a report by Nick Harris (UK bologna Expert and international HE consultant) 30 th May 2010

Transcription

1 Elaboration of a model of institutional and programme accreditation taking account of the specifics of Poland s higher education as well as the standards and criteria employed in the assessment. a report by Nick Harris (UK bologna Expert and international HE consultant) 30 th May 2010 Projekt współfinansowany ze środków Unii Europejskiej w ramach Europejskiego Funduszu Społecznego

2 Contents 1. Background 1.1 Overview of current Polish HE Challenges in developing a new approach to quality assurance for Poland s HE 1.2 Current QA arrangements for Polish HE (ex ante) Institutional accreditation Review of institutional performance (ex post institutional accreditation) Ex ante programme accreditation Ex post programme accreditation Detailed standards 1.3 Planned changes for Polish HE Revisions to the law on Polish HE The Polish National Qualifications Framework (NQF) Expert reports Strategy for the development of HE KRASP et al Strategy for the development of HE in Poland until 2020 Ernst & Young 1.4 European and international developments Implementation of the Bologna Process European Standards and Guidelines for the QA of HE Mutual recognition of evaluation / accreditation decisions Quality labels 2. A time for change / a time of change 2.1 Meeting changing needs 3. A new approach to QA for Polish HE 4. A new model of QA of Polish HE is a higher education institution what it claims to be? does a diploma represents what it says in the title? is a study programme is coherent [ and set at the right level]? does a study programme actually deliver what it claims to offer? do students have a fair chance to complete their chosen study programme? 5. Components of a new approach to QA 5.1 Procedures Approval for the establishment and dissolution of HEIs Periodic review of HEI s regarding the quality assurance of their programme provision: ex post institutional evaluation / accreditation Quality assurance at programme level Programme design and approval Main principles to be addressed regarding programme design and approval 5.2 Standards and criteria 2

3 5.3 Integration of components within a new model On the setting of academic standards and coherence of study programmes On the description of specific study programmes On the management of quality within HEIs 6. A way forward 6.1 A road map for the development of components and their implementation 7 Conclusions and recommendations Annex 1. Diagrammatic of programme accreditation schemes referred to in the Report: current, proposed by Ministry, an alternative proposal. 3

4 Background 1.1 Overview of current Polish HE Higher education in Poland has a long and distinguished history, starting with the establishment of the Jagiellonian University of Krakow in In recent decades there has, as elsewhere in Europe, been a significant change in the size and nature of higher education. Whereas previous a relatively small number of universities taught approximately 5% of the relevant age group of young people, today there 456 higher education institutions (HEIs) listed by the Polish Ministry of Science and Higher Education 1. These teach approximately 50% of the relevant age cohort, and with a very low incompletion rate (significantly less than 10%). The sector includes a diverse range of institutions in both the public (131 bodies) and non-public (325) sectors. Some are rather large with over tens of thousands of enrolled students whilst others may include less than Similarly, the range of subject taught varies from a comprehensive range of sciences, social sciences, arts and fine arts to essentially mono-tech institutions that focus on one particular area (e.g. business, agriculture, sectors of performing or creative arts etc.). Whilst some have high international standing others seek more direct engagement with their immediate locality, often with a focus on meeting particular economic needs. Not only is there a wide variety of types of HE institutions but the missions, key aims, organisational structures, resourcing and staffing of these institutions also varies greatly. In some the Rectorate maintains an overall and active co-ordinating role for the institution as a whole, whilst in others some faculties (often larger than some institutions) are effectively self contained with regard to short term planning cycles. It is notable however that students appear to regard themselves primarily as students of the university they attend rather than students of a faculty Challenges in developing a new approach to quality assurance for Poland s HE Accreditation is a particular form of quality assurance and, like other forms, its main aims are to provide interested parties with information on the merits (or otherwise) of activities and products. It is inherent in any system however diverse that the same questions / principles regarding quality should be addressed by all parts, although the detail of the procedure in which this may be carried out may differ. Similarly the criteria used within those procedures should address similar generic areas but the precise nature of criteria might reasonably be expected to be adapted to the specific context(s) in which they are being applied. The challenges to developing a new model of institutional and programme accreditation for Poland s HE lie in the facts that: the sector is diverse in terms of institutional size, mission, structure and staffing there is diversity amongst the student entrants institutions are at different stages in the development of any internal QA systems 1 See: 4

