FAQ-Kategorie: 13 Working methods of the Accreditation Council

Accreditation applications are regularly handled by the German Accreditation Council in the following manner:

The Head Office first carries out a plausibility check. This consists of a reading of the accreditation report and, if necessary, individual inquiries in the self-evaluation report and attachments. For reasons of efficiency and cost savings, it is important to avoid duplicate reviews in the peer-review procedure with the Agencies and the peer review panel on the one hand, and in the Accreditation Council on the other, as far as possible. Comprehensible accreditation reports are therefore essential in the new Accreditation system. If too many questions remain unanswered, the report is returned (see FAQ 13.2).

Based on this reading – every accreditation report is read in full – the Head Office prepares a draft resolution. In this, the decision proposals of the Agencies (formal report) and the peer review panel (peer review report) can be followed or deviated from with reasons.

In the next step, a rapporteur from the group of university lecturers in the Accreditation Council examines the draft resolution, accreditation report and any other documents and submits a vote. Additional members of the Council from other member groups may also participate in this phase.

The vote on the report, any revised draft resolution and the application documents are submitted to the Accreditation Council for a resolution. It decides at one of its usually four annual meetings. Each member can request a discussion on each application. In practice, it has been shown that the majority of applications are undisputed; the Accreditation Council endeavors to concentrate the limited resource of “consultation time” on cases that are actually disputed and on those of fundamental importance.

The accreditation decision is issued on the basis of the resolution. If the Accreditation Council intends to deviate from the decision proposals in the accreditation report in a way that is burdensome for the applicant higher education institution, namely by imposing additional conditions or a negative decision, no notification is issued. Instead, the higher education institution is first given the opportunity to comment on the Accreditation Council’s provisional resolution (§ 22 para. 3 MRVO). If use is made of this opportunity and the statement questions the intended decision, the Accreditation Council deals with the application a second time. Only then, taking into account the statement, does it make a final decision on the accreditation of the study programme or the QM system and any necessary conditions and issues the accreditation decision. In the event that conditions are imposed, the deadline for fulfilling the conditions is only set in this accreditation decision.

If conditions are imposed, the higher education institution must submit evidence of fulfillment of conditions by the deadline specified in the notification (§ 27 para. 3 MRVO); the Accreditation Council then decides on the fulfillment of conditions. If the Accreditation Council comes to the conclusion that the fulfillment of conditions has not been proven, the higher education institution is given a one-time grace period of usually six months.

During the processing of accreditation applications, it may become apparent that the accreditation report is not sufficient as a basis for decision-making and that establishing the decision-making capability (extensive recourse to self-evaluation report and annexes, inquiries at higher education institutions and Agencies) would be too time-consuming. In order for the Accreditation system to function efficiently, it must be ensured that the Accreditation Council only has to carry out its own extensive research and develop assessments in exceptional cases and that, as a rule, there is no “double review” of content by the agency/peer review panel on the one hand and the Accreditation Council on the other.

The key to the entire accreditation procedures are the accreditation reports. The Accreditation Council has set out its requirements for them in an initial general resolution (see here). In addition, numerous individual accreditation resolutions have provided further guidance on the aspects to be considered for manageable accreditation reports. The Foundation’s Head Office has also provided continuous feedback to the Agencies.

Nevertheless, it is still too often the case (as of January 2020) that accreditation reports do not provide a sufficient basis for decision-making or cannot be produced with reasonable effort. In such cases, which can occur in any processing phase, a return is made to the applicant higher education institution with the request to submit an accreditation report revised by the Agencies and the peer review panel. The return is usually decided by the Board of the Foundation.

The higher education institutions should not suffer any disadvantage from such situations, any deadlines are met and accreditation gaps do not arise.
The respective reasons are communicated with the return. Accreditation reports that have one or more of the following problems are generally not ready for a decision and will be returned:

(1) Unclear subject of assessment
The accreditation report does not clearly indicate which (partial) study programmes and / or study programme variants were the subject of the assessment, or not all (partial) study programmes, variants etc. were sufficiently assessed. The review must clarify which study programmes, partial study programmes and variants are actually offered by the higher education institution. In any case, a complete inventory and evaluation must be carried out. As a rule, the examination regulations are decisive here, and in regulated study programmes, external specifications may also be relevant; in teacher training, for example, state law determines which subjects/partial study programmes are available. Often “overlooked” are dual variants/study programmes, double degrees, variants with and without practical semesters, etc.
In combined study programmes, this is the subject of accreditation and must primarily be assessed and evaluated before the subjects/partial study programmes are added. Cf. FAQ 10.1

(2) Non-comprehensible report
An accreditation report is largely not comprehensible on its own. In order to obtain a valid basis for decision-making, a considerable amount of additional fact-finding would have to be carried out by researching the self-evaluation report and the application documents and / or making enquiries with the higher education institution concerned and / or the responsible accreditation agency.

(3) Inconsistent report
The assessment of individual academic criteria within the accreditation report is blatantly contradictory. A valid basis for decision-making cannot or cannot easily be established without knowledge of the on-site discussions and / or comprehensive technical expertise.
The contradictions are usually expressed in the fact that a blatant deficiency is stated in the documentation and especially in the assessment of a criterion, but the criterion is reported as fulfilled and no conditions or only a recommendation is proposed. Examples from practice:

• For a laboratory-intensive study programme, the evaluation stated that the spatial equipment was not up to date and was in great need of modernization. A specific “shopping list” was given as a recommendation; it was not clear why no conditions were proposed here.
• The lack of a permanent study program coordinator was presented in abstract terms as a drastic problem in the evaluation, without, however, going into more detail about specific negative effects on ongoing study operations. Only a moderately formulated recommendation was given. In the exceptional follow-up investigation carried out by the Accreditation Council, it emerged that the peer review panel had made a “courtesy recommendation” here, combined with an exaggeratedly critical description of the situation in order to strengthen the faculty for financial negotiations with the university management. Such maneuvers contradict the conventions for honest reporting; moreover, they complicate the work of the Accreditation Council considerably.
• The peer review panel analyzed quite plausibly that central qualification goals in a study programme were only taught in the compulsory elective area and were therefore not achieved by all students, but derived only one recommendation from this.

