Uddannelses- og Forskningsudvalget 2015-16
UFU Alm.del
Offentligt
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Report of the External Review of the Accreditation
Institution
August 2010
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TABLE OF CONTENTS:
EXECUTIVE SUMMARY................................................................................. 3
GLOSSARY ................................................................................................ 4
INTRODUCTION ......................................................................................... 5
SELF-EVALUATION REPORT AND THE REVIEW PROCESS OF ACE Denmark ..... 6
Self-evaluation report ........................................................................... 6
Site visit ............................................................................................. 6
Concluding the report ........................................................................... 7
CONTEXT OF THE REVIEW........................................................................ 7
Higher education system in Denmark...................................................... 7
Historical Overview of the quality assurance system in Denmark ................ 9
COMPLIANCE WITH THE EUROPEAN STANDARDS AND GUIDELINES ............... 11
1. ENQA CRITERION 1 ........................................................................... 11
1.1 ESG PART 2 .................................................................................... 11
1.1.1 ESG 2.1 USE OF INTERNAL QUALITY ASSURANCE PROCEDURES...... 11
1.1.2 ESG 2.2 DEVELOPMENT OF EXTERNAL QUALITY ASSURANCE
PROCESSES....................................................................................... 12
1.1.3 ESG 2.3 CRITERIA FOR DECISIONS.............................................. 13
1.1.4 ESG 2.4 PROCESSES FIT FOR PURPOSE........................................ 14
1.1.5 ESG 2.5 REPORTING .................................................................. 16
1.1.6 ESG 2.6 FOLLOW-UP PROCEDURES .............................................. 17
1.1.7 ESG 2.7 PERIODIC REVIEWS ....................................................... 18
1.1.8 ESG 2.8 SYSTEM-WIDE ANALYSES ............................................... 18
1.2 ESG 3.1 USE OF EXTERNAL QUALITY ASSURANCE PROCEDURES FOR
HIGHER EDUCATION.............................................................................. 20
1.3 ESG 3.3 ACTIVITIES ........................................................................ 20
2. ENQA CRITERION 2: ESG 3.2 OFFICIAL STATUS.................................... 21
3. ENQA CRITERION 3: ESG 3.4 RESOURCES ........................................... 22
4. ENQA CRITERION 4: ESG 3.5 MISSION STATEMENT .............................. 23
5. ENQA CRITERION 5: ESG 3.6 INDEPENDENCE ...................................... 23
6. ENQA CRITERION 6: ESG 3.7 EXTERNAL QUALITY ASSURANCE CRITERIA
AND PROCESSES USED BY THE AGENCIES ............................................... 26
7. ENQA CRITERION 7: ESG 3.8 ACCOUNTABILITY PROCEDURES................ 27
8. ENQA CRITERION 8: Miscellaneous ...................................................... 28
ADDITIONAL RECOMMENDATION ............................................................... 30
CONCLUSION........................................................................................... 32
Annex 1: Standards and Guidelines for Quality Assurance in the European Higher
Education Area (ESG) ............................................................................... 33
Annex 2 - Programme of the site visit ......................................................... 36
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EXECUTIVE SUMMARY
This report analyses the compliance of the Accreditation Institution with the
European Standards and Guidelines for external quality assurance agencies and
thus with the membership criteria of the European Association for Quality
Assurance in Higher Education (ENQA).
The Accreditation Institution was established by law in 2007 for external quality
assurance in higher education, namely to accredit study programmes and have
the overall responsibility for quality of the higher education system. The
Accreditation Council, as the main decision making body of the Accreditation
Institution, takes strategic and accreditation decisions and oversees the quality
of the agency. It accredits all study programmes although they fall under the
auspices of several ministries. Besides the Accreditation Council the Accreditation
Institution consists of ACE Denmark, which includes two secretariats that are
also defined in the Accreditation Act. The Council Secretariat administratively
supports the Council and the Professional Secretariat is carrying out accreditation
procedures which include: development of accreditation guidelines, training of
experts, receiving applications, preparing site visits, drafting accreditation
reports and preparing final reports. In the Danish context ACE Denmark is called
“the operator” and carries out accreditation procedures for study programmes
that fall under the Ministry of science, technology and innovation.
The review of the Accreditation Institution had the sole purpose of examining
whether it meets requirement of ENQA membership (“type A review”). The panel
received sufficient documentation prior to the visit that provided fruitful
additional information. Thus the panel managed to gather evidence for
judgement of standards fulfilment.
In the very short period of time the Accreditation Institution managed to set up
an accreditation system with sufficient human, financial and expert resources.
The panel found the system substantially compliant with the European Standards
and Guidelines, however, proposes several recommendations in the light of
further development of the Accreditation Institution.
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GLOSSARY
ENQA
The European Association for Quality Assurance in Higher Education
ESG
Standards and Guidelines for Quality Assurance in the European Higher
Education Area
HEI
Higher Education Institution
HEIs
Higher Education Institutions
Dialogue Forum
Dialogue Forum, which was established for more overall and general discussions,
comprises representatives from all the universities, students and the business
community – a total of 30 representatives. Dialogue Forum meets approx. four
times a year with changing themes on the agenda.
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INTRODUCTION
This is the report of the review of the Accreditation Institution undertaken in
June 2010 for the purpose of determining whether the agency meets the criteria
for Full membership of the European Association for Quality Assurance in Higher
Education (ENQA). The provisions for membership of ENQA are listed in Annex 1
to this report.
BACKGROUND AND OUTLINE OF THE REVIEW PROCESS
ENQA’s regulations require all Full member agencies to undergo an external
cyclical review, at least once every five years, in order to verify that they fulfil
the membership provisions.
In November 2004, the General Assembly of ENQA agreed that the third part of
the Standards
and Guidelines for Quality Assurance in the European Higher
Education Area
(ESG) should be incorporated into the membership provisions of
its regulations. Substantial compliance with the ESG thus became the principal
criterion for Full membership of ENQA. The ESG were subsequently adopted at
the Bergen ministerial meeting of the Bologna Process in 2005.
The third part of the ESG covers the cyclical external review of quality assurance
and accreditation agencies. In accordance with the principle of subsidiarity,
external cyclical reviews for ENQA membership purposes are normally conducted
on a national level and initiated by national authorities in an EHEA State, but
carried out independently from them. However, external reviews can also be
coordinated by ENQA if they cannot be nationally organised, as this is the case
for this Accreditation Institution’s external review. In that event, ENQA plays an
active role in the organisation of the review, being directly involved as
coordinator, whereas, in the case of national reviews, it is only kept informed of
progress throughout the whole process.
The external review of the Accreditation Institution was conducted in line with
the process described in
Guidelines for external reviews of quality assurance
agencies in the European Higher Education Area
and in accordance with the
timeline set out in the Terms of Reference. This review of the Accreditation
Institution had the sole purpose of examining whether it meets requirement of
ENQA membership.
The review panel for the external review of the Accreditation Institution was
composed of the following members:
- Séamus Puirséil, President, Dublin Business School, former Chief Executive
HETAC-Ireland, Ireland (Chairman);
- Janja Komljenovič, Advisor for Higher Education, Ministry of Higher Education,
Science and Technology, Slovenia (Secretary);
- Karin Järplid Linde, Assistant Head of Department, National Bologna Expert,
Swedish National Agency for Higher Education, Sweden;
- Jacques Lanares, Vice Rector, University of Lausanne, Switzerland;
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- Bruno Carapinha, doctoral student in Political science, University of Lisbon,
Portugal.
The Accreditation Institution produced a self-evaluation report and provided
substantial documentation which represented an important portion of the
evidence that the panel used to form its conclusions. The panel conducted a site-
visit to validate the self-evaluation and clarify any points at issue. Finally, the
review panel produced the present final report on the basis of the self-evaluation
report, site-visit and its findings. In doing so it provided an opportunity for the
Accreditation Institution to comment on the factual accuracy of the draft report.
The review panel confirms that it was given access to all documents and people it
wished to consult throughout the review.
SELF-EVALUATION REPORT AND THE REVIEW PROCESS OF ACE Denmark
Self-evaluation report
The Accreditation Institution produced a self-evaluation report (60 pages), which
was sent to the review panel prior the site visit. The self-evaluation report was
prepared by a project group with participants from the Accreditation Council and
ACE Denmark. Other members of the Council and employees at ACE Denmark
have been involved in respect of relevant topics.
The review panel found the self-evaluation report to be well laid out and
informative. However, the panel missed sufficient information in relation to
different quality assurance structures in Denmark, namely ACE Denmark, Danish
Evaluation Institute (EVA) and the Accreditation Council. The panel was also
disappointed that the self-evaluation report was essentially descriptive and
lacking in self-analysis.
The Accreditation Institution submitted 32 annexes to the self-evaluation report;
the most relevant of those translated into English and prepared to translate any
further documents upon the panel request. The panel found annexes sufficiently
informative and was able to benefit from the additional information that was
provided.
