Precedents database
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2.4 Peer-review experts – A3ES – Partial compliance (2019) absence of student reviewers in panels for NCE procedures and overseas accreditations
A3ES
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 2.4 Peer-review experts Keywords absence of student reviewers in panels for NCE procedures and overseas accreditations Panel conclusion Substantial compliance Clarification request(s) Panel (21/10/2019)
RC decision Partial compliance “The involvement of students was flagged when A3ES was admitted to the Register. While the panel’s conclusion was that A3ES was substantially compliant withthe standard, the Register Committee noted that students were not involved in prior accreditation of study programmes (NCE) and international assessment teams. The Register Committee sought clarification from the panel in that regard. Inits response the panel explained that NCE was a compliance-check procedure based on juridic judgement and it involved only experts knowledgable in law. Furthermore, the panel considered A3ES arguments not to involve students in international assessment teams as reasonable andas exceptional cases that do not indicate that A3ES deviates significantly from the quality standards expected under 2.4.The clarification from the panel thus confirmed that students are not part of the panels for prior accreditation of study programmes (NCE) nor part of the panels for overseas compliance check. The Registered Committee considered that this arrangement did not meet the requirements of the standard and that students should be involved as expert panel members in all activities that involve an assessment by a panel of experts. Also for new study programme concepts and for existing programmes implemented in a new setting abroad, students may add a valuable additional and specific perspective to the process. Given the absence of student reviewers in panels for NCE procedures and overseas accreditations, the Register Committee concluded that the flag was not fully addressed and was unable to concur with the panel’s conclusion. The Register Committee concluded that A3ES only partially complies with the standard.”
Full decision: see agency register entry
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2.4 Peer-review experts – AHPGS – Partial compliance (2020) training of experts, clarity of rules for expert pool
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.4 Peer-review experts Keywords training of experts, clarity of rules for expert pool Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “21. […] the review panel noted that the criteria for the recruitment of the experts were not formalised and published.
22. The review panel discussed that the training of experts consisted only of a phone briefing. The panel recommended that AHPGS intensify and further improve the training for both new and experienced experts.
23. The Register Committee took note of AHPGS' explanation that most of its new experts had prior experience from serving as accreditation experts for other agencies in Germany; given the common system there would be no need to re-train them. While the Committee could follow this argument for experts with prior experience, it considered that there will certainly be some – even if few – experts who participate in their first accreditation with AHPGS, and the Committee considered that a more in-depth training was warranted for those.
24. The additional representation underlined that AHPGS offers a regular training programme [...] it remained unclear whether it was ensured that all panel members have participated in a formal training session […]
25. The representation further clarified that there actually is an open invitation, […]
27. Given the panel’s analysis and the issues that remain unclear after clarification and additional representation, the Register Committee was unable to concur with the panel’s conclusion but considered that AHPGS only partially complies with the standard.”
Full decision: see agency register entry
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2.4 Peer-review experts – PKA – Partial compliance (2019) Student involvement in panels
PKA
Application Renewal Review Full, coordinated by ENQA Decision of 19/06/2019 Standard 2.4 Peer-review experts Keywords Student involvement in panels Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The panel’s findings show that in the opinion-giving process students are not involved as members of review panels. Opinions are prepared by members of relevant Sections or PKA experts, following which the Presidium prepares a resolution that is forwarded to the Minister and highereducation institutions. The panel noted that students are to a certain extent involved as members of the Presidium of PKA. In its statement to the review report PKA acknowledged its shortcomingregarding the student involvement in the opinion giving processes and decided to set up a team of student experts to issue opinions on applications.The Register Committee welcomed PKA’s intention but found that the composition of the relevant sections and experts panels is still unchanged. The Committee further underlined that students are normally expected to beinvolved as part of the peer-review expert groups and to contribute as equal partners. As the current arrangement of PKA could not yet be reviewed by an external panel the Committee was unable to conclude whether the way students are involved meets the requirements of the standard. Register Committee therefore concurred with the review panel’s view and concluded that PKA complies only partially with ESG 2.4.”
