Database of Precedents
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2.6 Reporting – ANECA – Partial compliance (2023) reports, publication
ANECA
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.6 Reporting Keywords reports, publication Panel conclusion Compliance Clarification request(s) Panel (17/02/2023)
RC decision Partial compliance “14. The panel reported that all reports from programme evaluations were now published on ANECA’s website in a more extensive format; for SIC, AUDIT and AUDIT INTERNATIONAL the agency published the full expert reports.
17. The panel further explained (see clarification) that in programme evaluations the external review reports are prepared by ANECA’s Committees, based on the initial experts’ reports and following the multiple-stage process that is described in the review report. For SIC, AUDIT and AUDIT international procedures the panel noted that ANECA did not have the same practice and specific committees preparing external review reports, but instead considered the full experts’ reports as final report.
18. Having thus considered the report and the clarification, the Committee concluded that the two step approach, where the external review reports are prepared by internal specialised committees, might mean that the full content of the reports prepared by the panel would not be publicly known. Further, the Committee could not, based on the evidence provided by the panel, identify "before" and "after" examples of programme evaluation reports, and hence understand what "more extensive" might mean in practice, and was therefore unable to concur with the panel assessment of compliance.
19. The Committee therefore concluded that ANECA is not living up to the intentions of standard 2.6 which states that "full reports by the experts should be published”. Therefore, the Register Committee concluded that ANECA only partially complies with ESG 2.6.”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – AQU – Compliance (2022) how ESG 1.9 is addressed in AQU’s activities
AQU
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.1 Consideration of internal quality assurance Keywords how ESG 1.9 is addressed in AQU’s activities Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that in the implementation of ESG 1.9 the review panel considered how AQU’s different activities address the cyclicity of external reviews. The Committee, however, underlined that the focus of the standard is on the monitoring and periodical review of programmes as part of the institutions internal QA, ensuring that objectives set for the programmes are achieved and that monitoring processes lead to the continuous improvement of the programme.
Given that the Register Committee was unable to draw a definitive conclusion on how ESG 1.9 is addressed in AQU’s activities, the issue should thus receive close attention in AQU’s next review.”
Full decision: see agency register entry
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2.6 Reporting – AQU – Compliance (2022) publication of reports from ex-ante accreditation
AQU
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.6 Reporting Keywords publication of reports from ex-ante accreditation Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its previous renewal decision, the Register Committee noted that AQU publishes all reports except those from ex-ante evaluations that result in a negative accreditation decision. The review panel reports that AQU now publishes all review reports, independent of their outcome. The Committee also noted that reports with a negative ex-ante accreditation outcome are released with an initial page warning that the degree will not be taught. While the practice of publishing ex-ante reports with a negative outcome was originally met with unease by the institutions whose study programme was rejected, there now is an agreement within AQU on the value of ensuring accountability and trust in the whole system. In relation to the AQU reports for the ex-ante accreditation of short learning programmes (SLP) and micro-credentials, the Committee noted that the agency struggles in scaling the demands of accrediting such programmes, in particular ensuring the proportionate length and detail in its reporting. The Committee underlined the panel’s suggestion on expanding the level of detail and analysis in reports for SLPs to facilitate the usability by various stakeholders and to reflect the detailed evaluation work of the experts. Having considered the change in practice in the publication of negative ex-ante reports, the Register Committee concurred with the panel’s conclusion that AQU now complies with ESG 2.6.”
