Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Limited scope of the appeals system
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (of 18/11/2010) the Register Committee flagged for attention FIN(H)EEC’s appeals procedure. The Committee noted that considerations should be given to this matter even though FIN(H)EEC’s decisions do not have a formal consequence (in terms of an institution’s license or financing), its audits result in a formal result, i.e. the report. The panel stated that audit results are considered expert opinions and according to Finnish law, appeals can be filed against administrative decisions only. The Register Committee underlined that a system for complaints and appeals should be in place irrespective of the formal status, while the status of the appeal system may be different from the common system of appeals that might be applicable to public administration. The panel explained that FINEEC has nevertheless made it possible for higher education institutions under review to request an assessment of the results of an audit or a re-audit on the grounds that the audit has not been carried out in compliance with the audit manual. Higher education institutions cannot, however, appeal the actual conclusion of the audit or accreditation team nor the decisions of the decision-making committees, a situation the panel described as “less optimal”. The panel further established that until now there was only one request to review the result of an audit, but the case was not yet decided upon by the time of the site visit. While an appeals system is established and publicly described, due to the lack of actual practice the Register Committee was so far unable to conclude whether the current system, limited in scope, was sufficient to safeguard the interest of institutions under review. The Committee noted that practical experiences with the appeals system should be addressed in the next review of FINEEC.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Scope of the thematic analysis (evaluations)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the eligibility verification (see letter to FINEEC of 12/02/2016) the Register Committee considered FINEEC’s thematic evaluations to be activities within the scope of the ESG, as far as they concern individual institutions or programmes of higher education. The Register Committee noted from the panel’s analysis that thematic evaluations have been paused after the merger of FINHEEC, and that the agency intends, according to its National Plan for Education Evaluations to reintroduce these evaluations between 2016-2019. […] the panel stated that thematic evaluations were found to be outside the scope of the ESG. The panel noted that thematic evaluations did not evaluate individual higher education institutions (or parts of them) or programmes, nor did they address the effectiveness of internal quality assurance as defined in Part 1 of the ESG. The panel, however, added that – although these evaluations are outside the scope of the ESG – the procedures and practices applied by FINEEC largely comply with the ESG. While the Register Committee concurred with the panel in that thematic evaluations in general fall outside of the scope of the ESG. The Register Committee, however, noted that at least in one particular case, i.e. the thematic evaluation of education in the maritime sector (2015-2017), FINEEC (also) addressed the quality management of individual education units and that the results of the FINEEC evaluation will serve as a basis for the International Maritime Organization (IMO) to decide on the right of the educational establishments in the maritime field to issue certificates of competency. The Register Committee concluded that thematic evaluations are within the scope of the ESG only if they apply to the three cycles described in the QF-EHEA and include formal results, statements or judgements on individual higher education institutions. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.3 Independence
Keywords	organisational independence
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its analysis, the panel discussed that the processes for the appointment of the Director and members of the Evaluation Council may be seen as political and as a potential risk in terms of FINEEC’s organisational independence. The panel thus emphasised the need for transparent procedures with clear and predetermined criteria. The Register Committee sought clarification from the panel as to how it satisfied itself that there was no undue influence in the nomination process given the current absence of a formal procedure and criteria. In its response letter, the panel stated that the need for the procedure to be transparent was brought up to underline the need to guarantee the independence of the agency and not to indicate that there was not a formal procedure in place or that it was not transparent. The panel clarified that in case of the Director, the appointment follows the procedure for the recruitment of civil servants in Finland, while in case of appointing the members of the Evaluation Council, the members are chosen from the proposals made by different stakeholder groups (from the educational sector, teacher education, research, working life and students). The Register Committee was able to verify that the documentation related to both procedure is published.In the review report the panel stated that FINEEC might in the future merge with the National Board of Education and the Centre for International Mobility (CIMO). The panel noted that this merger might affect the independence of evaluation activities as the tasks of the Board of Education are closely related to the political work of the Ministry of Education and Culture.