Full decision: see agency register entry
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2.4 Peer-review experts – ANVUR – Partial compliance (2020) lack of student experts in some review panels
ANVUR
Application Initial Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.4 Peer-review experts Keywords lack of student experts in some review panels Panel conclusion Partial compliance Clarification request(s) Panel (20/02/2020)
RC decision Partial compliance “In its additional representation ANVUR acknowledged the lack of student experts in review panels, and referred to the involvement of students in the internal consultation process on new study programmes. ANVUR added that starting from November 2019, the agency has included (PhD) students in the evaluation groups for PhD programmes at two institutions. The agency also presented its plans to involve students in the AFAM’s external reviews, starting with a pilot project during
2020. ANVUR further stated that starting in 2021 the fees will be aligned between the faculty panel members and student panel members. The Register Committee considered that if student experts have an equal role in panels there is no ground for paying them differently, and welcomed ANVUR's commitment to change its practice in that regard. The Register Committee underlined that the consultation of student representatives in the institutions' internal preparation processes for new study programmes cannot replace the requirement of the standard, i.e. that students are part of ANVUR's expert groups.”
Full decision: see agency register entry
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2.4 Peer-review experts – EQ-Arts – Partial compliance (2019) no student on a panel at a request of an individual HEI
EQ-Arts
Application Initial Review Full, coordinated by ECA Decision of 19/06/2019 Standard 2.4 Peer-review experts Keywords no student on a panel at a request of an individual HEI Panel conclusion Substantial compliance Clarification request(s) Panel (19/11/2018)
RC decision Partial compliance “17. [...] students had not been involved in the panels for enhancement reviews previously.
18. [...] The panel’s clarification confirmed that student involvement on panel’s was not yet a fully established practice across all reviews, but that students will be part of all future procedures.
20. [...] The Committee, however, noted that the December 2018 review of the Royal Academy of Fine Arts (KASK) in Ghent did not include a student panel member; with a note in the report that “contrary to EQ-Arts’ policy and practice, it was the decision and request of School of Art KASK that a student panel member was not included in this review process”.
21. The Register Committee concluded that EQ-Arts was apparently ready to make such exceptions, which are in contradiction to ESG standards. The Committee underlined that such exceptions are incompatible with the spirit of a predefined quality assurance process that is implemented consistently.
22. As EQ-Arts does not stringently implement its policy as regards student panel members, the Register Committee remained unable to concur with the panel’s conclusion, but considered that EQ-Arts only partially complies with the standard.”
Full decision: see agency register entry
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2.4 Peer-review experts – MAB – Partial compliance (2019) student involvement in ex-ante procedures
MAB
Application Initial Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 2.4 Peer-review experts Keywords student involvement in ex-ante procedures Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that students are not involved in ex-ante accreditation of new institutions, the accreditation of doctoral schools and in the initial evaluation of programmes. The Register Committee agrees with the panel’s reasoning that the anonymity of experts in ex-ante evaluations precludes evaluators for becoming answerable for their decisions.[...] The agency also stated that the practice of maintaining the anonymity of experts will be changed following the Board’s decision (of February 2019). Regarding the involvement of students in the ex ante evaluations, the agency argued that students are involved in the decision-making process, as members of the expert committees where findings are discussed and that all eight expert committees now involve a student. In the view of the agency ex-ante evaluations call for an academic judgement as the focus is on academic content. The Register Committee welcomed HAC’s decision to lift the anonymity of experts (in case of ex-ante procedures) and acknowledged HAC’s intention to address the involvement of students in its follow-up report to the coordinator. The Committee nevertheless noted that such changes are yet to take place, and underlined that students should be appropriately involved in all peer expert groups, including the ex-ante evaluation stage as per the requirement of the standard.”
Full decision: see agency register entry
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2.4 Peer-review experts – QAA – Partial compliance (2019) infrequent involvement of students in some procedures
QAA
Application Renewal Review Full, coordinated by ENQA Decision of 15/03/2019 Standard 2.4 Peer-review experts Keywords infrequent involvement of students in some procedures Panel conclusion Substantial compliance Clarification request(s) Panel (05/11/2018)
RC decision Partial compliance “The involvement of student reviewers in reviews for Degree-Awarding Powers (DAP) was flagged when QAA was admitted to the Register. The Committee noted that student reviewers now take part in these reviews […]. The panel's report, however, suggested that the standard was not fully met, as there were no student review panel members in some of QAA's review methods. The Register Committee sought clarification from the panel in that regard. The Committee noted that students are not on the review teams for General Osteopathic Council reviews (GosC); and it could not be established how frequently students are on the panels for Higher Education Review (Alternative Providers) or Transnational Education review (TNE).”
