Comparing Quality Assurance Practices For International Branch Campuses Across Eight Agencies: Is There Common Ground? Ralph A. Wolff ABSTRACT One of the growing trends in higher education is the expansion of International Branch Campuses (IBCs) across the globe. Several countries have become major senders of programs into receiving countries. 1 As well, over the past decade, several cities have become major educational hubs for these branch campuses, where there is a concentration of multiple providers from different countries offering a wide range of programs to residents and non-residents alike. As the number and scale of IBCs increase, it has become an important issue for all involved students, provider institutions, sending and receiving countries that there are adequate quality assurance systems in place to monitor the quality and integrity of these offerings, and assure the comparability of the credential offered to that of the home campus. This study reviewed the quality assurance processes of agencies in eight countries or administrative units representing both senders and receivers: Dubai, Hong Kong, Singapore, Malaysia, United Kingdom, Australia and two regional accrediting agencies in the United States the New England Association of Schools and Colleges (NEASC) and the WASC Senior College and University Commission (WSCUC). For the purpose of the study a common template was developed that was completed by each agency (see Appendix). Preliminary results were documented and presented at the first Quality Beyond Boundaries Conference in March 2014. One of the topics discussed at this conference was whether there were sufficient common processes among the QA agencies to develop a set of general principles or build on several advisory statements already in existence. The group found, however, that developing common principles was premature. More important would be direct conversations among the principals of those QA agencies most engaged with either sending or receiving IBCs to share practices and concerns and to further potential collaboration. Subsequently, the study was expanded and earlier submissions updated. The major finding of this study is that there are understandable variations in quality assurance practices between sending and receiving agencies that 1 Sending quality assurance agencies are those who review and monitor the quality of the institution offering programs outside of the home jurisdiction of the institution. Receiving quality assurance agencies are those that have processes to review only those operations in their local or host jurisdictions. Some agencies act as both sending and receiving agencies. Where applicable, the policies for these agencies with respect to each category are noted. 1
demonstrate the need for greater communication and collaboration among the agencies. A few clusters of similar practices were found among subsets of both sending and receiving QA agencies. The focus of sending QA agencies is primarily on the institution as a whole, rather than a single branch campus or cluster of programs. Receiving agencies, on the other hand, focus primarily on the branch campus and its programs operating within its jurisdiction, giving a much higher degree of scrutiny therefore to a small subset of institutional operations. 2 As a result, a series of issues are presented in the final section for discussion at the Quality Beyond Boundaries II Conference in London. Given the variations in many aspects of process, further understanding of each agency s policies and procedures is needed along with identifying areas for greater collaboration and mutual recognition. Background to the study Both this study and the first Quality Beyond Boundaries Conference were initiated by the Knowledge and Human Development Authority of Dubai (KHDA). As one of the largest educational hubs in the world, KHDA has developed a University Quality Assurance Institutional Board (UQAIB) that relies in its review of programs operating in the free zones of Dubai on the accreditation or quality assurance validation of the sending country. Thus, there was great interest in better understanding the quality assurance processes of the countries sending programs to Dubai, and determining if there was common ground for collaboration with other jurisdictions serving as major educational hubs. Attending the first conference were representatives of the United Kingdom, Hong Kong, Malaysia, Singapore, WSCUC and the staff and Board members of UQAIB. The representatives of local IBCs were also present during the first day of the meetings. A template was developed to gather information of an initial group of five QA agencies the QAA of the United Kingdom, TEQSA of Australia, Dubai and, from the United States, NEASC and WSCUC. Additional support for this project was provided by Peter Ewell of the National Center for Higher Education Management Systems (NCHEMS) along with additional research and financial support from Laureate Global Education Services. Preliminary findings were presented and discussed at the Quality Beyond Boundaries I Conference in Dubai in March 2014. The findings from the study of the initial group led to the conclusion that further collaboration and communication between both sending and receiving QA agencies would be valuable, and that it would be important to have the senior leadership from each agency represented at 2 In the United States, the term branch campus is defined to include a site where multiple programs of the institution are offered with its own administrative and managerial staffing, to be distinguished from the offering of a single degree program in a foreign location. The use of the term branch campus in this paper refers to all forms of offerings in a foreign country. 2
