Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/06/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholder involvement in the governance and work of the agency
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While the panel noted that a broader stakeholder involvement would require a change of the law on higher education and might have further implications for the overall functioning of the agency, the Register Committee underlined that the unbalanced composition of NEAA's governing bodies was already flagged as a matter requiring attention when NEAA was first admitted to the Register in 2009”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.2 Designing methodologies fit for purpose
Keywords	fitness for purpose of doctoral schools EQA
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“Considering the fitness for purpose of external QA processes, the Register Committee noted the panel’s concerns with the effectiveness of the practice of evaluating doctoral schools every six months. In its additional representation HAC explained that the biannual checking of compliance with criteria for doctoral programmes has now been discontinued and that a new approach and criteria have been developed, which are expected to be finalised in autumn.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.4 Peer-review experts
Keywords	student involvement in ex-ante procedures
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that students are not involved in ex-ante accreditation of new institutions, the accreditation of doctoral schools and in the initial evaluation of programmes. The Register Committee agrees with the panel’s reasoning that the anonymity of experts in ex-ante evaluations precludes evaluators for becoming answerable for their decisions.[...] The agency also stated that the practice of maintaining the anonymity of experts will be changed following the Board’s decision (of February 2019). Regarding the involvement of students in the ex ante evaluations, the agency argued that students are involved in the decision-making process, as members of the expert committees where findings are discussed and that all eight expert committees now involve a student. In the view of the agency ex-ante evaluations call for an academic judgement as the focus is on academic content. The Register Committee welcomed HAC’s decision to lift the anonymity of experts (in case of ex-ante procedures) and acknowledged HAC’s intention to address the involvement of students in its follow-up report to the coordinator. The Committee nevertheless noted that such changes are yet to take place, and underlined that students should be appropriately involved in all peer expert groups, including the ex-ante evaluation stage as per the requirement of the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.7 Complaints and appeals
Keywords	Absence of a formal complaints procedure
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (20/11/2018)
RC decision	Partial compliance

“The Register Committee noted that the agency does not have a clear, structured and effective complaints process. In its self-evaluation report the agency acknowledged that complaints reach HAC by letter, mail or telephone enquiries, and are handled on a case by case basis. HAC also explained that in practice complaints (referring to the evaluation process) may be also considered as part of the appeals heard by the Board of Appeals, but they are mostly considered through the agency informal processes. The Register Committee considered HAC’s explanation that in case of a positive result of an evaluation complaints cannot be lodged, but underlined that any individual or organisation should nevertheless have the possibility to bring to the attention of HAC substantiated concerns about the evaluation process or conduct of review experts in line with a formal complaints policy.

In its additional representation the agency acknowledged that it has not introduced a separate process for complaints but that it is currently in the process of changing its regulation to implement a formal complaints procedure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.3 Independence
Keywords	Organisational independence: selection and dismissal of the agency’s board members
Panel conclusion	Full compliance
Clarification request(s)	Panel (20/11/2018)
RC decision	Partial compliance

“The Register Committee learned from HAC’s self-evaluation report and the review panel’s analysis that the President of HAC’s Board is chosen from among the Board members by the Minister in agreement with the Hungarian Academy of Sciences. The Committee also noted that nine of the 20 HAC Board members are nominated by the Ministry of Human Resources and that the Minister has the authority to recall members of the HAC Board. [...] The panel stated that it is not aware of a published set of criteria for the selection and appointment of Board members and that it was assured by the ministry that a priority is put on nominating experienced and senior academics to the Board. The panel further added that possible reasons for the dismissal of the members of the HAC Board might be for inappropriate, unprofessional or illegal behaviour, although a specific list of admissible reasons did not exist. The agency further argued that the legality of HAC’s activities is overseen by the minister (Art 71/a) and thus the only case where the government may interfere in the agency’s operations are in cases where the law is breached. Dismissal of Board members is, according to the agency, also based on legal grounds, as legislation requires that the Minister state its reasons for such an action. The agency also admits that while the legal framework may seem to leave open the challenge to its (organisational) independence this has not been the case in practice.[…] The Committee noted that the agency’s explanations did not change the fact that there is a lack of clear safeguards to prevent possible (even if unlikely based on experience to date) interference in the activity of the agency or in the dismissal of its Board members. The Register Committee underlined the importance of ensuring not just a balanced representation in the nominated delegates to the Board but also of formal mechanisms and regulations to safeguard its organisational independence.. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.4 Thematic analysis
Keywords	Use and regular publication of thematic analysis
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While evidence of thematic analysis can be found within the programme accreditation reports, annual reports and other publications of the staff on the "activities, trends and outlook" of the HAC (SAR 41), the panel found that HAC’s level of activity in thematic analysis is limited and insufficiently developed. In its additional representation the agency stated that a thematic overview and analysis on ESG compliance from its most recent institutional accreditation round was presented during a recent event and it will be published by HAC. Further thematic analysis are planned for

