DANISH ACCREDITATION INSTITUTION

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1 XXXXXXXX 2016 ENQA REVIEW SELF-ASSESSMENT REPORT JANUARY 2016 DANISH ACCREDITATION INSTITUTION

2 Danmarks Akkrediteringsinstitution Citat tilladt ved kildeangivelse Rapporten kan downloades via hjemmesiden

3 Table of Contents Preface... 5 Self-evaluation outline... 6 Part 1 Management Reflections and Perspectives on the Practice of the... 7 Part 2 Accreditation and Education in Denmark Historical Overview The Accreditation Institution The Accreditation Institution s tasks The organisation of the The Accreditation Council The Accreditation Council as Decision Maker Decision-making Process of the Accreditation Council Outline of the Danish Higher Education System Higher Education Institutions and Study Programmes Qualification Levels in the Danish Higher Education System Part 3 Compliance by the with the European Standards and Guidelines for the External Quality Assurance of Higher Education ESG Part 2 - Compliance by the with the ESG for External Quality Assurance ESG 2.1 Consideration of internal quality assurance ESG 2.2 Designing methodologies fit for purpose ESG 2.3 Implementing processes ESG 2.4 Peer-review experts ESG 2.5 Criteria for outcomes ESG 2.6 Reporting ESG 2.7 Complaints and appeals ESG Part 3 Compliance by The with the ESG for Quality Assurance Agencies ESG 3.1 Activities, policy and processes for quality assurance ESG 3.2 Official Status ESG 3.3 Independence ESG 3.4 Thematic analysis ESG 3.5 Resources ESG 3.6 Internal quality assurance and professional conduct ESG 3.7 Cyclical external review of agencies... 62

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5 Preface This self-evaluation by the (AI) was initiated and commissioned by AI. The evaluation has one main purpose: To examine whether the Accreditation Institution meets the Standards and Guidelines for Quality Assurance in the European Higher Education Area (Approved by the Ministerial Conference in Yerevan, May 2015) This document contains the self-evaluation of the AI, which is part of the application to renew membership of European Association for Quality Assurance in Higher Education (ENQA). It is also forming part of the basis for the application to renew the listing of AI in the European Quality Assurance Register for Higher Education (EQAR). The self-evaluation is submitted with a view to the external review panel paying a site-visit to AI in April The report has been prepared by a project group from AI. Other employees at AI have been involved in respect of relevant topics. Copenhagen, Denmark, 20 January

6 Self-evaluation outline The report is divided into the following parts: Part 1 contains reflections on the present status of AI and discusses a number of the challenges facing AI. Part 2 contains a description of the organisation of AI and the Accreditation Council as well as a description of the higher education system in Denmark. Part 3 contains the self-evaluation part of the report, in which an account is made of how AI is compliant with the European standards and guidelines (ESG). A number of annexes in English have been enclosed with the report to support the reading of the self-evaluation. Other documents have not been translated into English, but will be so on the Panel s request (see also the appended Examples of relevant documents at AI). 6

7 Part 1 Management Reflections and Perspectives on the Practice of the Danish Accreditation Institution 7

8 The Management s reflections This section contains the management s reflections regarding the current status of the Danish Accreditation Institution (AI). The management wishes to present an overview of recent developments in the Danish accreditation system and wishes to highlight some of the challenges in our work and in the sector in general. Fit for purpose and documentation requirements from the institutions The Accreditation Council and the Accreditation Institution was established with the Accreditation Act of 2007, and this also introduced programme accreditation in Denmark. All study programmes across all sectors were to be systematically accredited by two independent, external quality assurance operators (ACE Denmark and EVA). The programme accreditation system contained very detailed, pre-defined criteria, which stemmed from a political desire to check the quality of the individual programmes in the almost entirely publicly funded Danish higher education institutions (HEIs). The programme accreditation system was an ambitious system with fixed standards, very consistent assessments and clear consequences for non-compliant programmes. A refusal of accreditation meant that the programmes could ultimately be closed down. Although this decision was (and is) extremely rare, the actual possibility of receiving a refusal of accreditation forced the HEIs to strengthen the quality assurance of programmes much faster than a system with lesser consequences could have done. Thus, the programme accreditation system of 2007 formed the basis for a less problematic transition to the institutional accreditation system of 2013 in which the responsibility for the quality assurance lies with the HEIs themselves. From the very beginning, the HEIs, and especially the universities, were raising the problematic issue of over-documentation. They felt, somewhat rightly, that the system s benefits regarding equal treatment of the HEIs did not measure up entirely to the costs of a programme accreditation system in which all programmes had to be compliant with the same standards and demands for documentation. The programme accreditation system has contributed to increased awareness of quality assurance in the higher education sector, and this quality assurance methodology has proved to be efficient regarding the systematic approach to quality assurance of the individual programme. This systematic approach, however, only gave little freedom to the institutions and programmes to define their own quality standards and set up their own quality assurance processes. Also, the programme accreditation system had confirmed that the quality of the programmes was indeed sufficiently high, since approximately 85 percent of all accredited programmes in all sectors had received a positive accreditation. On the other hand, the high percentage of positive accreditations indicated a less efficient usage of resources, since much effort and resources had been put into every accreditation, compliant or non-compliant, by both the HEIs and AI. In 2010, the first steps in a system change were made. The intention was to offer greater degrees of freedom to the HEIs. Experience from carrying out programme accreditation formed an important basis for the second version of the Danish accreditation system, which came into 8

