Database of Precedents

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“7. The review report showed that the coverage of the particular standards is ensured with guiding questions for institutions and for review teams. However, the evaluation reports are still not checked with a specific focus on how ESG is covered by the IEP Secretariat.

8. While the Register Committee concurred with the panel’s judgement and found the agency to be compliant with the standard, it highlighted the panel’s recommendation on importance of systematic signposting of ESG Part 1 criteria in the evaluation reports.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.3 Implementing processes
Keywords	Implementing processes
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“9. In the last review, the agency was found to be partially compliant with the standard as the follow-up model did not ensure a consistent follow-up for all evaluated higher education institutions.

10. The Register Committee noted from the panel’s analysis IEP’s efforts in addressing the shortcomings with the standards. Furthermore, the Committee noted that IEP took further measures to increase the rate of submission of follow-up reports by evaluated higher education institutions. .

11. The Register Committee therefore concurred with the panel's conclusion that IEP complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	Organisational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In the previous renewal decision of IEP’s registration, the Register Committee noted that the agency’s organisational independence still continued to be compelled by the close link with the EUA.

13. The Register Committee understood that IEP has taken further steps to address the flagged issues raised in the previous decision. The Committee notes the panel’s analysis and the conclusion that while the EUA is providing resources to IEP, it does not have any role in the decision making processes within the IEP. Furthermore, the Committee notes that in order to better distinguish between EUA and the separate activities undertaken by the IEP, the agency has developed a new website and a distinguishable new corporate identity.

14. Furthermore, the Register Committee took note of the agency’s revised Terms of Reference in order to show the Steering Committee’s full ownership of the development and operation of the IEP.

15. The Register Committee therefore concurred with the panel's conclusion that IEP complies with the standard. The Committee, however, shared the panel’s view that the agency should make publicly visible the IEP Terms of Reference and other official documents that state the organisational independence of IEP from EUA.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.3 Implementing processes
Keywords	follow-up, online procedures,
Panel conclusion	Partial compliance
Clarification request(s)	Panel (04/10/2023)
RC decision	Compliance

“12. The Register Committee noted that PKA does not have separate follow-up mechanisms in place, but that they are part of the re-accreditation process i.e., after a conditional two year period (or longer depending on the length of the study cycle) the agency monitors the implementation of recommendations, while in case of a six year accreditation cycle, the agency monitors if the recommendations for improving the quality of education are addressed.

13. The Register Committee finds this approach completely reasonable and in line with the requirement of the standard

14. The Register Committee noted that all of PKA’s evaluation procedures (with some exceptions) are being carried out remotely. In its clarification call the review panel explained that PKA is following clear regulations regarding its remote procedures, regulations that have been updated following wide consultations with the sector. The panel was reassured with PKA’s approach in its online accreditation procedure i.e., PKA carries out observations of classes, institutions are asked to provide a video of the learning facilities and during the remote visit PKA experts also meet with different stakeholders to verify the facts in the review report.

15. The Register Committee further noted concerns from the review panel’s analysis regarding the factual accuracy-check of review reports, as this practice was not clear for those the review panel interviewed. The Register Committee however noted that the possibility for the higher education institution to comment on the assessment report is given to all higher education institutions (as confirmed by the panel) and that this is part of the procedure of the agency in the consideration of the report. The Register Committee nevertheless underlines the panel’s recommendation to further clarify the stage of factual accuracy check in PKA’s procedures.

16. Having considered the clarification of the panel and PKA’s statement to the review report, the Register Committee could not concur with the review panel’s decision of partial compliance, and found that the agency is in fact compliant with ESG 2.3.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.4 Peer-review experts
Keywords	students
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“17. In its past decision, the Register Committee noted PKA’s intention to ensure students are part of the peer-review expert groups in the opinion-giving process and to contribute as equal partners.

18. In its 2023 review report, the panel noted improvements related to the wider engagement of different stakeholders’ groups. In the case of opinion-giving procedure, panels are now composed of members of relevant sections or experts appointed from the academic teachers expert group and a student.