Full decision: see agency register entry
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3.3 Independence – AQU – Compliance (2022) composition of governing bodies; independence of the appeals process; financial independence
AQU
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.3 Independence Keywords composition of governing bodies; independence of the appeals process; financial independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its previous decision the Register Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies. The review panel found that AQU has separated the membership of its strategic and oversight bodies from its specific commissions and review panels. The Register Committee welcomed these changes, including the appointment of two non-local members to the Appeals Committee, but noted that the Chair of the Appeals Committee is a member of the Governing Board. While the role of the members in the Governing Board is limited to the strategic decision-making and management of the organisation, the Register Committee found that the involvement of a representative of the Board (in particular as a Chair) in the Appeals Committee might put undue pressure in the discussion and decision-making of the Appeals Committee. The Register Committee nevertheless agreed that the Appeals Committee was sufficiently independent given that the AQU’s Governing Board does not adopt the reports or decisions that are being appealed. The Register Committee further noted that AQU’s funding comes primarily from the Government of Catalonia (about 90% of the agency’s budget) and is allocated on an annual basis. The Committee welcomed AQU’s plans to move to a four-year contract with the Government of Catalonia, which could further improve its operational independence. Considered the steps taken to separate the membership of the agency’s strategic and oversight bodies, the Register Committee could follow the panel’s conclusion that AQU now complies with the standard ESG 3.3.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – ANQA – Partial compliance (2022) Student involvement in decision making bodies
ANQA
Application Renewal Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords Student involvement in decision making bodies Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “ANQA involves students in the review panels, but not in the body
responsible for making decisions on accreditation (i.e. the Accreditation
Council). The Committee highlighted the panel’s recommendation and
found it necessary that the agency improves the involvement of students in
the decision-making process.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – AQAS – Partial compliance (2022) Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest
AQAS
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The governing body (i.e. the Managing Board) of the agency does not involve other stakeholders than academics. The agency has not published any policy or statements in regards to the separation of its consultancy activities and preventing conflicts of interest.”
Full decision: see agency register entry
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3.4 Thematic analysis – AQAS – Partial compliance (2022) Content of the thematic analysis
AQAS
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 3.4 Thematic analysis Keywords Content of the thematic analysis Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “the content of the thematic publications mainly involved reflections on the agency’s own experiences in conducting EQA rather than analysis of the results of the EQA (an analysis which could be more appropriate to serve the internal quality assurance processes, ESG 3.6). The Committee agreed with the panel’s views that the agency could improve the content of the analyses so they are more meaningful for the wider academic and QA community”
Full decision: see agency register entry
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2.7 Complaints and appeals – AKAST – Compliance (2021) Lack of an independent appeals committee and limited coverage of appeals
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 2.7 Complaints and appeals Keywords Lack of an independent appeals committee and limited coverage of appeals Panel conclusion Substantial compliance Clarification request(s) Agency (07/12/2021)
RC decision Compliance “In its decision of rejection (of June 2020), the Register Committee noted that AKAST’s appeals and complaints procedure did not cover the peer institutional evaluation procedures and that the appeals were only considered by the same committee that also took the appealed decision. While AKAST agreed to revise its procedure and to establish a complaints committee consisting of independent members, the Register Committee remained unable to follow the panel’s judgment of compliance since the procedure was not yet in operation and the committee handling appeals has not been elected. 8. The panel notes that AKAST has now a revised complaints and appeals regulation and has elected a Complaints Committee at the AKAST General Meeting on 28/01/2021. In the description of the provisions for complaints (AKAST Complaints and Appeals Regulations as amended on 28/01/2021), the agency noted that the Complaints Committee’s statement is to be taken into account in the final decision of the Executive Board or the Accreditation Committee and that further details shall be regulated in the rules of procedure issued by the Complaints Committee and approved by the Executive Board.”
