Evaluation and Accreditation in Germany: A Wave of Reforms

In Germany accreditation and evaluation are conceptualized in the same way as in the rest of Europe, and are also formally defined as having totally different purposes. As Schade (2007) describes, referring to Germany, evaluation is mainly “an analysis of strengths and weaknesses of an institution, department or faculty”, while accreditation “contribute[s] to improving and ensuring the quality of teaching and research by basing the review process on previously and externally defined standards and gives a study programme the right to exist”. Again, conceptually, evaluation is portrayed as a benign and useful process for a university’s staff, while accreditation clearly represents a normalising external gaze. Schade, like other experts in the matter, insists on the differences in aims of both procedures, and states that they are not closely linked because “there are different owners of the procedures” (p. 191), meaning that the ownership of an evaluation process lies with the members of a university, whereas an accreditation process falls out of their hands. However, she also explains that in practice they tend to be treated as one process, and separating them as it is meant to be would have a very

high economic cost and would also create a quality assurance system with two separate parts “one for comparability and the other for quality improvement” (p. 191).

While quality assurance managerial processes initiated in Western Europe around 1984 (Schwarz & Westerheijden, 2007b, pp. 5-6), Germany is considered a “newcomer” in the field of accreditation in Europe, having started to apply evaluation procedures in the mid- 1990s (Schade, 2007, p. 180; Rhoades & Sporn, 2002) – when the German Conference of Rectors and the Standing Conference of the Ministers of Education and Culture launched two quality assurance projects to develop indicators for the measurement of performance (Rhoades & Sporn, 2002, p. 364) – and to accredit graduate degrees in 1998 (Hämäläinen, 2001, p. 16), when policies were established by the government. The arguments found in the literature to justify the implementation of the new managerial tools and explain their approval are the ‘massification’10 _{of higher education and the challenges it presented for central} control, accompanied with the neoliberal trends of deregulation and budgetary limits (van Vught, 1994). The introduction of the reforms in Germany was seen as a special achievement that prevailed in spite of its antagonism with the national academic culture. The Bologna Process is hailed as a timely source of external pressure:

Internal politics were among the main driving forces in Germany. The federal system with shared responsibility of higher education between the states (Länder) and the federal level (Bund) made the higher education system extremely resistant to change. The Sorbonne and Bologna Declarations may thus be interpreted as creating external pressure to overcome internal inertia (van der Wende & Westerheijden, 2001, cited in Schwarz & Westerheijden, 2007b, p.35).

As an imported practice, the accreditation process in Germany follows the general tendency found in other countries. It functions through accreditation agencies that are, in turn, accredited by a general council, the Akkreditierungsrat, compounded of “four representatives from higher education institutions, four representatives of the Länder, five practitioners, two international experts and two students” (Schade, 2007, p. 181). The

Akkreditierungsrat in Germany has the responsibility of “organising the system of quality

assurance in learning and teaching through accreditation”. Its purpose is “to contribute to the development in the quality of teaching and learning in Germany” but significantly its purpose, at the same time, is “to cooperate in the realisation of the European Higher Education Area”

10 _{The massification of higher education was the result of expanding enrolment in universities but also of}

the labelling as universities of institutions that where formerly not recognised as such (Shore & Wright, 1999).

(Accreditation Council, 2014), guaranteeing equivalence and comparability, in tone with the Bologna Process.

Clearly in line with the way accreditation processes are conducted elsewhere, the following is the official description that the Akkreditierungsrat offers for the German accreditation system:

The accreditation process is made up of several stages and is based on the peer review principle. When a Higher Education Institution submits an application for the accreditation of a study programme to an agency that they have chosen, the relevant Agency deploys an evaluation group whose composition must be a reflection not just of the specialist content focus of the study programme but also of its specific profile. In each case the evaluation group is made up of representatives of Higher Education Institutions, i.e. teachers and students, and of representatives of the profession. The evaluation of the study programme is carried out in accordance with the given Criteria for the Accreditation of Study Programmes by the Accreditation Council and, as a rule, includes an on-site visit of the institution by the evaluators. On the basis of the assessment report drawn up by the evaluation group, and in accordance with the decision regulations provided by the Accreditation Council, the responsible Accreditation Commission from the Agency decides either to grant an accreditation for the relevant study programme, to grant an accreditation with conditions, to abandon the process or to reject the accreditation (Accreditation Council, 2013).

Furthermore, following the general trend, an accreditation in Germany lasts/or is valid between three and five years, and for a maximum of seven years. However, in contrast with other European countries, the Akkreditierungsrat is not allowed by law to impose any sanctions on agencies when they do not comply with directives or standards (Schade, 2007, p.186). A total of 10 agencies were accredited by the Akkreditierungsrat as of June 2015:

 AAQ Swiss Agency for Accreditation and Quality Assurance

 ACQUIN Accreditation, Certification and Quality Assurance Insitute

 AHPGS Accreditation Agency for Study Programmes in Health and Social Sciences  AKAST Agency for Quality Assurance and Accreditation of Canonical Study

Programmes

 AQ Austria Agency for Quality Assurance and Accreditation Austria

 AQAS Agency for Quality Assurance by Accreditation of Study Programmes

 ASIIN Accreditation Agency for Degree Programmes in Engineering, Informatics/Computer Science, the Natural Sciences and Mathematics

 evalag evaluation agency Baden-Württemberg

 FIBAA Foundation for International Business Administration Accreditation  ZEvA Central Evaluation- and Accreditation Agency Hannover