19. The Register Committee thus concluded that the agency has addressed the issues raised in the previous report and therefore can follow the panel’s judgment of compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.6 Reporting
Keywords	publication of reports
Panel conclusion	Compliance
Clarification request(s)	Panel (04/10/2023)
RC decision	Partial compliance

“20. In the past decision, the Register Committee noted that reports of its initial (ex-ante) programme evaluation/opinion-giving process were not published. In its recent review, the panel confirmed that all “expert reports and resolutions of the opinion giving process are now published and available on PKA’s website”.

21. While the Committee noted that PKA has published all decisions from the initial (ex-ante) programme evaluation/opinion-giving process, the Register Committee however found that such decisions did (in particular after July 2020) not include full reports. Given the missing number of a large number of full reports the Register Committee sought further clarifications from the review panel. The panel explained that they understood there was a delay in the publication of reports but that the statutory requirement is for PKA to publish all reports. This reassured the panel that the earlier concern regarding the publication of reports was resolved.

22. Given that PKA has not published all reports from its opinion giving process, the Register Committee found that the earlier concern has not been addressed.

23. In its representation, PKA provided information on the planned changes in its provisions to ensure publishing all reports from its opinion-giving processes. PKA explained that it would be possible to publish all reports from its opinion giving process without the need to wait for information from the Minister regarding their final decision through these changes.

24. Furthermore, in its additional documentation provided on 2024-03-28 PKA informed of its statutory changes where the planned changes have been done.

25. The Register Committee welcomed the actions taken by PKA. However, these changes in the provisions remain to be considered and reviewed by an external review panel to determine whether the changes have been properly implemented.

26. The Register Committee therefore could not concur with the review panel’s conclusion, and found that PKA complies only partially with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	organisational independence, minstry,
Panel conclusion	Partial compliance
Clarification request(s)	Panel (04/10/2023)
RC decision	Partial compliance

“27. In its decision of the Substantive change report decision (of 28-06-2022) the Register Committee concluded that the dismissal of the President casts serious doubts on whether PKA remains able to “act autonomously” and to assume “full responsibility for [its] operations”, as required by ESG standard 3.3.

28. The Register Committee considered that the law and regulations on PKA provided insufficient safeguards against an infringement on the agency's independence by allowing for such a decision to be taken discretionary by the Minister. The Committee found that its earlier conclusion that PKA complies with ESG 3.3 might have been flawed, and based on a positive external review report that did not allay such concerns.

29. In its current review the panel confirmed the concerns of the Register Committee i.e., the panel “could not gauge the extent to which the looming possibility of dismissal without reason may affect the behaviour and performance of the President…”. The panel also noted that there are no clear rules and procedures for the dismissal of PKA’s President, thus the Minister can continue to use discretionary power to dismiss the President of PKA.

30. Following the review panel’s recommendation, the President of PKA submitted a letter, dated August 2, 2023, to the Minister of Education and Science, articulating the recommendations delineated in the ENQA’s review report. In its response letter (Annex 1 of Statement), the Minister showed readiness for a discussion that would determine the criteria for dismissing the PKA President.

31. The Register Committee considered that the Minister was willing to recommend a change in the Law and that would remove the question mark over the independence of PKA (as noted in the Review Report and PKA’s Statement to the Review Report). The Committee nevertheless found that since its Change Report (of 2022-06-28) and the review panel’s review report of June 2023, no change or new evidence in the form of a policy, protocol, procedure or similar, specifying reasons/rationale for the dismissal of the President regulating the Minister’s discretionary power was developed and adopted.

32. The Committee further noted existing possible conflict of interest in PKA’s decision making bodies (see further under ESG 3.6), which raises concerns related to the integrity and independence of the agency’s formal outcomes.

33. The Register Committee finds the above issues of significance given the powers conferred in the position of the PKA’s President (expressed mainly in article 7, 8, 9 & 11a of PKA Statutes) and the controlling stake laid in the hands of the Minister, who has already employed its discretionary power to dismiss the President of PKA at any point (see Change Report Decision of 2022-10-25).

