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Document 52014DC0029

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Report on Progress in Quality Assurance in Higher Education

/* COM/2014/029 final */

52014DC0029

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Report on Progress in Quality Assurance in Higher Education /* COM/2014/029 final */


TABLE OF CONTENTS

1........... INTRODUCTION....................................................................................................... 3

2........... TRENDS IN QUALITY ASSURANCE SINCE 2009.............................................. 4

2.1........ How has QA supported the academic community, students and other stakeholders in reaching quality goals?............................................................................................................................ 4

2.2........ How has QA helped institutions to broaden access and ensure that students complete their degrees?      5

2.3........ How has QA supported HEIs in providing students with high quality, relevant skills? 6

2.4........ Has QA supported study mobility and internationalisation?....................................... 7

3........... CONCLUSIONS – EU SUPPORT FOR QUALITY ENHANCEMENT IN HIGHER EDUCATION 9

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS

Report on Progress in Quality Assurance in Higher Education

(Text with EEA relevance)

1.           Introduction

European higher education faces significant challenges. The European Commission, in a series of recent strategy papers, has highlighted these challenges – greatly expanding the student population, raising quality and aligning teaching and learning more closely to wider societal and labour market needs[1]; adapting to globalisation and the huge growth in higher education students and institutions across the world, challenging Europe's position as a world leader in education[2]; and improving and widening the delivery of higher education by harnessing new technologies such as MOOCs and virtual or blended learning[3]. The PIAAC survey of adult skills[4] has pointed to differences in the levels of graduates' skills across countries. In the face of these challenges, it is vital to maintain and enhance the quality of higher education, developing modernised higher education institutions (HEIs) that equip people with high level skills and drive economic and social development, helping to achieve the Europe 2020 goals of better jobs and stronger growth.

HEIs have the ultimate responsibility for the quality of their offering (setting, monitoring and renewing their quality goals through 'internal' quality assurance). They are supported by external agencies (QAA) which assess quality standards, evaluating institutions, accrediting programmes or benchmarking performance against other HEIs ('external' quality assurance). But public authorities have a duty to ensure that the quality of individual institutions, and of their higher education system as a whole, are fit for purpose. A framework of national and European tools and cooperation enhances trust across systems. Quality assurance mechanisms are therefore essential to help institutions and policy makers to make a success of their reforms.

The present report follows the first published in 2009[5], responding to the invitation from the European Parliament and Council in 2006 to report on progress in quality assurance[6]. Building on the findings of the 2009 report - which identified the need to make QA more efficient and transparent for users; to link it overtly to wider higher education priorities; and to develop cross-border cooperation to improve quality – and drawing on a wide range of sources, it highlights the potential for quality assurance to play a more active role in supporting reform at system and institutional levels and proposes EU actions to support institutions and Member States.

Quality assurance (QA) is often perceived as focusing on process rather than content. But QA still has untapped potential to support institutions in reaching their objectives. QA that is tailored to each HEI’s vision and priorities will encourage greater diversity and specialisation of HEIs and promote wider engagement with and accountability to stakeholders, systematically feeding results back into strategic decision-making, with an emphasis on continuous improvement. And change is taking place. The remit of some QAAs is being extended to review broader higher education objectives such as widening access, lifelong learning, internationalisation, etc.[7] In some cases, doctoral training[8] and human resources strategies[9] are also subject to quality reviews. There is an on-going shift, in external QA, from the traditional focus on accreditation of individual programmes offered by an institution to the evaluation of the entire institution. The large majority (69%) of QA systems now focus on a combination of institutional evaluation and programme accreditation and a growing minority have shifted to exclusively institutional evaluation[10]. This is promising for the future direction of QA – institutional evaluation empowers academics and HEIs to build curricula and to ensure their quality, avoiding the need for formal, external accreditation of each individual programme and allowing them to adapt provision rapidly to changing labour market needs and to changes in the make-up of the student population.

2.           TRENDS IN QUALITY ASSURANCE SINCE 2009 

2.1.        How has QA supported the academic community, students and other stakeholders in reaching quality goals?

The vast majority of HEIs have established explicit QA structures and processes (in a 2010 survey only 5% had no quality policy statement)[11]. Over 75% of HEIs have a public strategy for continuous quality enhancement and in CZ, DK, ES, IT, FI, LU and NL this reaches 100%[12]. But institutions are grappling with how to move away from process-orientation to establish a genuine culture of continuous quality improvement[13]. Designing QA so that it creates a process of continuous feedback into an institution's strategic orientation, with clear accountability at all levels, remains a challenge[14]. 