the next meeting, The QAA agreed to host a follow up conference in October 2014. Several follow up steps were identified such as updating the information provided for each of the original five agencies, expanding the scope of agency comparisons to include Hong Kong, Singapore and Malaysia, and mapping international campuses among the countries represented. Important Issues the Study Addresses As more institutions engage in establishing IBCs, the receiving quality assurance agency needs to know what provisions are in place in the home country or jurisdiction for reviewing and assuring the ongoing quality of the sending institution in the international location. Even if the receiving QA agency undertakes its own review, it is relying on the assurance of quality of the home institution provided by that institution s QA agency. A quality assurance review of the home institution might address such issues as faculty qualifications, library and technology resources, learning outcomes assessment, etc. for the whole institution, but may not drill down to addressing each of these issues at the international branch campus. Institutions, in turn, need to be clear about and meet all requirements of the QA agency in both its home and local jurisdictions. As discussed later, sending QA agencies typically rely on the institution to determine and meet local legal and licensing requirements. As well, students rely on the equivalency of quality and outcomes of IBC programs to those at the home campus, as do employers. Students also need transparent information about the qualifications necessary for admission, graduation, and how the degree or qualification will be recognized within the local jurisdiction. In addition, they need to know whether they may file a complaint with the local or home QA agency regarding institutional practices. To gather information in a common format across agencies, the study research team developed a template to identify key areas of review such as whether prior and post-implementation reviews are required, costs, handling of complaints, external examiners and grading moderation processes, the use of Qualifications Frameworks and more. The use of a common template has allowed the determination where there are common practices and where variations occur across agencies in the same substantive and procedural areas. Differentiating Between Sending and Receiving Agencies There are multiple perspectives relevant to the treatment of IBC s: that of the sending QA agency, that of the receiving jurisdiction s quality assurance agency, that of the institution and that of students enrolled in the IBC s programs. One principle is common across all agencies that the institution is fully responsible for the quality and integrity of all of its programs wherever located, and the quality assurance processes of all eight agencies rely upon and are intended to validate that these internal quality controls are in place both in terms of process and results. 3
At the same time, there are considerable differences among the eight agencies. Policies and procedures are best divided into two categories those QA agencies in sending jurisdictions (NEASC, WSCUC, QAA, TEQSA, and to some extent, Singapore), and those in receiving jurisdictions (Hong Kong, Dubai, Singapore and Malaysia). QA agencies in sending jurisdictions are responsible for ensuring the quality of operations of the home institution in foreign locations, whereas the receiving jurisdiction QA agencies need to ensure that local requirements are met. As reflected below, the differences in procedures for sending and receiving agencies make communication and collaboration all the more important. In all cases, the sending agency holds the institution responsible for the quality and integrity of all activities of the institution wherever located; yet there are significant differences in how this responsibility is monitored, ranging from little to no monitoring to extensive prior review and approval procedures. The receiving QA agency, on the other hand, has to determine whether to accept the work of the sending QA agency or undertake its own independent reviews. Here we found significant variations. Finally, while being ultimately responsible for qualify and integrity, the institution needs to have clarity of the procedures and criteria applied by both the sending and receiving QA agencies. It is accountable to assure quality and integrity through its internal processes. The main finding of this study is the considerable variation of practices by both sending and receiving QA Agencies, with few common principles across all agencies. 3 Sending QA Agency Practices While considerable information has been collected regarding each agency s practices, the following areas seem the most important: Prior approval required to establish an IBC: Yes US accreditors (NEASC and WSCUC) and Singapore (one-time registration) No QAA, TEQSA, and Malaysia Periodic Monitoring through required reporting and site visits 3 Programmatic or specialized accreditors also engage in international accreditation but are not the focus of this study. In Malaysia, for example, they are relied upon as part of the MQA programmatic review process. 4
Yes US accreditors conduct a site review within the first year of operation and thereafter only if a follow-up site visit to a specific location is called for based on the initial review or as part of a sample of sites visited in a comprehensive institutional review.) No TEQSA only if complaints or a risk analysis creates a high level of concern about the site; QAA only if the IBC is in a jurisdiction subject to a countrywide review. International provision is included in the scope of periodic comprehensive reviews of both agencies even if site visits are not conducted. Costs Additional fees for IBC approval and monitoring NEASC and WSCUC Included within ongoing institutional fee structure QAA and TEQSA Public Reports Only WSCUC and QAA make all reports and actions public on their websites; for QAA, IBC reports, however, would only occur as part of a country-wide review. Agency handling of complaints from students All agencies require the institution to maintain a student complaint process Yes NEASC and WSCUC required to receive complaints by US federal law On a limited basis TEQSA, QAA and Singapore no individual complaint handling process but will receive complaints from individuals and may take follow up action. Communication and Collaboration with Receiving QA Agency Yes QAA only as part of a country-wide review; TEQSA only if a site visit is conducted to the IBC (which is rare); No - WSCUC instituted a policy calling for direct communication with the host QA agency when visiting a foreign institution for its institutional accreditation, but it does not normally communicate with the receiving QA agency when reviewing a degree program or site in another country through its substantive change process; NEASC has collaborated through a formal agreement with the Commission for Academic Accreditation in the UAE but does not communicate with all QA agencies when IBCs are visited. Requirement of External Review (e.g., External examiner or program review) 5