34. In its additional representation, the agency provided a declaration from the new Minister of Science of Poland, where he shows willingness to initiate an amendment on the provisions of the Act of Higher Education and Science in order to limit the Minister’s powers and remove their right to dismiss the President of PKA. Furthermore, the declaration states that the proposed amendment it would empower PKA to be responsible for the dismissal of the President.

35. The declaration of the Minister also informed the Register Committee, that until the legislative framework is changed, he shall introduce an internal procedure in case the President needs to be dismissed, in order to eliminate any further doubts of the Register Committee.

36. The Register Committee welcomed the proposed changes by PKA and the Polish Ministry of Science. Nevertheless, the presented changes have not been implemented in practice yet and at the moment are promises that have yet to be implemented. Therefore, once adopted it remains to be considered and reviewed by an external review panel to determine whether the changes have been properly implemented.

37. The Register Committee therefore concurs with the panel that PKA complies only partially with ESG 3.3. The agency is expected to submit a Substantive Change Report informing the Register Committee once the changes have been made.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.5 Resources
Keywords	resources
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“38. In its past review, the Register Committee noted concerns related to the lack of resources, the high turnover of the Bureau staff and the agency’s capacity to perform thematic analysis.

39. The Register Committee noted from the findings of the latest review (review report of 2023) that the agency now benefits from an increase in support and resources, a decrease in staff turnover, an improved focus on thematic analysis and a legislative recognition for this activity. The panel also found that staff, managers and stakeholders were satisfied with the current resources of the agency.

40. Based on the findings of the review panel, the Register Committee was able to concur with the judgement of compliance with standard 3.5.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal QA,
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“41. In its Change Report Decision (of 2022-11-25), the Register Committee considered the reported change on the newly established body, the Quality Council, and expressed concern with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council.

42. While the panel was unable to address concerns with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council, it noted that the PKA’s President maintains a supervisory role in the internal quality management system of the agency (by being responsible for supervision of the internal quality management system (IQMS) and in appointing a Quality Management System.

43. The Register Committee found that the current proposal for Quality Council (based on Statutes articles 11a & 15a) could have far reaching consequences, while also noting the organisational issues highlighted under ESG 3.3.

44. The Committee was also made aware of possible conflict of interest scenarios (1) where the Chairs of Section may participate in the discussion of the Presidium, even if they have been part of assessments they have previously prepared and (2) where the Chair of the Appeals Body may vote on resolutions adopted by the Presidium which may be later considered by the Appeals Body. The Register Committee found that this setup lacks the appropriate checks and balances and may affect the integrity of PKA’s activities. The Committee could not understand why PKA has not set up a system that would allow the recusal from the discussion or the possibility for restricting the participation (to no voting rights) of those that could be in a conflict of interest scenario.

45. In its additional representation, PKA informed that the responsibility for establishing the Quality Council will be with the Presidium and no longer solely with the President.

46. Furthermore, PKA committed to introduce provisions stipulating that members of the Presidium participating in programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on those procedures.

47. In its additional representation, PKA clarified that the participation and voting rights of the Chair of the Appeals Body in the Presidium is based on the provisions of the Higher Education Act and PKA’s Statutes. PKA clarified that the Chair of the Appeals Body participates only in the part of the meetings where motions for reconsideration of assessment of opinions are discussed and votes only on this matter.

48. Furthermore, PKA clarified that the Chair of the Appeals Body does not take part in the proceeding assessments of opinions that may become object of applications for reconsideration, nor do they vote on such matters.

49. In the additional documentation (of 2024-03-28), PKA reported that the following statutory changes have been made: (a) The responsibility for establishing the Quality Council will be with the Presidium rather than solely with the President; (b) The members of the Presidium participating in the programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on the decisions resulting from those procedures.

50. While the Register Committee welcomed the changes taken by PKA, it underlined that the issues outlined before remain to be addressed and subsequently to be considered and review by an external review panel in order to determine their implementation in practice.

51. The Register Committee therefore could not follow the review panel’s judgment of compliance and found that PKA complies only partially with ESG 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	reports sometime lacking depth of analysis, expert reports not always publlshed
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. The Register Committee noted from the panel’s analysis that the central part of the agency’s reports appears to be merely a check list “occasionally lacking depth of analysis and evidence-based material”. The panel further raised concerns with regards to the accessibility of reports on the ARACIS website, which the panel found somewhat challenging to navigate.

