Memorandum submitted by The Quality Assurance
Agency for Higher Education (QAA)
EXECUTIVE SUMMARY
1. The principal purposes of the Bologna
Process are to increase student and staff mobility, simplify and
improve the recognition of qualifications and enhance the attractiveness
of Europe as an international study destination. The extent of
structural reforms at national level and the development of the
Bologna instruments at European level are, even now, impressive,
but it is too early to judge how far the overall aims have been
achieved.
2. In the UK, higher education has been
subject to continual reforms for nearly 20 years and these are
progressing in parallel with the Bologna Process and the Lisbon
Agenda. These developments have not always been specifically labelled
as "Bologna compliant". This has, perhaps, contributed
to both the feeling often expressed abroad, and the misconception
encountered within many UK higher education institutions, that
the UK has done little to engage seriously with the Bologna Process
and has, at best, been semi-detached from it.
3. Assertions and assumptions that the implementation
of the Bologna instruments will (or should) result in the homogeneity
of the quality of higher education and academic standards of qualifications
in Europe are misplaced and potentially dangerous for the reputations
of individual institutions and national higher education systems.
The achievements and aims of the Bologna Process have to be set
alongside the urgent need for other steps to be taken to modernise
or revitalise universities in many parts of Europe.
4. A key factor in the success of the Bologna
Process to date has been its voluntary nature. It needs to remain
thus rather than become a regulatory straitjacket to constrain
innovation and change in higher education at institutional or
national level. The 2010 deadline for the "completion"
of the European Higher Education Area is unrealistic and it is
likely to take much longer for the full fruits of the Process
to be borne.
INTRODUCTION
QAA and its role in the Bologna Process
5. QAA was established in 1997 and is an
independent body funded by subscriptions from UK universities
and colleges of higher education, and through contracts with the
main UK higher education funding bodies.
6. Our mission is to safeguard the public
interest in sound standards of higher education qualifications
and to inform and encourage continuous improvement in the management
of the quality of higher education. We do this by working with
higher education institutions to define academic standards and
quality, and by reviewing institutions' effectiveness as guardians
of these important facets of higher education.
7. QAA performs important international
functions. It is a member of the European Association for Quality
Assurance (ENQA) and the Chief Executive is currently President
of the Association,[15]
in which capacity he participates in the meetings of the Bologna
Process Follow-up Group. QAA is also a member of the International
Network of Quality Assurance Agencies for Higher Education (INQAAHE)
and a formal observer at the Asia Pacific Quality Network (APQN)
in recognition of the fact that the international activities of
UK higher education institutions extend well beyond the boundaries
of Europe.[16],
[17]
8. QAA has provided, and continues to provide,
experts for the development of the two key Bologna instruments—the
overarching framework of qualifications in the European Higher
Education Area (EHEA), and the European Standards and Guidelines
for Quality Assurance (ESG)—and our staff have participated
in many of the seminars and workshops associated with the process.[18]
We have also taken part in projects funded by the European Commission
to explore other aspects of the Bologna Process. We support the
UK Europe Unit and participate in its activities, including the
development of UK higher education positions on European matters.
We also support the higher education sector by, for example, holding
workshops on specific topics related to quality assurance and
Bologna lines of action, including joint degrees.
Quality Assurance in the UK and compatibility
with systems in Bologna
9. The autonomy of UK higher education institutions
over their affairs is much more extensive than that of universities
in most other Bologna Process participating countries. UK higher
education institutions with degree awarding powers can design,
approve and monitor their own programmes without having to seek
external approval. They can and do deliver their awards in many
different modes (for example through partnerships with other bodies)
and locations, both within and outside the UK. They select and
appoint their own staff, set their own admissions criteria and
select and recruit their students. External involvement in universities,
however, tends to be greater in the UK; for example, a wider range
of stakeholders participates in institutional governance than
is commonly the case elsewhere in Europe, and the use of external
examiners in the assessment of student learning is unknown except
in two other Bologna countries (Denmark and Ireland). The UK's
particular approach to autonomy and regulation in higher education
has influenced strongly the external quality assurance processes
employed in its four national systems and has been one of the
reasons behind QAA's reluctance to endorse calls for a single
European quality assurance system.
