The MRVO uses both the singular and the plural in § 31. In fact, it is the same whether one speaks of several random samples or of a sample with several (at least two) components. In order to better differentiate between the various aspects (see FAQ 19.03), the Accreditation Council prefers to use the plural as in the title of § 31 MRVO.
FAQ-Kategorie: 19 Random samples in system accreditation
The specimen decree does not assign specific terms to the three different types of random samples according to § 31 para. 2 no. 1 and 2 and para. 3 MRVO. In order to facilitate understanding, the following terms are used in this FAQ 19 “Random samples in system accreditation”:
- Program sample: The random samples in accordance with § 31 para. 2 no. 1 MRVO are referred to as program samples.
- Criteria sample: The random samples in accordance with Section 31 (2) no. 2 MRVO are referred to as the criteria sample.
- Regulatory sample: The random samples in accordance with Section 31 (3) are referred to as regulatory samples.
In accordance with § 31 para. 1 MRVO, the random samples are to examine “whether the intended effects of the quality management system (QMS) to be assessed occur at the level of the individual study programme”. The explanatory memorandum goes on to state that the random samples must demonstrate […] on the basis of a study programme to be determined by the peer review panel that the quality management system ensures that all formal and academic criteria are taken into account in the internal accreditation by the higher education institution.” In addition, the peer review panel must define formal and academic criteria […] compliance with which must be guaranteed by the quality management system to be assessed.”
Since the peer review panel in system accreditation generally does not have any subject-related expertise or at least does not have to have such expertise (see explanatory memorandum to § 25 para. 2 MRVO), the random samples are also not intended to carry out a comprehensive (renewed) peer review of a study programme or several study programmes. Rather, the random samples are aimed at checking whether the assessment of study programmes by the QMS of the higher education institution is based on a complete and plausible assessment of all formal and academic criteria of the relevant state ordinance and whether the functionality of the QMS with regard to compliance with the criteria is also guaranteed in the sense of closed control loops.
As a result, the core interest in findings is directed towards the functionality of the QMS, which is to be assessed through the in-depth examination of exemplary selected study programmes and criteria. Accordingly, the peer review report findings from the random samples should lead to conclusions at the system level.
For good reason, the specimen decree leaves open how the random samples are to be carried out in operational terms in individual cases. In this way, the agency or the peer review panel is given the opportunity to decide, depending on the situation, at which point it would like to reflect findings from the random samples back into the assessment of the QMS and which methods (interviewing persons responsible for study programs or internal peer review reports, examination of selected facts on the basis of files, inspection of premises, etc.) should be used.
The random samples consist of at least two of the following:
1. section 31 (2) no. 1 MRVO “Program sample”
For the sake of clarity, the random samples in accordance with Section 31 (2) no. 1 MRVO will be referred to below as the “program sample”.
In the program random sample, the peer review panel should review the consideration of all formal and academic criteria (with the exception of §§ 17 and 18) of the applicable legal regulation at least within one study programme (§ 31 para. 2 no. 1 MRVO). In order to assess whether the intended effects of the quality management system to be assessed occur at the level of the study programme (§ 31 para. 1 MRVO), it may be necessary to reproduce the course of an internal university accreditation procedure as an example.
If the higher education institution offers study programmes that also prepare students for a regulated profession, further study programmes are added (see regulatory sample, point 3).
2. section 31 (2) no. 2 MRVO “Criteria sample”
For the sake of clarity, the random samples in accordance with Section 31 (2) no. 2 MRVO will be referred to below as the “criteria sample”.
In the criteria sample, the consideration of formal and academic criteria (with the exception of §§ 17 and 18) should be evaluated, whereby the selection should be made in accordance with the peer review panel. The selection must include at least one formal criterion and at least one technical criterion.
The criteria sample deliberately provides for a large degree of freedom in order to enable the peer review reports to make a targeted selection of criteria and study programmes based on the knowledge they have already gained. In this context, the criteria sample also opens up the possibility, for example, of checking whether Quality Management is applied throughout the university.
3. section 31 (3) MRVO – “Regulatory sample”
For the sake of clarity, the random samples in accordance with Section 31 (3) MRVO will be referred to below as the “regulatory sample”.