9 effect in It was on the basis of experience from this system that AI stressed the importance of a new system with less focus on merely documenting compliance with the pre-defined criteria, and more focus on the HEI s own responsibility for the quality assurance of its programmes through real, day-to-day quality work at the institution. With the introduction of an institutional accreditation system in 2013, responsibility for the quality of programmes was placed with the HEIs. Furthermore, it was decided that all HEI sectors should be accredited under the same legislation and criteria. Thus, the institutional accreditation criteria are now established by the Ministry of Higher Education in such a way that they cover all institutions from the largest universities to the smallest maritime school ships. Through interpretation of the broad criteria, AI aims at being able to honour the diversity of these institutions by taking the specific identity and culture of every institution into account. Since focus is still on accreditation, and thus leads to a decision, the system must also be transparent and explicit regarding the demands imposed on the HEIs. The documentation from the institution that forms the basis of the panel s assessments must be sufficiently thorough and nuanced so that a well-substantiated decision can be made by the Council. HEIs prefer their quality assurance work to be assessed on their own terms, but they are also very focused on consistency, i.e. just and uniform assessments and decisions. This forms a dilemma for AI, which we are trying to resolve by focusing on very well-substantiated and thorough reports, so that the assessments and the basis for our decisions are clear and comparable across institutions and sectors. However, the thorough analyses and reports cannot be carried out without sufficient documentation, and it became clear from the evaluations after the first institutional accreditation round that the documentation requirements are still quite burdensome to the institutions. It is clear that we have yet to find the optimal balance between having sufficient material for the accreditation panel to make sound, fair and nuanced assessments and not requiring too much documentation from the institutions. We are focused on ensuring that the accreditation system remains fit for purpose. Thus, we will continue our on-going dialogue with the institutions at management level. Furthermore, we will continue to carry out thematic analyses that present overviews on subjects that are important to the institutions. The aim of both the dialogue and the thematic analyses is to disseminate knowledge, but also to learn more from the institutions, so that the processes and methods are continuously improved and are as efficient and relevant to the institutions as possible. Development and control We are well aware that a system with a strong element of control such as the accreditation system, while strengthening the possibilities for impact, also demands a very cautious preparation and organization to succeed. The institutional accreditation system aims at supporting quality development at the institutions. This is done by refraining from setting fixed 9

10 and detailed standards for how the institutions are to carry out quality assurance, but rather assessing whether the individual institution s system functions in practice and in its own right. The institutions have a free hand to establish an internal quality assurance system that supports their own goals, as long as they also live up to the accreditation criteria and, thus, the ESG s. As mentioned, the accreditation criteria are very general, so that all institutions can be covered by the same system. As a consequence of this, AI has issued a number of briefs aimed at explaining and interpreting the criteria, so that the institutions are well informed when going into an accreditation process. However, this sort of communication has unfortunately not been received in this spirit by all institutions. Some institutions perceived the briefs as supplementary demands and extra criteria with which the institutions must comply. We are not discouraged by this, since we consider that we are obliged to inform the institutions on a variety of platforms. Still, we find that the reactions are an indication of two issues that we have to address continuously. Firstly, the institutional accreditation system is new for every institution that is to be assessed and, thus, we have to maintain focus on meeting with the institutions and explaining the system s rationales, framework and processes as the institutions go into the process. Secondly, we must be aware that the new system, although simplified and less detailed, is still an external control process, and that, quite understandably, the institutions interpret our briefs, notes and letters in this context. It should also be noted, in a broader perspective, that we regularly conduct thematic analyses of important issues of quality and quality assurance. Here we aim to collect and disseminate our knowledge in a focused and accessible format. Our thematic analyses have three aims. Firstly, we hope to distribute knowledge and inspiration between the institutions of higher education by analysing key issues and by showing examples of how these issues are addressed at different HEIs. Secondly, it is our aim to inform our own practice of programme and institutional accreditation. And lastly, we hope to contribute to the public discussion on higher education with our knowledge and insight. Coordination with other authorities AI is not the only agent carrying out supervision of the quality and performance of the HEIs. Apart from accreditation, the higher education institutions also have to collaborate with the Danish Evaluation Institute (EVA) in various kinds of thematic or cross-sector evaluations. Furthermore, they are also subject to on-going ministerial supervision of key indicators such as drop-out rates and unemployment rates. Therefore, from time to time the institutions raise the question of overlapping authorities. AI understands this challenge very well, and in a coordination dialogue with both EVA and the Ministry of Higher Education, we aim to lessen the administrative burden for institutions, for example by using data collected by the Ministry in the accreditations. Although the establishment and alterations of these other supervision systems lie outside of AI s jurisdiction, 10