5 Poland is committed to adopting the Bologna Process but the process of adaptation is incomplete international expectations concerning the quality assurance of higher education have changed substantially within the last decade (and some but not all of Poland s HE operate within an international community). 1.2 Current QA arrangements for Polish HE The rapid expansion of the HE sector, particularly following the 1990 law that resulted in a very substantial increase in the non-public sector, led to the introduction of a comprehensive QA system whose purpose was to ensure that this wide range of different types of HEIs provided programmes that met the standards expected by society. Although not formally stated as such many regard these as minimum standards. An accountability for the expenditure of public finances has until now not been a significant factor in QA, although this is expected to change. External quality assurance in Poland currently involves a number of organizations, including the Ministry of Science and Higher Education (MSHE), the State Accreditation Committee (SAC / PKA 2 ), the Ministry of Health (MH) and the National Council for Accreditation of Medical Education (NCAME), and Peer Accreditation Commissions (PACs) which operate under the umbrella of the CRASP Accreditation Commission (ex ante) Institutional accreditation From the 2005 Law on Higher Education, the Minister of Science and Higher Education can grant permits for the establishment of new non-public HEIs; in effect the ministry grants ex ante institutional accreditation, although it is not currently described in these terms. She is supported in this by opinions provided by SAC. The detail of the procedures and the minister s powers differ depending on the public or non-public establishment of the institution: the establishment of a non-public HEI and the authorisation to provide degree programmes in a given field and at a given level of study requires the permission of the minister responsible for HE, with a request for a permit to establish a non-public HEI only being submitted to the minister by an individual or corporate body other than one administered by national or local authorities whereas a public university-type HEI can only be established or terminated, change its name and merge with another public HEI only by Act of Parliament a public non-university HEI can be established or terminated, change its name and/or merge with another no-public HEI by a regulation of the Council of Ministers. Thus the minister is only responsible for what might be regarded as an ex ante accreditation of non-public HEIs, and is advised in this by PKA. 2 State Accreditation Committee SAC also known as, and referred to in this document as, PKA 5

6 1.2.2 Review of institutional performance (ex post institutional accreditation) The ministry also extends, on advice of SAC, permits for the continued establishment of nonpublic HEIs (in effect, but not in current terminology, ex post institutional accreditation). By contrast public HEIs are not expected to undergo similar institutional level review Ex ante programme accreditation The ministry provides authorisations for both public and non-public HEIs which do not have the relevant autonomous powers to establish new degree programmes (ex ante programme accreditation). In all of these procedures the ministry seeks opinions from the SAC Ex post programme accreditation SAC, which was established in 2002 and operates on the basis of LoHE, is the only statutory body responsible for mandatory external quality assessment in all HEIs and, consequently, for ex post programme accreditation. SAC performs the latter function jointly with MSHE and its decisions are legally binding in so far as the Minister of Science and Education is required by law to suspend or withdraw programmes with a negative rating from SAC Detailed standards NCAME, which operates on the basis of the 2001 Regulation of the Minister of Health on NCAME and the procedure for awarding accreditation, assesses compliance of degree nursing programmes with national standards and on this basis presents to the Minister of Health proposals for awarding or withdrawing accreditation for such programmes (ex post programme accreditation). The PACs were established as a voluntary initiative by the academic community between 1993 and 2001 and entrusted with the responsibility for accreditation in specific types of institutions and/or fields of study. PACs are not referred to in the national legislation. They conduct external quality assessments and offer ex post programme and/or institutional accreditation on the basis of applications submitted by higher education institutions on a voluntary basis. A positive or negative accreditation decision taken by PACs has no legal implications. HEIs are, in principle, required by the national legislation (LoHE and 2007 the Minister of Science and Higher Education Regulation on national standards for degree programmes) to establish internal quality assurance systems, including two obligatory elements, student evaluation questionnaires and teacher performance appraisal to be carried out every four years. However, there is no timeframe for the establishment of such systems and no specific national guidelines in this area. While progress in this area varies considerably, in general fully fledged and functional internal quality assurance systems are yet to be established in most HEIs. In keeping with the expectations of the times, the quality assurance arrangements introduced since 2000 (and reflected in the 2005 and 2007 LoHE) reflect a focus on what might be largely regarded as input measured to answer questions such as: do the programmes claim to deliver the contents appropriate to a particular diploma title? was there an appropriate number of suitably qualified staff (as determined in large part by their research experience in 6

