Database of Precedents

Application	Initial
Review	Focused, coordinated by ASIIN
Decision of	30/06/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between HEIs and alternative providers/ Stakeholder involvement in governance
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“28. The Register Committee found ECTE to be only partially compliant with the standard (see decision of 2022-06-28), given the lack of a clear and transparent distinction made between officially-recognised higher education institutions (HEIs) and alternative providers (APs).

29. The panel analysed ECTE’s comprehensive measures introduced and how they have been implemented by both ECTE itself and the accredited providers.

30. The Register Committee commended ECTE for the steps taken and concurred with the panel that these address the earlier mentioned issues.

31. The Register Committee considered that the panel's concerns regarding the Accreditation Commission's (AC) dominance by staff and the lack of other stakeholder representation (e.g. students and business) are an issue related to the requirement of stakeholder participation in ESG 3.1 rather than related to ESG 3.3.

32. The Committee took note of ECTE’s immediate steps to ensure the appointment of stakeholder members (see ECTE statement of 2022-12-21). The Committee further considered the analysis provided by the panel in its addendum to the review report, on the new composition of the Accreditation Commission, that now ensures a broader stakeholder representation.

33. Given that the issues related to the involvement of stakeholders' perspectives on the AC was addressed, Register Committee was now able to concur with the panel's conclusion of compliance.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ASIIN
Decision of	30/06/2023
Standard	3.3 Independence
Keywords	Appointment process for accreditation body
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Partial compliance

“34. The Register Committee considered ECTE partially compliant with the standards 3.3 (see decision of 2022-06-28), due to concerns with regard to ECTE’s structure, the composition and overlapping functions of the ECTE Council and the possible conflict of interest in the role of some staff members; while steps to resolve this were taken, these had not been analysed by an external review panel.

35. The Register Committee took note that the new governance structure of ECTE separates the governance role of the Council from the accreditation decision-making role of the Accreditation Commission (AC) and that members of the committee hold no other positions within ECTE. The Committee further noted that ECTE has put additional measures in place to remove all staff representation from the Accreditation Commission.

36. The Committee however maintained that the practice whereby the Accreditation Commission nominates candidates for the same body is problematic in terms of ensuring the agency’s operational independence. Even if the candidates are nominated by the Board, the Register Committee found this approach may lead to conflict of interest scenarios and can affect the agency’s operational independent and fair selection process.

37. The Register Committee also found the appointment period of the AC confusing and ill-designed as it did not provide a limited term or a clear period for the mandate of the Commission i.e. ‘members of the Accreditation Commission are appointed by the Board for a period of two-four years, re-appointments are possible.

38. Given the above mentioned issues, the Register Committee found ECTE to be partially compliant with the standard as established previously.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	coverege of ESG Part 1
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. The Register Committee follows the panel’s analysis regarding the requirement of a public quality assurance policy (ESG 1.1), explicitly in the Inclusion of a licensed study programme on the accreditation form of a study field and the Accreditation of foreign study programmes frameworks. The Register Committee noted that AIC has yet to fully take up the national qualification framework (ESG 1.2) in each assessment framework, focussing more on assessment policies in all assessment frameworks, including a focus on student-centred assessment (ESG 1.3), and adding reference to public information (ESG 1.8) in the Inclusion of a licensed study programme on the accreditation form of a study field framework.

11. After consideration of the additional representation by AIC regarding the points addressed in the panel review report and the Register Committee decisions, the Register Committee concluded that even when considering that different procedures could be considered as a package, there are missing elements with regards to standards 1.1, 1.2, 1.3 and 1.8 in the QA model of the agency.

12. Therefore the Register Committee agrees with the argumentation of the panel and judgement of the standard only as partial compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.3 Implementing processes
Keywords	inconsistencies in the implementation
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. The Register Committee noted that there are inconsistencies in the implementation of the processes. The Register Committee underlines the panel’s recommendation that the agency should clearly communicate on the valid reasons behind multiple inputs to its accreditation process and decisions, by publishing them on the website as noted also in its Substantive Change Report Decision of 15 October 2021.

14. The Register Committee further noted the concerns raised by the review panel concerning the lack of relevant criteria and information integrated in AIC’s guidebook from the Law on Higher Education and Cabinet Regulations, as well as the updating of assessment methodologies, frameworks and the guidelines for institutions, as well as experts.

15. From the additional representation by the agency, the Register Committee understood that, when considering that different procedures would be considered as a package the Methodology for organising the assessment of higher education institutions and colleges could be seen as a follow-up procedure for the one-off procedure Accreditation of higher education institutions. While the panel noted that the agency is preparing a cyclical institutional accreditation, the Committee reiterates the need for clear follow-up measures.