11 on-going coordination with the other agents in the field will be a focal point for further development. A new location in 2017 As part of a decentralisation reform, the Danish Government has decided to move 4,000 state employees from Copenhagen to other parts of Denmark. For AI this means that, in 2017, we are moving to Holbæk, a smaller city one hour s drive from Copenhagen. This could pose a challenge in keeping qualified staff members and could have negative consequences for the otherwise quite well-functioning cooperation between staff members, professionally and socially. However, AI has previous experience with major changes in the working environment. In 2013, the institution was formed on the basis of ACE Denmark and a section from EVA. This merger was prepared jointly by the management and staff, and it was executed in a cautious manner. On the basis of this recent history we remain positive regarding the move to the new location. If carried out in the same manner, it is hoped that the move will be completed without any major problems and loss of knowledge or experience within the institution. 11

12 Part 2 Accreditation and Education in Denmark 12

13 This part of the report describes the historical and legislative context of the Danish accreditation system and provides an overview of the organisational units mentioned in the report. 1.1 Historical Overview The (AI) was established by law in 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 European level. With the introduction of the Danish Government s Globalisation Strategy in 2006, which aimed at strengthening Denmark s position in the increasing international competition, an additional initiative was added to the quality assurance of the Danish study programmes. One of the objectives formulated in the Globalisation Strategy was for Danish higher education programmes to become world-class. In order to achieve this objective, all higher education programmes should, among other things, meet international quality standards, and the programmes should also comply with society s demand for highly qualified and competitive labour. The system was operated by two external quality assurance agencies, ACE Denmark The and the Danish Evaluation Institute (Danmarks Evalueringsinstitut (hereinafter called EVA)). Prior to the establishment of AI, the Danish Centre for Quality Assurance and Evaluation in Higher Education (Evalueringscenteret) ( ) and later EVA (from 1999) conducted a number of external programme evaluations of Danish higher education programmes. This involved a systematic evaluation of all higher education programmes according to an overall rotation plan. The results of the evaluations were not legally binding, and the evaluations could not have any financial consequences for the institutions. Between 2004 and 2007, EVA also conducted programme and institutional accreditations at mid-termed higher education level. However, the criteria were different from those after 2007 and focused on university colleges. Following experience from the first six years of programme accreditation, the Danish accreditation system was modified in The programme accreditations had shown that 85% of the programmes evaluated had achieved a positive accreditation. The HEIs raised a critique of the existing system, claiming it was unnecessarily bureaucratic and resource-intensive compared to the high number of programmes which achieved a positive accreditation. In 2011, a new government in Denmark gathered all higher education institutions under the Ministry of Higher Education and Science. Furthermore, one of the Panel s conclusions in the ENQA review of AI in 2010 was that accreditation at institutional level should be considered. AI and the Accreditation Council shared this view and contributed to the process of change prior to the new Act. The contribution included stakeholder dialogue and the Council s input to the design of the new system. On this background, the Danish accreditation system was modified by the Minister for Higher Education towards one common system for all types of higher education programme and institution, with strong focus on compliance of the HEIs internal quality assurance systems with the ESGs. As a consequence of the new Accreditation Act in 2013, ACE Denmark and the 13

