FAQ-Kategorie: 18 Essential changes

§ 28 of the specimen decree (state ordinances accordingly) reads:

“1) The higher education institution is obliged to notify the Accreditation Council immediately of any essential changes to the subject of accreditation during the validity period of the accreditation.

(2) The Accreditation Council shall decide whether the essential change is covered by the existing accreditation.”

The explanatory memorandum to this paragraph goes into more detail:

“As accreditation is a permanent administrative act and changes to the formal or academic criteria may occur during the validity period of the accreditation, essential changes must be reported to the Accreditation Council without delay. […]
The duty of disclosure enables the Accreditation Council to check whether its accreditation decision is up to date and – if necessary – to adapt it to the new circumstances in the event of essential changes (e.g. by issuing a subsequent condition or revoking the accreditation decision).”

The explanatory memorandum to Section 28 MRVO lists nine changes that may be “in particular” essential changes: These concern

1. Study program title,
2. Standard period of study for the study programme,
3. Final degrees of the study programme,
4. Concept of the study programme,
5. Qualification goals of the study programme,
6. Profile of the study programme,
7. Contents of the study programme,
8. Establishment of specializations that lead to substantially different competencies among graduates,
9. if an identical curriculum is offered in different forms of delivery, at different learning locations or by different partners.

The term “essential change” is an undefined legal term that must be interpreted.  There is room for judgment here. The list of examples of possible essential changes in the explanatory memorandum provides orientation for the interpretation of the undefined legal term. Cf. FAQ 18.03 on how the Accreditation Council interprets the term.

The rationale is obviously based on program accreditation. All FAQs in this chapter therefore deal with program accreditation with the exception of FAQs 18.10, 18.11 and 18.12, which are partly or entirely dedicated to system accreditation and Alternative Procedures.

Note on the amendment: Parts of the FAQ correspond to the previous FAQ 18.02 (valid until July 2023).

The Accreditation Council would like to support higher education institutions in further developing their study programmes at any time if they so wish. It therefore wishes to avoid administrative hurdles as far as possible. With this in mind, it interprets the term “essential change” to mean that the duty of disclosure should be limited to the absolute minimum.

This trust in higher education institutions has grown out of administrative practice in recent years: essential changes that were notified were generally well-founded and were almost always approved without conditions.

The “hard core” of what inevitably constitutes an essential change consists of changes to the master data in the Accreditation Council’s accreditation database: Each accredited study programme has a specific entry in this accreditation database, which is reviewed and, if necessary, adjusted with each reaccreditation. Accordingly, every change (additions and deletions are also changes) to the master data represents an essential change. These are (this list is exhaustive):

• Study program title;
• Degree (Bachelor, Master etc…);
• Master’s type (consecutive/further education);
• Degree title (B.A., M.A., M.Sc…);
• Type of degree program (undergraduate/postgraduate);
• Teaching type;
• Forms of study (full-time, part-time, dual, part-time…);
• Standard period of study;
• Locations;
• ECTS points.

These changes also generally include a reassessment of the content of the relevant criteria of the MRVO or the applicable study accreditation ordinance of the host country.

Beyond the study programme master data (cf. FAQ 18.04), the Accreditation Council considers the case that “an identical curriculum is offered in different forms of delivery, at different learning locations or by different institutions” (explanatory memorandum to § 28 MRVO) to be an essential change.

This includes, in particular, if the study programme is offered at other locations of the same higher education institution. An essential change in this sense is also usually justified by the fact that higher education institutions and / or non-university cooperating institutions are newly involved in the implementation of the study programme.

Otherwise (see FAQ 18.03 and 18.06), the usual further developments in terms of content are not essential within the meaning of Section 28 MRVO and notification should only be made in the event of exceptionally far-reaching changes.

By no means every change to the characteristics of a study programme mentioned in the explanatory memorandum to § 28 – concept, qualification goals, profile, content – is essential. On the contrary, most changes are “insignificant” in the accreditation sense, even if they are important (= “essential”) for the further development of the study programme.

A typical example of a change that is important but not essential in terms of accreditation is the replacement of compulsory elective areas/specializations/focus areas, triggered for example by the desire to modernize or by a change in professorships.

As long as the overall framework in terms of qualification goals and resources remains broadly the same, this is not an essential change.

Note on the change: This FAQ corresponded in parts to FAQ 18.03. until July 2023.