Site visit
The review panel visited the offices of ACE Denmark in Copenhagen on 17 – 18
June 2010. The panel held a telephone briefing with ENQA vice-president and
staff member on 14 June 2010 and a preparatory meeting the day before the
review to further discuss the self-evaluation report and other available
information. The panel also further discussed the initial lines of inquiry and
distributed tasks between themselves.
During the two-day visit the panel met with different groups of the Accreditation
Institution representatives and higher education stakeholders. Programme of the
visit is included in the annex 2 of this report. The panel felt convinced that scope
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and level of the programme provided relevant information for the review and
provided relevant additional information.
The site visit was expeditiously prepared and well organised. ACE Denmark
offered strong organisational support prior and during the visit. Its staff was at
all times available and provided the panel with all necessary information and
access to additional documents. Furthermore, ACE Denmark's support regarding
the logistical organisation, transport, accommodation and meals, was of a very
high order.
Concluding the report
During the visit and after the programme finished the panel members discussed
in detail the compliance of the Accreditation Institution with all of the ESG and
ENQA membership criteria. They reached high degree of consensus on each
criterion separately.
After the visit the review secretary prepared the initial draft report in cooperation
with the chair and panel members. It was submitted to the Accreditation
Institution for comment on its factual accuracy.
After receiving comments, further revisions to the report was agreed between
the Review Chair and Review Secretary, in consultation with the panel. The final
text was then submitted by the review secretary to the ENQA Secretariat for the
attention of the Board, and to the Accreditation Institution.
CONTEXT OF THE REVIEW
Higher education system in Denmark
1
Danish higher education programmes are organised according to a binary
division between research-based and professionally based programmes. The
purpose of the research-based programmes is to educate students to the highest
international standards within and across the research-based disciplines, whereas
the purpose of the professionally oriented programmes is to ensure education
closely based on practice and at an international level to meet the need for well
qualified professionals in the private and public sectors. The Danish higher
education programmes fall under the auspices of different ministries.
The research-based programmes are offered by eight universities, and regulated
by the Ministry of Science in the Danish University Act (Universitetsloven). There
are approximately 1,050 study programmes, educating approximately 121,000
students. ACE Denmark is the operator of accreditation of these research-based
higher education programmes in the university sector. Following the University
Act of 2003, all universities are organised as self-governing institutions funded
by the state. In 2007, a merging of several institutions took place and thus
reduced the overall number of universities to 8; for example the Royal Veterinary
1
Parts of this chapter are taken from:
- Eurydice – Eurybase Descriptions of National Education Systems and Policies;
- Accreditation Institution’s self evaluation report.
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and Agricultural School is now part of University of Copenhagen and the Danish
School of Education merged with University of Aarhus. The aim was to create
new and stronger universities with better services as part of the Danish
government’s globalization strategy. In addition, 3 major new government
research institutes have also been established.
The professionally oriented programmes with approximately 83,000 students are
predominantly offered by seven University Colleges and ten Academies of
Professional Higher Education. Whereas the university programmes are research-
based, these programmes are based on development and close contact with
practice. These programmes and institutions are regulated by the Ministry of
Education. The programmes fall under the Danish Act on Academy Profession
and Professional Bachelor Programmes (Lov om erhvervsakademi- og
professionsbacheloruddannelser). As of January 2008, a merging of the
university colleges and centres of higher education (CVU) took place and resulted
in 8 new regional university colleges
(professionshøjskole).
Furthermore 10 new
academies of professional higher education (consisting of the existing business
and technical colleges) have been established. They offer short-cycle education
(KVU) and further adult education (VVU). The aim of these new structures is to
strengthen the development and cooperation of medium- and short-cycle higher
education.
A third, and smaller, group of educational programmes fall under the auspices of
the Ministry of Culture and encompass educational programmes in the Arts, and
provide education for approximately 5,000 students at fifteen institutions. The
programmes in the Arts are governed by the Danish Act on Tertiary Artistic
Education Institutions under the Auspices of the Ministry of Culture (Lov om
videregående kunstneriske uddannelsesinstitutioner under Kulturministeriet) and
by the Danish Royal School of Library and Information Science Act (Lov om
Danmarks Biblioteksskole). It should be mentioned that specific institutions
under the auspices of the Ministry of Culture also offer research-based
programmes.
Finally, there are the professionally oriented programmes offered at institutions
under the auspices of other ministries, e.g. the Ministry of Defence, the Ministry
of Economic and Business Affairs and the Ministry of Justice.
As already mentioned, most Danish institutions of higher education have been
merged to form larger units in recent years. This means both that the institutions
have been strengthened with more students and a broader provision of study
programmes, but also that the administrative systems are undergoing adaptation
and development.
The Danish higher education system is organised into four qualification levels,
with a number of both ordinary and adult further education degree types at each
level. The Danish qualification framework systematically describes the different
degree types within the Danish higher education system. Students completing
non-university higher education receive a diploma after one to four years. There
are a number of medium tertiary (non-university) educations that last three to
four years and lead to specialised job-specific qualifications. With the University
Reform, the 3+2 structure of 3- year BAs followed by 2-year postgraduate
candidate/master programmes has been implemented in all university degrees.
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Historical Overview of the quality assurance system in Denmark
In the early 1990’s, the Danish government established Centre for Quality
Assurance and Evaluation in Higher Education (Evalueringscenteret). This agency
was one of the early quality assurance agencies for higher education and played
a significant role in the quality assurance system in Europe. In 1999
Evalueringscenteret was incorporated in a new Danish Evaluation Institute
(Danmarks
Evalueringsinstitut
– EVA). The new agency as part of a wide
mandate conducted a number of external programme evaluations of the Danish
higher education programmes. These were part of a systematic evaluation of all
higher education institutions and their programmes. While the results of the
evaluations were not legally binding, and the evaluations also could not have any
financial consequences for the institutions the reports were viewed as having
considerable influence on the policies and practices of the universities and
colleges reviewed by EVA.
The Danish Accreditation Institution was established by law in 2007. The
establishment came as a natural extension of Denmark’s adoption of the Bologna
declaration in 1999, according to which Denmark is under an obligation to
incorporate quality assurance in the Danish legislation on higher education.
Denmark also undertook to enter into collaboration on quality assurance at the
European level.
The Danish Government launched a Globalisation Strategy in 2006 which aimed
at strengthening Denmark’s position in the increasing international competition.
As part of this strategy the government aimed to make Danish higher education
programmes world-class and meet international quality standards The
programmes would also be required to comply with society’s demand for highly
qualified and competitive labour.
The new approach set out to reduce the number of universities and higher
education institutions and to ensure an independent and focussed strategic
approach by these institutions through reform of their governance systems. This
was in line with developments, or at least proposals, in other developed
countries.
Parallel to this approach the government set out to ensure an independent and
rigorous approach to the accreditation of study programmes in Danish
universities and colleges. Responsibility for accreditation of all higher education
study programmes was given to a new statutory body the Accreditation
Institution headed by a small nine member board drawn from senior persons
among the various partners in higher education.
The Accreditation Institution trades under the brand name ACE-DK or Ace-
Denmark
2
.
The panel had some difficulty with the nomenclature of the Institution and its secretariats during the early
part of the review. To the extent that this report may still reflect this confusion the relevant authorities
concerned may consider the extent to which this arises from a fault of the panel or otherwise.
2
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While all higher education programmes are subject to accreditation under the
new system the operation of the reviews and reporting arrangements differ
between different types of institutions:
•
University study programmes are reviewed and reported on by the
operating arm of the Accreditation Institution which also (and perhaps
confusingly) trades as ACE-Denmark. These programmes are offered by
universities under the broad remit and funding of the Ministry Science,
Technology and Innovation.
•
Higher Education programmes in college and other institutions are
reviewed and reported on by EVA which continues to operate under the
recent legislation with a new mandate. While most of these study
programmes come under the remit and funding of the Ministry of
Education some programmes are subject to broad oversight of other
ministries such as Arts, Culture and Defence.
The accreditation decisions are in all cases made by the Accreditation Council
while the evaluation procedures leading up to accreditation decisions can be
performed by ACE Denmark, EVA or possibly other organisations.
While the accreditation system established in 2007 is in large measure
sui
generis
and reflects the particular needs of Denmark at that time the board and
executive have succeeded in establishing very good working relations between
the various bodies involved.
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COMPLIANCE WITH THE EUROPEAN STANDARDS AND GUIDELINES
1. ENQA CRITERION 1
1.1 ESG PART 2
1.1.1 ESG 2.1 USE OF INTERNAL QUALITY ASSURANCE PROCEDURES
STANDARD:
External quality assurance procedures should take into account the effectiveness
of the internal quality assurance processes described in Part 1 of the European
Standards and Guidelines.