Students' involvement in quality enhancement is improving, according to the QUEST survey, with around 85% of students having the chance to take part in student evaluations, and significant numbers believing these impact on the quality of education[15]. Students are 'highly involved' or 'equal partners' in QA in 17 countries in 2012, compared with 9 in 2009 – but their involvement varies not only across, but within, national systems; in many HEIs it is limited to formal presence and observation.[16]

Many countries have a formal requirement that employers participate in external quality assurance (BE-fr, BG, CZ, DE, DK, EE, EL, FR, IT, LT, LV, PT, UK-Sc). [17] However, actively involving them in quality enhancement through participation in institutional audits, for example, is not widespread: employers participate in external review teams only in BE(fr), DE, EL, FI, LV (for professional programmes), LT and UK (depending on institutions)[18].

Outside stakeholders are also more likely to be involved at an information-sharing level rather than as active partners in the institution’s own internal QA.

Publishing QA results stimulates quality enhancement and helps build trust and transparency, but the tendency to publish positive evaluations only (BE-nl, CY, CZ, ES, FR, HR, LT, MT, PL, UK) is not helpful. In only 12 cases (BE-de, BE-fr, DK, EE, FI, HR, IE, IT, LU, LV, PT, SK) do more than one quarter of institutions also publish their critical reports.[19] The information is often not easy to understand or accessible, limiting its value.[20]

At European level, the European Standards and Guidelines (ESG), developed in 2005, have helped convergence of QA across countries and provided a framework for cooperation between QAAs. However, their current generic nature means that they are understood differently and applied unevenly. At institutional level, their penetration and impact remains limited. Only 12% of respondents to a EURASHE survey considered the ESG useful to academics; only 10% considered them useful to students, alumni or employers[21]. Many HEIs consider that although the generic frameworks exist, there is not enough practical advice on how to develop a strong quality culture[22]. Students are largely unaware of them (59.7 % reported having no knowledge at all; 23.9 % very limited knowledge)[23]. The ESG are being revised, as requested by the Bucharest Ministerial conference in 2012, to improve their clarity, applicability, usefulness and scope[24]. The revision is an opportunity to reinforce the institutional response to challenges such as widening participation, reducing dropout, improving employability etc., and to ensure that QA encourages the development of a strong quality culture and the genuine engagement of the academic community.

2.2.        How has QA helped institutions to broaden access and ensure that students complete their degrees?

To reach the Europe 2020 and national targets to increase graduate numbers and so close the skills gap, Europe needs to attract a broader cross-section of society into higher education. QA needs to support institutions in reviewing and strengthening the quality and impact of their policies for recruiting students and how these impact on widening access. However, initial research shows little evidence that QA agencies support institutions in widening access through more innovative approaches to admission, for example, through recognition of prior learning, allowing students to document and transfer credits from programmes from which they have dropped out, or by developing access pathways from VET and other education sub-sectors [25].

The quality of HEI strategies to prevent dropout[26] and stimulate retention, with indicators or targets to measure progress, influences students’ chances of successful completion. Involving students in programme design and curriculum development can lead to better outcomes for the students. However, only 50% of HEIs do so, and only 40% use student surveys to measure workload.[27] Systems that track students' progress - as in BE-nl, DK, DE, IE and UK - can identify risk elements, targeting intervention to improve study success. Monitoring completion targets, as do half of EU QA systems (BE de, BE-fr, BE-nl, EE, EL, FI, IT, LT, HU, PT, SI, IS, LI, NO),  or linking completion rates to funding, as in a minority of countries (AT, BE-nl, CZ, DK, I, DE, IT, NL, SE, UK-Sc)[28], incentivises HEIs to monitor, and improve, their success in preventing dropout.

Currently only 40% of HEIs regularly evaluate their support services for students.[29] While almost all offer educational support such as tutors, mentors, guidance and counselling, only just over half evaluate how well these perform. A similar pattern can be observed for library, computing, or laboratory support.