7 the field)? were there appropriate facilities? and did the study programme extend over a suitable time period? The abilities of applicant candidates and the provision of appropriate intellectual stimulus and physical and pedagogical support are important factors in the quality of (higher) education but they do not necessarily demonstrate or assure the level of success. 1.3 Planned changes for Polish HE Whilst the initial phase of quality assurance in Polish higher education, which lasted for centuries, depended largely on an acceptance of the profession responsibilities of those involved, the second phase dominated by ensuring inputs were at least appropriate, has been sufficient for a few decades. A new paradigm emanating from the more traditional one is however now emerging in many parts of the globe, and is included within the aims and priorities of the European Bologna Process to which Poland is a signatory. This new approach focuses not just on input but also and particularly on the achievements of the students referred to as their learning outcomes. Study programmes are increasingly designed with a an emphasis on their intended learning outcomes (a quality assurance measure is the extent to which these make a coherent whole for the programme leading to a particular qualification) and the real test of a programme is the extent to which the students have been able to demonstrate these intended learning outcomes. Here the quality assurance measures should be concerned with not just what has been demonstrated by students but also the validity of the means of assessment Revisions to the law on Polish HE Within these changing national and international contexts, proposed future arrangements for quality assurance in Poland are discussed in The aims underlying proposed amendments to the Law on Higher Education and the Law on the Academic Degrees and Title and the Academic Degrees and Titles in Fine Arts, a strategic document adopted by the Government in October The proposed higher education reform is designed to enhance the quality of higher education, and be in line with the Bologna reforms to which Poland is committed. New proposals and expectations set out by the government include: the development of a new model for HE governance, with a special (quality promoting) fund to support the establishment of internal QA systems within HEIs which will enhance quality; revised (new) national standards for degree programmes offered in those HEIs that have demonstrated best quality; these standards will be less prescriptive and be designed to promote continuing quality improvement; the introduction of two new types of accreditation at programme and institutional levels. The new programme accreditation will, in line with changes occurring elsewhere in Europe, focus more on learning outcomes (without neglecting curricular inputs and pedagogical process(es)). The new institutional accreditation will focus on the internal QA systems that HEIs operate to support the array of programmes they offer; increased levels of activity for SAC, which will be expected to strengthen its collaboration with NCAME and the PACs. As a consequence, SAC s role will shift from the current focus on control to also cover to a greater extent quality improvement functions. All these arrangements are expected to come into 7

8 force after the implementation of a new National Qualifications Framework. Until then the current QA arrangements will remain in force. Draft changes to the law on Polish HE are currently under consideration with the phase of public consultation just having been completed. It is not proposing minor amendments and adjustments to current practice but rather it sets the scene and parameters for a transformation of Polish HE. Whilst it does not include any proposals for specific new types of institutions these are not excluded and indeed it would seem appropriate for a subsequent review to propose the introduction of a typology of HEIs. This is also a major priority for the European Commission, which considers that a Europe wide typology would be a valuable transparency tool. A summary of some of the key points concerning the current law and the proposals embedded in the new draft law are set out below concerned with quality assurance aspects are set out below under: QA tools and definitions new procedural approaches and criteria applied to ex ante programme accreditation there are no apparent procedural changes for ex post programme accreditation but changes to criteria are proposed, with an emphasis on learning outcomes the roles of the State Accreditation Committee (PKA) CURRENT PROVISIONS Current distinction between: 1) Units of HEIs (both public and nonpublic) which are authorised to award doctoral degrees in at least 4 disciplines of science (or 2 disciplines in fine arts) may provide Bachelor s and Master s degree programmes within the officially recognised fields of study without an authorisation from the Minister (provided that they fulfil the requirements concerning, in particular the national standards and the minimum PROPOSED AMENDMENTS Key concepts and terms are introduced and defined (NQF, qualification, learning outcomes, ECTS, profile of a programme) The Minister will establish (by regulation) the NQF for areas of education (8 broad areas), defining/describing 3 [defining/laying down] learning outcomes for each field and level of study (cycle) and profile, and methods for their verification. EX ANTE PROGRAMME ACCREDITATION New distinctions between: 1) Units of HEIs which are authorised to award postdoctoral degrees (dr hab.) may provide programmes within areas corresponding to the disciplines in which they can award postdoctoral degrees, without an authorisation from the Minister authorisation. Learning outcomes are defined in a resolution of the HEI Senate. PKA conducts only ex post programme accreditation. 3 The important issue, of whether the NQF descriptors are really descriptors (to be drawn upon) or are (if only perceived as) definitions to be quoted, is addressed elsewhere in the report. 8

9 staff resources, laid down in the relevant Minister s Regulation. The provision of programmes in other fields, or interdisciplinary programmes, requires an authorisation from the Minister. In this case PKA conducts only ex post programme accreditation to confirm the quality of programmes offered. 2) Units of HEIs (both public and nonpublic) which are not authorised to award doctoral degrees in at least 4 discipline of science (or 2 in fine arts) are required to obtain an authorisation from the Minister to provide Bachelor s or Master s degree programmes in a specific field and at a specific level of study. In this case PKA gives an opinion as part of ex ante programme accreditation where a decision is taken by the Minister. Subsequently, PKA conducts ex post programme accreditation. 2) Units of HEIs which are not authorised to award postdoctoral degrees have two options: a) they may provide programmes in specific fields and at specific levels of study without an authorisation from the Minister s if the programme approved by its Senate comprises all learning outcomes from the NQF for a given field of study; PKA conducts only ex post programme accreditation; or b) it may offer programmes in fields of study other than those defined in the NQF by the Minister, or interdisciplinary programmes, only with a prior authorisation from the Minister. PKA gives an opinion as part of ex ante programme accreditation with a decision taken by the Minister. Subsequently, PKA conducts ex post programme accreditation. PKA [ Role becomes more explicit ] PKA is recognised as an independent institution promoting quality improvement PKA will continue to conduct quality assessments in fields of study but with increasing emphasis on the verification of learning outcomes corresponding to those in the NQF for areas of education and fields of study PKA will continue to assess the functioning and activities of basic organisational units of HEIs (which suggests action at faculty/department level rather than whole institutional assessment/ accreditation other than for small HEIs) PKA presents to the minister responsible for higher education opinions and proposals concerning: 1) the establishment of a HEI, and the authorisation for a HEI to provide degree programmes in a given field and at a given level of study; 2) the assessment conducted by the Committee of the quality of education in a given field of study, including the training of teachers and the compliance PKA presents to the minister responsible for higher education opinions and proposals concerning: 1) REVISED: the establishment of a HEI; [ex ante programme accreditation deleted here]; 2) the assessment conducted by the Committee of the quality of education in a given field of study, including the training of teachers and the compliance with the requirements for the provision of degree 9