10. The Standards and Guidelines for
Quality Assurance in the European Higher Education Area (ESG)
have become the principal instrument for the creation of a "European
dimension" to quality assurance. Born of a recommendation
in the 2003 Berlin ministerial communiqué, and adopted
at the subsequent 2005 Berlin ministerial meeting, they provide
a text to facilitate "the establishment of a widely shared
set of underpinning values, expectations and good practice in
relation to quality and its assurance, by institutions and agencies
across the European Higher Education Area". The ESG comprises
of three parts, covering institutions' own internal quality assurance
practices, external quality assurance as practised by quality
assurance agencies, and the external quality assurance of the
agencies themselves.
11. QAA has carried out an intensive internal
exercise mapping of all of its current audit and review processes
and the UK's national external reference points for quality and
academic standards against the ESG. In respect of the ESG for
internal and external quality assurance, no gaps or omissions
have been found. As QAA carries out the revision of its processes
and manages the revision of the national external reference points,
including its Code of Practice for the Assurance of Quality
and Standards in Higher Education,[19]
explicit references to Bologna and other appropriate European
instruments, such as the Diploma Supplement are being made. In
this way, alignment with the ESG will be made more transparent
and institutions can be re-assured that no additional regulatory
burden will need to be imposed on them in respect of quality assurance
as a result of the Bologna Process.
12. However, there remains a tension between
the "principles-based" regulatory approach to quality
assurance used in higher education in the UK and the tendency
towards a "rules-based" approach widely adopted elsewhere
in Europe. This latter way of thinking, linked as it is to the
widespread continental European tradition of legal codification,
has led to expectations in Europe that the ESG should be enshrined
in law as a demonstration of their implementation. The approach
also encourages a rigid interpretation of the guidelines as a
checklist of rules to be adhered to, rather than as examples or
illustrations of how the standards might be achieved. There is
also a danger that adoption by ministers of the ESG is either
interpreted or presented as evidence that there is homogeneity
of academic standards and quality across Europe. We have already
seen examples of this outside Europe, for example at a recent
symposium in Washington on the recognition of three-year degrees
from Europe for the purpose of admission to US graduate schools.
At that event, a European representative, in an interview with
the press, stated that "European higher education is more
homogeneous such that the rigor for a bachelor's degree from a
`top' university isn't that different from one at a less prestigious
institution".
13. A further area where a well-intentioned
Bologna initiative appears to be in danger of developing in undesirable
directions is the proposed "Register of European quality
assurance agencies". This was initially envisaged as a simple
information source, listing all quality assurance agencies operating
in Europe, categorised by their distinguishing characteristics.
It is now, however, rapidly turning into a European accreditation
system for agencies, in which national interests and practices
will be rendered subservient to the need to comply with the ESG.
Current proposals also envisage a new European body to run it,
and a self-appointed committee to decide which agencies can be
on the Register and which cannot. Although envisaged at present
as a voluntary instrument, many commentators assume that the combination
of national legislation involving the ESG in some countries, and
the central role envisaged for the Register in the recent EC/European
Parliament Joint Recommendation on Quality Assurance,[20]
will quickly turn the Register's voluntary nature into the normative
and ultimately the normative into the regulatory.
Advantages and disadvantages of the Bologna Process
14. The main intended advantages of the
Bologna Process include enhanced student and staff mobility and
simpler and improved recognition of qualifications. Despite this,
however, UK student participation in the EU HE mobility programme
has continued to fall throughout the period of the Bologna Process.
Perhaps it is simply too soon to see whether the introduction
of the three cycles of "Bologna awards" (equating to
bachelor's, master's, and doctor's degrees) will have an effect
on this. But it is also necessary to recognise that there is now
greatly increased international competition for UK students' attention
and interest, presented by study abroad opportunities that are
(or are perceived to be) more exciting or potentially contribute
more to employment prospects than the existing European schemes.