2.3.        How has QA supported HEIs in providing students with high quality, relevant skills?

The shift to student-centred learning is one of the most challenging recent reforms. While most HEIs define study programmes in terms of the intended learning outcomes for students, the challenge remains of incorporating learning outcomes into teaching, learning and assessment. QA can encourage HEIs to support academics in this task (e.g. the compulsory training for academics in using learning outcomes provided by AT, BE-fr, CZ, IE, LV, RO, UK)[30] Applying QA to programme design can help academics to design and assess study courses around clear and relevant outcomes and to award credits in a consistent way. However, this is generally not done in external programme accreditation.[31] By ensuring the proper application of other transparency tools based on learning outcomes – qualifications frameworks, the European Credit Transfer and Accumulation System (ECTS), the Diploma Supplement – QA can support learning outcomes as the building blocks of higher education delivery – and so support also the better recognition of academic qualifications from other countries[32].

Most HEIs use QA to evaluate and develop teaching skills and qualifications, but research activity still tends to outweigh teaching in academic promotion, and only one quarter of HEIs provide compulsory training for their teachers[33]. QA can support the development of national and institutional strategies that promote staff training; recognise teaching skills in career development; promote teaching awards or fellowships; use student feedback; and incentivise international experience[34].

New modes of delivery, such as blended learning or massive open online courses (MOOCs), have the potential to change how education is delivered. QA frameworks and institutions need flexibility to support institutions in adopting different modes of innovative course delivery, adapting their concepts of quality and developing new indicators to enable these changes. Institutional evaluation should support institutions to plan and allocate resources to developing their new modes, to enhance their attractiveness, develop niche services, or reach learners outside formal education. Some countries – ES, IT, NO – are currently investigating the potential for QA bodies to assess MOOCs.

Many institutions find it difficult to involve employers systematically in curriculum design and delivery, for example in ensuring that placements lead to clear learning outcomes. QA can support institutions to involve employers in designing work-based learning around relevant learning outcomes and assessment methods. In some countries (BE-fr, BG, DK, EE, AT, NO, CH) HEIs must show that they involve employers in programme development[35]. More systematic cooperation with vocational education and training, both by HEIs and QAAs, can support this goal and help develop more flexible learning pathways.

To help ensure that graduates have the right skills for the labour market and to reduce skills mismatches, QA can be used to demonstrate that study programmes meet labour market needs. In BG, CZ, IT, AT and SI, HEIs can be required to show that their programmes answer an existing demand[36]. QA can also support HEIs to feed knowledge about graduate career paths into the design and delivery of programmes – for example, linking graduate tracking to funding (CZ, IT, SL, UK) or to (re)-accreditation (AT, BE-nl, BG, DE, DK, NL) [37]. In several countries (e.g. BG, DK, EE, IE, EL, FR, IT, LV, LT, HU), higher education institutions regularly submit data or show they monitor or track graduate employment.[38]

Despite these findings, overall, few HEIs currently track or survey their alumni to improve educational programmes and graduates’ employability[39]. Those that do see multiple benefits – developing a more systematic approach to QA, improving accountability, contributing actively to a Europe of knowledge,  and improving links with stakeholders[40].

2.4.        Has QA supported study mobility and internationalisation?

Growing international cooperation in higher education has created peer pressure for institutions to develop strong QA, and HEIs intending to develop their international profile want to be able to demonstrate their quality standards, as a prerequisite for the trust that underlies international partnerships[41]. Students value known quality standards when making study choices, ensuring they avoid poor quality providers and institutions that offer or accredit fake or poor quality degrees without authorisation. A commitment to QA can also help offset concerns (as raised inter alia by the PIAAC survey) about the quality of foreign degrees, which can hinder recognition and student mobility.

The European Association for Quality Assurance in Higher Education (ENQA) and the European Quality Assurance Register (EQAR) foster cooperation on QA at European level. Through ENQA membership, about two-thirds of QAAs in the EHEA (up from around half in 2009)[42] are recognised as acting in compliance with the European Standards and Guidelines. However 10 EU countries (CY, EL, IT, LV, LU, MT, PT, SE, SI, SK) are without a full member agency in ENQA[43].