As seen by experts in quality assurance, these agencies are meant to be in competition with each other in terms of pricing and services, but also in terms of the ‘product’ they offer by providing special quality seals with international recognition (Schade, 2007, pp.186-187). Hence, the system is based on the coalition of interests of the universities and the agencies. Currently, an increase in the number of accredited programmes is considered highly desirable, and so the tendency is evidently towards an increase. For example, in the state of Hessen, up to March, 2nd_{, 2015 there was a total of 752 accredited programmes in} higher education institutions of all types (Universitäten, Fachhochschulen, and Kunst und

Musikhochschulen). Just four months later, this amount had increased to 766

(Akkreditierungsrat, 2015).

The Akkreditierungsrat also allows the possibility of a “system accreditation”, which is the accreditation of the whole of a higher education institution’s internal quality assurance system. When an institution obtains a system accreditation it means that all programmes that pass through its accredited system become automatically accredited. Perhaps because of its greater practicality in comparison with the programme accreditation, this modality shows a growing tendency in the country. While in January 2014, there were 17 Systems accredited in Germany, up to June 2015 there were 34, and 23 institutions in process (Accreditation Council, 2015).

In accordance with the notion that students should also “own” accreditation processes, in 2000 the Akkreditierungsrat promoted the creation of a Students’ Accreditation Pool, in order to include the participation of students in accreditation processes11_{. On} 20.12.2006, a follow-up was given by the Akkreditierungsrat, promoting this initiative further by encouraging cooperation between the accreditation agencies and the Students’ Accreditation Pool, and by encouraging the financial support of the latter12_{. Information on this}

Studentischer Akkreditierungspool can be found at their official Website13_{, where it was}

11 _{This is in line with ENQA’s official statement that students should participate in quality assurance}

activities (ENQA, 2009, p. 17).

12 _{“Die weitere Ausgestaltung der Beteiligung von Studierenden im Akkreditierungssystem soll vor diesem}

Hintergrund die folgenden Punkte umfassen: 1. Der Akkreditierungsrat wird einen Prozess moderieren, in dem zwischen dem Studentischen Pool und den Agenturen geeignete und belastbare

Kooperationsstrukturen geschaffen werden. 2. Der Akkreditierungsrat wird den Studentischen Akkreditierungspool bei der Gewinnung ausreichender finanzieller Mittel unterstützen, um so sicherzustellen, dass auch bei einer steigenden Verfahrenszahl ausreichend viele studentische GutachterInnen zur Verfügung stehen. Die Agenturen werden gebeten, sich daran im Rahmen ihrer Möglichkeiten zu beteiligen.“

reported that by the end of 2014, there were 301 active members, 66% men and 34% women. They also report that 88% of them come from universities and 12% from Fachhochschulen. Further information about the student members is not yet available, however, a report mentions that in 2015 they will have more details about their members, such as the

Fachbereich (faculty) they belong to (Studentischer Akkreditierungspool, 2014). A member of

this pool should be a part of the commission conducting an accreditation process. Officially, the student does the same kind of work as the rest of the peer evaluators: they read the institution’s report in advance and in some cases write a brief assessment, they participate in the on-site visit and are invited to ask questions to staff, teachers and students or visit the installations to take a look at any particular space they desire, and finally they can discuss their impressions with the rest of the evaluators before the final report is written (Studentischer Akkreditierungspool, 2014).

A clarification should be made at this point: the introduction of accreditation processes in Germany should not be seen as the general initiation in the country of concern for quality assurance in higher education. Nevertheless, it does represent a significant and thorough change in perspective regarding quality control. Before the reforms, quality assurance in teaching was conducted through “ex-ante control (quantitative specification and approval of examination regulations by the state)” (Schade, 2007, p. 180). With the introduction of the new trends, other European countries started conducting “ex-post control on the basis of evaluation results”. In that context, a change in Germany from ex-ante to ex- post control was seen as inevitable, as a way of “following the international development” and as a result of “growing quality assurance awareness” (p. 180). Clearly, the external pressure towards the implementation of quality assurance processes in Germany should not be underestimated. The impact of standardised testing, particularly PISA, was a considerable mobiliser (see Pongratz, 2006). The PISA (Programme for International Student Assessment) study is in line with objectives expressed by the OECD, the WTO, the World Bank and the IMF, which are interested in the implementation of private sector managerial processes in the public sector, and the introduction of business principles in education and research institutions (2006, p.472).

In sum, when discussing the introduction of evaluation and accreditation processes in Germany, three issues emerge as significant: 1. That even though the introduction of quality assessment through evaluation and accreditation is portrayed as the result of growing awareness of the importance of quality assurance, this was in fact not the beginning of quality assessment in universities, but instead a radical change of perspective regarding the moment

in which quality should be “measured”; 2. That evaluation and accreditation have been enforced mainly as part of the European Union’s Bologna Process14_{; and 3. That quality per se} is not the main justification behind the establishment of quality assessment through evaluation and accreditation, as issues of competitiveness and international prestige were and are also used to justify their introduction.

3.4. Evaluation and Accreditation in Central America: A Long