Full decision: see agency register entry
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2.4 Peer-review experts – NEAQA – Partial compliance (2018) student involvement in some reviews and involvement limited to student matters; anonymous review team experts, site-visit undertaken by an agency sub-commission instead of the group of exprts which prepared the report
NEAQA
Application Renewal Review Full, coordinated by ENQA Decision of 06/12/2018 Standard 2.4 Peer-review experts Keywords student involvement in some reviews and involvement limited to student matters; anonymous review team experts, site-visit undertaken by an agency sub-commission instead of the group of exprts which prepared the report Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The panel’s findings show that students (and employer representatives) take part in periodic programme accreditations only when they are combined with institutional ones. The panel also noted that the involvement of students is limited to student matters.The Committee further noted that at the time of the application by CAQA review team experts remained anonymous and that their involvement was limited to assessing compliance based on documentation. The site visits were undertaken by a CAQA sub-commission, which subsequently prepared the final report integrating the experts' feedback.The Register Committee considered that this arrangement did not meet the requirement of the standard and that assessments should be undertaken by a “group of external experts”. ”
Full decision: see agency register entry
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2.4 Peer-review experts – ARACIS – Compliance (2019) student involvement & training of experts
ARACIS
Application Renewal Review Full, coordinated by ENQA Decision of 04/04/2019 Standard 2.4 Peer-review experts Keywords student involvement & training of experts Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “While the panel confirmed the practice of involving students as review experts in all ARACIS’s reviews, including at programme level, the panel added that at the time of its review the agency had had little practical experience. The panel further commented that “some evaluation panels treated student members as supernumeraries and not as full partner-evaluators in the review exercise and that some evaluators were not attuned to the necessity for ‘student centeredness’ in higher education and what that required of tutors and of them as evaluators.” (Review Report, p. 35)
In its additional representation ARACIS [...] commented that its policies and procedures gave students equal rights and obligations i.e. the coverage of mission costs and remuneration is the same as for the other members, and that students are required to participate in the Council, the Permanent Speciality Commission and expert panels. (p. 8-9) ARACIS further added that one of the aspects considered in the selection process of the Permanent Speciality Commission in 2018 was the understanding of students’ role and involvement in quality assurance activities.
The Register Committee noted that, while ARACIS regularly offers training sessions for its evaluators, the panel found that the format for training sessions offered few opportunities for learning through simulation and practical exercise and that the ‘virtual’ and ‘online’ training were lacking in efficacy. In the additional representation, ARACIS clarified that the e-platform is a complementary facility to the face to face training sessions and not a substitute. [..] The agency provided a list of past training sessions focused on the practical activity of the Permanent Speciality Commissions.”
Full decision: see agency register entry
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2.4 Peer-review experts – SKVC – Compliance (2017) Involvement of students in external review process
SKVC
Application Renewal Review Full, coordinated by ENQA Decision of 16/11/2017 Standard 2.4 Peer-review experts Keywords Involvement of students in external review process Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its decision of inclusion, the Register Committee flagged the involvement of students in all external review expert groups.The panel’s findings showed that students participate in all SKVC’s expert teams for all types of evaluations, whether in Lithuania or abroad. In its interviews the panel also learned that students were not always involved equally in the external review process, an issue that was mostly depended on the chair of the team (Review report pg. 36).The Register Committee noted that SKVC involved students in all its reviews and has therefore addressed the flag. he Committee nevertheless underlined the panel’s recommendation that SKVC could play a more supportive role in ensuring that students participate as equal members in all panels.”