16. The Register Committee concluded that AIC complies with ESG 2.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.4 Peer-review experts
Keywords	student in panel
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee stressed in its Substantive Change Report Decision of 2021-10-22 that the group of experts in the inclusion of licenced study programme on the accreditation of study field procedure, does not include a student. While the Committee understands that this procedure was created as a temporary and short-term solution in order to close possible gaps in the accreditation periods of programmes (until the next re-accreditation of the corresponding study field), the Committee could not follow the agency’s decision of not involving students, as per the requirement of the standard 2.4.

18. The Register Committee further noted from the review panel’s report that the agency has not resolved this issue and sustained its position that two experts should be sufficient in this procedure.

19. Considering AIC’s statement to the report that, the Register Committee understood that AIC is applying the national framework. The Committee however underlined that it is AIC’s responsibility to ensure ESG compliance with all standards and that it has taken measures to ensure the involvement of students in all procedures.

20. The Register Committee underlines the panel’s recommendation to include student-members in all procedures involving external experts, in particular in the procedures for Inclusion of a licensed study programme in the accreditation form of study field.

21. In its additional representation, AIC explained that the inclusion of licenced study programme on the accreditation of study field procedure is not a stand-alone procedure, but a temporary measure while the new quality assurance system from 2025 will include students in all procedures. The Register Committee however noted that students are at the time not included in this procedure, as the new system is not implemented yet. The Register Committee underlined the expectation of the standard, that

students should be involved in all QA processes.

22. The Register Committee concurs with the panel that AIC complies only partially with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	publication of decisions
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. The panel’s analysis shows that AIC does publish full reports of the experts panels for its procedures ‘Accreditation of higher education institution’, ‘Assessment and accreditation of a study field’, ‘Licensing of study programme’ and ‘Accreditation of study programmes abroad’.

24. The Register Committee further noted however, that these published reports and the decision letter do not reflect the additional elements which have been provided and taken into consideration after the site visit nor the additional tasks given to the higher education institution.

25. The Register Committee could not find any new supporting evidence to AIC’s position in the additional representation. Both from the panel’s report and the AIC website, it was clear that only the duration of accreditation terms is published, while the full decisions are not published together with the reports.

26. The Register Committee therefore concludes that there is no sufficient transparency in AIC’s reporting processes and therefore concurs with the panel’s conclusion of partial compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	appeals procedure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“27. The Register Committee noted in its past decision that the chairperson of the agency’s board takes the final decision on the appeal and reviews the conclusions of the Appeals Committee. The Register Committee found this may affect the integrity of the appeals process. Additionally, the Register Committee found that higher education institutions do not have the possibility in case of institutional accreditation to appeal the report with AIC (only with ministry).

28. In the Substantive Change Report (of 2022-03-15), AIC elaborated further on the modalities for potential appeals against accreditation decisions regarding the Accreditation of foreign study programmes. The explanations, however, left open how such appeals would be considered.

29. In the review report the panel explained the possibility to appeal accreditation decisions made by the agency. The panel considers that the appeals procedure which has been developed, and the Appeals Committee which has been compiled in January 2022, brought the agency’s review procedures for Latvian higher education institutions in line with the standard.

30. The Register Committee considered the statement of the agency regarding the appeals and complaints procedures and noted that the amendments to the legislation were approved and an appeal procedure including independent appeals commission, has been set and is functioning. The Register Committee welcomes the progress made, but follows the panel’s concern on the lack of the transparency of external quality assurance system, due to a lack of written procedure for hearing complaints.

31. The Register Committee underscores the panel recommendations on the publication of the procedures to follow-up complaints concerning activities of the agency in Latvia and on the development of an appeals and complaints procedure for its accreditation procedure for foreign degrees.

32. Having considered the improvements by the agency, the Register Committee noted the need to further elaborate on the procedure for complaints. The Register Committee agrees on compliance for this standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal management system, feedback mechanisms
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“33. The Register Committee understood from the panel’s analysis that AIC has set up an internal management system to support the daily work of the agency and the collection of feedback from different sources to inform improvements.

34. The Committee however noted AIC’s internal quality assurance system faces a number of issues and limitations: no major changes/ improvements can take place without government regulation or legal change; the informal nature of the feedback limits the ability of the agency to measure objectively “the outputs of the system”; no sufficient evidence that experts are getting acquainted with additional requirements or obligations set by Study Quality Commission after the accreditation procedure.

35. The Register Committee therefore finds that AIC has yet to consolidate its internal quality assurance system, including internal and external feedback mechanisms for continuous improvement.

