to be constrained by the close link and dependency in both legal and practical terms, even if less so than at the time of the previous review. The Committee concurred with the panel's analysis that IEP operates and undertakes its evaluations independently and that the Steering Committee has full responsibilities for the operations of IEP and its evaluation results. The Committee thus considered that the constrained organisational independence bears a residual risk of a perceived lack of independence, elements of which should be closely considered in IEP’s next renewal of inclusion.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	2.1 Consideration of internal quality assurance
Keywords	Alignment of PKA standards not sufficiently ensured against Part 1 of the ESG
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel noted that criteria for programme evaluation are in line with Part 1 of the ESG. However, the panel expressed concerns with the opinion giving process as the alignment with some standards of the ESG (i.e. 1.2, 1.4) was much weaker or some standards (i.e. ESG 1.7, 1.8 and 1.9) were not specifically represented within PKA’s methodology for this procedure. The agency explained in its statement to the review report that PKA has requested the Minister to extend the scope of information on the proposed regulation in the opinion giving process for study programme, and that the request was accepted in September

2018. PKA further detailed in its Substantive Change Report the new criteria adopted in December 2018 for granting permission to provide a degree programme. The Register Committee took note of the detailed criteria and confirmed that the new assessment framework addresses the standards from Part 1 ofthe ESG more comprehensively. In light of the enacted changes, the Register Committee concluded that PKA now complies with standard 2.1.”

Full decision: see agency register entry

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

“The panel’s findings show that in the opinion-giving process students are not involved as members of review panels. Opinions are prepared by members of relevant Sections or PKA experts, following which the Presidium prepares a resolution that is forwarded to the Minister and highereducation institutions. The panel noted that students are to a certain extent involved as members of the Presidium of PKA. In its statement to the review report PKA acknowledged its shortcomingregarding the student involvement in the opinion giving processes and decided to set up a team of student experts to issue opinions on applications.The Register Committee welcomed PKA’s intention but found that the composition of the relevant sections and experts panels is still unchanged. The Committee further underlined that students are normally expected to beinvolved as part of the peer-review expert groups and to contribute as equal partners. As the current arrangement of PKA could not yet be reviewed by an external panel the Committee was unable to conclude whether the way students are involved meets the requirements of the standard. Register Committee therefore concurred with the review panel’s view and concluded that PKA complies only partially with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	2.6 Reporting
Keywords	Publication of reports for opinion-giving process
Panel conclusion	Partial compliance
Clarification request(s)	Agency (21/05/2019)
RC decision	Partial compliance

“In the previous decision of renewal the Register Committee flagged for attention PKA’s publication of reports of its ex-ante evaluations. The panel’s findings show that while the reports for programme accreditation and resolutions are published the reports and resolutions of the opinion-giving process are however not published online.PKA explained in its statement to the review report that all reports have been published since October

2018. The Register Committee noted that according to the information published by PKA on its website some of the reports of its opinion-giving process are not published and has therefore asked the agency to clarify the delay and timeline of their expected publication.In its clarification letter, the agency explained that the publication of resolutions before 2018 are delayed due to the changes in the legal framework and due to the requirements of the European Unions’ General Data Protection Regulation adopted in

2018. This required changes in PKA’s internal reporting templates and procedures.PKA added that legal grounds for publishing opinion-giving resolutions and reviews was established with its Statute as approved in 2018, but explained that this regulation does not apply retroactively.Having considered the additional clarifications given by the agency, the Register Committee noted that PKA would, however, be able to publish already prepared reports from 2016 and

2017. As this issue was already flagged in PKA’s last application, the Register Committee therefore concurred with the review panel’s conclusion that PKA complies only partially with the standard, pending the publication of the remaining reports.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	clarification of external QA carried abroad
Panel conclusion	Full compliance
Clarification request(s)	Agency (21/05/2019)
RC decision	Compliance

“In its confirmation of eligibility, the Register Committee noted that PKA is expected to also address activities carried out by the agency abroad i.e. in Lithuania. As it was unclear on whether such activities were addressed in the external review of PKA, the Committee asked PKA for further clarifications. PKA explained that the external QA activities carried out in Lithuania only extended to one foreign branch of a Polish higher education institution and that the procedures and criteria used were identical with those applied in the case of national HE providers.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.5 Resources
Keywords	human resources
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its analysis, the review panel commented that, while the situation of resources is acceptable in the short to medium term, some of PKA’s activities “cannot be addressed appropriately due to the lack of resources”. The Panel further expressed concerns with regards to the high turnover of the Bureau staff, who perform the functions of secretaries for the sections Committee. The Register Committee further underlined the review panel’s recommendations on the need to increase the agency’s capacity to perform thematic analysis. The Register Committee was therefore unable to follow the panel’s conclusion of (substantially) compliant but concluded that PKA complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.1 Consideration of internal quality assurance
Keywords	Aspects of ESG 1.1 – 1.10 insuficiently covered.
Panel conclusion	Partial compliance
Clarification request(s)	Panel (20/02/2020)
RC decision	Partial compliance