Full decision: see agency register entry
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2.4 Peer-review experts – HCERES – Partial compliance (2017) Lack of involvement of students
HCERES
Application Renewal Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 2.4 Peer-review experts Keywords Lack of involvement of students Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “In its decision of initial inclusion (18/05/2011) the Register Committee flagged the participation of international experts and students. The panel noted that usually two experts are involved in the evaluation of bachelor and master programmes, and that these panels do not include students. According to the review panel, HCERES found it very hard to recruit students due to their need for extra time to carry out evaluations alongside their studies. The Register Committee further noted that in the ‘evaluation of doctoral schools’ the agency included a recent doctoral graduate rather than an actual student or doctoral candidate (p. 13 external evaluation report). The panel further noted that the involvement of students in institutional evaluations is limited to panel discussions. In its statement to the review report (of 10/03/2017) the agency, however, commented that students have the same role and responsibilities as other members of the panel in institutional evaluations. The Register Committee concluded that the agency has not addressed the flag and does not meet the requirements of standard 2.4 to involve students in all its external quality assurance activities.While considering that the failure to meet the requirement of the standard concerns a large proportion of HCERES' activity, the Register Committee noted that due to the immanent transition from programme accreditation to the evaluation of study fields, the involvement of students is to be resolved in this new setting.”
Full decision: see agency register entry
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2.4 Peer-review experts – ACQUIN – Partial compliance (2016) Inadequate and insufficient preparation of experts in system accreditation
ACQUIN
Application Renewal Review Full, coordinated by GAC Decision of 03/12/2016 Standard 2.4 Peer-review experts Keywords Inadequate and insufficient preparation of experts in system accreditation Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The panel considered that ACQUIN generally follows common practice in terms of preparation of experts, but remarked critically that ”ACQUIN only ensures a minimum for the preparation for the system accreditation”. The panel specifically noted that the preparation of experts in system accreditation was less intensive compared to other agencies working under the auspices of the German Accreditation Council (GAC). Consequently, the panel recommended that ACQUIN offer at least voluntary trainings or workshops to those experts. The development of ACQUIN's activities for training and preparation of experts was flagged for attention when ACQUIN's registration was last renewed. Considering the assessment by the panel, the Register Committee concluded that practice did not change materially and the issue was therefore not resolved”
Full decision: see agency register entry
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2.4 Peer-review experts – ASIIN – Compliance (2017) (non-local) student involvement
ASIIN
Application Renewal Review Full, coordinated by GAC Decision of 20/06/2017 Standard 2.4 Peer-review experts Keywords (non-local) student involvement Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The Register Committee took note of the explanation in ASIIN's additional representation of its policy and efforts to recruit “local” students, i.e. coming from the same country as the institutions under review. The Committee noted that the participation of students nationally and internationally was increased “to practically 100%”. The Register Committee noted that there was only one case reported where no student could be recruited for the panel. The Register Committee, however, underlined that it would not be compatible with the ESG to use the policy in the sense that only a local student can be appointed. That is, if no local student can be recruited for whatever reason, ASIIN is obliged to involve a non-local student, rather than no student at all.”
Full decision: see agency register entry
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2.4 Peer-review experts – ECCE – Compliance (2017) Independence of the review panels
ECCE
Application Renewal Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 2.4 Peer-review experts Keywords Independence of the review panels Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “The panel stated that the agency’s conflict of interest procedure has not been addressed since the agency’s initial review. The analysis of the panel showed that ECCE’s procedure lack clear criteria with regards to areas of possible conflict of interest and that this has led to unsatisfactory choices of experts in a number of reviews carried out by ECCE. The panel further expressed concern regarding the presence of an evaluation secretary from ECCE’s staff within each expert panel. In its additional representation ECCE stated that it has nominated two non-chiropractic experts to evaluation panels and that it has de-centralised the secretary function, so that there is a separate secretary for each review. The Register Committee noted that ECCE has made steps to address the independence of its review panels. ”
Full decision: see agency register entry
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2.4 Peer-review experts – ZEvA – Partial compliance (2016) Lack of consistent involvement of students
ZEvA
Application Renewal Review Full, coordinated by GAC Decision of 03/12/2016 Standard 2.4 Peer-review experts Keywords Lack of consistent involvement of students Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “In its decision of renewal (of 25/11/2011) the Register Committee flagged the lack of involvement of international experts and representation of the perspectives of students and professional practice in assessments of large clusters including study programmes from different disciplines.In the review report, the panel noted that ZEvA appoints external expert groups in all procedures, and as a general rule at least one student member is included in these groups. The Register Committee however noted that while the agency has involved students in most of its reviews it has not done so for any of its certification procedures and at least one programme accreditation (i.e. PhD in World Maritime University).While the panel formed the view that overall ZEvA’s procedures are well structured in its key areas of activity the newly added procedures, i.e. certification procedures lacked clear statements regarding the processes and responsibilities for the selection, nomination and appointment of experts. In ZEvA’s response to the panel’s report (of 31/5/2016) the agency stated that the responsibility for the appointment of experts lies with the consulting commission and that this has been clarified within the updated Guidelines for Certification and Quality Guidelines. The Register Committee noted the agency’s clarification and action taken to address the panel’s concern.”