The Register Committee underlined that FINEEC is expected to submit a Substantive Change Report should its organisational status change in the future.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	Lack of thematic analyeses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While a number of thematic analyses have been published since the last external review of the agency, the panel found that the analyses have been paused since the merger of FINHEEC into FINEEC. The panel also noted that FINEEC has not yet initiated thematic analyses of the accreditations of engineering degree programmes due to the small number of finished accreditations. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	Lack of consistent follow-up procedures
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (18/05/2011) the Register Committee flagged the introduction of site visits as well as follow-up procedures undertaken by HCERES. The panel noted that since its last review HCERES did not ensure a consistent follow-up in its EQA activities due to a prolonged process of succeeding evaluations (that included the introduction of site evaluations). The agency replaced the follow-up with a progress report that higher education institutions would prepare as part of their self-evaluation so as to facilitate and speed up the process. Moreover, the panel noted that evaluations of programmes are carried out without site visits.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.4 Peer-review experts
Keywords	Lack of involvement of students
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (18/05/2011) the Register Committee flagged the participation of international experts and students. The panel noted that usually two experts are involved in the evaluation of bachelor and master programmes, and that these panels do not include students. According to the review panel, HCERES found it very hard to recruit students due to their need for extra time to carry out evaluations alongside their studies. The Register Committee further noted that in the ‘evaluation of doctoral schools’ the agency included a recent doctoral graduate rather than an actual student or doctoral candidate (p. 13 external evaluation report). The panel further noted that the involvement of students in institutional evaluations is limited to panel discussions. In its statement to the review report (of 10/03/2017) the agency, however, commented that students have the same role and responsibilities as other members of the panel in institutional evaluations. The Register Committee concluded that the agency has not addressed the flag and does not meet the requirements of standard 2.4 to involve students in all its external quality assurance activities.While considering that the failure to meet the requirement of the standard concerns a large proportion of HCERES' activity, the Register Committee noted that due to the immanent transition from programme accreditation to the evaluation of study fields, the involvement of students is to be resolved in this new setting.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	lack of consistent application of criteria for institutional evaluations; lack of criteria for evaluation of study fields
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“With regard to institutional evaluations the panel noted that the application of criteria for outcomes leaves too much room for interpretation and therefore undermines the consistent application of criteria. Considering the agency’s transitioning to evaluation of study fields the review panel further highlighted the need for development of criteria for the outcomes of subject level evaluations.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Conflict of interest of the body responsible for handling complaint/appeals
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged in its decision of initial inclusion the procedure for complaints and appeals. While recognising the agency's efforts in developing regulations for appeals and complaints, the panel found that the current system does not clarify who is the responsible party (ministry or agency) in handling complaints and recommended a coordination with the responsible ministry. In its statement to the review report (of 20/03/2017) the agency stated that it cannot interfere in the decision-making process of the ministry and that coordinating a complaints procedure with the ministry would affect its independence and confuse its role. HCERES further explained that in case of a complaint that concerns evaluation reports, the case would be handled by the agency, and in case the issue concerns a contract or decision of the ministry, the case will be handled by the ministry. In its Substantive Change Report (of 23/02/2017) HCERES described further updates to its appeals system that was adopted in October 2016, i.e. after the review panel’s visit in June

2016. The agency reported that eight new members have been appointed to the Appeals’ Commission who would address complaints concerning all activities of HCERES. The Commission will consider issues regarding the implementation or findings of an evaluation, the selection of experts, the decision of the accreditation commission and the decisions to validate other bodies’ evaluation procedure. The Register Committee noted that the majority of members in the Appeals’ Committee are also members of HCERES’s other bodies responsible for parts of the evaluation procedure (i.e. Board, evaluation departments) and might thus have a conflict of interest in handling complaints.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.2 Designing methodologies fit for purpose
Keywords	overlaping and duplication of processess
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its decision to admit ASHE to the Register, the Register Committee had flagged the need to review ASHE's different processes with a view to avoiding duplication. The Register Committee noted that the review panel remained concerned about different ASHE processes addressing the same or very similar issues. Moreover, the panel appeared to be concerned that the new processes for re-accreditation of doctoral programmes and the possible future processes related to the Croatian Qualifications Framework (CROQF) might even lead to further duplication.The Register Committee therefore concluded that the flag was not addressed and remains a matter deserving the urgent attention of both ASHE and the Croatian Ministry of Science and Education, being responsible for the legal framework of the external quality assurance processes implemented by ASHE.