Yes QAA (external examiner); TEQSA (external examiner or program review), WSCUC and NEASC (program review) Requirement of a Grading Moderation Process 4 Yes QAA and TEQSA No NEASC and WSCUC Focus on Learning Outcomes/Use of a Qualifications Framework All require an institutional focus on learning outcomes; TEQSA, QAA and Malaysia reference degree programs against their national Qualifications Frameworks. Allowance for local curricular adaptation All expect the program to be the same as offered at the home campus but allow adaptation to local laws and customs where needed. NEASC has an additional policy on gender separation. How best to apply principles of academic freedom within the context of different national customs and laws has been a topic of discussion and controversy within the USA in relation to IBCs. WSCUC has begun to explore functional equivalencies in the context of accrediting institutions in other countries in areas such as academic freedom, governance, and general education; how these policy adaptations might be extended to IBCs is not yet known. Receiving QA Agency Practices Prior approval required to establish an IBC Yes Both Hong Kong and Malaysia have extensive registration procedures and follow up monitoring. IBCs with robust internal quality assurance processes may qualify for self-accrediting status. Dubai has an extensive validation system that relies on the home institution s being accredited or approved by its country s QA agency. Singapore requires that any program be approved prior to implementation. Periodic Monitoring through required reporting and site visits 4 Grading moderation is an external review process intended to ensure consistency across grades or marks assigned by instructional staff; it is used in the United Kingdom, Scotland, Australia, and a number of other countries. 6
Yes Hong Kong, Malaysia and Dubai have regular reporting and follow up validation processes at time of institutional and program revalidation. Dubai requires periodic revalidation and also an annual report. Costs Kong. Fees for IBC approval and monitoring Dubai and Malaysia but not Hong Public Reports No In Dubai, Malaysia and Hong Kong, however, lists of approved programs are published Agency handling of complaints from students All agencies require the institution to maintain a student complaint process On a limited basis The Malaysian Ministry and MQA maintain a formal complaint process. Dubai does not maintain a formal complaint review process but will receive complaints and may take follow up action. Hong Kong does not have a provision to receive complaints. Communication and Collaboration Between Sending and Receiving QA Agencies No Malaysia, Hong Kong, Singapore and Dubai do not contact the Sending QA agency when a local site visit is conducted nor maintain ongoing communication with the agency. Requirement of External Review (e.g., External examiner or program review) Yes Hong Kong, Malaysia and Dubai. Requirement of a Grading Moderation Process Yes Hong Kong, Malaysia and Dubai. Focus on Learning Outcomes/Use of a Qualifications Framework All require an institutional focus on learning outcomes; Hong Kong and Malaysia reference degree programs against their national Qualifications Frameworks. 7
Allowance for local curricular adaptation Yes Hong Kong, Malaysia and Dubai where justification is demonstrated. Analysis Several major finding emerge from the review of all eight agencies: 1) there are significant differences between the practices of sending and receiving QA agencies, and 2) communication and collaboration between sending and reviewing agencies is quite limited, despite the existence of Memoranda of Understanding between multiple agencies. In all cases, the receiving QA agency relies upon the validation of quality provided by the accreditation or recognition of the home institutional provider. Yet, in the case of two of the major sending countries of IBCs, the United Kingdom and Australia, there is no formal review of an international branch campus before or after a new campus is established. It is assumed that the IBC will be operated at the same level of quality as the home institution. US accreditors, on the other hand, as well as the Malaysian, Singapore and Hong Kong QA agencies, all require prior review and approval of IBCs outside of their home jurisdictions. While the QAA of the United Kingdom includes individual visits to IBCs as part of country-wide reviews, only two such reviews have been conducted with programs in other countries reviewed only as part of the periodic institutional review and there is no mandatory follow-up required of any recommendations made in the course of such a review. Transnational provision is included in the institutional review conducted periodically through a review of documents provided by the institution about the international site. In the case of US accreditors, a site visit is typically conducted within a year following implementation of an IBC. Unless serious problems are found, which would lead to required follow-up, any further review of an IBC would only occur only if included as part of a sample of sites visited in the institution s comprehensive review process. Given cost and other considerations, there is no assurance that an IBC would be reviewed on-site again. On the other hand, all of the receiving agencies studied have established formal review and approval processes for both the institution and each program being offered in the receiving jurisdiction. All rely on the quality assurance systems of the home institution, and expect them to be validated by the sending QA agency, including some form of external review of quality (e.g., external examiner or program review). Grading moderation is not common in the US, and therefore is not an expectation of US accreditors. Only the US accreditors and Hong Kong maintain 8