10 with the requirements for the provision of degree programmes. Ratings not specified in the current LoHE; PKA introduced these ratings The current Presidium membership is maintained and.. programmes.[the same as now]; NEW: 3) the re-granting of authorisations to provide programmes in a given field and at a given level of study [in accordance with the arrangements concerning ex ante programme accreditation see above PKA assesses existing programmes; if a negative rating is given, the Minister suspends or abolishes the programme; the unit concerned applies for accreditation when it has remedied shortcomings]. 4) the assessment of the functioning and activities of a basic organisational unit (institutional assessment); 5) the establishment of a foreign HEI or a branch campus of a foreign HEI in Poland. PKA formally asked to provide ratings as: outstanding, positive, conditional, or negative. The Minister establishes, by regulation, criteria for programme and institutional assessment, taking into account: the compliance with the requirements for HEIs to provide programmes in specific fields and at specific levels of study; the functioning and improvement of internal QA systems; accreditations granted or certificates awarded by international institutions... is strengthened by addition of two representatives of employers organisations. Other aspects of the draft changes to the law on HE that interface with the quality agenda include: a quality support ( PRO-QUALITY ) fund within the State budget will provide funds to be allocated for: o supporting HEI organisational units which the status of National Leading Research Centre/Unit (see below), including top-up salaries for staff and special grants/scholarships for doctoral students; o supporting basic organisational units of HEIs which have received an outstanding rating for the quality of education from PKA; o supporting basic organisational units of HEIs in the implementation of the NQF; o financing tasks related to full-time doctoral programmes. National Leading Research/Academic Centres/Units: proposal for the development of organisational units within an HEI which conducts highest-quality research in 10

11 connection with highest-quality doctoral programmes (as well as a research centre which is not part of a HEI) may acquire the status of a National Leading Research/Academic. Such status will be given for 5 years, through a competition procedure. Other policy developments being discussed and considered within the ministry, and that include quality aspects, include: changes in HEI governance that may provide more extensive powers for Rectors (thus emphasising the importance of the overall HE institution to which the student belongs and which the public in general tends to recognise (this contrasts with the organisation units / faculties within HEIs that can be the basis of separate quality assessments). additional points to be given in programme accreditation for programmes delivered in English HEIs to be required to monitor the progression of their graduates into and within the labour market The Polish National Qualifications Framework (NQF) Work on the Polish NQF is at an advanced stage and the framework is expected to be implemented later in It will be an essential and integral part of the new quality assurance arrangements for HE. In line with many countries Poland is adopting an 8 level framework based on the European Qualifications Framework for Lifelong Learning (EQF- LLL), with levels 5 to 8 equating to the 1 st, 2 nd and 3 rd cycles of the Bologna Process on higher education. In addition to developing level descriptors for each of the 8 levels including those for HE, the NQF will include qualification / cycle descriptors based on the Dublin descriptors of the Framework for Qualifications of the European Higher Education Area (FQ-EHEA). This is an important feature and often overlooked from a purely political aspect. Level descriptors and qualification / cycle descriptors are designed for different purposes. Whilst level descriptors can be of great value in establishing expectations within a level of study, and particularly for modules and components of programmes, qualification descriptors are essential to give an indication of the more holistic nature of entire qualifications which, in the case of bachelors / 1 st Bologna cycle programmes span a number of levels. The generic framework descriptors will be further developed through a series of 8 discipline descriptors that will focus on the typical outcomes of learning associated with and expected of those fields. These descriptors will be included within the revised law but the further and more detailed exemplification, that will be needed as guide to programme design and outcomes, will be provide through 120 descriptors that will act as reference points rather than as legally binding requirements. These statements must be written by the relevant communities of academics and practitioners, with consultation on their content.. 11