EQAR has also grown in numbers (from 19 government members at its founding in 2008 to 32 in 2013[44]). The register supports a pan-European approach to external quality assurance, where institutions may choose to be evaluated by any QAA outside their country, stimulating a European, quality-enhancing dimension to QA. Thus far, 39 EHEA agencies (84% of all eligible QAAs - those which have been reviewed against the ESG) have applied to join EQAR, of which 35 applications have been approved[45]. Key users of the Register are now more confident that EQAR is helping to open national QA systems for agencies from abroad (60% of national students unions in 2012, compared to 41% in 2009)[46].

However national ministries tend to prefer working with their own rather than foreign Agencies. As yet, only two-fifths of EQAR-registered QAAs actually operate across borders, and for those that do, national differences in QA and the lack of a common European QA dimension pose challenges. Six EU countries (AT, BE-nl, BG, LT, PL, RO) allow their HEIs to work with foreign registered agencies for regular evaluation, audit or accreditation. Two more countries (DE, DK) recognise QA decisions of all EQAR-registered agencies on joint programmes[47].

The external QA and accreditation of joint programmes is a challenge as it normally includes multiple national accreditation procedures. Governments have undertaken to examine national legislation and practices relating to joint programmes and degrees as a way to dismantle obstacles to cooperation and mobility. A current Bologna Process initiative to develop a European approach for accrediting joint degrees may help minimise bureaucracy and facilitate the growth of joint degrees. In the meantime, projects by ECA[48] are a step towards simplification and mutual trust.

Budget restrictions have meant that many QAAs have concentrated on core activities inside their national systems.[49] But as higher education becomes more globally connected, QA needs to develop to create the trust needed by HEIs to cooperate internationally. One positive development since 2009 is the tendency to include international experts in QA panels. ENQA and EQAR can play a key role in building trust, including by involving ministries and other stakeholders, gathering data on QAAs’ activities across borders, and promoting common standards and approaches (encompassing data collection at national level, comparable standards, strategic documents and reports).[50]

Cross-border cooperation in QA is particularly essential for cross-border higher education (CBHE - franchising and branch campuses). Although it affects only a small number of students in Europe, it is increasing and quality assurance arrangements vary substantially between countries and providers. By monitoring the quality of their institutions' CBHE exports, QAAs can help to ensure high quality education and so safeguard the reputation of their HE system and their wider ability to attract incoming students.

An increased focus by QAAs on the quality of cross-border cooperation, with agencies strengthening their own international links, will increase the credibility, transparency and consistency of their assessments. To facilitate the process, QAAs in the hosting country could be informed about quality assessments of CBHE institutions located in their country, or could carry out joint assessments. Bilateral agreements mandating the QA agency in the receiving country to act on behalf of the sending QA agency, or to allow an EQAR-registered agency to evaluate the CBHE institution, would help meet quality concerns and have the added advantage of encouraging cross-border cooperation and mutual learning.

3.           CONCLUSIONS – EU SUPPORT FOR QUALITY ENHANCEMENT IN HIGHER EDUCATION

This report demonstrates some progress since 2009, but also reveals gaps in how QA supports higher education reforms such as widening access, improving employability and internationalisation, or improving doctoral training and human resources strategies. To bridge these gaps, QA has to become a support to creating an internal quality culture rather than a tick-box procedure. It needs to engage with all areas of an institution's activities, to keep up with change in how higher education is designed and delivered, and involve the entire institution in creating a quality culture that underpins teaching and learning.

Moreover, citizens increasingly move between systems – both in the traditional initial education pathway and to upgrade and widen their knowledge and skills throughout their lives. More and more learning opportunities no longer fit in conventional classification arrangements. Learners are increasingly offered – and rightly so – the chance of assembling their learning pathway by selecting opportunities from different sub-systems and forms of delivery, including via learning resources delivered through ICT, and they need to be able to trust their quality.

The emergence of quality assured qualification frameworks for lifelong learning, strongly promoted by the EQF, calls for reflections on a sector-based approach to quality assurance and on whether it is possible to identify some basic principles and guidelines valid across sectors and applicable to all qualifications. To address such challenges, it would be valuable to discuss QA in higher education within a comprehensive context of all instruments for transparency and quality assurance. The case for closer coordination of all European instruments for transparency and quality assurance is being explored by the Commission as a way to achieve a full European area of skills and qualifications. The scope of quality assurance should be widened to cover a broader range of topics relevant to higher education.