From April 2024, essential changes to the subject of accreditation will be notified via ELIAS. An application type “Notification of (essential) change” has been set up in ELIAS for this purpose.

After logging into ELIAS, please click on the “Create new application” tile on your ELIAS home page. A selection of available application types will open. Please select the application type “07. Notification (essential) change” to display an essential change according to § 28 MRVO.

In your notification of change, you must provide evidence-based proof that the criteria of the model law or the relevant state ordinance are also met under the changed conditions. You should outline and justify your change in a short letter. In your application, please always upload amended study program documents and other evidence as PDF files (or as a ZIP file) and clearly mark the passages that have been changed.

A detailed description of the application process can be found in FAQ “ELIAS 13”.

Note on the change: This question was FAQ 18.04 until July 2023; only the “Status” has been updated.

It is determined whether there is an essential change to the subject of accreditation and, if so, whether this change is covered by the accreditation. A positive decision can be linked to ancillary conditions (conditions).

As change requests are generally decided by the Board of the German Accreditation Council, you are not bound by the Accreditation Council’s meeting schedule when submitting your application. However, please note that the Board can refer cases to the Accreditation Council or postpone a decision, for example to obtain external expertise.

Note on the change: This question was FAQ 18.05. until July 2023.

According to § 28 MRVO, essential changes must be reported “immediately”. The Accreditation Council does not set a specific deadline for this; however, it assumes that essential changes will be notified promptly after implementation.

It is also possible to notify change projects. The prerequisite is that the planning status is sufficiently advanced for an evidence-based assessment of the proposed change to be carried out.

A commitment to review intended or already implemented essential changes within a certain period of time cannot currently be given.

If a higher education institution wants to implement an essential change quickly, it is advisable to display it after the change has been made.

This cannot be assessed as part of the notification of an essential change. If a study programme changes sponsor, i.e. is transferred from one higher education institution to another, this always results in a new subject of accreditation and a new accreditation procedure is required (if the receiving higher education institution is system-accredited, it must also initiate an internal procedure immediately). Please contact the Head Office of the German Accreditation Council as early as possible.

18.11.1 (Essential) changes to internally accredited study programmes

Changes to internally accredited study programs do not fall under § 28 MRVO and therefore do not have to be reported to the Accreditation Council. Such changes are the subject of the university’s internal quality management systems, which, according to § 17 para. 1 sentence 4 MRVO, includes the further development of study programs. Whether an essential change is covered by the existing accreditation is therefore a matter for the higher education institution to decide and not for the Accreditation Council (see also FAQ 2.3). However, the higher education institution must ensure that any essential changes that have been implemented, such as those concerning study program names, study forms, degrees or degree titles, are promptly entered in the Accreditation Council’s database (ELIAS).

The registration of essential changes to the subject of accreditation as part of internal procedures of accredited higher education institutions (system accreditation or Alternative Procedures) has been carried out via ELIAS since August 2024. The entry can be made analogous to the already known application type “Entry of an accreditation (internal)”. A process description is available under the FAQ “Questions about ELIAS”(ELIAS 13).

18.11.2 (Essential) change to the quality management system of an accredited higher education institution (system accreditation or Alternative Procedures)

In the course of their system accreditation, higher education institutions have demonstrated that they regularly review the functionality and effectiveness of their QM system and continuously develop it further (§ 17 para. 2 sentence 4 MRVO). The further development is regularly carried out on the basis of a continuous evaluation of the processes set up in the system and includes a data-supported control of the results, according to the Explanation to § 17 para. 2 sentence 4 MRVO.

The far-reaching responsibility that higher education institutions are given with system accreditation therefore extends not only to the quality and further development of the study programmes they offer, but also to the QM system itself and the need for its continuous further development.

Against this background, notification of an essential change to the QM system to the Accreditation Council is only required if it involves a very far-reaching and fundamental reorientation of the system. This may be the case, for example, if several (partially) system-accredited higher education institutions, each with their own QM systems, merge or if a QM system that was previously oriented towards program accreditation is to be transferred to an accompanying QM system that follows completely different processes.

Not with reference to § 28 MRVO, as this paragraph belongs to Part 4 of the MRVO, which is entitled “Rules of procedure for program and system accreditation” and thus already expresses that Alternative Procedures are not affected by this (cf. also § 34 MRVO). The handling of essential changes to the subject of accreditation is regulated individually with the higher education institutions in the agreements to be made at the beginning of the accreditation procedures (§ 4 VoAAv).