Database of Precedents

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

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In the last review of the agency the Register Committee flagged for attention the publication of reports for evaluation of study programmes and monitoring reports of study programmes, which then were only communicated to the interested party.The review panel found that Unibasq published all reports, except for the ex-ante accreditation reports on programmes that have not been successful.In its additional representation Unibasq confirmed that it does not publish reports for the from ex-ante accreditation, arguing that it would be confusingfor readers to find information on a study programme that will never exist. Unibasq did not express any intention to change this practice in future.The Register Committee underlined that all reports should be published as required by the standard. The Committee underlined that even if a study programme will not be offered it can be of interest for the public to know which concepts were denied accreditation and why. In particular, such information is important if the same programme applies for accreditation by another agency, which needs to be able to find out that it was earlier denied accreditation by another agency.As the flag was largely, but not fully, addressed the Register Committee did not concur with the review panel’s conclusion of compliance, but concluded that Unibasq still complies only partially with ESG 2.6”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.7 Complaints and appeals
Keywords	unclear process for handling complaints
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In order to improve the appeals procedure, the former Ethics Committee became the Ethics and Guarantees Committee, which was composed of members who play an active role within the agency. The review panel noted that the composition of the Committee was limiting its independence. The Register Committee underlined the recommendation of the panel that the Ethics and Guarantees Committee be composed of members who are independent from the agency and the Basque higher education system. In its additional representation, Unibasq stated that the composition of the Committee had been changed. The new Ethics and Guarantees Code, which was approved by Unibasq’s Governing Council, established that the Committee is now composed of experts from outside the Basque University System, who moreover cannot be part of any other Unibasq body or committee. The Register Committee was able to see the new composition on Unibasq’s website. Furthermore, while the panel confirmed that Unibasq has developed a clear appeals processes, it referred to “a more general procedure for the reception and handling of complaints and suggestion”, but did not analyse that in detail. In its additional representation, Unibasq did not comment further on the complaints procedure. Given the unclear process for handling complaints, the Register Committee remained unable to concur with the review panel’s conclusion of compliance, but concluded that Unibasq complies only partially with ESG 2.7.”

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	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the previous review the panel found that Unibasq had yet to produce a system-wide analysis and there was a lack of sufficient resources which is why this standard was flagged.The panel recognised that Unibasq has made clear progress in this area in recent years. The reports that agency produces show a clear shift from the evaluation of the procedures to a genuine thematic analysis (see page 24 of the report).The Committee concluded that the flag has been addressed and concurred with the review panel’s conclusion that Unibasq complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.5 Resources
Keywords
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the last review of the agency the Register Committee expressed concern regarding Unibasq’s capacity to ensure adequate resources for the increasing number of its activities.In the meantime, the agency has received additional funds which have allowed the agency to play a very active role in the international quality assurance community. The panel commended the agency for the achievements and the active role.The Register Committee considered that the flag was addressed and therefore concurred with the panel’s conclusion that Unibasq complies with ESG 3.5.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.6 Reporting
Keywords	acessibility and user-friendliness of th website
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its initial application for inclusion the Register Committee flagged AQ Austria’s publication of external QA reviews, as at that time only a few reports have been published. In the 2019 external review of AQ Austria, the panel’s analysis show that the agency has since published in full all its accreditations and audits related to its activities in Austria and abroad. The panel further commented that AQ Austria’s website however needs to be further improved in terms of accessibility and user-friendliness and recommended that the agency develops a database of reports to make the results of its quality assurance activities more accessible to its stakeholders.While the Register Committee concluded that the agency has addressed its flag, the Committee further underlined the panel’s recommendation.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.3 Independence
Keywords	Independence of formal outcomes/link to the ministry
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous application, the Register Committee expressed concerns with regards to the possibility of the Austrian Ministry to dismiss a decision of accreditation by the agency and has therefore flagged AQ Austria’s independence of formal outcomes. In considering this matter the panel stated in its review report (2019) that the legal framework stipulates the independence of the Board of AQ Austria. While the responsible Minister can withheld the decision of the Board, this can be done only in case of unlawful acts and with “overarching political deliberations”. The Register Committee concluded that a change in accreditation of decisions can only happen in exceptional situations and therefore concluded that the flag has been satisfactorily addressed.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords	Producing effective thematic analysis reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“At the time of its previous review in 2014, the Register Committee noted that AQ Austria was working on its first thematic analysis report on the development of quality assurance in Austria, and has not yet produced documentation to evidence substantial compliance. In its 2019 review report the panel’s findings show that the agency has since produced a number of reports focused on the results of QA processes and related issues in higher education. While the Register Committee underlined the recommendations of the panel for a further development of the thematic analysis, the Register Committee concluded that the flag has been satisfactorily addressed.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Efectiveness of internal QA
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision of inclusion, the Register Committee noted that the internal quality assurance system have been recently put in place, and therefore has flagged this matter for the next external review of the agency. According to the 2019 external review report of AQ Austria, the agency has clearly defined processes for all its activities and consolidated its work as a result of its internal quality assurance processes.The Register Committee therefore concluded that the flag has been addressed.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ECA
Decision of	19/06/2019
Standard	2.4 Peer-review experts
Keywords	no student on a panel at a request of an individual HEI
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (19/11/2018)
RC decision	Partial compliance

“17. [...] students had not been involved in the panels for enhancement reviews previously.

18. [...] The panel’s clarification confirmed that student involvement on panel’s was not yet a fully established practice across all reviews, but that students will be part of all future procedures.

20. [...] The Committee, however, noted that the December 2018 review of the Royal Academy of Fine Arts (KASK) in Ghent did not include a student panel member; with a note in the report that “contrary to EQ-Arts’ policy and practice, it was the decision and request of School of Art KASK that a student panel member was not included in this review process”.

21. The Register Committee concluded that EQ-Arts was apparently ready to make such exceptions, which are in contradiction to ESG standards. The Committee underlined that such exceptions are incompatible with the spirit of a predefined quality assurance process that is implemented consistently.

22. As EQ-Arts does not stringently implement its policy as regards student panel members, the Register Committee remained unable to concur with the panel’s conclusion, but considered that EQ-Arts only partially complies with the standard.”

Full decision: see agency register entry