12 1.3.3 Expert reports Strategy for the development of HE A major report was prepared in 2010 by a consortium including CRASP (KRASP), the Conference of Rectors of Polish Non-University HEIs (KRZaSP), Conference of Rectors of Public Higher Vocational Education Schools (KRePSZ) and the Foundation of Polish Rectors; presented in December 2009). The Strategy is centred on 4 areas for which new arrangements are proposed: Teaching activities of HEIs (which includes most of the proposals concerning QA and accreditation summarised below); Research and R & D activities of HEIs; Cooperation between HEIs and their environment; HE system (also with some proposals concerning QA and accreditation). One of the key strategic objectives in the area Teaching activities of HEIs is improving the quality of education, to be achieved through: improving the quality of student applicants (through coordination of activities in the school and the HE systems); providing systemic conditions to ensure transparency and improvement of learning outcomes, and to increase public confidence in HE (this includes the implementation of the NQF); increasing the effectiveness of QA mechanism in the context of increasing diversification and internationalisation of HEIs. This last area, which is critical if any new quality assurance arrangements are become embedded within normal teaching activities, would involve: introducing mechanisms which encourage HEIs to give priority to quality issues; creating conditions which encourage the involvement of academic staff in quality improvement processes; introducing mechanisms designed to improve the quality of 2 nd cycle programmes; establishing and promoting a quality and transparency culture to be adopted as the main aim in the area of QA; this is to include: o enhancing HEIs awareness of their primary responsibility for quality and QA; o publishing of quality assessment results and QA arrangements; adopting an approach which focuses on internal QA systems to ensure correspondence/match between intended and achieved learning outcomes. An internal QA system for education should be one of the key elements of a comprehensive quality management system which covers all types and aspects of HEIs activities. promoting the following arrangements as elements of an internal QA system: o flexibility of the study system, i.e. creating opportunities for students to follow individual study programmes); o using modern methods, techniques and tools in teaching which serve to increase the effectiveness of learning; o increasing the participation of external stakeholders in the design and implementation of the teaching process; o rewarding in a way which provides a real incentive for involvement in quality improvement academic staff who deliver high quality teaching, and in particular use new and effective teaching methods, techniques and tools; 12

13 o implanting a system for the monitoring of graduates (including doctoral programme graduates) and collecting feedback on completed programmes from graduates; providing HEIs with opportunities and support for the participation in training, the use of experts, support in designing and implementing internal QA systems and adjusting them to the NQF; transforming the methodology of external quality assessment, focusing on learning outcomes defined by HEIs being in compliance with their missions, development strategies and the NQF; whether the internal QA system functions properly; and in particular, how efficient the mechanisms introduced by HEIs are to check if, and to what extent, the learning outcomes defined for a given programme are actually achieved through this programme; developing a model for external quality assessment which integrates programme and institutional accreditation; defining rules for the recognition of accreditation decisions taken by international/foreign agencies. The paper recommends creating flagship or research HEIs and discusses the status and development prospects of higher vocational education schools and non-university HEIs. It further suggests that the current criteria for labelling HEIs as vocational or non-university are no longer clear and do not reflect realities as many programmes offered in these two types of HEIs are not really vocationally/professionally/practically oriented. The section of the report on The HE system proposes establishing A Polish Committee for Accreditation and Academic Authorisations. The responsibilities of this body would include those currently carried out by PKA and accreditation responsibilities covering all forms and levels of study which lead to a diploma or certificate in the NQF and including doctoral/3 rd cycle programme which are not accredited at present Strategy for the development of HE in Poland until 2020 A major report prepared by the management consultancy firm Ernst and Young has provided an alternative view of the potential development pathways for Polish HE. It covers a comprehensively wide range of aspects and this section summarises only those dealing directly with HE provision and its quality assurance. At the heart of the E&Y proposals is a categorisation of the bodies that provide HE in Poland. This is in keeping with a number of European initiatives and reflects the increasing diversity of expectations of HE in modern society. Improved clarity (or transparency ) about not only what an organisation is providing but also the organisation itself is at the heart of such proposals. It may however be premature for Poland to consider its own categorisation at a time when it is know that the European Commission is undertaking a similar but much wider exercise to develop a multi dimensional transparency tool that is expected to be an integral part of the information sources supporting the Bologna Process, to which Poland is committed. The Ernst and Young report also considers QA matters in some detail including the development of criteria for the institutional categorisation and their application by PKA. The PKA decisions would then be reported through inclusion of categorised (and accredited) institutions within a national register. The Ministerial web site currently contains a list of all 13