GUIDELINES:
The standards for internal quality assurance contained in Part 1 provide a
valuable basis for the external quality assessment process. It is important that
the institutions’ own internal policies and procedures are carefully evaluated in
the course of external procedures, to determine the extent to which the
standards are being met.
If higher education institutions are to be able to demonstrate the effectiveness of
their own internal quality assurance processes, and if those processes properly
assure quality and standards, then external processes might be less intensive
than otherwise.
According to the Danish Accreditation Act, the Accreditation Institution takes
accreditation decisions based on five criteria laid down in the Accreditation order
issued by the Minister of Science, Technology and Innovation. Among the five
criteria is one which requires the Accreditation Institution review to determine
whether study programmes have continuous internal quality assurance in place.
In addition to these five criteria there may be additional criteria for a smaller
number of study programmes that are under the auspices of the Ministry of
Education, Ministry of Culture or other ministries.
The review panel gathered additional evidence at the site visit and extra
information from the interviews with various stakeholders. The panel
understands that during the process of programme accreditation the
Accreditation Institution gathers information on internal quality assurance
regarding the study programme in question based on the documentation
received by the HEI and at the site visit. The Institution also takes into account
the information provided by the HEI and the self evaluation report it receives.
The panel recognises that the requirements for the documentation of the
institution’s quality assurance system have been made more explicit by the
reduction of the ten accreditation criteria to the current five criteria. The
Accreditation Institution has pointed out to the panel that they recognise the
need to establish the effectiveness of the internal quality assurance systems as a
key focus of an accreditation and the need to diminish the bureaucratic burden
for instance by ensuring that the universities will only have to document
standard descriptions once, unless specific circumstances warrant otherwise.
However, since the accreditation system in Denmark focuses exclusively on study
programmes it sometimes happens that the reviews give insufficient emphasis to
an analysis of the university’s internal quality assurance system. The
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Accreditation Institution focuses on elements that are directly connected to the
quality assurance of study programmes under revision and less on the
institutional quality assurance as a whole. Thus it can happen that some parts of
institutional quality assurance are overlooked or that HEIs sometimes provide
same information several times.
Standard fulfilment: Substantially compliant
Recommendations:
The Accreditation Institution should develop an approach that takes into account
institutional internal quality assurance as a whole that is linked to study
programmes.
In addition to noting internal quality assurance the Accreditation Institution
should put more emphasis on evaluation of its effectiveness as well.
1.1.2 ESG 2.2 DEVELOPMENT OF EXTERNAL QUALITY ASSURANCE PROCESSES
STANDARD:
The aims and objectives of quality assurance processes should be determined
before the processes themselves are developed, by all those responsible
(including higher education institutions) and should be published with a
description of the procedures to be used.
GUIDELINES:
In order to ensure clarity of purpose and transparency of procedures, external
quality assurance methods should be designed and developed through a process
involving key stakeholders, including higher education institutions. The
procedures that are finally agreed should be published and should contain explicit
statements of the aims and objectives of the processes as well as a description of
the procedures to be used.
As external quality assurance makes demands on the institutions involved, a
preliminary impact assessment should be undertaken to ensure that the
procedures to be adopted are appropriate and do not interfere more than
necessary with the normal work of higher education institutions.
Danish Accreditation Act was enacted in 2007 after wide public consultation and
debate. Following the Act the Accreditation Order was issued in which 10 criteria
for accreditation were defined. The Accreditation Institution developed detailed
Guidelines for accreditation in which it further elaborated procedures for
accreditation. The criteria and guidelines were published and available prior to
accreditation.
After the first round of accreditation a thorough revision of accreditation
procedures and criteria was made by the Accreditation Institution. In this
revision HEIs and other stakeholders were consulted as well as experts that
cooperated in the reviews. The Accreditation Institution suggested updates of the
criteria to the Minister of Science, Technology and Innovation. In order for
criteria to be more comprehensive, the number was reduced from ten to five.
The stakeholders the panel interviewed showed satisfaction on this issue. After
the reduction was made, the Accreditation Institution updated the Guidelines for
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accreditation. The Institution constantly consults HEIs, other stakeholders and
experts in order to develop accreditation procedures to be most fit for purpose.
Stakeholders are to a wide extent involved on an ongoing basis in the
development and adaptation of the overall accreditation concept. At the same
time, the Accreditation Institution is aware at all times that the involvement of
stakeholders must not take place at the expense of the independence.
Figure 1: Overview of the process for the review of the executive order and the
guidelines taken from the self evaluation report
August 2009
The Accreditation Council and
ACE Denmark submit a
proposal for a new executive
order to the Ministry of
Science, Technology and
Innovation
December 2009
The Ministry of Science,
Technology and Innovation
publishes a new executive
order
1 March 2010
The Accreditation Council and
ACE Denmark publish
guidelines for new and existing
study programmes
- Joint meetings held with the
universities on
17 June, 25
June and 18 August
- Meeting held with student
organisations on
21 August
- The Ministry of Science,
Technology and Innovation
submits the proposal for a new
executive order for
consultation
- The proposal is presented to
students and employers at a
dialogue forum
- Individual meetings held with all
universities in December
- Joint meeting held with the universities on
14 January
- Meeting held with employers and students
on 25 January
- Guidelines submitted for consultation 1-15
February
At the interviews the panel learned that although stakeholders are included in
the process of development of accreditation procedures, their suggestions are
not always fully implemented. This is however self evident due to independency
of the Institution.
Standard fulfilment: Fully compliant
Recommendations:
We suggest to the Accreditation Institution endeavour to increase involvement of
HEIs and students in the ownership of the accreditation guidelines and
procedures. This would allow HEIs to better transfer the quality / accreditation
requirements into their institutional practice.
1.1.3 ESG 2.3 CRITERIA FOR DECISIONS
STANDARD:
Any formal decisions made as a result of an external quality assurance activity
should be based on explicit published criteria that are applied consistently.
GUIDELINES:
Formal decisions made by quality assurance agencies have a significant impact
on the institutions and programmes that are judged. In the interests of equity
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and reliability, decisions should be based on published criteria and interpreted in
a consistent manner. Conclusions should be based on recorded evidence and
agencies should have in place ways of moderating conclusions, if necessary.
The accreditation criteria, guidelines and procedures are published and publicly
available as shown in the documents provided to the panel, on the Accreditation
Institution webpage and as discussed at the interviews.
Stakeholders at the interviews on the site visit also mentioned that
comprehensive understanding and explanation of the criteria by the ACE
Denmark’s staff improved over the two years and that criteria are now
consistently interpreted and used.
In addition the Accreditation Institution puts great emphasis on the consistent
usage of criteria and guidelines. This is guaranteed by several measures:
-
Before each accreditation round ACE Denmark’s staff is divided into teams
on the basis of disciplines. Junior and senior staff is mixed as well. The
teams then follow the whole accreditation procedure and ensure
consistency of methods and criteria for the whole range of programmes
that have been assigned to them.
The experts who form review panels take part in the general training
organised by ACE Denmark.
In addition prior to the site visit each expert team gathers at the
preparation meeting at ACE Denmark to prepare for the site visit. At this
meeting participants go through the agenda, questions and lines of
inquiry.
At the site visit ACE Denmark’s staff are present but are not full equal
members of expert teams.
When final accreditation reports are handed to the Accreditation Council, it
again checks and compares the criteria fulfilment through all of the reports
in a manner of overall consistency of assessments across universities and
educational fields. The analyses comprise all current accreditations as well
as experience gained from previous accreditation processes.
-
-
-
-
Standard fulfilment: Fully compliant
1.1.4 ESG 2.4 PROCESSES FIT FOR PURPOSE
STANDARD:
All external quality assurance processes should be designed specifically to ensure
their fitness to achieve the aims and objectives set for them.
GUIDELINES:
Quality assurance agencies within the EHEA undertake different external
processes for different purposes and in different ways. It is of the first
importance that agencies should operate procedures which are fit for their own
defined and published purposes. Experience has shown, however, that there are
some widely-used elements of external review processes which not only help to
ensure their validity, reliability and usefulness, but also provide a basis for the
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European dimension to quality assurance. Amongst these elements the following
are particularly noteworthy:
• insistence that the experts undertaking the external quality assurance activity
have appropriate skills and are competent to perform their task;
• the exercise of care in the selection of experts;
• the provision of appropriate briefing or training for experts;
• the use of international experts;
• participation of students;
• ensuring that the review procedures used are sufficient to provide adequate
evidence to support the findings and conclusions reached;
• the use of the self-evaluation/site visit/draft report/published report/follow-up
model of review;
• recognition of the importance of institutional improvement and enhancement
• policies as a fundamental element in the assurance of quality.