14 unit responsible for accreditation in EVA were merged into one: The Danish Accreditation Institution. The first round of the new institutional accreditations was conducted during , and included eight HEIs. In January 2016, the second round of institutional accreditations is now running, supplemented by follow-up on one HEI, which achieved conditional positive accreditation in the first round. In 2016, an additional six HEIs have applied for institutional accreditation, supplemented with the reaccreditation of one HEI which achieved conditional positive accreditation in the first round. The accreditation processes will start during spring It is up to the HEIs do decide when to apply for institutional accreditation, but it is expected that all HEIs will be accredited by 2018/ The Accreditation Institution From a legislative perspective, the Accreditation Institution (AI) is anchored in the Danish Act on the Accreditation of Higher Education Institutions (Lov om akkreditering af videregående uddannelsesinstitutioner) of 2013 (hereinafter the Accreditation Act). Responsibility for the Accreditation Act lies with the Danish Minister for Higher Education and Science (hereinafter the Minister for Higher Education). AI s funding is from the annual Finance Act. In 2014, funding totalled DKK 36.6 million, with 41 employees (38,5 full-time equivalents) The Accreditation Institution s tasks The Accreditation Act sets out the responsibilities of AI, which are to ensure and document the quality and relevance of higher education programmes. AI meets these responsibilities by carrying out institutional accreditations as well as programme accreditations. Institutional accreditation is based on pre-defined criteria for the HEIs to ensure their continuing and systematic assurance and development of programme quality and relevance. Furthermore, AI carries out accreditations based on centrally defined criteria for the quality of existing and new study programmes. The accreditation tasks of AI are as follows: Accreditation of all higher education institutions in Denmark Accreditation of new and existing bachelor, master s (candidatus) and master programmes 1 at universities Accreditation of new and existing professional bachelor and academy profession programmes as well as further adult education and diploma programmes Accreditation of new and existing bachelor, master s (candidatus) and master programmes under the Ministry of Culture, including the bachelor, master s (candidatus) and master (postgraduate education) programmes in the Arts 1 In the Danish educational system a distinction is made between on the one hand master s (candidatus) degree studies, which are full time university studies principally targeting students graduating from secondary education, and on the other hand master studies, primarily offered to people in work as part-time further educational activity at university level. 14

15 Thus, following the logic of the 2013 Accreditation Act, two systems are currently in operation, but institutional accreditation is gradually succeeding programme accreditation. A clear outcome of achieving a positive institutional accreditation is that it allows the HEI the option to set up new programmes as well as justifying existing programmes. Furthermore, an HEI s existing programmes will no longer have to undergo programme accreditation. In practise, this outcome means that institutional accreditations will replace accreditation of existing programmes and provisions of programmes. Higher education programmes in Denmark are primarily anchored in the Ministry of Higher Education. A minor group of artistic education institutions are anchored in the Ministry of Culture. The accreditation criteria vary depending on the rules applying within the two ministries. As a result of the Danish system, the Accreditation Act is therefore implemented in two different ministerial orders with different sets of criteria. One ministerial order for institutions and study programmes under the Minister for Higher Education and one for institutions and study programmes under the Minister for Culture. Accreditation is mandatory and a precondition for attaining public funding for all institutions and study programmes. A very limited group of HEIs and programmes are anchored within other ministries, for instance the Police Academy and the Royal Danish Defence College. AI also conducts programme and institutional accreditations for these HEIs as revenue-funded activities. In addition to the accreditations, an important element in the Accreditation Act stipulates that AI has to gather and disseminate relevant national and international accreditation experience. AI has carried out this task by conducting annual thematic analyses. The analyses reflect the findings in the accreditation reports or other themes regarding quality assurance and educational policy issues. Furthermore, AI participates in relevant national and international conferences and disseminates new international experience and knowledge to stakeholders. In recent years, the institution has also contributed to international conferences by presenting papers. For instance at the INQAHEE conference 2015 and the EQAF AI puts a very strong emphasis on a close dialogue with all key stakeholders regarding all activities. In practice, this means that AI annually hosts start-up meetings with the HEIs prior to new rounds of programme and institutional accreditations and AI regularly meets with both the senior management and administrative units to discuss experience from previous accreditations. A recent initiative is the establishment and hosting of STAR (Student Accreditation Council), which is a discussion forum for students engaged in quality assurance and political activities at the HEIs. Additionally, the subjects for the thematic analyses are determined in dialogue with key stakeholders such as the rectors conferences for the different sectors in Danish higher education, national students associations and representatives from the Danish labour market The organisation of the Pursuant to the Accreditation Act, the Danish accreditation system formally consists of: 15

16 The Accreditation Institution, which is an independent authority within the State Administration, and which conducts accreditation of higher education institutions and their programmes The Accreditation Council, which makes decisions concerning all the above accreditation tasks The Minister for Higher Education appoints a Director nominated by the Accreditation Council, which also approves advertisements for the position. In performing her duties, the Director is not subject to the power of instruction from the Minister or the Accreditation Council. The Director has an obligation to complete accreditation reports as the basis for the Accreditation Council s decisions. In terms of budgetary matters, AI has its own budget line in the annual Finance Act and in matters of administration, the management reports to the Minister for Higher Education as the management is subject to the general rules applicable within the State Administration. As can be seen from the description of the statutory organisational units, a clear division of work has been defined between the decision-making authority, the Accreditation Council, and AI, which is also reflected in the Director s outline of the organisation. The Accreditation Council is thus an independent unit outside AI, whereas the four internal units have their separate duties. According to the Accreditation Act, AI is to serve the Accreditation Council. This is reflected in the establishment of the Council Secretariat. However, the employees of the Council Secretariat are a part of AI and contribute to projects across different areas. Management secretariat Assists the other secretariats with their work. Manages finances. Law matters. Handles internal and external communication. The Area for Professional, Vocational and Maritime Institutions (PEM) Handles accreditation of new and existing programmes and local provisions of programmes within the area. Handles accreditation of university colleges, academies of professional higher education and maritime education institutions. Takes part in Danish and international cooperation and development projects. Documents and communicates activities and results. The Area for Universities and Educational Institutions of Arts and Culture (UNIK) Handles accreditation of new and existing programmes within the area. Handles accreditation of universities and art academies. Takes part in Danish and international cooperation and development projects. Documents and communicates activities and results. The Council Secretariat Provides the Accreditation Council with service. 16