36. The Register Committee could not conclude that, as it stands, the agency’s internal quality assurance processes are fully sufficient to assure and enhance the quality and integrity of its activities and therefore could not follow the panel’s conclusion, but found that AIC complies only partially with the standard 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.1 Consideration of internal quality assurance
Keywords	Insufficient coverage of ESG 2.1
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Looking at systemic level, the

different regulations touch upon the three particular standards of Part 1 of the ESG. However, the full coverage of all the standards of Part 1 is still not ensured through agency’s own criteria. Partial coverage of aspects through national legislation does not substitute coverage through external QA procedures and coverage of the ESG part 1 by higher education institutions’ internal QA is a prerequisite for EQA being able to assess their implementation”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of formal complaints procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Partially compliant with the standard due to the lack of formal complaints’ procedure– the higher education institutions could express their dissatisfaction with the process only informally throughout the review process. The agency is yet to establish a clear

complaints procedure that is known by higher education institutions”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ENQA
Decision of	03/03/2023
Standard	3.3 Independence
Keywords	Infringement of the operational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Dependency of the agency on staff paid by higher education institutions”

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	Inconsistent application of criteria
Panel conclusion	Compliance
Clarification request(s)	Agency (18/07/2023)
RC decision	Partial compliance

“The current set up brings confusion not only for the higher education institutions, but also for the

agency itself. The Committee found that agency’s criteria are not always applied consistently in the reviews and this leads to different standards being covered in the reports. During the clarification call, the agency explained that the SOP 2023 will be stabile - only reviewed and amended after 3 years again. The Committee welcomed these changes but found that the agency still enables usage of different SOPs – a practice that can lead to different outcomes and inconsistencies in the conclusions of its reports. This is especially problematic considering the regulatory function of the agency’s reviews for veterinary education.”

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	Involvement of stakeholders
Panel conclusion	Compliance
Clarification request(s)	Agency (18/07/2023)
RC decision	Partial compliance

“The Committee was displeased to learn that EAEVE has not involved students and other stakeholders in the decision-making bodies since its registration on EQAR in

2017. While the Committee understood that involvingstudents from a narrow scientific field in the work of the agency could be a challenging task, it found that EAEVE could have found alternatives since its registration (e.g. establish stronger ties with stakeholders associations and or/create incentives for motivating other stakeholders to participate in the work of the agency, expand the involvement of students from closely related scientific fields etc.). The Committee found that the agency’s involvement of stakeholders, including students, in its governance and work is insufficient.”

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	training, training of experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. The Register Committee noted from the panel’s analysis that the trainings of experts have been reduced to only a briefing session taking place before the site visit. The panel’s analysis further show that the last training organised by NEAA took place in 2018 (before the Covid-19 pandemic).

9. The Register Committee underlined that the agency is expected to ensure that experts have the appropriate skills and competences to carry out external reviews and that such skills and competences are acquired through regular (periodic) trainings organised by the agency.

10. In its representation, NEAA provided information that it has started intensively working on preparation and implementation of several trainings focused on specific standards and criteria. NEAA also informed that future training sessions will be included in its Action Plan.

11. The Register Committee welcomed the steps taken by NEAA to address the earlier concerns, but noted that the Committee could not verify whether these training activities will ensure that all members of a panel will be systematically trained prior to undertaking an external quality assurance procedure. The Committee noted that these will remain to be determined in NEAA’s next external review.

12. The Register Committee therefore remained unable to concur with the panel’s conclusion, but considered that NEAA complies only partially with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.7 Complaints and appeals
Keywords	appeals and complaints, committee
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its initial application for inclusion the Register Committee raised concerns regarding the lack of an internal appeals system within the agency.

14. The Register Committee noted that since the last external review of NEAA, nothing has changed in relation to the possibilities for higher education institutions to make an appeals with the agency.

15. The Register Committee further noted, that NEAA does not have its own appeals process nor a separate body in considering appeals and that the only existing appeals procedures are outside of NEAA’s remit, defined by law and under the legal competency of the Bulgarian courts.

16. The Committee considered that external quality assurance processes should always include an internal possibility to appeal within the responsible body that carried out the review itself.

17. In its representation the agency provided full documentation on its new internal provisions for complaints and appeals and for the functioning of its body the Complaints and Appeals Committee. The Committee noted that the new body is a standing committee within the agency, fully operative with permanent members and clear provisions outlined in the Statutes of the Complaints and Appeals Committee.

18. Having been able to verify that the agency provides both internal processes for complaints and appeals, the Register Committee finds that the initial concerns have been addressed. The Register Committee therefore concluded that NEAA now complies with ESG 2.7.”

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	stakeholders, stakeholders involvement, Accreditation Council
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“19. In its last decision, the Register Committee noted that the composition of NEAA’s Accreditation Council (AC) is dominated by representatives of the academia and that there is a lack of stakeholder involvement with no student or labour market/employment representatives involved in the work and governance of NEAA.

20. The Register Committee noted that while NEAA expanded the direct participation of stakeholders in its work i.e., including representatives of students and employers in the Expert Groups and the Standing Committees, that the composition of the Accreditation Council (AC) is still limited to only representatives of the academic community.