The Register Committee concluded that all processes deployed by ASHE in themselves are fit for purpose and were developed in line with the standard, while the overlap and duplication identified by the panel is primarily the result of the typology of external quality assurance processes prescribed by law, the Register Committee was nevertheless able to concur with the panel's conclusion that ASHE complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	lack of transparency in criteria; inconsistency in the application of critera; insufficient documentation for interpretation of criteria
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel identified that some policies that affect ASHE's decision-making are not fully transparent and known by the stakeholders concerned. The panel further referred to some inconsistency in the application of ASHE's criteria and an insufficiency of the reference documents that panels use to interpret the criteria.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Publication of reports of initial accreditation
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision to admit ASHE to the Register, the Register Committee had flagged the accessibility and readability of ASHE reports. The Committee noted that ASHE took several steps to enhance the accessibility and readability of its report during the past five years, including the publication of summary reports. The Register Committee therefore concluded that the flag has been addressed. The review panel noted that reports of initial accreditation procedures are not published. The review panel considered that these reports “serve as a base for the ministerial decision to admit the HEI or programme to be established and that therefore these reports do not carry information directly addressed to the general public” (report p. 40) and that in case of a negative decision “the HEI or programme concerned will not be launched and so there is no tangible public interest in reading these reports” (idem). The Register Committee, however, considered that the standard clearly requires the publication of all external quality assurance reports. Even if the reports' addressee is the ministry, there is a clear public interest in the basis of ministerial decisions being public and transparent.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Absence of appeals procedure for initial accreditation and inadequate body to address the appeal.
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel considered that the body deciding on appeals should not be identical to the body that made the decision being appealed, but identified an overlap in the case of ASHE. It further noted that there is no appeals procedure (internal to ASHE) for initial accreditation, but only a possibility to appeal decisions in a court.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.1 Consideration of internal quality assurance
Keywords	Addressing the effectiveness of internal QA
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that the decision-making procedure of the Accreditation Council does not give any special consideration to the effectiveness of internal quality assurance process e.g. by linking the varying progress made by institutions in the development of IQA to the three possible final outcomes. While the panel found that IQAA’s approach reflects the early stages of its development, the panel recommended a stronger focus on the effectiveness of internal quality assurance in IQAA’s accreditation methodology as well as a refining of accreditation standards on student-centred learning (ESG 1.3) so that they give more consideration to how the concept is translated into pedagogical approaches and assessment practices; and more consideration to the primary responsibility of institutions for quality in its interpretation (ESG 1.9). The RC noticed shortcomings in addressing the effectiveness of internal QA processes in its institutional and specialised accreditation procedure and the need for a refining of its standards,”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.2 Designing methodologies fit for purpose
Keywords	fitness for purpose of IQA’s methodology
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Considering the fitness for purpose of the agency’s metholodogy, the panel identified a number of shortcomings i.e. lack of a regular review of the agency’s methodology, blurring of boundaries between the agency’s different functions (such as the preliminary review processes and the post-accreditation monitoring process).