14 HEIs in Poland with an indication of whether they are in the public or non-public sector but, other than through title, does not include overt information on the type, levels of awards that can be made, or extent of any accreditations. The Ernst and Young report makes several comments regarding programme accreditation, which would also be carried out through PKA, noting that ANY new programme should only be able to enrol students once it had been accredited (i.e. universal ex ante accreditation), and further that academic and research programmes should only be offered where there is sufficient research expertise and capacitiesavailable. In contrast to the Rector s report Strategy for the development of HE , which reflects on HE s contribution to the wider needs of society and has an emphasis on the further development of internal quality cultures within the HEIs primarily as a means for improvement, the Ernst and Young report takes a more focussed approach to the role of HE as a provider for and supporter of economic development as a key driver for the improvement of society. In this regard it takes a view of quality more in terms of a primary purpose for control and accountability primarily and then secondarily as a means for improvement. 1.4 European and international developments Implementation of the Bologna Process The Bologna Process has brought about wide ranging and substantial changes to higher education not just in Poland but across Europe. It is clear that not only are different countries at different stages of development but within them different institutions, and even different parts of individual HEIs, are at different stages in the development of, and even commitment to, the Bologna reforms. The major impacts of Bolognawith regard to the topics of this report are the introduction of new forms of study programmes and in particular the introduction of 3 cycles of study that are relatively consistent not only across the geographic / political boundaries but also across discipline / subject areas as well. Agreements on expectations about typical student workloads and the nature of what they are expected to have learnt, and be able to do, are widespread although interpretation and implementation of details varies, often as a reflection of historical and pedagogical contexts. One of the more significant of these is the extent to which HE may be truly autonomous, or works within a legal framework that is more or less prescriptive; this is reflected in the extent to which HEIs set standards either by considering reference points or applying requirements. For some qualifications descriptors are just that descriptors! Whilst for others they are regarded as definitions. Similarly learning outcomes are seen and used by some as detailed requirements whilst for others they are indicators of expectations. Linked to these different perspectives are quality assurance systems that rely more or less on quantitative and qualitative measures and are focussed to different extents on inputs or achievements. Thus, whilst Bologna has had an major impact and is in many aspects an undoubted success, there are still significant variations in progress and major hurdles to overcome. 14

15 1.4.2 European Standards and Guidelines for the QA of HE What are know as the European Standards and Guidelines (for the quality assurance of higher education) are a remarkable product of bottom up developments, brought about by the shared (but not always identical) needs of the various contributors to European higher education in particular the universities and other HE sectors (coordinated through their representative bodies EUA 4 and EURASHE 5, the quality assurance agencies (represented through ENQA 6 ) and the students (coordinated through ESIB initially and more recently ESU 7 ). The ESG set out the principles that the various bodies / sectors jointly regard as critical to the quality of higher education. They cover expectations regarding: internal quality assurance with HEIs quality assurance of HEIs carried out by external bodies quality assurance of those external bodies carrying out QA of HEIs Mutual recognition of evaluation / accreditation decisions It would be remiss to discuss new approaches to the quality assurance of higher education without making some reference to mutual recognition. Mutual recognition is at the heart of one of the key drivers of the Bologna Process increased mobility of students, academic and professional staff, and graduates. Closer equivalence between types of awards made in different countries is key to increased mobility of graduates whether within or for further study or as part of employment. A simple expectation is there is or should be mutual recognition of the award/ the degree/ the diploma but this is in fact extremely complicated because of not only the different rates at which different countries are implementing the new arrangement of study programmes leading to what will be similar awards, but also because of many aspects of national legislation regarding the recognition of awards. As a step in the right direction a number of accreditation agencies across Europe formed a project group consortium (the European Consortium for Accreditation - ECA 8 ) to explore the barriers to mutual recognition of, in their particular case, the accreditation decisions. Even this is made more complex by the fact that in many cases, as in Poland, it is not the accreditation body that makes the final decision but only makes a recommendation regarding that decision. In practice of course the recommendation is seldom if ever overturned BUT recognition issues are deeply embedded within (national) legal frameworks and such distinctions may not be merely semantic but critical EUA - see: EURASHE see: ENQA - see: ESU - see: 8 ECA see: 15

16 There is however no doubting two major aspects of Bologna which make further work by the relevant Polish bodies essential in this area. These factors are the increased promotion and clear value, particularly from some employer s perspectives, of the added value of (transnational) joint programmes and the needs to ensure that where students are encouraged and attend joint programmes the expectations about such programmes and their awards are quality assured in much the same way as those students attending single site / provider programmes. Similar principles apply where Polish education providers may deliver outside of Poland and external providers may deliver programmes within Poland. There is very little benefit in multiple accreditations of a single transnational programme by various national agencies, but the difference in approach, procedures and detailed criteria can make a single accreditation procedure problematic. It should be noted however that PKA is actively engaged in the consortium leading this work 9. The issues are addressed briefly in below in the section on the purposes of quality assurance Quality labels Quality labels are prevalent in many walks of life and are becoming increasingly common within higher education. Furthermore, the European Commission is promoting the development and use of such labels as a means of providing clear information about the quality of particular programmes and institutions, including its own ECTS and Diploma Supplement quality labels. As yet the use of such quality labels is not in widespread use in Polish HE however their use is likely to be promoted by the increasing internationalisation of higher education and the potential of Polish HEs to earn fees through the recruitment of overseas students. PKA may wish to consider collaborating with for example the Dutch accreditation body NVAO in exploring the possibility of a joint label ion this area. It will be appropriate to consider the extent to which a quality label awarded by a reputable external body may provide sufficient evidence to reduce the need for the fullest scrutiny within the normal Polish evaluation systems. 2. A time for change / a time of change 2.1 Meeting changing needs The current quality assurance system has served Polish HE through a time of rapid change, and its strengths were recognised in the positive outcomes of the ENQA review of SAC. However, the general context and increasing international expectations associated with the quality assurance of HE provide a strong incentive for a re-evaluation of current arrangements. In particular the current system may be considered to be: not sufficiently flexible and adaptable to provide the most effective quality assurance across the now very diverse range of Polish HE institutions and programmes; not sufficiently aligned with the increasing emphasis on learning outcomes (an integral and critical aspect of the Bologna Process). The current criteria focus particularly on compliance with national standards for degree programmes without necessarily providing 9 ECA - see: 16