The US, Canada and Australia are becoming more popular locations
for UK study abroad students and new, even further flung, destinations
such as China and India are emerging. The formation of global
consortia of universities such as Universitas21 and World Universities
Network and the emergence of UK university campuses abroad are
also offering new and different types of study abroad opportunities.
15. The closer alignment of qualifications
structures amongst the countries of the EHEA does, however, offer
greater opportunity for institutional cooperation in curriculum
development and joint programmes of study. There is now clear
evidence of some UK universities taking advantage of this through
participation in the EU's Erasmus Mundus programme for joint master's
degrees which, although not part of the Bologna Process is, like
many other EC initiatives, closely allied to it. The ESG also
offer a useful and neutral negotiating tool for (often tricky
and sensitive) discussions between institutions to establish quality
assurance processes in joint programmes.
16. The improved recognition of UK degrees
in other European countries, resulting from a better understanding
of national HE systems, is still to come. Long existing problems
have not gone away: in at least one case they appear to be escalating.
The introduction of the three cycles of qualifications has not
led to the ready convergence of qualification frameworks. In many
countries the strategy of establishing the bachelor/master degree
structure has simply led to the division of the existing five-year
first degrees into two parts—either "4+1" or "3+2",
thus leaving the UK's typical "3+1" looking lightweight
and out of kilter with general EHEA practice. The perpetuation
of the "3+2 Bologna myth" is putting new pressure on
the recognition of the UK's one year full-time master's degree
in Europe. The evidence of problems is as yet anecdotal and not
quantifiable but it is an aspect to watch. It is to be hoped that
this may turn out to be a passing phase until there is more experience
of offering the three cycles of awards elsewhere. There may then
be more awareness that at the second cycle there needs to be greater
diversity in design, delivery mode and structure of programmes
than simply a two year full-time model; however, as many international
students in the UK come specifically to study on a one year master's
degree programme, we would not in the interim want the recognition
of them to be undermined in Europe or beyond.
17. Many of the recognition problems stem
from a continued reliance in the EHEA on the duration of studies
as the sole or "real" indicator of the level of student
achievement rather than an appropriate emphasis on learning outcomes
(what students emerge from their studies knowing, understanding
and being able to do). While there is much talk of learning outcomes
in the Bologna Process there seems as yet to be little real understanding
or acceptance of them as the main measure of achievement.
18. One European recognition measure that
has attracted significant international interest and currency,
however, is the Diploma Supplement, which was again adopted at
the ministerial meeting in Berlin in 2003. From Australia to the
United States there have been many recent references to the usefulness
of it, so much so that the Australians intend to adopt a version
for themselves. It is important that UK universities take cognisance
of this and produce accurate and complete Diploma Supplements
for their graduates.
19. Allied to the recognition issue is the
continuing debate as to whether the European Credit Transfer System
(ECTS)—which was developed 15 years ago—remains fit
for purpose. Some ECTS counsellors in other European countries
have commented publicly and consistently (while also extolling
the virtues of learning outcomes) that UK awards are deficient
in time and workload hours. QAA is pleased that the European Commission,
the only "owner" of ECTS, is undertaking a review of
it. We hope that the review process will be transparent and far
reaching and that it will consult extensively a wide group of
stakeholders, including some from the UK. Effective guidance on
the use of ECTS should in future focus at the level of principle,
rather than on narrow compliance with specific rules, a lesson
for success learnt from the development of other Bologna instruments.
The broader impact, including standardisation
20. The creation and use of European higher
education structures and frameworks through the Bologna Process,
or even the adoption of the ESG (which are principles-based standards),
must not be used as evidence that all higher education in Europe
is of the same quality and academic standard. This is not the
case now and is unlikely ever to be so. The real value of using
the Bologna instruments will lie in the greater transparency and
comparability of national structures that it will permit, and
which may in the longer term serve to highlight the strengths
of individual institutions and/or systems. Indeed, the whole credibility
of the Process may be put at risk if assumptions and assertions
about the standardisation and acceptability of current levels
of quality across the EHEA are allowed to go unchallenged.