formal complaint processes although all of the other agencies will respond when serious allegations are filed or a pattern of complaints arises. It would appear as well that despite MOUs between many of the agencies, individual institutional and program reviews are largely conducted by receiving agencies without significant communication or collaboration with the sending QA agency. In turn, the sending QA agencies rely upon the institution to ensure it is meeting all local laws and regulations for operating, typically without independent communication or verification. Assuming the differences highlighted by this analysis reflect local issues and concerns, there is need for opening the door to an important conversation about what greater consistency might mean for students, the institutions that serve them, and the nations that depend on a highly educated and competent citizenry and workforce in an era of increased mobility. An inventory of key elements essential for threshold quality assurance, a shared vocabulary and terminology for common issues and procedures, and a protocol for systematic bi-lateral and group communication emerge as important topics for further development. In addition, the complexity of translating one country s values into another cultural setting would seem to call for increased communication and an ongoing forum to deal with any issues that might arise from the operations of IBCs. Issues for Discussion 1. From the standpoint of a receiving QA agency, what would be reasonable expectations of oversight and monitoring of IBCs by sending QA agencies? Are these expectations being met? What a priori relationship would have to be established to assure the receiving QA agency that the sending QA agency s standards of review were adequate that is, comparable? 2. How can communication be improved between sending and receiving agencies about local laws and regulations institutions are expected to meet? Should reports and actions be routinely shared between agencies? What about complaints? 3. Should there be a forum for sending and receiving QA agencies to discuss different approaches to substantive topics such as academic freedom, online education, career and vocational education, or other topics? 4. Are there ways to increase student mobility and recognition of degrees through mutual agreements or better understanding of each agency s requirements? 9
APPENDIX IBC TEMPLATE Comparative Study of Quality Assurance Agencies International Branch Campus (IBC) 1. Quality Assurance (QA) agency name: 2. Does the QA agency have a published policy and procedure for prior approval of operations outside the geographical scope of the agency? If so, what is the procedure? What are the elements of review? Is there a prescribed template or format for submitting an application for prior approval? Does the policy or procedure involve peer and/or staff review? What is the cost? What is the timeframe for processing an application? How are MOUs with organizations in the host country reviewed? Is licensure by the host country required? Is any kind of legal review conducted prior to initiation of the program or jurisdictional venue for resolution of disputes determined? Is the institution permitted or expected to adapt the curriculum for principles of academic freedom or diversity to conform to local laws and customs? If prior approval is not required, are IBCs or international programs 3. Once approved, what kind of reporting is required, and what follow-up monitoring is conducted? Is there a template for follow-up reporting and/or visits to the IBC? What is the cost to the institution of reporting or monitoring the program/institution? Are there specific triggers for intervention by the QAA? If so, what? Is a complaint process maintained by the QAA for students and others at the international site to submit complaints directly to the QAA? Is the IBC required to have its own? 4. Site visits after initiation Are site visits required after the international activity is implemented? If site visits are conducted, at what frequency? Are all international sites visited or only a sample? 10
How are site visits conducted (to individual sites or programs, to all operating within a region or country)? Are virtual visits conducted or being considered? In the course of a visit, is the host country QAA notified or consulted? What is the typical size of the visiting teams? What is the duration of a typical site visit? Are team members given special training for international reviews? Are team members compensated? What is the cost of the review to the institution? How are international sites considered when the home institution is 5. Team Reports Are reports public? If yes, describe how the reports are publicly available. Is there a required template? If yes, please provide the template. Who prepares the reports the site visit team or the IBC staff? How are IBC visits and reports tied to comprehensive institutional reviews? 6. Data How many IBCs or sites are currently operated by institutions accredited (or quality assured) by the agency? Is enrollment and retention data at the IBC reported for each site and monitored by the QAA? Does the QAA collect information about the size, composition, and qualifications of the faculty at international sites? 7. Internal quality assurance requirements What type of home institution monitoring is required by the QAA to ensure comparative quality of the IBCs? Is external review required (e.g., external examiners or program reviews)? Is grading monitored? Are learning outcomes for each program required to be identified and assessed? Are degree qualification frameworks considered for the IBCs? 11
8. QAA actions What actions are available to the agency prior to and after a program or campus is initiated? What process exists to ensure the recommendations/requirements are implemented by the institution? What power or sanctions are available to the QAA for institutions that do not comply with the recommendations or requirements? Does the agency have reciprocity agreements with other QA agencies? If so, with which agencies. 12