The regulation sample is carried out in the form of a program sample. The main focus is on the question of whether the quality management system is able to deal with aspects that arise from the formal and academic criteria with regard to any regulations.
In this context, it is also necessary to examine whether the cooperation and approval requirements pursuant to Section 18 (2) in conjunction with Section 25 (1) sentences 3 to 5 MRVO and, if applicable, the requirements for the accreditation of study programmes are also met in the internal university accreditation procedures. additional national legal provisions and professional requirements are taken into account
For the scope of the regulatory sample, see FAQ 19.05 and 19.06; for the participation of professional licensing bodies, see FAQ 19.07.
19.05 What should be considered in the regulation sample - apart from teacher training and theology?
If the higher education institution offers study programmes that also prepare students for a regulated profession, one of these must be included in the random samples, taking into account all formal and academic criteria (Section 31 (3) MRVO).
In addition to the separately regulated teacher training courses and theology courses (see FAQ 17.6 and 19.06), study programmes that prepare students for a regulated profession within the meaning of Section 31 (3) MRVO only include those regulated study programmes for which a professional licensing body must be involved in the peer-review procedure by law. This is implicit in Section 31 para. 3 sentence 2 and applies, for example, to study programmes in psychotherapy (see Law on the Profession of Psychotherapist – PsychThG) or – depending on the state regulations – to study programmes in social work (see, for example, the Hesse Social Professions Recognition Act). If the higher education institution offers study programmes of this type, one of these study programmes is to be considered as an example in the regulation sample.
Teacher training
If the higher education institution offers teaching degree programs, one of each type of teaching degree offered must be included, taking into account all formal and academic criteria (§ 31 para. 3 MRVO). The Standing Conference of the Ministers of Education and Cultural Affairs (KMK) distinguishes between a total of six types of teaching profession, namely: (1) teacher training at elementary school or primary level, (2) overarching teacher training at primary level and all or individual school types at lower secondary level, (3) teacher training for all or individual school types at lower secondary level, (4) teacher training at upper secondary level [general education subjects] or for the Gymnasium, (5) teacher training at upper secondary level [vocational subjects] or for vocational schools and (6) special education teacher training.
If the teacher training courses are offered in the form of combined study programmes, the entire combined study programme with all associated partial study programmes does not have to be included in the random samples. Depending on the characteristics of the combination model pursued by the higher education institution, the Agencies or peer review panel decide on a case-by-case basis in which form a combination of a selective model assessment (of the combined study programme) and an assessment of one or more partial study programmes is expedient. Where possible, combined study programmes and a selection of partial study programmes assigned to them should be considered as examples (see section 3.2 of the handout “Promoting quality development through accreditation – a look at teacher training study programmes“).
In the aforementioned handout, the Accreditation Council recommended focusing the random samples in particular on specific characteristics in order to meet the requirement of considering the overall model of teacher training in the assessment. The subject of these random samples could therefore also be the interlinking between the training phases as well as between didactic, subject-specific and educational science training, the function of the centers for teacher training or schools of education or practical phases during the course of study and the opportunity to spend time abroad.
Theology / Religion
If the higher education institution offers full or partial theological study programmes with Protestant theology/religion and/or partial study programmes with Catholic theology/religion in accordance with § 22 para. 5 MRVO, one of these must be included in the random samples, taking into account all formal and academic criteria (§ 31 para. 3 MRVO). This means: If study programs with Protestant theology/religion and study programs with Catholic theology/religion are offered, one study programme per denomination must be included in the random samples.
In accordance with the amendment of the resolution “Key points for the study structure in study programmes with Catholic or Protestant theology/religion” by the KMK on 08.09.2022, the study programs in Catholic church music are now also understood as divisional theology.
However, the accreditation of Catholic theologicalstudy programmes that qualify students for the priesthood and the profession of pastoral worker (full Catholic theological studies) is carried out exclusively in the form of programme accreditation in accordance with Section 22 (5) sentence 1 MRVO, meaning that these study programmes are not included in the regulatory sample.
If the study programmes with Protestant or Catholic theology or religion are teacher training courses, these can be integrated into the teacher training sample, whereby the cooperation and approval requirements of the professional licensing authorities must be observed accordingly in accordance with Section 18 (2) MRVO (see FAQ 19.07).