2019. The Committee acknowledged the agency’s recent activity, however as it stands the agency’s progress is modest. The Committee underlines the review panel’s recommendation of ensuring the regular publication of thematic work and making use of such analysis more widely.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Implementation of the processes for external feedback mechanism
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted from the review panel’s analysis that [...] internal and external feedback mechanisms are not entirely in place within the agency and the processes for examining data and collecting feedback are not systematic and formalised (Review Report p. 30). In its additional representation, HAC explained that internal quality assurance practices that are in place i.e. internal regulations for professional conduct and integrity, code of ethics, by-laws laying down the responsibilities for all activities of external members and staff, handbook for programme officers etc. The agency added that the surveys carried out with evaluated institutions were discussed in staff meetings and by the HAC Board and actions have been taken to improve procedures. The Register Committee further took note that HAC’s Quality Assurance and Development Committee has scheduled further activities to revise and develop surveys on accreditation procedures.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/03/2019
Standard	2.4 Peer-review experts
Keywords	infrequent involvement of students in some procedures
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/11/2018)
RC decision	Partial compliance

“The involvement of student reviewers in reviews for Degree-Awarding Powers (DAP) was flagged when QAA was admitted to the Register. The Committee noted that student reviewers now take part in these reviews […]. The panel's report, however, suggested that the standard was not fully met, as there were no student review panel members in some of QAA's review methods. The Register Committee sought clarification from the panel in that regard. The Committee noted that students are not on the review teams for General Osteopathic Council reviews (GosC); and it could not be established how frequently students are on the panels for Higher Education Review (Alternative Providers) or Transnational Education review (TNE).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/03/2019
Standard	2.6 Reporting
Keywords	publication of reports and publication of the experts involved
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The publication of review reports regarding Degree-Awarding Powers (DAP) was flagged for attention when QAA was admitted to the Register. The Register Committee welcomed that regulations were changed to the effect that such reports are now published [...] the Register Committee noted that the composition of the panels for TNE review is not mentioned in the published report. The Committee therefore drew attention to the guidelines to ESG 2.6, which suggest that the members of the review panel should be listed in the review report.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/03/2019
Standard	2.7 Complaints and appeals
Keywords	No possibility to appeal in cases where the review does not end in a judgment
Panel conclusion	Full compliance
Clarification request(s)	Panel (05/11/2018)
RC decision	Compliance

“The Committee noted that appeals are only possible in those review methods that result in a formal judgement on some type of scale, but not for methods that results in a report alone; the panel considered a complaints process sufficient in those cases. The Register Committee concurred with the panel's conclusion that QAA complies with the standard, considering that the current wording of the EQAR Policy on the Use and Interpretation of the ESG might be understood in that way. The Committee, however, underlined that also a report without a formal summarising judgement or decision contains (published) judgements about an institution. In the interest of full accountability these should thus in principle be open to appeal, too.”