Expert teams are always carefully selected by the Accreditation Institution. HEIs
are invited to suggest experts to the agency’s data base of experts from which
panels are selected. Ultimately the Accreditation Institution finally decides for
each expert in order to guarantee objectivity. It can happen however, that a HEI
is evaluated by the expert it suggested itself. All experts are trained during
workshops and in addition to this training they are invited for initiative meeting
at ACE Denmark before they go on the site visit. However, the panel heard on
several occasions that the experts were not always fully relevant for the
programme under evaluation.
Processes are based on a model: detailed guidelines are issued and presented to
HEIs, self-evaluation reports and documentation from HEIs, initial workshop for
expert teams, external review, initial draft expert report, comments by HEIs,
expert report, accreditation decision, published report, and to a varying degree
follow-up. A final report provides clear information on fulfilment of each
accreditation criteria as well as recommendations for quality improvement.
Accreditation criteria are developed for the process and consistently
applied. Prior to each accreditation round, ACE Denmark holds a start-up
meeting at the universities with the quality managers and representatives of the
study programmes which are to be accredited. The meeting is used to present
and discuss the process, criteria and measuring points.
The Accreditation Institution often uses international experts in the expert teams
which are formed by three members. One of those members is always a student.
One student is also a full and equal member of the Accreditation Council which
has altogether nine members.
The guidelines for accreditation are very detailed and the Accreditation
Institution gets the evidence for all. It can sometimes happen that the material
that is demanded of HEIs duplicates and can be a heavy administrative burden.
The panel, however, is concerned about the accreditation of new study
programmes. Our concern was endorsed also by various stakeholders at the
interviews. The panel realises that due to the legal requirement experts are used
for accreditation of existing study programmes. New study programmes are
assessed for accreditation by ACE Denmark’s staff who prepare a report for the
Accreditation Council. The Accreditation Council decides whether to accredit the
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new programme. Expert panels are used only in exceptional cases. In our view
this arrangement does not ensure consistent and expert treatment of all study
programmes (new and existing). In addition to this, new study programmes are
accredited for the same length as existing, which is 6 years and without the
external expert judgement.
The panel gave some consideration to the fact that only one academic expert is
involved in the accreditation process of existing study programmes. As already
mentioned, the expert teams consists of three members: one academic expert,
one student and one employer. The panel believes that a peer review model used
for subject wise accreditation of study programmes would gain in involving more
than one academic expert. This would ensure an accreditation model better fit for
its purpose.
Another concern is sometimes the involvement of ACE staff (consultants) in the
review at content level. The fact that there are two of them on the site visit with
each panel is also a source of imbalance in the interactions with programme
representatives.
Standard fulfilment: Substantially compliant
Recommendations:
The Accreditation Institution should consider how to include experts also for
accreditation of new study programmes.
The Accreditation Institution should consider involving more than one academic
expert in the accreditation of existing study programmes.
1.1.5 ESG 2.5 REPORTING
STANDARD:
Reports should be published and should be written in a style which is clear and
readily accessible to its intended readership. Any decisions, commendations or
recommendations contained in reports should be easy for a reader to find.
GUIDELINES:
In order to ensure maximum benefit from external quality assurance processes,
it is important that reports should meet the identified needs of the intended
readership.
Reports are sometimes intended for different readership groups and this will
require careful attention to structure, content, style and tone.
In general, reports should be structured to cover description, analysis (including
relevant evidence), conclusions, commendations, and recommendations. There
should be sufficient preliminary explanation to enable a lay reader to understand
the purposes of the review, its form, and the criteria used in making decisions.
Key findings, conclusions and recommendations should be easily locatable by
readers. Reports should be published in a readily accessible form and there
should be opportunities for readers and users of the reports (both within the
relevant institution and outside it) to comment on their usefulness.
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All accreditation reports are published and are structured in the same manner.
They contain, in chronological order: Introduction; information on the panel and
the case processing, timetable etc.; recommendation; summary of assessments;
critical legal factors; basic information; competency profile of the study
programme; structure of the study programme; assessment; and legality.
However, as pointed out by the Accreditation Institution itself, they are not too
simple to read by a general reader as the main purpose of the report is to
provide information for accreditation decision. Thus the reports do not seem to
be used as student information about study programmes.
Standard fulfilment: Fully compliant
Recommendations:
We recommend to the Accreditation Institution that it tries to further develop the
accreditation reports in a way that is more comprehensive and useful for a
general reader.
1.1.6 ESG 2.6 FOLLOW-UP PROCEDURES
STANDARD:
Quality assurance processes which contain recommendations for action or which
require a subsequent action plan, should have a predetermined follow-up
procedure which is implemented consistently.
GUIDELINES:
Quality assurance is not principally about individual external scrutiny events: It
should be about continuously trying to do a better job. External quality
assurance does not end with the publication of the report and should include a
structured follow-up procedure to ensure that recommendations are dealt with
appropriately and any required action plans drawn up and implemented. This
may involve further meetings with institutional or programme representatives.
The objective is to ensure that areas identified for improvement are dealt with
speedily and that further enhancement is encouraged.
As the Accreditation Institution can make three decisions (positive accreditation,
conditional positive accreditation and refusal of accreditation), the follow up
procedures are elaborated in case of conditional positive accreditation.
Conditional positive accreditation means that a study programme does not meat
one or more accreditation criteria and accreditation has a shorter period of
‘validity’, namely 1 or 2 years. During this time the study programme has a
possibility to implement changes and improvements in the areas that were found
to be ‘problematic’. At the next accreditation only the areas identified before are
checked. In this case the Accreditation Council can only make two decisions:
positive accreditation or refusal of accreditation.
For study programmes with a positive accreditation, follow-up on the part of the
Accreditation Council and ACE Denmark is only carried out once the study
programme again forms part of the rotation (cycle). These study programmes
may – in addition to the decision on the positive accreditation – receive
recommendations from the Council in the form of critical factors and comments.
Critical factors have no bearing on the formal decision. It is up to the universities
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alone to act on the critical factors. The Accreditation Institution does not carry
out actual follow-up on the critical factors, which typically highlight areas on
which the Council finds the universities should focus in their further quality
development of the study programmes.
Standard fulfilment: Fully compliant
Recommendations:
The panel realises that in the context of such strict accreditation system there is
no legal need or opportunity for follow up after the positive decision. However, in
order to ensure further development of institutional quality, we suggest the
Accreditation Institution to develop follow up procedures to offer support to HEIs
even in case of positive accreditation.
1.1.7 ESG 2.7 PERIODIC REVIEWS
STANDARD:
External quality assurance of institutions and/or programmes should be
undertaken on a cyclical basis. The length of the cycle and the review procedures
to be used should be clearly defined and published in advance.
GUIDELINES:
Quality assurance is not a static but a dynamic process. It should be continuous
and not “once in a lifetime”. It does not end with the first review or with the
completion of the formal follow-up procedure. It has to be periodically renewed.
Subsequent external reviews should take into account progress that has been
made since the previous event. The process to be used in all external reviews
should be clearly defined by the external quality assurance agency and its
demands on institutions should not be greater than are necessary for the
achievement of its objectives.
The study programmes are subject to accreditation every 6 years which is clearly
defined and published. The Accreditation Institution can decide to evaluate a
study programme even before the ‘accreditation expires’. In case of conditional
positive accreditation, the programme is subject to accreditation in 1 or 2 years.
With the establishment of the Accreditation Institution in 2007, the study
programmes are being accredited for the first time. The rotation plan covers the
period 2008-14 and comprises the approx. 1,050 university study programmes.
The current rotation plan thus runs until 2015, after which time the programmes
must be reaccredited. This ensures a cyclical assessment of all university study
programmes. The Accreditation Institution is also responsible for accrediting
proposals for new study programmes.
Standard fulfilment: Fully compliant
1.1.8 ESG 2.8 SYSTEM-WIDE ANALYSES
STANDARD:
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Quality assurance agencies should produce from time to time summary reports
describing and analysing the general findings of their reviews, evaluations,
assessments, etc.
GUIDELINES:
All external quality assurance agencies collect a wealth of information about
individual programmes and/or institutions and this provides material for
structured analyses across whole higher education systems. Such analyses can
provide very useful information about developments, trends, emerging good
practice and areas of persistent difficulty or weakness and can become useful
tools for policy development and quality enhancement. Agencies should consider
including a research and development function within their activities, to help
them extract maximum benefit from their work.
The Accreditation Institution is a young organisation that successfully set up
resources, procedures and methods in a very short period of time. So far it has
developed an overall analysis of criteria and methods after the first accreditation
round which ended up in reduction of criteria, more comprehensive system and
new guidelines for accreditation.
At the site visit the panel was informed that as development of the rules and
procedures guiding the processes of the work of the Accreditation Institution and
on the other hand developing the principles and procedures of the accreditation
process itself is now firmly established, the Accreditation Institution has
commenced work on system-wide analyses that may serve as a vehicle for
quality assurance and quality improvement in the Danish universities.