17 Prepares Council meetings. Is responsible for the Council s communication with AI. Maintains contact with the Council s stakeholders. The two areas will be named PEM and UNIK in the following. Figure 1: Organisational chart of the Accreditation Institution 17

18 1.3 The Accreditation Council Accreditation Council Responsibilities and Organisation According to the Accreditation Act, the Accreditation Council is the specific body which makes the decisions regarding accreditation of all higher education institutions and their programmes based on accreditation reports prepared by the. The Council has authority to award, conditionally award, or deny accreditation for all higher education institutions and their programmes. The Council s decisions are based on the overall assessment and recommendations of the accreditation reports. The Accreditation Council holds approximately five meetings a year. At its meetings, the Council makes decisions regarding accreditation of higher education institutions, study programmes and the provision of programmes, in addition to considering a number of different issues of relevance to the accreditation task. The Accreditation Council defines its procedures and methods independently of both political and other institutional interests. The Council has overall responsibility for ensuring the quality and relevance of higher education programmes. The Council s decisions and the basis for these decisions are accessible to the public, as both the decisions and the accreditation reports are published on In addition to the Accreditation Council meetings, the Council Chair and Vice-chair (the Chairmanship) meet regularly with AI to plan the Council s meetings and deal with procedural problems and issues of principle as may arise in the course of their accreditation activities. Moreover, the Council meets with external stakeholders such as the Minister of Higher Education and the stakeholder organisations of the educational institutions in order to discuss issues of principle. Composition of the Accreditation Council The Accreditation Council has a Chairman, a Vice-chairman and seven other members, including two student members. The Minister for Higher Education appoints the Chairman. The rest of the Council s members are appointed by the Minister for Higher Education on the basis of recommendations from relevant institutions, organizations etc. The members of the Accreditation Council are appointed based upon their experience and knowledge of quality assurance, higher education, research and development and labour market conditions. At least one of the members must have international accreditation experience. The Council must be composed of an equal number of men and women. The Chairman and the members are appointed for a period of four years. However, the two student members are only appointed for a period of one year. Members are eligible for reappointment once. The As can be seen from section 1.2, the is the operator for all higher education institutions and study programmes in Denmark. The Danish Accreditation Institution also collects national and international experience of relevance to accreditation. The 18

19 s performance of its tasks and responsibilities are described in further detail in Part 2. Other operators According to the Accreditation Act, at its own initiative or following a request from a university, the Accreditation Council may base its accreditation decision fully or partly on an accreditation report from another internationally recognised institution, to the extent that such report is prepared in accordance with the same criteria as other accreditations within the field in question. So far, this option has never been exercised. The Advisory Committee to Assess the Range of Higher Study Programmes Offered (RUVU) In 2013, the Minister for Higher Education established the Advisory Committee to Assess the Range of Higher Study Programmes Offered (hereafter RUVU). This is a committee dedicated to deciding on the relevance of proposals for new programmes. RUVU is a part of the overall accreditation architecture, but is an independent committee within the ambit of the Ministry of Higher Education, and with no organizational affiliation to the. RUVU issues a recommendation of prequalification based on an assessment of the relevance or pertinence of the proposed new study programme. It is the Minister of Higher Education who on this basis formally decides on whether a programme is to be prequalified, and thus allowed to apply for accreditation. This decision is taken prior to any steps being taken to initiate the Accreditation Institution s accreditation processes and the Accreditation Council s decisions. In practice, the establishment of RUVU has meant that assessment of the relevance of new programmes is removed from the accreditation process. 1.4 The Accreditation Council as Decision Maker The Accreditation Council decides on accreditation of all higher education institutions and their programmes in Denmark, regardless of the ministry under which such programmes belong. The Accreditation Council fulfils this role by, among other things, entering into a broad dialogue with the most important stakeholders. Thus, the Chairmanship in particular engages from time to time in dialogue with the Minister for Higher Education, Parliamentary spokesmen on higher education policy, and with the various rectors conferences/rector chairmanships. Moreover, the Council hosts conferences that bring together many different players within the field of higher education in order to consider questions relating to quality assurance. Finally, it should be stressed that, due to its decision-making authority, the Accreditation Council is subject to public attention in connection with the announcement of its decisions and communication of the consequences of its decisions for the accredited programmes Decision-making Process of the Accreditation Council The Accreditation Council makes independent decisions based on accreditation reports prepared by the accreditation operators. As can be seen from part 3, the reports contain recommendations which form the basis of the Council s decisions. However, the Council is not 19

