13.2 Why and for what reasons does the Accreditation Council return accreditation reports to the applicants?

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.