8. The Committee further noted that in the case of doctoral study programmes, study domain accreditation and study domain authorisation ARACIS does not publish the experts’ final proposals for decision. The Committee does not understand why the final proposal for decision/expert conclusion is left out, in particular since this is included in all other external quality assurance activities of ARACIS. The Register Committee underlined that this approach affects the transparency of the agency’s decision making processes in the case of third cycle reviews.

9. The Committee also found that for some of its external QA activities the agency had changed its approach from publishing the full expert report to only publishing a short excerpt of the expert report i.e., the second cycle study domain accreditation reports only include up to a one page excerpt from the expert review report. The Register Committee underlined that it can be of public interest to know the basis on which the final reports are being developed, and that the publication (at least as annex) of the full reports is important to ensure the transparency in the decision-making of the Council.

10. Based on the above raised concerns, the Register Committee could not follow the panel’s conclusion of compliance and therefore concluded that ARACIS complies only partially with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of transparency in the agency’s appeals processes, accessibility of Appeals Procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“11. In its past decision, the Register Committee raised a concern regarding the lack of transparency in the agency’s processes concerning the members nominated to act in the Appeals Committee. The Committee also noted at that time that the appeals procedure was not easily accessible on ARACIS’s website.

12. The Register Committee noted from the analysis of the panel that ARACIS has appointed a Permanent Appeals Commission for a four-year term and published the composition of the commission. The Committee also learned that as of October 2022, ARACIS has a new, integrated and simplified Appeals and Complaints procedure that can be easily retrieved from the website1.

13. The Committee welcomed the newly updated procedure, and while noting that the procedure is rather generic in what concerns handling of complains, that it satisfies the requirements of the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality assurance (IQA) system not implemented
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. In its past decision the Register Committee found that the internal quality assurance (IQA) system had not been implemented at that time. In particular it found that the IQA had yet to prove its role in supporting the internal activity of its speciality commissions and in providing the agency with a sound basis for reviewing and improving the effectiveness with which it works.

16. The Register Committee noted from the detailed analysis of the review repot that ARACIS has set up a functional internal QA system including relevant documentation, structures and personnel. Having considered the evidence presented, the Committee can follow the panel’s conclusion that ARACIS now complies with the requirements of standard 3.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	publication of reports
Panel conclusion	Partial compliance
Clarification request(s)	Agency (28/11/2023)
RC decision	Compliance

“9. The panel reported that it could not identify any clear links where the decisions and the evaluation reports of the review panels are being published on the agency’s website.

10. The Register Committee sought further clarification from the agency (see minuted clarification) in order to understand the agency’s practice regarding the publication of reports and decision.

11. The agency explained (and presented) how the reports are being published on its website i.e. via links within a document uploaded on its website each time a new report is finalised. SAAHE further explained that the agency also publishes, the applications and self-assessment reports of higher education institutions undergoing review procedures. The agency is aware that the current way of publishing reports and decision is not ideal but explained that it was hesitant in making any changes during its review process.

12. The Register Committee sought further clarification on the lack of published reports in 2022 and

2023.

13. The agency explained that following a change in legislation, in 2021, all higher education institutions are required to undergo institutional accreditation and had to apply for such a review by the end of

2022. The agency clarified that while all 33 higher education institutions are have applied for an institutional accreditation, at the moment no procedure has yet been finalised. A pending decision by SAAHE’s Executive Board is expected in February 2024.(see minuted clarification)

14. Having considered the report and the clarification by the agency, the Committee concluded that despite the difficulty in accessing the links of published reports, that SAAHE has been publishing full reports and decisions on its website. The Register Committee underlined the recommendation by the panel to ensure the publishing of reports and decisions in a more accessible and informative way than the current practice.

15. The Register Committee noted that the agency is expected to inform the Register once it has concluded its first institutional accreditation procedure.