Full decision: see agency register entry
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3.3 Independence – AKAST – Compliance (2021) Independence of formal outcomes
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 3.3 Independence Keywords Independence of formal outcomes Panel conclusion Substantial compliance Clarification request(s) Agency (07/12/2021)
RC decision Compliance “In its past review the Register Committee noted that AKAST was subject to the vigilance of the German Bishops’ Conference and that its influence extended to giving consent for the admission of members of the association and the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and the Board, and the approval of each of the accreditation decision by the member of the Commission for Science and Arts (Commission VIII) of the German Bishops’ Conference. Due to these interlinkages, the Register Committee concluded (see decision of 30/11/2019) that AKAST did not comply with ESG 3.3. The Register Committee in particular found the requirement that each accreditation decision requires the consent of the representative of the German Bishops’ Conference (member of the Accreditation Committee) to be in contrast with the requirement of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation”
Full decision: see agency register entry
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3.4 Thematic analysis – AKAST – Partial compliance (2021) Lack of development in preparing thematic analysis
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 3.4 Thematic analysis Keywords Lack of development in preparing thematic analysis Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “7. The panel notes that AKAST reliably contributes the experience gained from its own quality assurance procedures to the regular evaluation of the Key Points and that the agency is documenting the results of its ongoing student survey on its website.
18. The Register Committee welcomes AKAST’s plan to further develop a thematic analysis after an appropriate number of programme accreditation procedures have been completed, but underlined that such an analysis has not been finalised.
19. Considering the limited development of thematic analysis, the Register Committee can follow the review panel conclusion that AKAST complies only partially with ESG 3.4.”
Full decision: see agency register entry
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2.2 Designing methodologies fit for purpose – GAC – Compliance (2022) no ownership or full responsibility resting with a single actor, consequences for improvement
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 2.2 Designing methodologies fit for purpose Keywords no ownership or full responsibility resting with a single actor, consequences for improvement Panel conclusion Substantial compliance Clarification request(s) Panel (05/10/2022)
RC decision Compliance “9. The panel noted that no actor had ownership or full responsibility for the entire accreditation system and process, since the specimen decree appoints specific responsibilities to both GAC and the agencies.
10. The Register Committee sought further clarification from the panel as to how that impacted continuous improvement and development. The panel noted that opportunities for improvements were discussed actively; the ongoing review of the Specimen Decree was an example of that. The panel, however, saw a lack of GAC itself assuming a more proactive, coordinating role and taking responsibility for the system as a whole; this would be reasonable given its unique and pivotal position.
11. The Register Committee concluded that continuous improvement seems to be ensured despite the distributed responsibilities and thus concurred with the panel's conclusion that GAC complies with standard 2.2; the issues related to GAC's role and strategy are considered under standard 3.1 below.”
Full decision: see agency register entry
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2.5 Criteria for outcomes – GAC – Partial compliance (2022) lack of formal mechanisms for consistency, unclear whether or not consistency improved
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 2.5 Criteria for outcomes Keywords lack of formal mechanisms for consistency, unclear whether or not consistency improved Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “12. The panel considered critically the lack of formal mechanisms to ensure a consistent understanding and application of the criteria (e.g. guidelines, interpretations or a precedent database made available by GAC).
13. The panel was unable to draw a conclusion whether the post-2018 system – with decisions made by GAC, including the practice to change conditions deviating from the proposal by the expert panels – actually delivered a higher degree of consistency or not.
14. The panel further noted that the current organisation of the Council's work included the risk that analysis of cases might often be “monopolised” in the hands of a single (academic) Council member, while some other Council members are currently not participating in the preparatory work as rapporteurs.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – GAC – Partial compliance (2022) strategy not reflecting agency's central role, lack of broad discussions with stakeholders
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.1 Activities, policy and processes for quality assurance Keywords strategy not reflecting agency's central role, lack of broad discussions with stakeholders Panel conclusion Substantial compliance Clarification request(s) Panel (05/10/2022)
RC decision Partial compliance “16. The panel considered that the lack of involvement of stakeholders beyond those individuals who are members of the agency bodies themselves might lead to a lack of critical distance. The panel thus saw a need for more and broader stakeholder feedback, and recommended more regular dialogues with stakeholder organisations on strategic and policy matters.