Full decision: see agency register entry

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

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

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	2.2 Designing methodologies fit for purpose
Keywords	clarity and consistency of standards, decision-making procedure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee shared the view that NEAQA’s standards would benefit from a revision to ensure full clarity, consistency and readability, in particular in what concerns the employment of site-visits in programme accreditation procedures. The Register Committee concurred with the panel's analysis as regards the arrangement whereby NEAQA’s members combine their decision-making function with that of external experts and with the recommendation to separate these functions. In its additional representation the agency stated that the inherited regulations, procedures and standards of CAQA were revised considering the panel’s concerns and the new by-laws. According to NEAQA particular attention was devoted to ensuring the broader inclusion of external reviewers and the separation of review experts from other member and staff positions in the organisation.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	2.3 Implementing processes
Keywords	consistent implementation of a follow-up procedure & site visits
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel’s analysis showed that the agency has made improvements, having also introduced follow-up procedure for its audits. The Register Committee found that while the panel was satisfied with this improvement, the approach to follow-up should allow higher education institutions to also report progress in the implementation of recommendations before all external review procedures. The Register Committee further noted that site-visits are not consistently carried out by NEAQA for programme accreditation.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	2.4 Peer-review experts
Keywords	student involvement in some reviews and involvement limited to student matters; anonymous review team experts, site-visit undertaken by an agency sub-commission instead of the group of exprts which prepared the report
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel’s findings show that students (and employer representatives) take part in periodic programme accreditations only when they are combined with institutional ones. The panel also noted that the involvement of students is limited to student matters.The Committee further noted that at the time of the application by CAQA review team experts remained anonymous and that their involvement was limited to assessing compliance based on documentation. The site visits were undertaken by a CAQA sub-commission, which subsequently prepared the final report integrating the experts' feedback.The Register Committee considered that this arrangement did not meet the requirement of the standard and that assessments should be undertaken by a “group of external experts”. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	2.6 Reporting
Keywords	Publication of initial accreditation reports, involvement of experts in preparing the reports, no fact-check verification process
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that CAQA does not publish initial accreditation reports of higher education institutions and their programmes since another accreditation review in these cases is carried out after one year. While the panel considered this approach to some extent justifiable, the Register Committee underlined that, according to the standard, reports by the experts should be published in full. This applies to all types of reports, whether part of an initial or follow-up process. The review panel also found that the current reporting arrangements limit substantially the input coming from academic experts, students and labour market representative. The findings of the panel also showed that NEAQA’s reports are not sent to the institutions concerned for a factual check before the final version is published.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	2.7 Complaints and appeals
Keywords	Absence of a formal complaints procedure; no possibility to appeal with the body that carried out the procedure.
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that in the case of refusal of accreditation, the higher education institution concerned may lodge an appeal to the NCHE who is the responsible body for deciding on the appeals on the agency's decisions. The Register Committee further noted that NEAQA does not have in place any procedures for complaints. While the review panel found that representatives of the evaluated higher education were fully familiar with the appeals arrangements, the panel recommended that appeals should be nevertheless considered by a separate body within the structure of an agency. The panel further recommended the establishment of a complaints procedure.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Agency lacks explicit goals and objectives; limited stakeholder involvement i.e. consultations only where specific topics are addressed
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that while NEAQA’s strategy could provide a comprehensive framework for the agency's daily operations, the agency does not have in place mechanisms for effective forward planning and reviewing progress towards its objectives. Considering the involvement of stakeholders, the panel’s findings show that, since its last review, NEAQA has improved the engagement with employer representatives in its quality assurance activities. However, stakeholder involvement is still limited in agency's work given that neither students nor employers are involved in NEAQA’s governance.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	3.3 Independence
Keywords	Organisation and operational independence (lack of evidence due to change in legal framework)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee had flagged the independence of NEAQA’s predecessor and the relationship between the agency and NCHE, in particular with regard to NCHE's double role of appointing members and being involved in the development of procedures and criteria as well as serving as the appeals body. The panel had also noted that CAQA was expected to become fully independent in terms of organisational and financial arrangements when incorporated into the new QA body, NEAQA, pursuant to the changed Law on Higher Education (LoHE) (review report, p. 19).The Committee nevertheless considered that the new organisational and financial arrangements still have to be fully implemented, and would need to be verified by an external panel.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	3.5 Resources
Keywords	financial sustainability
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“[...]The panel, however, added that NEAQA’s predecessor lacked human resources for other tasks which would enhance the agency’s performance. Considering the financial management of the agency, i.e. a bank account managed by the Ministry, the panel found that the planning, management and operational efficiency of the agency were limited due to its dependence on the Ministry’s administrative and financial services. The agency stated in its additional representation that it now has its own accounts and, while it continues to receive financial support from the Republic of Serbia for its initial activities, the agency’s further actions will be financed exclusively from its own funds.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Implementation of processes for IQA
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that while CAQA/NEAQA has a number of mechanisms to ensure internal quality [...] that the agency lacks formal mechanisms to act upon the external and internal feedback on a regular basis and thus foster continuous improvement. In its additional representation NEAQA stated its plans to improve communication among all stakeholders in quality assurance processes; to introduce software to support its information management processes and ensure transparency in the work of the agency.”

Full decision: see agency register entry