In addition to the information already provided, the panel learned about the
following plans of the Accreditation Institution:
In the course of 2010, the Accreditation Institution has planned an analysis of
“New tendencies in the educational landscape”. The analysis will take as a point
of departure the information gathered through the accreditation of new
university programme in the period 2008-2010. Apart from discussing the trends
and tendencies emanating from the analysis, it will also provide a systematic
presentation, based on commonality of characteristics, of the programmes
applied for and accredited during the period. Another interesting aspect that may
emerge from such an analysis is the possibility to identify the strengths and
weaknesses, amongst the new programmes, resulting from the application of the
various criteria across the different academic sub-fields. The results will be
published and discussed with the stakeholders - amongst other in the Dialogue
Forum.
In 2011, the Accreditation Institution will select a limited number of clusters of
educations that will be undergoing a closer analysis with a focus on mechanisms
to assure the continuous relevance of the programmes taught based on an
analysis involving amongst other the educational programmes’ on-going contacts
with graduated students, prospective employers, and other labour market
representatives. The programmes accredited during the first years of activity of
the Accreditation Institution will be a key source in the development of the study.
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Further, the Accreditation Institution plans some analyses of a more limited
scope: In 2010 the Institution will amongst other publish material targeting
students to demonstrate the relevance of programme accreditation to students.
In addition, the Institution will be contributing to broader – albeit not necessarily
system-wide – analyses in a Nordic and international context, such as the NOQA
projects, where the Institution has contributed to the 2009 study on the
accreditation/evaluation of joint master programmes and played an active role in
the 2010 study of the role of the expert-panels’ visit in the accreditation process.
The Institution intends to increase this international activity following the future
membership of organisations such as ENQA, ECA and EQAR.
Standard fulfilment: Partially compliant
1.2 ESG 3.1 USE OF EXTERNAL QUALITY ASSURANCE PROCEDURES FOR
HIGHER EDUCATION
Standard
The external quality assurance agencies should take into account the presence
and effectiveness of the external quality assurance procedures described in Part
2 of the European Standard and Guidelines.
Guidelines
The standards for external quality assurance contained in Part 2 provide a
valuable basis for the external quality assessment process. The standards reflect
best practices and experiences gained through the development of external
quality assurance in Europe since the early 1990s. It is therefore important that
these standards are integrated into the processes applied by external quality
assurance agencies towards the higher education institutions. The standards for
external quality assurance should together with the standards for external quality
assurance agencies constitute the basis for professional and credible external
quality assurance of higher education institutions.
The above sections on the relation between ESG 3.1 and ESG 2.1 – 2.8 include a
number of recommendations and reflections, and some findings of substantial
rather than full compliance regarding the standards of section 2.
The overall conclusion of the review panel is that the Accreditation Institution
complies substantially with ESG 3.1.
1.3 ESG 3.3 ACTIVITIES
STANDARD:
Agencies should undertake external quality assurance activities (at institutional
or programme level) on a regular basis.
GUIDELINES:
These may involve evaluation, review, audit, assessment, accreditation or other
similar activities and should be part of the core functions of the agency.
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The Accreditation Institution was established with the purpose of external quality
assurance. Accreditation is its main activity and is performed on a regular basis.
The universities have been informed that the Accreditation Institution is
authorised to make the following decisions regarding accreditation of the existing
study programmes:
- Positive accreditation if the Council assesses that the study programme in
general meets the accreditation criteria.
- Conditional positive accreditation if the Council assesses that the study
programme does not fully meet the conditions for a positive accreditation, but it
is assessed that it will be able to address the issues in the short term. The
Accreditation Council draws up a schedule for when the issues must be
addressed.
- Refusal of accreditation if the Council assesses that the study programme in
general does not meet the accreditation criteria.
As concerns applications for new study programmes, the Accreditation Council
can either hand down a positive accreditation or a refusal of accreditation.
The accreditations of the first existing study programmes took place in 2008
when 37 programmes were accredited. In the subsequent years, the
Accreditation Institution increased the number of study programmes, and plans
are currently to accredit approx. 150 existing programmes every year from 2010
on onwards. The plan is organised so that accreditations are initiated of approx.
75 study programmes every six months.
Standard fulfilment: Fully compliant
2. ENQA CRITERION 2: ESG 3.2 OFFICIAL STATUS
STANDARD:
Agencies should be formally recognised by competent public authorities in the
European Higher Education Area as agencies with responsibilities for external
quality assurance and should have an established legal basis. They should
comply with any requirements of the legislative jurisdictions within which they
operate.
The Accreditation Institution is formally recognised and set up by the
Accreditation Act in 2007 as a professionally independent body within the State
administration. The Institution is subject to the State rules and regulations,
including the Danish Public Administration Act, the Danish Access to Public
Administration Files Act (Offentlighedsloven) and the Ministry of Finance’s Budget
Guidelines (Finansministeriets Budgetvejledning). The Accreditation Institution is
not subject to the power of instruction of the Minister in relation to accreditation
issues. The panel, however, would like to further elaborate and explain different
structures within the Accreditation Institution and relations between them.
The Accreditation Institution consists of the Accreditation Council as the main
decision making body and ACE Denmark, which includes two secretariats that are
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also defined in the Accreditation Act. The Council Secretariat administratively
supports the Council. As the panel learned at the site visit this mainly includes
help with setting up meetings, document circulation, minutes keeping etc. The
task of the Professional Secretariat is carrying out accreditation procedures,
including: development of accreditation guidelines, training of experts, receiving
applications, preparing site visits, attendance at site visits, drafting accreditation
reports, preparing final reports, etc. From an organisational point there is also an
Administrative Unit that supports the Accreditation Institution as such: human
resources, legal support, etc.
The Accreditation Council also makes accreditation decisions for study
programmes under the auspices of other ministries than the Ministry of Science,
Technology and Innovation and in this case it receives accreditation reports from
EVA (Danish Evaluation Institute). EVA is, however, independent from ACE
Denmark and from the Accreditation Institution as such.
Standard fulfilment: Fully compliant
3. ENQA CRITERION 3: ESG 3.4 RESOURCES
STANDARD:
Agencies should have adequate and proportional resources, both human and
financial, to enable them to organise and run their external quality assurance
process(es) in an effective and efficient manner, with appropriate provision for
the development of their processes and procedures.
The Accreditation Institution has adequate resources. The number of staff grew
gradually from 21 FTE in 2008 to 29,5 FTE in 2009 and currently 37 employees
(34 FTE), which was estimated to be sufficient for the tasks and workload of the
Accreditation Institution (approximately 150 existing study programmes and 40
new study programmes annually).
The financial resources are also adequate to support the structure and work of
the Institution. In 2008 the annual budget was 17.3 million DKK (approximately
2,3 million EUR) and in 2009 18 million DKK (approximately 2,4 million EUR)
with supplementary funding in 2009 of 5,4 million DKK (approximately 725.000
EUR).
Staff gained in their competence since the establishment of the Institution. Since
the staff was young and mainly new to the field, the Institution offered
substantial training and support. It was mentioned in the interviews that
sometimes the interpretation of criteria by ACE staff was not comprehensive and
consistent in the past but that their competence for support of accreditation
procedures and criteria interpretation and usage grew.
Standard fulfilment: Fully compliant
Recommendations:
The panel recommends that further training be provided for staff and that they
be offered special support in writing accreditation reports.
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4. ENQA CRITERION 4: ESG 3.5 MISSION STATEMENT
STANDARD:
Agencies should have clear and explicit goals and objectives for their work,
contained in a publicly available statement.
GUIDELINES:
These statements should describe the goals and objectives of agencies’ quality
assurance processes, the division of labour with relevant stakeholders in higher
education, especially the higher education institutions, and the cultural and
historical context of their work. The statements should make clear that the
external quality assurance process is a major activity of the agency and that
there exists a systematic approach to achieving its goals and objectives. There
should also be documentation to demonstrate how the statements are translated
into a clear policy and management plan.
The Accreditation Institution’s mission, vision and values are publicly available
and read as follows:
Mission:
“As an independent operator, ACE Denmark contributes to ensuring the quality
and relevance of higher education in Denmark. Our accreditation work is based
on national and international quality assurance standards. ACE Denmark
generates knowledge on the quality of higher education through a dialogue with
the educational institutions and other relevant interested parties.”
Vision:
“The Accreditation Council and ACE Denmark strive to be a leading quality
assurance institution in Denmark and abroad that documents and generates new,
useful knowledge on the quality and relevance of higher education.”
Values:
“The Accreditation Council and ACE Denmark have four core values which run
through all of our accreditation work: The core values are: Independence,
transparency, professional capability and openness.
In addition, the performance contract, director’s contract, annual review and
annual report set out goals and results for the organisation. The goals from the
performance and director’s contracts have also been implemented in a
management plan.