20 bound by these recommendations and, if it sees reason to do so, may decide not to follow a recommendation. The present Accreditation Council was appointed in January 2014 and has enjoyed considerable stability among its members since. One of the present members was also a member of the former Council, and this overlap ensures consistency between the present Council and the former Council s experience. Even though this has created a sound basis for ensuring coherence and continuity in the Council s decisions, the Council is also working continuously to optimize its decision-making process, including the preparations which are necessary to ensure efficient and credible decisions based on a large number of accreditation reports. Finally, it should be mentioned that the always attends the Accreditation Council meetings so as to answer any questions from Council members. The Council members are requested to send any questions to AI a few days beforehand in order to allow the operator time to prepare. It is important for the Accreditation Council to be well acquainted with the procedures and methods which form the basis of the decision-making platform presented to the Council. Therefore, the Council is presented to the operators procedures and methods on a continuing basis. The procedures and methods are regulated under the auspices of the Danish Public Administrations Act, which governs instructions concerning the legal position of citizens towards the civil administration. Thus, the Council s feedback to the Danish Accreditation Institution is focused on enhancement and alignment in order to ensure transparency and equality. 1.5 Outline of the Danish Higher Education System This section provides an overview of the Danish higher education programmes. See also Annex H: Framework for Higher Education Institutions in Denmark Higher Education Institutions and Study Programmes The higher education system under the Ministry of Higher Education in Denmark includes eight universities, eight university colleges, nine academies of professional higher education, three artistic education institutions and 10 maritime education institutions. In total, there are approximately 240,000 students at higher education institutions under the Ministry of Higher Education. The number of applications for higher education programmes has grown in recent years. All higher education institutions are primarily publicly funded and are subject to various types of regulations and state supervision. In addition, there are seven HEIs under the Ministry of Culture and a few institutions under the Ministry of Defence and the Ministry of Justice. Accreditation is mandatory for all higher education under the auspices of the Ministry of Higher Education and the Ministry of Culture. 20

21 Figure 2: Overview of the Danish higher education institutions under the Ministry of Higher Education Danish higher education programmes are divided 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 a national level to meet the need for well-qualified professionals in the private and public sectors. The and the Accreditation Council cover all types of higher education institutions and study programmes in Denmark. In Denmark, it has been decided politically that PhD programmes are not subject to accreditation. Research-based programmes are offered by the universities, and regulated by the Ministry of Higher Education in the Danish University Act (Universitetsloven) (Annex xx). There are approximately 1,050 research-based study programmes, educating approximately 140,000 students. The professionally oriented programmes, with approximately 100,000 students, are 21

22 predominantly offered by the University Colleges and the Academies of Professional Higher Education. Whereas the university programmes are research-based, these programmes are based on up-to-date knowledge, recent research results and close contact with practice. These programmes and institutions are also regulated by the Ministry of Higher Education. The programmes fall under the Danish Act on Academy Profession and Professional Bachelor Programmes (Lov om erhvervsakademi- og professionsbacheloruddannelser). Furthermore, a small group of maritime education programmes are offered by the Maritime Education Institutions. Finally, there are the professionally oriented programmes offered at institutions under the auspices of other ministries, e.g. the Ministry of Defence and the Ministry of Justice. Most Danish institutions of higher education have been merged over the last years to form larger units. This means that the institutions have been strengthened with more students and a broader provision of study programmes, but also that the administrative systems have undergone adaptation and development Qualification Levels in the Danish Higher Education System 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. This is illustrated in Figure 3 below. The Danish qualification framework systematically describes the different degree types within the Danish higher education system. Figure 3: Qualification levels in the Danish higher education system 22

23 Part 3 Compliance by the Danish Accreditation Institution with the European Standards and Guidelines for the External Quality Assurance of Higher Education 23