17. The panel further considered that GAC's strategic planning did not sufficiently reflect its central, pivotal role in the accreditation system (see also the comments under ESG 2.2 above). The panel saw a strong need for a broader discussion with agencies and all stakeholders on GAC’s role in the system and its strategy. In particular in view of the upcoming revision of the
Specimen Decree, the panel found such a discussion was urgent to define a strategy that describes clearly the role GAC plans to assume in the system and its mid-term priorities.
18. While the Register Committee appreciates that GAC has begun to plan a strategy process (see statement on the report), it considered that the panel's analysis under this standard points to important issues in GAC's governance and engagement with stakeholders; these are particularly important in light of GAC's pivotal role in the German system.”
Full decision: see agency register entry
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3.4 Thematic analysis – GAC – Compliance (2022) relevance of topics, nature of topics to qualify, regularity and frequency of analyses
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.4 Thematic analysis Keywords relevance of topics, nature of topics to qualify, regularity and frequency of analyses Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “20. The panel discussed the analyses produced by GAC on various topics, with the most recent ones focusing on conditions imposed on higher education institutions/programmes in decisions by the agencies and by GAC, published in 2018 and 2020 respectively. While the panel questioned whether this was “a crucial topic in the development of the HE system”, the Register Committee considered that such an analysis is certainly based on the general findings of GAC's external quality assurance activities and thus meets the expectation of the standard. Moreover, while the panel did not specifically indicate whether stakeholders found the topic relevant, an analysis of conditions might show how the accreditation criteria resonate with the sector and indicate topics that are typically challenging for institutions and programmes, and hence be relevant beyond GAC.
21. Given the role of GAC as the central body of the German accreditation system, the panel considered that the current publishing rate (one paper per year) was “insufficient”. As the standard remains completely open as to the frequency of analysis, the Register Committee found it an overly strict interpretation of the standard to influence the compliance level on that basis; the remark should rather be seen as a recommendation to publish more analyses.”
Full decision: see agency register entry
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3.5 Resources – GAC – Compliance (2022) shortage of staff positions addressed
GAC
Application Initial Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.5 Resources Keywords shortage of staff positions addressed Panel conclusion Partial compliance Clarification request(s) Panel (05/10/2022)
RC decision Compliance “24. The review panel noted a lack of human resources at GAC's disposal, leading to staff having to prioritise initial accreditation in their work, with reaccreditation procedures taking longer than they should in turn.
25. In its comments on the review report, GAC informed EQAR that a staff increase by 9.25 FTE was now confirmed.
26. The Register Committee sought clarification from the panel on the resources in light of this increase. The Committee understood that this staff increase would address the resourcing in quantitative terms, but that the positive impact of this would remain limited as long as the reservations about the organisation of the Council's work remain, as noted under ESG 2.5.
27. In light of the staff increase, the Register Committee considered that GAC now complies with standard 3.5, while noting that the serious concerns stated under standard 2.5 relate to the question whether GAC effectively deploys its resources, especially in terms of organising the Council's work.”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – HCERES – Partial compliance (2022) lack of coverage for certain ESG Part 1 standards in international programme accreditation
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 2.1 Consideration of internal quality assurance Keywords lack of coverage for certain ESG Part 1 standards in international programme accreditation Panel conclusion Substantial compliance Clarification request(s) Panel (14/06/2022)
RC decision Partial compliance “9. The review report showed that several standards of ESG Part 1 (1.1, 1.4, 1.6, 1.7, 1.9, 1.10) are not addressed in (international) programme accreditation. While HCERES explained to the panel that they adapt their standards according to the foreign context, this creates a situation where a study programme might be accredited by HCERES without having been assessed against the full ESG Part 1.
10. The panel considered that (international) programme accreditations are small in number compared to (national) programme evaluations and other activities of HCERES. The Register Committee, however, considered that the issue at hand is not an occasional or statistical error, but a structural and systemic deficiency for an entire external quality assurance activity of HCERES.