17 a context or framework to allow and encourage development in curriculum design and pedagogical development and delivery; inappropriate to provide a effective basis for, and stimulate the development of, more efficient and effective internal QA arrangements within HEIs; unlikely to provide additional and increasing gains with each cycle of external quality assessment; indeed it is more likely that current arrangements will become increasingly less cost effective if repeated without modification. Across Europe there is increasing interest in the development of QA systems that are internal to HEIs and can provide effective and efficient means of evaluation at programme level. Such internal QA must include an appropriate level of externality. Nationally required external QA then focuses on each institution s abilities to assure the quality of programmes it delivers. There is however an important proviso; whilst large HEIs can, within a suitable national framework, develop their own effective internal QA structures and arrangements this is less likely to be the case for small institutions. These may be unlikely to have the scale and resources to devote to a dedicated internal QA unit, and thus require continuing full external QA at programme level, through the national agency (PKA). Within such changing national and international contexts, proposed future arrangements for quality assurance in Poland are discussed in The aims underlying proposed amendments to the Law on Higher Education and the Law on the Academic Degrees and Title and the Academic Degrees and Titles in Fine Arts. This strategic document was adopted by the Government in October The proposed higher education reform is designed to enhance the quality of higher education, in line with the Bologna reforms to which Poland is committed. The new proposals and expectations set out by the government include: the development of a new model for HE governance, with a special (quality promoting) fund to support the establishment of internal QA systems within HEIs which will enhance quality; revised (new) national standards for degree programmes offered in those HEIs that have demonstrated best quality; these standards will be less prescriptive and be designed to promote continuing quality improvement; the introduction of two new types of accreditation at programme and institutional levels. The new programme accreditation will, in line with changes occurring elsewhere in Europe, focus more on learning outcomes (without neglecting curricular inputs and pedagogical process(es)). The new institutional accreditation will focus on the internal QA systems that HEIs operate to support of the array of programmes they offer; increased levels of activity for SAC, which will be expected to strengthen its collaboration with NCAME and the PACs. As a consequence, SAC s role will shift from the current focus on control to also cover to a greater extent quality improvement functions. All these arrangements are expected to come into force after the implementation of a new National Qualifications Framework. Until then the current QA arrangements will remain in force. 3. A new approach to QA for Polish HE Whilst the draft amendments to the law provide some very clear guidance on the approaches, structures and tools that will be applied in the quality assurance the detail is of course yet to be determined. The two reports mentioned above (see section 1.3.3) share many views on 17

18 the need for, and the routes of, further development of QA for higher education, although a contrast in views on the primary roles of higher education may be detected. The primary role might be crudely polarised as contributing to a civilised and civilising society or providing the human and intellectual capital to promote economic development. It is clear that BOTH are expected of higher education and further that the quality assurance must reflect the multiplicity of roles. Additional and potentially complicating factors are also present in developments external to Poland but which have profound influences on Poland s higher education (see above). It is thus worth revisiting not only the purposes of higher education but also the purposes of the quality assurance of higher education. It is possible to measure all sorts of things that may influence or reflect or be of interest to some aspects of quality assurance, and there is a great diversity of methods and criteria that can and are being applied both in Poland and elsewhere. To make quality assurance most effective and efficient it is crucial to ask and answer!.. what is the quality assurance for? In straightforward terms, and apart from some accountability for the spending of public money, the most immediately obvious aspects as far as general society is concerned, might be summarised as: is a higher education institution what it claims to be? does a diploma represents what it says in the title? is a study programme is coherent and set at an appropriate level of demand whether academic and / or professional? does a study programme actually deliver what it claims to offer? and, particularly from a student s perspective, and those providing support during their studies do students have a fair chance to complete their chosen study programme? The focus of the draft amendments to the law is the introduction of an approach to quality assurance focused to a greater extent than present on the outputs of the higher education programmes, what students know and can do rather than what, how and by whom students have been taught. The new approach does not move entirely away from an appreciation of the importance of the context in which is student is learning, the appropriate research environment must be present where students are enrolled on research degrees and similarly where students are enrolled on programmes that focus on professional practice then it is advanced practitioners who will be important in passing on and assessing abilities. A further and critical point in the new approach to teaching and learning in Polish higher education is that its quality assurance will also focus on not just what it is intended that a student should know and be able to do but what is that a student actually knows and can do. This raises the importance of assessment and how and by whom it is carried out, and how assessment is quality assured and, if necessary, moderated through some independent externality. 18