21. Despite the improvements done by NEAA in the involvement of stakeholders’ in some of its processes and bodies, the Register Committee considered the lack of stakeholder involvement (as per the requirement of the standard) in the core governance body of NEAA as of crucial importance.

22. The Committee further emphasised the recommendation of the panel to ensure the inclusion of a representative of students and employers/industry in the AC, including a representative of students (preferably with a legal background) in NEAA’s Ethics Committee.

23. In its representation, the agency provided information on the actions taken toward the government and parliament around the need for legislative changes. The Committee took note and welcomed the positive developments towards the involvement of stakeholders in the Accreditation Council, however at the time of the Register Committee’s consideration, no changes have happened, nor a clear timeline for such changes has been provided.

24. The Register Committee acknowledge that although NEAA has taken all possible actions to improve the involvement of stakeholders within relevant normative documents, the fact remains that the level of compliance is negatively impacted by the regulatory framework within which NEAA operates.

25. The Register Committee therefore concurs with the panel that NEAA 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	3.5 Resources
Keywords	resources, financial independance
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“26. The panel noted that the main challenge for NEAA remains the fact that it cannot manage its own finances in a manner that will enable NEAA to ensure the best quality of its activities. Even if the majority of the funding comes from its external quality assurance activities i.e., mostly accreditation fees, due to the strict regulations and rules defined on national level, NEAA cannot access these revenues. The Committee concurs with the panel that this could have a negative impact on the sustainability and the quality of its processes.

27. The panel underlined that despite the improvements and increase of staff members since its last review, from 8 to 19 staff members, NEAA still had a high number of vacant positions.

28. The Committee emphasised the panel’s recommendations on the need for the agency to pursue with the Ministry changes in its financial management and to continue the recruitment of new staff to ensure optimal workload and implementation of external QA processes on time.

29. In its representation, NEAA reported of a further increase in its staff (i.e., from 19 to 23 employees), with recruitment for some of these positions currently underway. The Committee noted that the agency has taken active steps addressing specific proposals to increase pay rates to the Ministry of Education, the Ministry of Finance and the Prime Ministers office. Similar efforts are directed towards the Council of Rectors. Further, the agency stated that there are constant efforts made towards the responsible national authorities with a request to increase the budget of the agency.

30. The Register Committee welcomed the actions taken by NEAA. The Register Committee, however, noted that despite the improvements in NEAA’s permanent staff, the agency’s financial independence, due to external factors, remains constrained, and while the limitations in resources may not pose an immediate concern as to the sustainability of the agency, it may negatively impact the scope and quality of the activities undertaken by NEAA.

31. The Register Committee therefore concurred with the panel’s conclusion that NEAA complies only partially with ESG 3.5.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal, internal QA system,
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“32. The panel noted that NEAA started developing its internal quality assurance system introducing, some new mechanisms and procedures. However, the panel underlined that the elements of the procedures are fragmented and not fully structured, integrated and connected in a systematic way. The panel also noted the lack of transparency of the mechanisms and their results.

33. Despite NEAA’s efforts to develop its own internal quality assurance system, the Register Committee found that the process is still in a developmental phase. The Committee underlines the panel’s recommendation that all the elements of the internal QA system needs to be better connected, regularly implemented with the involvement of all internal and external stakeholders.

34. In its representation, NEAA informed that in 2023, the agency undertook an internal audit to identify the weaknesses and bottlenecks in its own internal processes and review procedures. The agency also provided details of the internal audit process and the series of recommendations that were outlined to correct the issues. NEAA further stated that necessary measures are being implemented to improve the functioning of the agency.

35. While the Register Committee welcomed the steps taken by NEAA, the Committee underlined that the issues outlined before remain to be considered and reviewed by an external review panel to determine the improvement in the functioning of NEAA’s internal QA system.

36. The Register Committee therefore concurred with the panel’s conclusion that NEAA only partially complies with ESG 3.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“At the time of the site visit the

agency’s website was under development, and the access to all reports was

not possible. The Committee noted that the website was still not upgraded

and fully functional at the time of taking the decision - almost one year after

the panel’s visit. This circumstance prevented the Committee from verifying

whether all the reports are publicly available. The Committee

concurred with panel’s conclusion of partial compliance.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.3 Independence
Keywords	Operational independence; Independence of formal outcomes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Committee learned that both the president and the vice president

of KAZSEE have voting rights in the two bodies in which they are members

of, i.e. the Accreditation Council and the Supervisory Board. In panel’s view

the “mixture of roles [of the President and the vice President] could make

the [decision making] system vulnerable”. The Committee could follow panel’s reasoning that the current

arrangements could pose threat for the operational independence and the

independence of formal outcomes.”

Full decision: see agency register entry