In that light the Commission plans to undertake the following actions towards better European cooperation in quality assurance for lifelong learning:

· Consulting stakeholders on the findings of this report and on the need for and feasibility of improving coherence between quality assurance in different education sub-sectors, as part of the forthcoming public consultation towards a European area of skills and qualifications, seeking further synergies and convergence of EU transparency and recognition tools[51].

· Stressing the need for a thorough-going revision of the ESG that lays emphasis on raising quality standards rather than on procedural approaches, widens its scope to include the issues raised by this report, and opens up to cooperation on quality assurance with other education and training sectors.

· Continuing to improve the articulation of European transparency tools that support quality assurance, recognition and mobility, inter alia in its follow-up to the 2013 evaluations of the European Qualifications Framework, EQAVET and Europass; through support to the ENIC-NARIC network, EQF National Coordination Points and Europass Centres; and in the revision of the ECTS Users’ Guide.

· Working with Member States to encourage[52] more quality assurance agencies to apply for EQAR registration; and to allow foreign EQAR-registered agencies to operate in their HE systems.

· Continuing to promote cooperation on QA at international level, through policy dialogue with key international partners and as a basis for partnerships with HEIs around the world.

Through Erasmus+, the EU will provide:

· Support for cross-border cooperation in QA through:

· Strategic partnerships and knowledge alliances, enabling HEIs to learn from each other in developing quality cultures and in supporting involvement of employers and new stakeholders such as researchers, employees, etc.;

· Providing support to QAAs and HEIs to work together to develop internal quality assurance processes to address key challenges and ensure better impact of the revised ESG at institutional level.

· Enhancing cross-sectoral dialogue with VET on the theme of QA;

· Sharing good practice to foster simpler procedures for accreditation of joint programmes, through European-supported initiatives.

· Support for higher education reform, including 

· An initiative to promote reform in higher education, including on the development of a quality culture, through peer-learning and review and stakeholder studies or tools, manuals, etc.,

· Innovative projects to enhance the capacity of quality assurance to support sustainable reform.

The Commission welcomes the emphasis placed by a number of countries on the quality of their higher education systems in the draft Partnership Agreements being submitted to provide a framework for spending under the 2014-2020 European Structural and Investment Funds. It is vital that these commitments are underpinned by focused initiatives in the operational programmes which will implement the Agreements, and strengthening quality assurance arrangements should be a clear objective of such initiatives.

[1]              COM(2011) 567 final

[2]              COM(2013) 499 final

[3]              COM(2013) 654 final

[4]               OECD Skills Outlook 2013: First Results from the Survey of Adult Skills. http://skills.oecd.org/documents/OECD_Skills_Outlook_2013.pdf

[5]              COM(2009) 487 final

[6]              Recommendation 2006/143/EC of 15February 2006 (OJ L 64of 4.3.2006)

[7]               Rauhvargers, Andrejs (2012): Report by the EHEA Working Group on Recognition, p 23. Available online at http://www.ehea.info/Uploads/%281%29/Recognition%20WG%20Report.pdf

[8]               http://www.eua.be/Libraries/Publications_homepage_list/Salzburg_II_Recommendations.sflb.ashx

                http://ec.europa.eu/euraxess/pdf/research_policies/Principles_for_Innovative_Doctoral_Training.pdf

[9]               http://ec.europa.eu/euraxess/index.cfm/rights/strategy4Researcher

[10]             EACEA (2012): The European Higher Education Area in 2012: Bologna Process Implementation Report, p 60

http://www.ehea.info/Uploads/%281%29/Bologna%20Process%20Implementation%20Report.pdf

[11]             Loukkola, Tia; Zhang, Thérèse (2010): Examining Quality Culture: Part 1. EUA. Brussels, p. 33. http://www.eua.be/pubs/Examining_Quality_Culture_Part_1.pdf

[12]             EACEA, op.cit, p 68

[13]             IBAR (2012): Identifying Barriers in Promoting the ESG for Quality Assurance at Institutional Level. Work Package 8, p 4

 http://www.ibar-llp.eu/assets/files/wp8/WP8%20Cross-country%20comparative%20study.pdf