The decisive factor is that the sample in the selected form must allow valid statements to be made about the specifics of regulated study programmes and at the same time the random samples character of the procedure must be maintained, also taking efficiency aspects into account.
In addition to the peer review reports of the system accreditation procedure, a representative of the respective competent professional accreditation body participates in the random samples for regulated study programmes (“regulatory sample”). The representative is appointed by the competent professional accreditation bodies, which must be involved in the accreditation by law. The central task of the representative of the respective competent professional accreditation body is to assess whether the participation obligations in the QMS of the higher education institution are being properly fulfilled.
In the case of teacher training courses, a representative of the supreme state authority responsible for education must be involved.
In the case of study programs with Protestant or Catholic theology or religion, a representative of the respective church office must be involved, taking into account the denominational orientation of the study programme. The responsible body is the locally responsible diocese or the responsible regional church.
If the higher education institution offers study programs with both Protestant and Catholic theology or religion, one representative from each denomination must be involved.
The approval requirement contained in § 25 para. 1 sentence 5 MRVO only applies at degree program level in the areas of teacher training and theology and must be taken into account by system-accredited higher education institutions in their internal accreditation procedures in accordance with § 18 para. 2 MRVO. In the regulatory random sample at system evaluation level, however, the approval requirement is generally not relevant.
The decision on the type and manner of participation, which may take the form of participation in the on-site visit or a written statement, is the responsibility of the respective competent body. A corresponding reference should be made in the accreditation report.
Program random samples, i.e. random samples in accordance with § 31 para. 2 no. 1 MRVO, are not programme accreditations in which the accreditation council’s seal is awarded. Accordingly, the specimen decree does not provide for any additional experts to be involved in the random samples. Only the peer review panel appointed for system accreditation is responsible for the peer review report in the entire accreditation procedures. The explanatory memorandum to § 25 MRVO explicitly points out that “the professional requirements for the peer review reports do not apply because no study programmes are assessed in system accreditation, but rather the university’s own quality assurance system.”
Obviously, a random check only allows valid statements to be made about the functionality of a quality management system (QMS) if the study programmes in question have passed through the quality management system in its entirety, if possible, or at least in part.
The requirement contained in § 23 para. 1 no. 3 MRVO that “at least one study programme must have undergone the quality management system” (emphasis AR) when applying for system accreditation for the first time is to be understood as a minimum requirement for higher education institutions that do not offer regulated study programmes (cf. FAQ 19.4).
The initial accreditation usually involves a newly developed quality management system, which may have undergone various more or less far-reaching changes in the course of the accreditation procedures. In addition, the number of study programs covered by the system is usually still very limited and a number of study programmes will only undergo the QMS at a later date due to their currently valid programme accreditation. In view of these special framework conditions, it is advisable to plan the sampling design in good time.
In principle, a higher education institution should ensure in the initial accreditation procedures that the study programmes to be included in the random samples in accordance with § 31 MRVO have passed the QMS by the second on-site visit at the latest.
For the reasons mentioned above, however, it may be necessary in individual cases to take the specific circumstances into account when selecting and conducting the random samples and to interpret “passing through the QMS” as follows: If a study programme is to be included in the random samples, it must have previously been integrated into the QMS in such a way that the effects and impacts of the QMS can be demonstrated and the peer reviewers are thus in a position to make valid statements on the functionality and impact of the QMS at study programme level and to present this in the accreditation report (cf. FAQ 19.10).
The presentation of the random samples in the accreditation report is an important final component of their implementation and is associated with a number of challenges.
The basis is initially to document the results of the random samples in the accreditation report, including the peer review conclusions on the functionality of the quality management systems (QMS) (see FAQ 19.03).
However, this alone has often proven to be insufficient for the informative value and comprehensibility of the random sample review. It is also extremely helpful to explain the reasons for the selection of study programmes and criteria.
At the same time, the following applies in the sense of FAQ 19.03: The accreditation report does not have to contain a detailed description of the study programmes considered in the random samples, nor does it have to contain a detailed “second opinion” based on the accreditation reports in the programme accreditation.
Finally, a statement by the peer review panel on the following question is of central importance: Based on the findings from the random samples, can it be determined that the QM system systematically and reliably ensures the implementation of the formal and academic criteria for study programmes? And if this is not the case, the follow-up question: What conclusions can be drawn from this?