19 These combined factors lead inevitably towards the development of a quality assurance system that is a mix of aspects some of which are internal to the HE institution, and indeed to the programme providers directly, and some external aspects. The extent of scrutiny and the balance between internal and external elements will of course depend on the nature of the programme, the extent to which it is subject to national and international expectations and regulations and may, in any second or subsequent review, depend on the success (or not) with which earlier quality assurance expectations have been met. An effective and efficient system would thus be one that focus on purpose(s), that balances internal and external elements and may include some form(s) of risk analysis. The key questions asked and the key principles that are expected to be met should apply to all, and be seen to apply to ALL. The precise ways and extents to which things are implemented may reflect the context(s) of the institution (or unit) and programme under scrutiny. 4. A new model of QA of Polish HE It is clear from the all of the discussion sessions held over the 24 th ad 25 th May at the Ministry of Science and Higher Education, and from the sections above, that higher education in Poland is in the middle of a period of considerable flux. Internal factors such as legal and social changes and demographics have and will continue to influence higher education provision in profound ways in the coming years. External factors such as the Bologna process, and overlapping but not synonymous educational reforms being promoted by the European Union, are having major impacts at teaching, research, and academicadministrative levels.. Similarly, the internationalisation of higher education in general and the increasing extent of provision both to international students within Poland and to a variety of students outside of Poland are also significant. It is perhaps not surprising that academic and professional staff within the system may feel somewhat confused and even overwhelmed by both the extent and pace of change. Similarly students are being offered new and unfamiliar opportunities and approaches to learning and employers are finding that the graduates they have been familiar with for many years now come with different sets of knowledge skills and attitudes. If any new approach to, and model for, implementation of the quality assurance of Polish higher education is to succeed it must be aware of and take account of these factors. It might be reasonable to reassert that the primary driver is academic improvement through reform and that quality assurance should reflect, secure and ideally contribute to the improvement of these reforms. It is sadly apparent that too many academics across Europe believe that it is the external adminstrative reforms, in which they have had little or no voice, and including quality assurance, that are the drivers which perturb their long held beliefs and practices and commitments to teaching and learning. Constructive engagement of the academy is an essential prerequisite to successful and long lasting reform and development. 19

20 Any new model for quality assurance must be seen to be relevant, must offer benefits to all involved and be proportionate to the risks involved. It must also been equitable and be seen to be fair in application. What then of the questions posed above; are there are clear answers / parameters than are required across all of Polish HE? and are there any that will be specific to particular sectors? is a higher education institution what it claims to be? Polish HE institutions are broadly categorised into public and non-public, and their nomenclature determined by a defined set of criteria. There is however no clear of profile as categorised by mission and roles. From a quality assurance perspective PKA assesses some institutions in their entirety, some units within institutions, some independent units, and most of the study programmes offered and delivered by this variety of providers. Both the Polish HE sector bodies report and the Ernst and Young report indicate that the current typology is inappropriate, insufficient and / or inaccurate and they offer alternative and distinctly different models. It is argued by some that the precise classification of all institutions / units is jst about impossible and that the pace of change would render any labelling out of date very quickly. However, some form of identification migh be of specific benefit. The recognition of flagship institutions, that provide research and or pedagogical and or professional leadership in their fields, could be of benefit in the shot to medium term. For others, it may be more appropriate to see what the European Commission develops by 2011 in terms of its multi dimensional transparency tool for HEIs and see whether this is relevant to the description/ typology of Polish HE. It is however in the potential longer term changes that attention may be more usefully focused. It is intended that HE institutions will be able to develop and implement their own programmes of study as opposed, at present, to being largely restricted to a set list of approved programmes. As new programmes become more widespread, reflecting the diversity of cultures within disciplines and between institutions/units, then the notion of state degrees may become increasingly untenable. Institutions/units that design and deliver innovative programmes are likely to see it as logical that these degrees should be degrees of the institution/unit rather than of the state. This is perhaps most likely to happen in those HEIs that lead advances at inter- and multi-disciplinary academic frontiers and in those that are most closely linked to the business world and its needs. It is likely that when, rather than if, institution s degrees are introduced this will require some detailed attention to the academic governance and quality assurance across the institution as a whole. Irrespective of the power and apparent autonomy of some faculties, including the roles of faculty boards to approve programmes, the main academic authority normally lies within an HEI s Senate. It will be important that large and complex institutions can demonstrate central awareness and control over critical QA parameters to ensure a general parity of treatment of students, irrespective of the disciple or faculty or programme in which they study. Whilst the detail of implementation of quality cultures is reflected in the context of faculties, disciplines and programmes, it is the HEI s responsibility to 20