“The panel noted that ANVUR fully integrates Part 1 of the ESG in AVA procedures, but that AFAM and PhD accreditation procedures cover only some aspects of ESG 1.1 – 1.10. In its additional representation ANVUR explained that AFAM and PhD accreditation procedures are limited in scope due to the existing Italian legal framework. ANVUR further added that it had already taken steps to integrate aspects of ESG 1.1 - 1.10 in these procedures by revising its own methodologies and guidelines for AFAM procedures and by testing its new preliminary evaluation protocol for PhD Programmes during two institutional visits. The Register Committee welcomed that ANVUR has intensified its dialogue with the relevant Ministry in order to review the appropriate regulations for its AFAM and PhD procedures, but considered that the changes have not yet been enacted and the agency has thus not yet fully addressed its compliance with ESG 2.1 in practice.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.4 Peer-review experts
Keywords	lack of student experts in some review panels
Panel conclusion	Partial compliance
Clarification request(s)	Panel (20/02/2020)
RC decision	Partial compliance

“In its additional representation ANVUR acknowledged the lack of student experts in review panels, and referred to the involvement of students in the internal consultation process on new study programmes. ANVUR added that starting from November 2019, the agency has included (PhD) students in the evaluation groups for PhD programmes at two institutions. The agency also presented its plans to involve students in the AFAM’s external reviews, starting with a pilot project during

2020. ANVUR further stated that starting in 2021 the fees will be aligned between the faculty panel members and student panel members. The Register Committee considered that if student experts have an equal role in panels there is no ground for paying them differently, and welcomed ANVUR's commitment to change its practice in that regard. The Register Committee underlined that the consultation of student representatives in the institutions' internal preparation processes for new study programmes cannot replace the requirement of the standard, i.e. that students are part of ANVUR's expert groups.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.6 Reporting
Keywords	Publication of sysntetic reports for its main EQA
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ANVUR only publishes synthetic reports, resulting from its AVA system reviews, while the experts’ full reports from its other external QA activities have not been made available to the general public. The Register Committee underlined that while higher education institutions may decide to publish the reports on their own website, that ANVUR is expected to publish itself the full reports by the experts and that it should make its reports and decisions clear and easily accessible to the academic community, external partners and other interested individuals. In its additional representation, ANVUR stated that the new AVA guidelines would address the issue of the publication of full reports and final decisions. As from the second round of the institutional accreditations in 2021, ANVUR would publish its full AVA reports; the same would apply to reports resulting from its other activities. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.7 Complaints and appeals
Keywords	Implementation of an appeals process and independent appeals body.
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (20/04/2025) Panel (20/02/2020)
RC decision	Partial compliance

“The panel noted in the review report that a clear and transparent formal complaints procedure within ANVUR was not yet fully developed. The panel also noted that there was no specific appeals committee, but that the Governing Board fulfilled both the role of the accreditation body and that of the re-examination body. The Register Committee further noted that the agency has no clear processes in handling complaints (EER, p. 51-52). In light of these concerns and the panel’s conclusion of compliance, the Register Committee sought further clarifications. The panel responded that the spirit of the standard was followed in practice, although the clarity and transparency of appeals processes could be further improved. In its response letter, ANVUR explained that its Governing Board had now approved the establishment of a separate Appeals’ Committee, which will include a member from ANVUR’s Governing Board, one member appointed by the Board of Rectors of Italian Universities and one member from the National Authority for anti-corruption, transparency and public procurement (ANAC).”

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	2.3 Implementing processes
Keywords	strengthening follow-up procedures for voluntary international reviews
Panel conclusion	Full compliance
Clarification request(s)	Agency (20/05/2019)
RC decision	Compliance

“The external review panel noted that for (voluntary) international accreditation procedures “the full responsibility to request any kind of follow-up lies in the hands of the institution”.The Register Committee considered the clarification by Unibasq that it follows up programmes' improvement plans in its international quality assurance activities, which is mentioned in the relevant protocol. Having considered Unibasq's clarification, the Register Committee was ableto concur with the panel's conclusion of compliance.The Register Committee, however, encouraged Unibasq to look into possibilities to strengthen its follow-up procedure for (voluntary) international reviews, and to clarify the expectation towards HEIs regarding the follow-up.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.4 Peer-review experts
Keywords	Involvement of students in review committees
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the previous review this standard was flagged due to the fact that the regular involvement of students on all review committees was yet to become practice.The Committee noted that steps have been taken in order to ensure regular involvement of students. Participation of students in evaluation procedures isguaranteed by the Basque Country Act 13/2012.The Register Committee therefore concluded that the flag has been addressed and concurred with the panel's conclusion that Unibasq (substantially) complies with the standard”

Full decision: see agency register entry