Standard fulfilment: Fully compliant
5. ENQA CRITERION 5: ESG 3.6 INDEPENDENCE
STANDARD:
Agencies should be independent to the extent both that they have autonomous
responsibility for their operations and that the conclusions and recommendations
made in their reports cannot be influenced by third parties such as higher
education institutions, ministries or other stakeholders.
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GUIDELINES:
An agency will need to demonstrate its independence through measures, such
as:
• its operational independence from higher education institutions and
governments
• is guaranteed in official documentation (e.g. instruments of governance or
legislative acts);
• the definition and operation of its procedures and methods, the nomination and
appointment of external experts and the determination of the outcomes of its
quality assurance processes are undertaken autonomously and independently
from governments, higher education institutions, and organs of political
influence;
• while relevant stakeholders in higher education, particularly students/learners,
are consulted in the course of quality assurance processes, the final outcomes of
the quality assurance processes remain the responsibility of the agency.
According to the Accreditation Act, the Accreditation Institution is independent
organisation within the public administration. The panel found that the Institution
meets the criterion Independence in relation to higher education institutions,
ministries and other stakeholders.
The Accreditation Council has a Chairman, a Vice-chairman and seven other
members. The Minister for Science appoints the Chairman after consulting with
the Minister for Education and the Minister for Culture. In addition, the Minister
for Science appoints eight members, of whom three have been nominated by the
Minister for Education and one by the Minister for Culture. The Minister for
Science appoints three members. The last member is a student who is appointed
by the Minister for Science following a nomination from the student
representatives on the executive committees of the institutions of higher
education.
Since it is the Minister who appoints members of the Council it might seem to
influence the independence of the Accreditation Institution. However, at the site
visit the panel learned about the national (legal) context, the procedure that
leads to the appointment and the general understanding of the independence by
all stakeholders. The choice of the Council members follows wide public
consultation in which all stakeholders have opportunity to suggest members. The
panel inquired in detail what was the actual process of nomination of members,
which happened once until now. We learned that there was generally wide
consensus among all relevant parties which members are to be nominated. There
were some members that caused some concern among some stakeholders,
however, at the interviews all stakeholders confirmed and even assured that the
Council is completely independent and is not influenced by either of the
ministries, nor by HEIs or other parties. The Accreditation Institution also
independently decides upon the processes it uses as well as expert appointment.
The Accreditation Institution worked even further on the perceived
independence. Although the Accreditation Institution is completely independent
in evaluating study programmes according to the criteria and preparing final
accreditation reports, it holds discussions with the ministry regarding legal
matters that exclude expert, content discussion. Initially reports were not
published until after discussions with the ministry on specific legal matters as set
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out in the ministerial order on criteria on the relevance of study programmes. For
the avoidance of any possible doubt on the independence of the procedures the
Accreditation Institute is in the process of changing this practice so that the
reports are issued after the accreditation process itself is finished and prior any
discussion on legal matters with the ministry.
The panel feels it necessary to elaborate on the appeals procedure and
negotiation for the budget in the light of independence as well as both processes
are connected to the Ministry of Science.
When the draft accreditation report is prepared it is sent to the HEI for
comments (the Accreditation Institution calls this ‘a hearing process’) in which
HEI has a right to comment on the findings. This is then reviewed by ACE
Denmark’s staff and experts involved in the reviews and decided which
comments are to be included in the final accreditation reports. Based on the final
report the Accreditation Council makes a final decision. HEI can then appeal to
the Ministry for the procedural errors and not content decision. This is again
compliant to the national legal framework and is not disputed by any
stakeholder. That kind of appeals procedure does not seem to be understood to
hamper independence by any party.
Regarding the budget negotiation the Accreditation Institution has to negotiate
annually with the ministry on the basis of its work plan. This is, however, a
negotiation about the number of accreditations that will be processed in the
following year including the resources needed for the work plan and not about
which particular accreditations will be done. Thus the panel estimates that this
procedure does not hinder the operational or other type of independence.
The panel believes that there is one aspect in which the Accreditation Institution
could strengthen its independence, which is regarding the accreditation criteria.
As already mentioned before in the report, the general five criteria are laid down
in the Accreditation Order by the Minister of science. There is also an Annex to
this Order in which the five criteria are further developed. The Institution
independently prepares detailed guidelines for accreditation based on these
established criteria in which elements to be evaluated for accreditation are
elaborated. The panel sees this as an important point for improvement of the
independence. From the panel’s point of view the Institution should own the
responsibility to elaborate on the criteria itself or at least the elaboration of the
general five criteria. However, looking at the criterion “Independence”, the panel
does not believe that these circumstances fit in to neither the standard nor the
guidelines for the criterion “Independence”. Therefore, the panel concluded this
standard to be fully compliant.
Standard fulfilment: Fully compliant
Recommendations:
The Accreditation Institution should identify the whole set of accreditation criteria
itself without ministerial interference and freely elaborate them. This would also
provide the opportunity to create consistent criteria for all study programmes
which run under the auspices of different ministries.
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6. ENQA CRITERION 6: ESG 3.7 EXTERNAL QUALITY ASSURANCE
CRITERIA AND PROCESSES USED BY THE AGENCIES
STANDARD:
The processes, criteria and procedures used by agencies should be pre-defined
and publicly available. These processes will normally be expected to include:
• a self-assessment or equivalent procedure by the subject of the quality
assurance process;
• an external assessment by a group of experts, including, as appropriate, (a)
student member(s), and site visits as decided by the agency;
• publication of a report, including any decisions, recommendations or other
formal outcomes;
• a follow-up procedure to review actions taken by the subject of the quality
assurance process in the light of any recommendations contained in the report.
GUIDELINES:
Agencies may develop and use other processes and procedures for particular
purposes. Agencies should pay careful attention to their declared principles at all
times, and ensure both that their requirements and processes are managed
professionally and that their conclusions and decisions are reached in a
consistent manner, even though the decisions are formed by groups of different
people. Agencies that make formal quality assurance decisions or conclusions
which have formal consequences should have an appeals procedure. The nature
and form of the appeals procedure should be determined in the light of the
constitution of each agency.
Processes, criteria and procedures used by the Accreditation Institution are
predefined and publicly available, cf. the analysis of ESG 2.3 (cf. section 1.1.3) of
this report.
The evaluation processes involves the self-assessment phase and an external
assessment by a group of experts including a student member (cf. section 1.1.4,
ESG 2.4). ACE Denmark prepares an accreditation report on every assessment
process undertaken based on the initial report and comments received by HEIs.
The reports are then published on the Institution website.
Follow-up procedures are in place in case of conditional positive accreditation.
Comments and conclusions of the review panel on this subject can be found in
the analysis of ESG 2.6 (cf. section 1.1.6) of this report.
The Accreditation Institution has a procedure in place for HEIs to comment on
the results of the assessment processes that lead to the final accreditation report
and formal decision. After a decision has been taken there is also an appeals
procedure in place (cf. analysis of ESG 3.6 in this report).
We found certain unevenness in the views expressed by representatives of
universities with whom we discussed experience of accreditation site visits. Some
people expressed a high level of satisfaction with the expert teams and their
accompanying staff from ACE Denmark. However others found some unevenness
in the competence of expert panels. There was a lack of unanimity regarding the
influence which may be exercised by ACE Denmark’s staff who accompany the
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panels. The panel recommends the Accreditation Institution to work further on
the consistency of site visits and evaluation procedures.
Another point, which was also already mentioned before, is the inconsistency of
procedures between the accreditation of new study programmes in which the
experts are not involved and the accreditation of existing study programmes in
which experts are involved (cf. analysis ESG 2.4 in this report).
Appeals procedure is also not set up as literally suggested in the guidelines for
the standard 3.7 as the agencies that make formal quality assurance decisions or
conclusions which have formal consequences should have an appeals procedure.
This was already commented previously under the analysis of the ESG 3.6 in this
report.
Standard fulfilment: Substantially compliant
Recommendations:
The Accreditation Institution should consider how to include experts also for
accreditation of new study programmes.
The Accreditation Institution should further work on consistency of site visits in
terms of expert teams and ACE Denmark’s staff role in the teams.
7. ENQA CRITERION 7: ESG 3.8 ACCOUNTABILITY PROCEDURES
STANDARD:
Agencies should have in place procedures for their own accountability.
GUIDELINES:
These procedures are expected to include the following:
1. A published policy for the assurance of the quality of the agency itself, made
available on its website;
2. Documentation which demonstrates that:
• the agency’s processes and results reflect its mission and goals of quality
assurance;
• the agency has in place, and enforces, a no-conflict-of-interest mechanism in
the work of its external experts;
• the agency has reliable mechanisms that ensure the quality of any activities
and material produced by subcontractors, if some or all of the elements in its
quality assurance procedure are subcontracted to other parties;
• the agency has in place internal quality assurance procedures which include an
internal feedback mechanism (i.e. means to collect feedback from its own staff
and council/board); an internal reflection mechanism (i.e. means to react to
internal and external recommendations for improvement); and an external
feedback mechanism (i.e. means to collect feedback from experts and reviewed
institutions for future development) in order to inform and underpin its own
development and improvement.