[14]             Ibid, p 38

[15]            Jungblut, Jens; Vukasovic, Martina (2013): QUEST FOR QUALITY FOR STUDENTS - Survey on Students’ perspectives. ESU, Brussels, p 68. http://www.esu-online.org/resourcehandler/30010f4b-c7a9-4827-93a5-84aaaaa91709/

[16]             Bischof, Lukas; Gajowniczek, Joanna; Maikämper, Moritz (2013): Study to Prepare the Report on Progress in the Development of Quality Assurance Systems in the Various Member States and on Cooperation Activities at European Level, p 27

[17]             Modernisation of Higher Education in Europe: access, retention and employability - Eurydice research, to be published first semester 2014. BE-de and IS involve employers in external QA without any formal requirements.

[18]             Eurydice source data for the Bologna Implementation report

[19]             EACEA, op.cit, p 69

[20]             Bischof et al., op.cit, p 39. Vercruysse, Proteasa, 2012

[21]            ENQA (2011): MAPPING THE IMPLEMENTATION AND APPLICATION OF THE ESG (MAP-ESG PROJECT). ENQA. Brussels, p 56. http://www.enqa.eu/files/op_17_web.pdf

[22]             IBAR (2012): Work Package 5, p 12

http://www.ibar-llp.eu/assets/files/wp5/WP5%20Cross-country%20comparative%20study.pdf

[23]             Jungblut, Vukasovic, op.cit, p 67

[24]             EHEA Ministerial Conference (2012): Bucharest Communiqué, p2. Revision undertaken by stakeholder organisations (ENQA; ESU; EUA; EURASHE, Education international; EQAR; Business Europe) for endorsement by Ministers in 2015

[25]             Eurydice, op. cit.

[26]             OECD average in 2011 is 68.4% of undergraduates who complete their degree.

[27]             Loukkala, Zhang, op.cit, pp. 11, 30

[28]             EACEA, op.cit, p 112

[29]            Sursock, Andrée; Smidt, Hanne (2010): Trends 2010: A decade of change in European Higher Education. EUA. Brussels, p 86

http://www.eua.be/typo3conf/ext/bzb_securelink/pushFile.php?cuid=2756&file=fileadmin/user_upload/files/Publications/Trends_2010.pdf

[30]             EACEA, op.cit, p 51

[31]             Ibid, p 51

[32]             Cf Bucharest Communiqué, p 4

[33]             Loukkala, Zhang, op.cit, p 34

[34]            Report of the High Level Group on Modernisation of Higher Education, http://ec.europa.eu/education/higher-education/modernisation/index.html

[35]             Eurydice unpublished

[36]             Ibid.

[37]            Gaebel, Michael et al (2012): Tracking Learners’ and Graduates’ Progression Paths (TRACKIT). EUA. Brussels, pp 27-28.

 http://www.eua.be/Libraries/Publications_homepage_list/EUA_Trackit_web.sflb.ashx

[38]             Eurydice unpublished

[39]             Gaebel et al., op.cit, p 26

[40]             Ibid, p 44

[41]             Sursock, Smidt, op.cit, p 21

[42]             Bischof, op.cit, p 50

[43]            http://www.enqa.eu/agencies.lasso, checked on 04/11/2013 (although this includes small countries that may not have a national QAA)

[44]             EU Governmental Members: AT, BE-nl, BG, HR, CY, CZ, DK, EE, ES, FR, DE, IE, PT, LV, LU, MT, NL, PL, PT, RO, SI - http://www.eqar.eu/association/members.html#c28

[45]             http://www.eqar.eu/fileadmin/documents/eqar/information/EQAR_AR12_screen.pdf

[46]             Bischof, op.cit, p 56

[47]             Tück, Colin (2013): EQAR Annual Report 2012, pp 15-17. http://www.eqar.eu/fileadmin/documents/eqar/information/EQAR_AR12_print.pdf

[48]             Ibid. See also MULTRA at: http://www.ecaconsortium.net/main/documents/mutual-recognition-agreements

[49]             Bischof, op. cit, p 52

[50]            ENQA and EQAR led projects to report in 2014.

[51]             COM(2012) 669 final

[52]             Strategic Plan 2013 – 2017 (Tück, op.cit, pp 25-29) suggests, inter alia, doing this through the ESG revision.

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