11. As a programme accredited by HCERES will be regarded as ESG-aligned by the public, confirmed by the entry of those programmes in DEQAR, the lack of full ESG Part 1 coverage represents a substantial shortcoming. The Register Committee was therefore unable to concur with the panel's conclusion that HCERES complies with the standard, but concluded that HCERES only partially complies with ESG 2.1.”
Full decision: see agency register entry
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2.3 Implementing processes – HCERES – Partial compliance (2022) follow-up with limited value added, no students interviewed in site visits
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 2.3 Implementing processes Keywords follow-up with limited value added, no students interviewed in site visits Panel conclusion Substantial compliance Clarification request(s) Panel (14/06/2022)
RC decision Partial compliance “18. The panel noted that HCERES programme evaluation panels do not meet with students during review visits. The panel discussed the new follow-up process introduced for institutional evaluation only, but noted that some questions remained regarding the added value given that there is no analysis or feedback in direct response to follow-up reports.
19. The panel considered that HCERES made improvements since the last review, as site visits were not carried out for programme evaluations at all previously and given there was no follow-up process previously.
20. While the Register Committee acknowledged that significant progress has been made, it did not consider that HCERES complies with the standard yet in light of the limited added value of the follow-up process and the fact that students are not interviewed during site visits. The Committee therefore did not concur with the panel, but concluded that HCERES remains partially compliant with ESG 2.3.”
Full decision: see agency register entry
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2.7 Complaints and appeals – HCERES – Compliance (2022) Board member in appeals committee, independence of decisions on appeals
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 2.7 Complaints and appeals Keywords Board member in appeals committee, independence of decisions on appeals Panel conclusion Full compliance Clarification request(s) Panel (14/06/2022)
RC decision Compliance “28. In the last renewal of registration, HCERES was found to be only partially compliant with the standard since its appeals and complaints processes were only just set up and not yet reviewed by an external panel; a specific concern was whether the decision-making on appeals was fully independent from those in charge of the appealed report/decision.
29. The panel considered that HCERES' appeals and complaints processes were clearly defined and communicated. The panel noted that HCERES had not received appeals or complaints since 2016.
30. The panel clarified that it considered the appeals committee's composition suitable. While HCERES Board members indeed serve on the appeals committee, the Board does adopt neither evaluation reports nor accreditation decisions. In addition, one external expert is part of the committee.
31. The Register Committee agreed that the appeals committee was sufficiently independent given that the HCERES Board does not adopt the reports or decisions that are being appealed. The Committee therefore concurred with the panel's conclusion that HCERES complies with ESG 2.7.”
Full decision: see agency register entry
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3.4 Thematic analysis – HCERES – Partial compliance (2022) separate research or bilbiometric analyses do not qualify as thematic analysis
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 3.4 Thematic analysis Keywords separate research or bilbiometric analyses do not qualify as thematic analysis Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “38. The panel considered that HCERES' recent activities have been focused on research and bibliometric analysis; analyses drawing on the results of evaluations within the scope of the ESG have not been produced regularly since the summary reports that HCERES/AERES used to produce following earlier evaluation campaigns.”
Full decision: see agency register entry
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3.6 Internal quality assurance and professional conduct – HCERES – Partial compliance (2022) feedback system not fully integrated, regression since last review
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 28/06/2022 Standard 3.6 Internal quality assurance and professional conduct Keywords feedback system not fully integrated, regression since last review Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “40. The panel noted that the representatives of institutions and reviewers gave different opinions on the possibilities for feedback.
41. The Register Committee agreed with the panel's analysis that this indicates that the feedback system might not yet be fully implemented and that there was a need to systematise and make more coherent the available feedback instruments.
42. The Register Committee further noted that the only partial compliance with ESG 2.1 and 3.4 is a regression since the last review and thus does not reflect positively on the agency's internal quality assurance arrangements.
43. In light of these reservations the Committee was unable to concur with the panel's conclusion, but considered that HCERES only partially complied with the standard.”
Full decision: see agency register entry