3. A mandatory cyclical external review of the agency’s activities at least once
every five years.
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The Accreditation Institution has a policy for the assurance of the quality of the
agency itself. ACE Denmark’s quality assurance policy sets out that the quality
assurance work is anchored in the management and comprises the accreditation
processes in connection with both new and existing study programmes. In
addition, the quality assurance policy stipulates that the quality assurance
system must proactively take the core values of the organisation into account
and develop the processes in the accreditation work on the basis of systematic
cyclical measurements. The Accreditation Institution also has several procedures
that function as internal reflection mechanisms in place. One of them is constant
internal feedback from staff and focus on process improvement. The other is
feedback from experts that take part in expert teams. The Council has thus
organised a quality assurance cycle in order to systematically safeguard key
elements in the operators’ processes and methods. The quality assurance cycle is
based on a transparent and predictable review of selected parts of the ACE
Denmark’s processes and methods.
Concerning the external feedback mechanism, an evaluation of the universities’
experience with the accreditation process was carried out already after the
Accreditation Institution’s first accreditation round. Moreover, an evaluation of
the accreditation of new study programmes which took place in spring/summer
2008 has also been carried out. Survey was made of views of stakeholders or
relevant actors regarding the satisfaction of the accreditation process. In addition
to this conferences with higher education stakeholders are organised to discuss
procedures and necessary changes as well as a so-called Dialogue Forum is
organised. The Accreditation Institution has also held meetings with
representatives of the universities as well as other stakeholders to discuss
procedures and necessary changes.
At the site visit it was mentioned by several stakeholders that they do have the
opportunity to comment on accreditation procedures and some recommendations
are taken into account by the Accreditation Institution, but not all. Some of them
feel that they are “listened to, but not heard”. The panel understands this
concern, although the independence of the Institution has to be safeguarded.
It is, however, strangely put in the self evaluation report that the Accreditation
Council quality assures ACE Denmark although both bodies are a part of the
Accreditation Institution. The panel learned at the site visit that this refers to the
general responsibility for the quality of the Institution and that there are
sufficient accountability procedures in place.
Standard fulfilment: Fully compliant
Recommendations:
The Accreditation Institution could improve consideration of feedback by
stakeholders.
8. ENQA CRITERION 8: Miscellaneous
i. The agency pays careful attention to its declared principles at all times, and
ensures both that its requirements and processes are managed professionally
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and that its judgments and decisions are reached in a consistent manner, even if
the judgments are formed by different groups;
ii. If the agency makes formal quality assurance decisions, or conclusions which
have formal consequences, it should have an appeals procedure. The nature and
form of the appeals procedure should be determined in the light of the
constitution of the agency;
iii. The agency is willing to contribute actively to the aims of ENQA.
Regarding the Accreditation Institution attention to its declared principles and the
appeals procedures this report already provides sufficient evidence and
interpretation.
The panel also inquired about the Accreditation Institution’s willingness to
contribute to the aims of ENQA. It was clearly stated that the Institution special
focus is the international dimension and contribution to the quality assurance
development in this area. It is prepared to disseminate information, experiences
and good practices in the field of quality assurance (QA) in higher education to
other European QA agencies, public authorities and higher education institutions.
Standard fulfilment: Substantially compliant
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ADDITIONAL RECOMMENDATION
The panel estimates that great work has been done in relatively short time. The
Accreditation Institution managed to set up the rules, procedures and support for
very demanding accreditation system. However, the panel also felt in order to
fully help the Institution to identify further points of development an external
evaluation a year or two later or a type B of evaluation seemed to be more
appropriate. In the type B evaluation, the review has a number of purposes, one
of which is to fulfil the external review requirement of ENQA membership / EQAR
listing. Thus the other purpose could be the overall and comprehensive
assessment of the new external quality assurance system in Denmark as such.
The panel believes that the Accreditation Institution meets most of the standards
to a high level. However, in the light of future development of quality of the
Institution, we would like to make additional suggestions.
The panel found the approach of detailed programme accreditation was
legitimate and operated on a fair basis. However it did appear to be quite
burdensome for the whole quality assurance system and HEIs. Understanding the
political consensus regarding the decision for this approach, the panel
recommends thinking about replacing programme accreditation with institutional
accreditation in the future or more flexible combination of both. The appropriate
time might be after the Accreditation Institution finishes with the first cycle of
accreditations. The picture of quality of study programmes will be clearer at that
point as well as involvement and competence of all stakeholders. For the time
being we suggest to the Institution to think about clustering the study
programmes on national level in the process of accreditation. This would allow
the Accreditation Institution to have a more proactive approach in the
accreditation process, which in turn would improve and facilitate recruitment of
experts, consistency in assessments, benchmarking possibilities for HEIs etc.
The articulation of External Accreditation and Internal Quality Assurance is not
optimal. On the one hand the need to document the effectiveness of the Internal
Quality Assurance system creates a significant increase of the bureaucratic
burden and on the other hand the effectiveness of these internal quality
processes is not checked in a consistent manner.
The current framework in which at least three different ministries set at least
three different kinds of criteria for accreditation seems to hamper the consistency
and general development of quality of study programmes. On the other hand the
Accreditation Institution has the overall responsibility for the quality of study
programmes as well as the most knowledge about the procedures and standards.
The panel thus suggests for the framework to change in a manner to allow the
Institution to have more impact on the different approaches used by different
ministries. This will allow better consistency and standards achievement for all
study programmes.
The panel realises the suggestions made impact the whole system and
competencies of several ministries, thus we feel the possible changes have to be
based on (rational and) real evidence in a sense of process development.
During this process careful consideration should be given to the criteria so that
they are not an obstacle to innovation.
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In the following paragraphs the panel would like to point out the main
recommendations of varying magnitude although some have been already
mentioned before.
Regarding the experts that are involved in the external evaluations we suggest to
include more than one academic expert from the (science) field. The current
situation is that the team comprises of three members: an academic expert, a
student and an employer. In order for the process to be better fit for purpose the
panel suggests to include more than one academic expert. The panel also
recommends reducing the role of ACE Denmark’s staff in the expert teams. The
panel learned that the accreditation officers as employees of ACE Denmark are
not formally equal members of the expert teams. However, there are two officers
present and three external members. The number ratio may be perceived as not
proper by some stakeholders. The other problem that was detected and is not
always present is the active role of the staff at the site visits of HEIs as it can
happen that the officer takes over the questioning and even interrupt the expert
while asking questions. Using a peer review accreditation model the panel
believes that it is important for t he experts to have a responsibility in the
process of choosing questions to be asked and the actual questioning at the site
visit.
For proper consistency and academic as well as expert consideration of all study
programmes the panel suggests including academic experts in the process of
accreditation of new study programmes. The panel already described the
situation and presented the reasons for this suggestion in previous chapters of
the report. The panel suggests also considering the evaluation of PhD study
programmes as the system in place ensures quality for the whole higher
education sector. Thus we believe they should be a part of systematic evaluation.
A particular element in the system which could be easily improved is the
nomination of a student to the Accreditation Council. Currently a great number of
students can suggest members (every student that is a board member at any
Danish HEI) which can lead to the case that there is a high number of suggested
students out of which the minister chooses one. This can cause additional
confusion and lower the transparency procedure. Thus we suggest for the
ministry to cooperate with the representative organisation in the process of
suggesting the student members.
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CONCLUSION
The review panel has in the Accreditation Institution’s self-evaluation report, the
many supplied documents and in the context of the site visit found much to
commend in the Accreditation Institution’s organisation and operations,
especially due to its recent establishment which results in substantial compliance
with the European Standards and Guidelines. Much has been done to set up a
demanding accreditation processes and the Accreditation Institution gained
valuable expertise. All of the stakeholders the panel met pointed out generally
positive developments and showed satisfaction with the Accreditation
Institution’s efforts to candidate for ENQA membership.
There are normally points in the system for further development and
improvement which will contribute to higher quality of the system. The panel
thus posed several recommendations for further development of the system
which are elaborated in the report. The panel recommends the future changes to
be evidence based and consulted between all stakeholders.
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Annex 1: Standards and Guidelines for Quality Assurance in the
European Higher Education Area (ESG)
Part 1
1.1 -
Policy and procedures for quality assurance
Institutions should have a policy and associated procedures for the assurance of
the quality and standards of their programmes and awards. They should also
commit themselves explicitly to the development of a culture which recognises
the importance of quality, and quality assurance, in their work. To achieve this,
institutions should develop and implement a strategy for the continuous
enhancement of quality. The strategy, policy and procedures should have a
formal status and be publicly available. They should also include a role for
students and other stakeholders.