In the analysis the panel further underlined the need to shift the responsibility for quality from the agency towards the institution and that the current procedures might be impeding such development. While the Register Committee considered the agency’s statement to the review report, noting the phasing out of preliminary reviews and the clarification regarding post-accreditation reviews, the Committee concluded that the achieved fitness for purpose of IQA’s methodology needs to be externally reviewed.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	difference in reports regarding recommendations and level of compliance/Inconsistencies between the provisions for programme accreditation and institutional accreditation,
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted some inconsistencies between the provisions for programme accreditation and institutional accreditation, i.e. the IQAA Accreditation Council can only modify the points awarded for decisions in case of programme accreditation but not for institutional accreditation. The panel further noted that it is not always clear how the number and weight of recommendations is linked to the compliance levels of each standard i.e. some reports may include recommendations or critical comments, while other reports do not although in both cases the standard is considered ‘fully compliant’. The panel considered this was a result of the fact that the guidelines for experts are not sufficiently precise. The panel recommended a revision of the agency’s decision-making algorithm, in particular a clarification of the minimum requirements to be fulfilled by higher education institutions and the acceptable shortcomings for each of the four levels of compliance within IQAA’s accreditation standards.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Publication of negative reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that IQAA’s regulations regarding the publication of results from accreditation reviews were not entirely clear and consistent. Whereas some provisions stated that all reports and decisions would be published, others stated that only reviews leading to a positive decision were being published. The panel found that in case of a negative decision on accreditation, neither reports nor outcomes are published. In addition, the panel noted that discrepancies exist between the information available on the Russian and English languages websites. In its statement on the review report, the agency announced that it had recently published all expert review reports and decisions of the Accreditation Council and that it had updated its regulations to explicitly outline that all review reports are published irrespective of their outcomes. The Register Committee could, however, not verify the statement of the agency that also negative decisions would be published, using the link provided.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	separation of consultancy and preliminary reviews
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel noted (p. 30, under ESG 2.2) that IQAA’s efforts to support institutions throughout the assessment process have led to the blurring of boundaries between the agency’s different functions i.e. consultancy-type support offered to individual institutions as part of its preliminary reviews and its regular external QA activities. In its statement to the review report the agency explained that IQAA’s Accreditation Council has phased out preliminary reviews in December

2016. Based on the understanding that the agency has ceased these activities, the Register Committee concluded that there is no further risk of conflicts of interest. The Register Committee, however, underlined that agency is expected to make a substantive change report should IQAA resume the same or similar consultancy-type activities offered to higher education institutions.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	studies based on expert panel review reports are published
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“While the panel welcomed the consistent publication of studies by IQAA addressing the Kazakh higher education and QA systems and the impact of IQAA’s reviews on institutional enhancement the panel however noted that IQAA does not analyse in its publication the results from its institutional and programme reviews. In its statement on the External Review Report, the agency explained that it did not interpret standard 3.4 to explicitly require analyses based on external review reports, but it nevertheless agreed on the importance of these findings and has published a number of studies based on expert panel review reports on institutional accreditation. Considering the evidence provided the Register Committee found that IQAA has addressed its compliance with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	2.1 Consideration of internal quality assurance
Keywords	Addressing the effectiveness of internal QA
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its decision of inclusion Register Committee noted that it should receive attention how AI takes into account the effectiveness of institutional quality assurance arrangements in relation to study programmes and has therefore flagged this matter.The Register Committee noted that since its last review, AI has shifted from performing programme reviews to institutional accreditations and that the accreditation of programmes is expected to fade out by

2019. Since a positive outcome of institutional accreditation means that the institution is mature enough to take the responsibility for the quality assurance of the programmes they offer, the Register Committee concluded that through institutional accreditation AI now takes into account the effectiveness of internal quality assurance and has therefore addressed the flag.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	2.2 Designing methodologies fit for purpose
Keywords	stakeholder involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“While the panel finds that in general AI’s methodologies are designed to ensure quality and relevance for all higher education institutions, it underlined that the agency does not give recommendations following a positive programme accreditation or a negative decision for institutional accreditation.The panel further noted that “methods are defined and designed to ensure that the aims and objectives for external quality assurance are achieved methodologies are fit for purpose” and that “AI put more emphasis on the developmental dimension of external quality assurance.” Considering the analysis of the panel the Register Committee formed the view that the developmental dimension of external quality assurance has been sufficiently well integrated in AI’s external quality assurance procedures. The panel stated that AI doesn’t have a proactive role in the involvement of stakeholders in the design of new procedures. As stakeholder involvement is nevertheless ensured in the consultations on new procedures initiated by the Ministry and Accreditation Council, the Register Committee concluded that this requirement of the standard is met.”

Full decision: see agency register entry