16. Having considered the review report and the clarification by the agency, the Register Committee was unable to concur with the panel’s judgement of partial compliance, and concluded that SAAHE complies with ESG 2.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student, stakeholder involvement
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee noted the panel’s concerns in terms of a lack of student perspective in the Executive Board of the agency. While the agency has two nominated student representatives in the Executive Board, neither one is a student or a recent graduate of a higher education institution.

18. Furthermore, the Committee noted the unrealistic requirements for one of the two student representatives to hold a third-level university degree and have at least 15 years of academic or professional experience.

19. Considering the lack of diverse stakeholder representation within the governance of the agency i.e., the limiting conditions in allowing the representation of a student or employer perspective the Register Committee could not follow the panel’s judgement of compliance and found that SAAHE complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	ministry involvement, organisational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The Register Committee noted the panel’s analysis that the members of the Executive Board, of the Board of Appeal, the agency’s auditor and the Head of Office are all appointed by the Ministry (following a public selection procedure).

21. The Committee further noted the panel’s concerns regarding a high involvement of the minister in oversight of the agency i.e, in appointing the Chair of the Executive Board, in maintaining authority to dismiss the Chair and all members of the Executive Board (if there are any infringements of legislation or internal rules of the agency).

22. Taking into consideration the panel’s analysis, the Register Committee expressed its concern that the organisational independence of the agency is constrained by its close link and dependency on the Ministry. The Committee underlined the panel’s recommendation to ensure that the agency becomes fully independent and is able to act autonomously without any influence from the Ministry or other authorities. The Register Committee concurred with the panel that SAAHE complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.4 Peer-review experts
Keywords	Involvement of students in review panels
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“11. The Register Committee already noted in its change report decision (of 2022-10-28) that QAA has changed its policy since the last review and addressed the concerns raised as regards to student involvement in review panels.

12. The Committee was reassured by the panel’s analysis that showed that QAA ensures there is always a student included in its panels for all of the activities under review, except for follow-up visits. The Register Committee understands that follow-up visits are part of an external QA activity, and not a separate activity on its own and therefore finds this approach acceptable.

13. The Register Committee therefore finds the earlier issues addressed and concur with the panel’s recommendation that QAA should extend its pool of international reviewers in light of its own increasing rate of international reviews.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.5 Criteria for outcomes
Keywords	lack of a body to ensure consistency of outcomes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“14. The Register Committee understood from the review panel’s analysis that there is no independent commission that reviews and checks all reports and their application across the agency, which may question whether criteria are being applied uniformly.

15. The Register Committee concurs with the panel’s recommendation that QAA should strongly reflect on its approach to ensuring the consistency of outcomes including the potential need to establish an independent commission that validates reports and makes the final decision.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	presentation of activities within and outside the scope of the ESG
Panel conclusion	Compliance
Clarification request(s)	Panel (03/10/2023)
RC decision	Partial compliance

“17. The Register Committee noted the following concerns with the way QAA has separated its consultancy and related activities from its external QA activities within the scope of the ESG. In particular the Register Committee remained in doubt whether:

• readers (at least lay readers) are able to distinguish whether the reviews carried out in Albania (with the national QA body) fall within the scope of QAA's registration on EQAR, as they were not officially certified as in line with the ESG and

• how the agency ensures a clear communication and separation of the QE-TNE activity from QAA’s activities within the scope of the ESG, given that the activity can be easily misconstrued as an ESG activity (see change report of 2023-02-13).

18. The Register Committee noted that these concerns have not been addressed in the self-evaluation and external review report and therefore the Committee sought further clarifications from the panel to clarify how are the services rendered by QAA itself (internationally or domestically) separated from QAA’s regular ‘ESG activities’.

19. The panel explained (see minuted call of 2023-10-03) that in its understanding the QE-TNE activity is outside the scope of the ESG and thus outside the scope of the review. While the panel did bring this matter up during its discussion with the agency, the panel was reassured by the agency that this activity is not within the scope of the review. The panel was also unaware of the concerns raised by the Register Committee with regards to the consultancy activity carried out by the agency in Albania.