Another phenomenon that is difficult for the Accreditation Council to handle occurs when recommendations are given at the end of the assessment of a criterion without their subject having been dealt with in the documentation and assessment.

Ideally, and this is also the case in numerous accreditation reports, the severity of a critical assessment is plausibly classified; this allows third parties to understand why conditions are proposed, why a recommendation is considered sufficient or why no action is required.

(4) Incomplete report
Assessments are missing for one or more criteria, possibly also status reports. Examples:

• The study programme is carried out in cooperation with higher education institutions or non-university institutions. However, this was not addressed in the accreditation report under the relevant paragraphs 9, 19 and 20 of the MRVO. Cooperation agreements were not documented or evaluated, and in some cases they were not available as an attachment to the self-evaluation report.
• In reaccreditations, academic success (§ 14 MRVO) was not evaluated. Drop-out rates and/or actual study times were not taken into account.

The Accreditation Council’s communication of news is based on four pillars:

1. The website is the central information repository. All relevant information can be found there.
2. On a daily basis, the Accreditation Council’s accounts on x, mastodon, bluesky and LinkedIn promptly link to any significant new information on the website.
3. Press Releases about the results and resolutions of Accreditation Council meetings are posted on the Informationsdienst Wissenschaft (idw) and published on the Accreditation Council’s website.
4. The Accreditation Council’s Newsletter provides bundled information about innovations on the website in the form of a “digest”. The newsletters are also made available on the website: https: //workshop.akkreditierungsrat.de/aktuelles/newsletter/newsletter-archiv/.

In addition to its Head Office, the Accreditation Council also relies on the freelance services of external experts to process accreditation applications. In this way, applications can be processed more quickly than would be possible with the limited capacities at the Head Office. In addition, the external freelancers, some of whom work in the German higher education system, provide important additional expertise. They are carefully selected and sworn to secrecy. Due to their freelance work, they are not integrated into the Head Office’s work organization and are therefore visible in ELIAS with their individual contact details (email address, telephone number).

13.5.1: What are the recommendations that the agency and peer review panel make to the higher education institution?

The legal basis for recommendations is described in the explanatory memorandum to § 24 MRVO:
“This does not exclude the possibility that the peer review report may contain, for example, recommendations on the quality development of the study programme or the quality management system, which are aimed at improving quality beyond the standards to be used as a basis for accreditation by the Accreditation Council and therefore cannot form the basis for any conditions.”

Recommendations therefore serve to develop quality. They do not mean that a criterion from the MRVO is only incompletely fulfilled.

13.5.2: How does the Accreditation Council deal with ‘recommendations’?

The Accreditation Council very much welcomes it when Agencies and peer review panels use the instrument of recommendation. This happens very often, as a random sample has shown: The 130 applications dealt with for the first time at the 112th AC meeting on 31.03/01.04.2022 contained 781 recommendations, with a median of five recommendations per application.

As a rule, the Accreditation Council does not comment on this type of recommendation and does not comment on it or adopt it as its own, as this is not its task. It concentrates on (potentially) condition-relevant issues, see 13.5.3 below. If the Accreditation Council comes to the conclusion that a recommendation proposed by the peer review report is to be classified as problematic with regard to the criteria of the MRVO, it will point this out to the higher education institution in the notification. In practice, however, this only happens very rarely.

13.5.3: Does the Accreditation Council convert recommendations into conditions?

In exceptional cases, the Accreditation Council comes to the conclusion that a condition-relevant fact was only given as a recommendation. The Council then independently issues a condition. In the random samples (see 13.5.2), however, this only affected approx. five percent of all recommendations, i.e. approx. 95 percent remained as recommendations.

13.5.4. Does the Accreditation Council itself make recommendations?

In fact, the Accreditation Council itself sometimes makes additional comments on the study programme or the QM system in its notifications. The term “recommendation” is avoided for such comments. Instead, the Accreditation Council refers to the fact that it combines its decision with a “note” or several “notes”.

13.5.5 What is meant by “recommended resolution”?

In Article 3 para. 2 sentence 1 no. 4, the interstate study accreditation treaty names the “assessment and preparation of a peer review report with resolution and evaluation recommendations in accordance with the standards laid down in the legal ordinance pursuant to Article 4” as a basis for accreditation procedures. Therefore, the entire accreditation report represents a recommendation to the Accreditation Council as to how the quality of the study programme or the university’s internal QM system should be assessed. The explanatory memorandum to § 22 MRVO explains further:
“The Accreditation Council assesses compliance with the formal criteria on the basis of a formal report. The Accreditation Council assesses compliance with the academic criteria on the basis of a peer review report. As these are recommendations of the Agencies, the Accreditation Council is not bound by these assessments.”

There is therefore a further dimension to the concept of recommendation here. In everyday life, however, when we talk about recommendations, we are referring to the recommendations made by the Agencies and the peer review panel in accordance with Section 24 MRVO.

The employees of the Head Office of the German Accreditation Council can be contacted by telephone and e-mail. The contact details can be found here and in ELIAS for the respective applications; freelance application processors may be named there, see FAQ 13.4.

ATTENTION: The Head Office’s digital telephone system does not currently display missed calls reliably. This means that if you have not reached anyone by telephone, the person you have called will unfortunately not be able to see this call. In such cases, please contact us briefly by e-mail.