Full decision: see agency register entry
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2.4 Peer-review experts – ANECA – Partial compliance (2023) students, panel members
ANECA
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.4 Peer-review experts Keywords students, panel members Panel conclusion Compliance Clarification request(s) Panel (17/02/2023)
RC decision Partial compliance “10. The panel noted that the internal system of the agency generally aimed to have students in every expert panel, in each of ANECA’s procedure. The panel, however, found out that the majority of AUDIT INTERNATIONAL experts panels did not include students (see clarification of 2023-02-17).
11. According to the panel, ANECA found it challenging to ensure student participation in these experts panel due to the limited availability of the students. The Committee acknowledged that recruiting student experts might be more difficult for some reviews than for others, but underlined that this challenge has to be addressed by any agency and cannot serve as a reason to carry out reviews without student panel members.
12. Given the absence of students from most expert panels for AUDIT INTERNATIONAL, the Register Committee was unable to concur with the panel’s conclusion, but concluded that ANECA only partially complies with ESG 2.4.”
Full decision: see agency register entry
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2.4 Peer-review experts – NEAA – Partial compliance (2023) training, training of experts
NEAA
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
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2.4 Peer-review experts – QAA – Compliance (2023) Involvement of students in review panels
QAA
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
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2.4 Peer-review experts – AIC – Partial compliance (2023) student in panel
AIC
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
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2.4 Peer-review experts – MFHEA – Partial compliance (2024) students
MFHEA
Application Initial Review Full, coordinated by ENQA Decision of 11/10/2024 Standard 2.4 Peer-review experts Keywords students Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “26. The Register Committee learned from the analysis of the panel that at the time of the review, some provider and programme accreditation procedures did not involve experts and that these procedures were conducted by MFHEA’s staff. The Committee understood that the only reviews that involved panels were the accreditation procedures for provider seeking university status and EQA Audit (see also ESG 2.3).
27. In its statement to the report, MFHEA informed that the revised manuals, referenced earlier in this decision, require that now every procedure is conducted by an external review panel of a minimum of three experts out of whom one is a student.
28. The Register Committee took note of the actions taken by the agency. Nevertheless, the Committee could not confirm whether these changes have been implemented in practice.
29. In its additional representation, MFHEA referred to the new manuals for provider and programme accreditation where the involvement of students in every external review panel will be guaranteed. Furthermore, MFHEA informed that despite that, the new Programme Accreditation Manual would be in place as of January 2025, the agency already includes students in the review panels for programme accreditation procedures.
30. From the additional representation, the Committee has learned that at the given time only a very small portion of programme accreditation reports are available on MFHEA’s website and further publication of reports is planned in January 2025 (see ESG 2.6). From the limited number of reports available online, the Committee could see that the agency started including a student reviewer in the expert panel.
31. The Register Committee welcomed the changes made by the agency in order to involve students in all external review procedures and encouraged MFHEA to continue this practice. The Committee, however, found that it remains to be evaluated by an external panel whether the planned changes have been consistently implemented and students are included in all programme review panels once the new programme accreditation manual is adopted. Therefore, the Committee concurred with the panel that the agency complies only partially with the standard.”
Full decision: see agency register entry