24 ESG Part 2 - Compliance by the with the ESG for External Quality Assurance ESG 2.1 Consideration of internal quality assurance STANDARD: External quality assurance should address the effectiveness of the internal quality assurance processes described in Part 1 of the ESG. GUIDELINES: Quality assurance in higher education is based on the institutions responsibility for the quality of their programmes and other provision; therefore it is important that external quality assurance recognises and supports institutional responsibility for quality assurance. To ensure the link between internal and external quality assurance, external quality assurance includes consideration of the standards of Part 1. These may be addressed differently, depending on the type of external quality assurance. Later in this report, under ESG 2.5, the criteria that the institutions and study programmes must comply with in institutional accreditations and programme accreditations are described in detail. The criteria were established by the Ministry of Higher Education. Thus, the Danish Accreditation Institution is responsible for implementation of the criteria, but responsibility for any alterations to the criteria lies with the Ministry. In general, institutional accreditation covers the following areas in ESG Part 1: ESG 1.1: policy for quality assurance (Criterion 1) ESG 1.2: design and approval of new study programmes (Criterion 5) ESG 1.3: student-centred learning (Criterion 4) ESG 1.4: student admission and progression (Criteria 4) ESG 1.5: teaching staff related to the programmes (Criterion 3) ESG 1.6: facilities and learning resources (Criterion 4) ESG 1.7, ESG 1.9 and ESG 1.10: cyclical external quality assurance as well as analysis and use of information for effective management and on-going monitoring of programmes (Criteria 2, 3, 4 and 5) ESG 1.9: contact and dialogue with labour market stakeholders for the monitoring of the programmes (Criterion 5) In general, programme accreditation covers the following areas in ESG Part 1: ESG 1.3: student-centred learning (Criterion 4) ESG 1.4: student admission and progression (Criteria 3 and 4) ESG 1.5: teaching staff related to the programme (Criterion 2) ESG 1.6: facilities and learning resources (Criterion 5) ESG 1.7 and ESG 1.9: analysis and use of information for effective management and ongoing monitoring of programmes (Criterion 5) 24

25 ESG 1.9: contact and dialogue with labour market stakeholders for the monitoring of the programmes (Criterion 1) Thus, the considers that it meets the part 1 standards to the extent that institutional accreditation reviews the effectiveness of the HEIs internal QA processes, and that the accreditation process for programme accreditation reviews the HEIs quality assurance systems for the programme as one of five criteria. A key element in both types of accreditations is that responsibility for the quality assurance of study programmes and institutions lie with the HEI itself. Accreditation is one important external element aimed at ensuring the quality of the HEIs study programmes. The legislation on higher education is another element, which also represents an important framework for the organisation and quality assurance of study programmes. Among other things, the Danish legislation ensures that student assessments are based on published criteria, rules and procedures. These are set out in the following ministerial orders: the Danish Ministerial Order on Bachelor and Master's (Candidatus) Programmes at Universities ( Uddannelsesbekendtgørelsen ), the Danish Ministerial Order on Academy Profession Programmes and Professional Bachelor Programmes ( Bekendtgørelse om erhvervsakademiuddannelser og professionsbacheloruddannelser ), the Danish Ministerial Order on the Grading Scale and Other Forms of Assessment of Institution Education ( Karakterbekendtgørelsen ) and the Danish Ministerial Order on Examinations ( Eksamensbekendtgørelsen ). The Danish Ministerial Order on Examinations also ensures that a minimum of 1/3 of the exams in every study programme are carried out with the participation of an external examiner, whose main task is to ensure the fairness and objectivity of the examination of the students. The organisation and the activities at the HEI s are in general regulated by a number of Acts and Ministerial Orders. As a consequence, not all aspects mentioned in ESG Part 1 are subject to accreditation, because these activities are already regulated by the national legislation and/or labour market agreements. Aspects which are not subject to accreditation are: Number of students admitted (part of ESG 1.4), recruitment of teaching staff (part of ESG 1.5), funding per student FTE (part of ESG 1.6), public information (ESG 1.8). In recent years, the Danish HEI s have endeavoured to establish and systematise their work on internal quality assurance systems. At present, institutions differ as to how far they have come in this work. Supporting the development of institutions quality assurance systems has therefore constituted a key focal point for the guidelines for the accreditation of institutions which came in effect in July 2013 (see also ESG 2.2). The institutional accreditations that have already have been decided on by the Council reflect the more diverse and developmental approach to external quality assurance. Firstly, very different systems and institutions, from the Technical University of Denmark to University College Sjælland, have received a positive accreditation. Secondly, institutional accreditation is an external quality assurance system with high threshold levels, and just four of the first nine 25

26 institutions have received a positive accreditation. Four institutions have received a conditional accreditation and one has received a refusal of accreditation (as of January 2016). As mentioned earlier, the Danish system of quality assurance of higher education is based on a political decision to shift the focus from programme accreditations to institution accreditations. However, in a transition phase, until all institutions are accredited, AI must make sure that also the non-accredited institutions are ensuring the quality of their programmes. As a consequence, programme accreditation is still carried out in these institutions, focusing on the larger programmes with a high number of students, or on faculties and institutions that have received a relatively higher number of less than positive accreditations in the past. 26