20. The Register Committee could not establish how the agency ensures a clear separation between ESG-type external quality assurance activities especially in cases where such a risk has been previously noted. The Committee therefore could not follow the panel’s judgment of compliance and found that QAA complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.4 Thematic analysis
Keywords	the geographical coverage of thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“21. The Register Committee noted that QAA carries out systematic thematic analysis within Scotland, sector-wide analysis in Wales, while UK-wide QAA has only carried out “The Quality Assurance of Alternative Providers: A Retrospective View”.

22. The Committee finds that the current activity is sufficient in its understanding and interpretation of the standard and therefore could not follow the panel’s judgment of partial compliance and concluded that QAA complies with ESG 3.4.

23. The Register Committee nevertheless underlines the panel’s recommendation that QAA should develop a clearer plan for thematic analyses for all of its external QA activities in all nations of the UK and publish them on its website.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ASIIN
Decision of	30/06/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	Coverage of ESG Part 1, issues re descriptors for alternative providers
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“11. ECTE was found to be non-compliant with ESG 2.1 following its initial review (see report of 2021-08-06) and the following Register Committee decision of 2022-06-28.

12. The Register Committee’s first concern was whether all ESG Part 1 were clearly enshrined in the ECTE standards for their new integrated review, covering both institutional and programme accreditation.

13. In its focused review, the panel analysed and confirmed that the integrated standards “cover all ESG I criteria”, based also on an analysis of the five accreditation procedures that took place since January 2022; these procedures featured programmes of various levels, profiles and types of providers. The Register Committee therefore found the issue addressed.

14. The Register Committee’s second concern was whether qualifications awarded by alternative providers refer to the correct level of the QF-EHEA.

15. The Register Committee found that the review panel's analysis was very generic containing no specific insights or findings on whether the concern was addressed. In particular, the Committee was not persuaded by the statement that ECTE Standards and Guidelines apply “uniformly to all ECTE programme levels (here 5-7), all types of providers (Higher Education Institutions as well as Alternative Providers) and all programme orientations (research and practice-oriented programmes)” given the fact that the learning outcomes in the Certification Framework differ between levels.

16. In its addendum to the report (submitted May 2, 2023) the panel clarified that all programmes accredited by the ECTE are classified as higher education and match the QF-EHEA descriptors, including practice-oriented programmes. The panel further explained that their formulation “of uniformly applied” meant to emphasise the use of one framework for different levels, in the way that programmes use one framework for evaluating different levels of programmes.

17. The Register Committee further found it hard to understand why the panel did not discuss the change of ECTE’s descriptors given the significant reduction in its detail and specificity. The Committee thus requested a comprehensive assessment on how ECTE’s subject-specific descriptors are considered in its new Certification Framework and on how the broad QF-EHEA descriptors themselves has impacted ECTE’s accreditation in practice.

18. The panel explained that they have not been aware of a different version of ECTE Certification Framework (earlier version published in 2019, analysed version published in September 2022)1, and thus only commented on the latest version.

19. In the view of the panel, ECTE’s documentation is consistently clear in requiring the application of ECTE standard B.2.1 (that concerns the application of QF-EHEA).

20. In its addendum to the report, the panel further provided an analysis of 16 reviews covering Short Cycle, First Cycle and Second Cycle qualifications delivered by alternative providers. The panel’s finding show that alternative providers have been specifically asked to link the learning outcomes of their programmes to the Dublin Descriptors and the associated higher education cycle.

21. The panel also checked whether ECTE evaluates the qualifications awarded by alternative providers at the correct QF-EHEA level and whether the intended learning outcomes and qualifications were in conformity with nationally agreed standards for theological education.

22. Following the consideration of the additional documentation, the Register Committee could follow the panel’s conclusion that ECTE is, in practice, examining whether qualifications at different levels match the QF-EHEA level.

23. Considering the effectiveness of how ECTE addresses these standards within its review reports (B2.1 and B5.1), the Committee found there’s a wide variation in the level of detail and specificity, that may hinder the successful application and interpretation. The Committee thus found that this concern was only partially addressed.”

Full decision: see agency register entry