21. This danger has been highlighted in
a series of high profile articles, presentations and communications
from the European Commission among others, in parallel with Bologna
Process activities, which have highlighted serious structural
problems in higher education in Europe. The Commission's 2006
Communication: Delivering on the modernisation agenda
for universities, education research and innovation,[21]
for example, points out that European universities are not currently
in a position to achieve their potential in a number of important
ways. As a result they are lagging behind in the increased international
competition for talented researchers and students and are not
generating the critical mass, excellence and flexibility needed
to succeed. These shortcomings are said to be compounded by a
combination of excessive public control coupled with insufficient
funding. Elsewhere, the OECD is carrying out a Thematic Review
of Tertiary Education in which the UK, along with 23 other countries
worldwide, is participating. This will not report until late 2007
but may present some novel views of higher education in those
European countries participating in the review.
22. Concerns about the standardisation of
European higher education as a consequence of the Bologna Process
may well also be behind the continued push of Dutch colleagues,
the OECD (IMHE) and the European Commission for projects to develop
typologies and classifications of European higher education institutions,
echoing the new Carnegie classifications in the USA. Pressures
are mounting too for a European ranking of universities—again
underwritten by the Commission—and there are initiatives
at national and institutional level in some countries, notably
Germany, variously to identify centres of excellence and clusters
of "top institutions".
23. A slavish following of the Carnegie
approach, however, is unlikely to be appropriate for Europe. While
the US may have 4,000 universities and colleges that share some
common features such as "the credit hour", the Associate
degree, the four-year baccalaureate degree, and the use of institutional
and specialist accreditation, no-one claims that all US universities
are the same in terms of mission, quality or standards. The Carnegie
classification suggests that there are fewer than 50 research
intensive universities in the US, in stark contrast with Europe,
where it appears that a very large number of universities responding
to a questionnaire about their Bologna activities see developing
research as their major mission. Europe needs much greater diversity
in terms of types of institutions, programmes and modes of delivery
in order to offer opportunities to a wider community of students
and support lifelong learning, a shared interest between the Bologna
Process and the Lisbon Agenda.
24. From QAA's experience of international
education, including 10 years of auditing the overseas partnership
links of UK universities—most recently those in China—we
see that UK higher education institutions have a very high level
of engagement in international activities beyond Europe. Many
UK universities appear to regard themselves as serving international
communities rather than prioritising Europe. This has been demonstrated
by significant growth in the development of UK cross-border education
through the establishment of branch campuses in China, the Middle
East and Malaysia but also through many partnership links, especially
in the Asia region, and the delivery of on-line education programmes
on a global basis. Others may have greater interest in the European
research framework programmes.
CONCLUSIONS
25. The Bologna Process is important to
the UK as it provides a structure for a greater understanding
of European higher education systems and the development of common
instruments to make that understanding useful in practice. It
has also demonstrated what can be achieved through voluntary cooperation.
The achievements so far are significant but implementation at
national level is very uneven across the EHEA. There is no "European
higher education system" or "European quality assurance
system" in place, even though some would wish to see these.
The 2010 deadline is unrealistic for the "completion"
of the EHEA. Much more time is needed for the full impact to be
realised and for effective evaluation to take place. We believe
that the UK should continue to support the voluntary nature of
the Bologna Process and that UK higher education institutions
should be encouraged to engage more fully with the process, but
in the expectation that—apart from requirements such as
the Diploma Supplement—the extent of engagement will vary
according to their individual missions and international strategies
and interests.
December 2006
15 www.enqa.eu Back
16
www.inqaahe.org Back
17
www.apqn.org Back
18
http://www.bologna-bergen2005.no/Docs/00-Main_doc/050221_ENQA_report.pdf Back
19
http://www.qaa.ac.uk/academicinfrastructure/codeOfPractice/default.asp Back
20
http://eur-lex.europa.eu/LexUriServ/site/en/oj/2006/l_064/l_06420060304en00600062.pdf Back
21
http://ec.europa.eu/education/policies/2010/doc/comuniv2006_en.pdf Back
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