1.2 -
Approval, monitoring and periodic review of programmes and
awards
Institutions should have formal mechanisms for the approval, periodic review and
monitoring of their programmes and awards.
1.3 -
Assessment of students
Students should be assessed using published criteria, regulations and procedures
which are applied consistently.
1.4 -
Quality assurance of teaching staff
Institutions should have ways of satisfying themselves that staff involved with
the teaching of students are qualified and competent to do so. They should be
available to those undertaking external reviews, and commented upon in reports.
1.5 -
Learning resources and student support
Institutions should ensure that the resources available for the support of student
learning are adequate and appropriate for each programme offered.
1.6 -
Information systems
Institutions should ensure that they collect, analyse and use relevant information
for the effective management of their programmes of study and other activities.
1.7 -
Public information
Institutions should regularly publish up to date, impartial and objective
information, both quantitative and qualitative, about the programmes and
awards they are offering.
Part 2
2.1 -
Use of internal quality assurance procedures
External quality assurance procedures should take into account the effectiveness
of the internal quality assurance processes described in Part 1 of the European
Standards and Guidelines.
2.2 -
Development of external quality assurance processes
The aims and objective of quality assurance processes should be determined
before the processes themselves are developed, by all those responsible
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(including higher education institutions) and should be published with a
description of the procedures to be used.
2.3 -
Criteria for decisions
Any formal decisions made as a result of an external quality assurance activity
should be based on explicit published criteria that are applied consistently.
2.4 -
Process fit for purpose
All external quality assurance processes should be designed specifically to ensure
their fitness to achieve the aims and objectives set for them.
2.5 -
Reporting
Reports should be written in a style, which is clear and readily accessible to its
intended readership. Any decisions, commendations or recommendations
contained in reports should be easy for a reader to find.
2.6 -
Follow-up procedures
Quality Assurance Processes which contain recommendations for action or which
require a subsequent action plan, should have predetermined follow-up
procedure, which is implemented consistently.
2.7 -
Periodic reviews
External quality assurance of institutions and/or programmes should be
undertaken on a cyclical basis. The length of the cycle and the review procedures
to be used should be clearly defined and published in advanced.
2.8
- System-wide analysis
Quality Assurance should produce form time to time summary reports describing
and analysing the general findings of their reviews, evaluations, assessments,
etc.
Part 3
3.1 -
Use of external quality assurance procedures for higher education
The external quality assurance agencies should take into account the presence
and effectiveness of the external quality assurance procedures described in Part
2 of the European Standard and Guidelines.
3.2 -
Official status
Agencies should be formally recognised by competent public authorities in the
European Higher Education Area as agencies with responsibilities for external
quality assurance and should have an established legal basis. They should
comply with any requirements of the legislative jurisdiction within they operate.
3.3 -
Activities
Agencies should undertake external quality assurance activities (at institutional
or programme level) on a regular basis.
3.4 -
Resources
Agencies should have adequate and proportional resources both human and
financial, to enable them to organise and run their external quality assurance
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process(es) in an effective manner with appropriate provision for the
development of their processes and procedures.
3.5 -
Mission Statement
Agencies should have clear and explicit goals and objectives for their work, set
down in a publicly available statement.
3.6 -
Independence
Agencies should be independent to the extent both that they have autonomous
responsibility for their operations and that the conclusions and recommendations
made in their reports cannot be influenced by third parties such as higher
education institutions, ministries or other stakeholders.
3.7 -
External quality assurance criteria and processes used by agencies
The process, criteria and procedures used by agencies should be pre-defined and
publicly available. These processes will normally be expected to include:
- a self-assessment or equivalent procedure by the subject of the quality
assurance processes;
- an external assessment by group of experts, including, as appropriate, (a)
student member(s) and site visit as decided by the agency;
- publication of a report, including any decisions, recommendations or other
formal outcomes;
- a follow-up procedure to review actions taken by the subject of the quality
assurance process in the light of any recommendations contained in the report.
3.8 -
Accountability
Agencies should have in place procedures for their own accountability.
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Annex 2 - Programme of the site visit
Panel activity
16th
June
The Panel arrives.
The Panel has its own meeting.
17th
June
9.00 –
9.15
9.15 a.m.
–
9.45 a.m.
Team gathering
Meeting with the Council
Chairmanship and ACE Denmark’s
management:
Chairman Mr. Søren Barlebo
Rasmussen
Vice Chairman Mr. Christian Thune
Acting Director Mr. Sami Stephan
Boutaiba
Head of the Professional Secretariat
Mr. Steffen Westergård Andersen
9.55 a.m.
– 10.40
a.m.
Meeting with representatives from
the Accreditation Council
(Chairman, Vice Chairman and two
other representatives)
Theme
Welcome
Presentation of the organisation,
roles, and division of competencies.
Presentation of the programme
Questions from the Panel.
10.50 a.m. Meeting with ACE Denmark’s
–
management:
11.20 a.m.
Acting Director Mr. Sami Stephan
Boutaiba
Head of the Professional Secretariat
Mr. Steffen Westergård Andersen
11.30 a.m. Meeting with representatives from
– 12.15
Ministry of Science, Innovation, and
p.m.
Technology (VTU):
Director Mr. Jens Peter Jacobsen
Head of Division Ms. Mette Ring
Rossing
Special Advisor Ms. Lene Britt
Boisen
Questions from the Panel
Questions from the Panel
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Panel activity
12.15
p.m. –
1.30 p.m.
1.30 p.m.
– 2.15
p.m.
Lunch – Panel meeting
Theme
Meeting with employees from ACE
Denmark:
Senior Advisor Mr. Lars Pedersen
Senior Advisor Ms. Vibeke Fahlén
Special Advisor Ms. Dorthe
Stadsgaard
Special Advisor Mr. David Metz
Accreditation Consultant Ms.
Christina Haulrich Klausen
Accreditation Consultant Mr. Jonas
Bech Hansen
Questions from the Panel
2.25 p.m.
– 3.00
p.m.
Meeting with representatives from
the Danish Evaluation Institute
(EVA):
Head of Division Mr. Tue Vinter-
Jørgensen
Questions from the Panel about the
Accreditation Council
7.30 p.m.
18th
June
8.30 a.m.
– 9.00
a.m.
The Panel has its own dinner
Evaluation in the team.
A liaison person who can access
documents or make necessary
arrangements. Also access to PC,
printer and photocopier.
Questions for the students
9.00 a.m.
–
9.45 a.m.
Meeting with representatives from
DSF. (The National Union of
Students in Denmark:
Ms. Rie Kjær Poulsen
Ms. Kristine Bak Nielsen
Mr. Andreas Kvist Bacher
Vice President Ms. Lena Skotte
9.55 a.m.
Meeting with president of
–
Universities Denmark. (The Danish
10.40 a.m. universities guild):
President Mr. Jens Oddershede
10.50 a.m. Meeting with representatives from
Questions from the Panel
Experiencing the accreditation
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Panel activity
-
programmes that have undergone
12.20 a.m. accreditation:
Mr. Henrik Vejre, University of
Copenhagen
Ms. Dorthe Kronborg; Copenhagen
Business School
Ms. Birte Hornemann, University of
Aalborg
Ms. Eva Sidelmann Karring,
University of Aarhus
12.20
p.m. –
1.30 p.m.
1.30 p.m.
–
2.30 p.m.
Lunch – Panel meeting
Theme
process. Questions from the Panel
Meeting with representatives from
ACE Denmark’s contacts at
universities – Quality Assurance
Managers
Ms. Hanne Harmsen, University of
Copenhagen
Ms. Geeske de Witte-Westergard,
University of Roskilde
Mr. Morten Vestergaard-Lund,
University of Southern Denmark
Ms. Marianne Lucht, University of
Aalborg
Ms. Iben Westergaard Rasmussen,
University of Aarhus
Meeting with Chairman of the
Dialogue Forum :
Chairman Mr. Mogens Hørder
Panel meeting and coffee.
ACE Denmark’s processes,
procedures, criteria, transparency,
cooperation. Questions from the
Panel
2.40
p.m.–
3.10 p.m.
3.10 p.m.
–4.30
p.m.
4.30 p.m.
– 5.00
p.m.
Discussion of the Dialogue Forum
content and experiences. Questions
from the Panel
Meeting with the Council
Chairmanship:
Chairman Mr. Søren Barlebo
Rasmussen
Vice Chairman Mr. Christian Thune
Additional, final questions from the
Panel for the Council Chairmanship
5.10
p.m.–
5.40 p.m.
Meeting with ACE Denmark’s
management:
Acting Director Mr. Sami Stephan
Boutaiba
Additional, final questions from the
Panel for ACE Denmark’s
management.
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Panel activity
Head of the Professional Secretariat
Mr. Steffen Westergård Andersen
Theme
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