27 ESG 2.2 Designing methodologies fit for purpose STANDARD: External quality assurance should be defined and designed specifically to ensure its fitness to achieve the aims and objectives set for it, while taking into account relevant regulations. Stakeholders should be involved in its design and continuous improvement. GUIDELINES: In order to ensure effectiveness and objectivity it is vital for external quality assurance to have clear aims agreed by stakeholders. The aims, objectives and implementation of the processes will bear in mind the level of workload and cost that they will place on institutions; take into account the need to support institutions to improve quality; allow institutions to demonstrate this improvement; result in clear information on the outcomes and the follow-up. The system for external quality assurance might operate in a more flexible way if institutions are able to demonstrate the effectiveness of their own internal quality assurance. AI has continually developed and amended the accreditation concept with the intention of ensuring an efficient accreditation concept in the sense that the criteria are transparent and predictable and at the same time wide enough to encompass very different types of programmes and institutions. It is important for AI that key stakeholders are involved in this work: - The institutions and their common representation, such as Danish Universities, University Colleges Denmark and Danish Business Academies - National student organisations - The Danish Ministry of Higher Education - Industry/labour market representatives, such as the Confederation of Danish Industries and the Confederation of Danish Employers - Trade unions The following section provides a description of the shift towards institutional accreditation and how the stakeholders are involved in development of the accreditation concept and guidelines. Furthermore, AI s procedure for the publication for guidelines and accreditation reports is outlined in section ESG 2.6. Regarding solutions for specific quality issues, the institutions can demonstrate their improvement in various ways; most notably in the follow-up process after a conditional accreditation (see section ESG 2.3). Fit-for-purpose an overarching principle in accreditation In 2013, when the accreditation system was amended, one of the main objectives was to establish a system that was both fit-for-purpose and also ensured less work load for the institutions involved. One way to lessen the workload and the cost for the institutions when being accredited is to ensure their involvement in the drafting of the guidelines that interpret the criteria. This ensures transparent criteria for assessment and a mutual understanding of the 27

28 needs for documentation. Another way is to make sure that the institutions can extensively use pre-existing documentation to show that they meet the criteria, such as annual reports to the board on study programmes, and minutes or key indicators that are already collected because they inform about ongoing quality assurance work. Involving the institutions and lessening their workload are conditions that AI finds important and takes into account when developing methodologies and conducting accreditations. Programme accreditation is largely comprised of a fixed set of assessment points that the programme must accommodate. With institutional accreditation the institutions themselves are responsible for designing and applying a system that ensures and develops the quality and relevance of their programmes. The institutions have the freedom to design a quality assurance system that reflects their programmes and any special circumstances that might pertain to them. Hence, in institutional accreditation, there is stronger focus on policies and strategies affecting quality assurance, and holistic assessments are made that take into account whether the institution s quality assurance policy and procedures are fit-for-purpose. With the introduction of institutional accreditation, the control perspective on quality assurance is now combined with a more developmental perspective. As part of the self-evaluation report, the institutions are to reflect upon the strengths, weaknesses and potential for improvement within their own quality assurance systems, and take into consideration, for instance, the way in which the system functions in relation to the specific character of the institution, its visions, objectives and challenges. Because the higher education sector is composed of institutions that have different knowledge bases, size and institutional set ups, an important aspect of institutional accreditation is that it allows for different quality assurance systems, provided the dispositions within them are wellsubstantiated and of course meet the criteria for quality and relevance laid down in the Ministerial Order. It is thus stated in the guidelines that: Institutional accreditation places the responsibility for the quality of programmes squarely with the institution and the institution management. This means that the institution must have established a quality assurance system that reflects the programmes at the institution. (Annex D: The Guide for institutional accreditation, p. 3). When drafting the criteria, it was important to AI, that the criteria took into account the heterogeneity of the HEIs. There is focus on the overall framework for quality assurance at the institution, and the criteria concerning how it is put into practice are also phrased in inclusive and broad terms to take into account the heterogeneity of the HEIs (see ESG 2.5). At the same time, this consideration must be balanced with the need for a transparent system where it is clear to the institutions that they are assessed on equal terms. The choice of using audit trails is another way to ensure methodologies are fit-for-purpose. This method ensures that the accreditation panels have an opportunity to select several areas of interest that they can examine more closely. This can be areas of general importance, but most often it will be areas of interest due to the specific characteristic of the institution being accredited. The institutions are consulted in identifying the relevant interviewees and the 28

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