Rising Above Institutional Constraints? The Quest of German Accreditation Agencies for Autonomy and...

Rising Above Institutional Constraints? The Questof German Accreditation Agencies for Autonomyand Professional Legitimacy

Kathia Serrano-Velarde

� Springer Science+Business Media Dordrecht 2014

Abstract European quality assurance has a complicated history that must be

viewed as taking place on two levels: first, in a national effort to deregulate the

public sector and to make universities accountable for their teaching performance;

and second, a supranational endeavor to accomplish European integration in the

field of higher education. Similarly, the web of institutional constraints and

opportunity structures in which accreditation agencies are embedded spans two

policy levels, the national and the European. In this paper, we examine how German

accreditation agencies achieve some level of autonomy in a highly entrenched

institutional environment. The paper is based on a qualitative study comprising

archival data and over 70 semi-structured interviews. Drawing on the insights of

neo-institutional theory, we argue that quality assurance agencies seek political

leverage at the European level in order to strengthen their standing in the higher

education systems of their own countries.

Keywords Accreditation agency � Quality assurance � Institutional strategy �Bologna Process � Higher education

Introduction

European quality assurance has a complicated history that must be viewed as taking

place on two levels: first, in a national effort to deregulate the public sector and to

make universities accountable for their teaching performance; and second, a

supranational endeavor to accomplish European integration in the field of higher

education. Although quality assurance in higher education emerged in Europe in the

K. Serrano-Velarde (&)

Max-Weber-Institute for Sociology, Heidelberg University, Bergheimer Str. 58, 69115 Heidelberg,

Germany

e-mail: [email protected]

123

Minerva

DOI 10.1007/s11024-014-9245-2

late 1980s, most countries implemented quality assurance practices between 1999

and 2003, in the early phases of the Bologna Process. European reform initiatives

therefore played an important role in the development of European quality

assurance, both by furthering the implementation and systematization of quality

assurance on the national level, and by adding a European dimension to national

agendas. Quality assurance agencies may therefore be seen as embedded in a web of

institutional constraints and opportunity structures that spans two policy levels, the

national and the European.

Because they are subject to piece-meal regulation on behalf of the ministries and

vociferous public criticism at the national level (Kuhne 2011; Schwertfeger 2011),

quality assurance agencies perceive the European reform process as a platform for

fostering political leverage and autonomy – it may even be said that their political

aspirations are overwhelmingly focused on the European level, meaning that their

work entails far more than the ‘‘harmonisation’’ envisaged in the Bologna Process

(Sorbonne 1998). Rather, in the context of the increasing Europeanization of

professional regulation (Evetts 2008), Bologna’s policy network offers new

opportunities and political entry points for stakeholders. This paper will explore the

challenges faced by quality assurance agencies in the European Higher Education

Area, and build an answer to the central question of how quality assurance agencies

achieve autonomy in a highly entrenched institutional environment.

We will examine how German accreditation agencies gain relative autonomy by

pursuing institutional strategies at the European level. Drawing on the insights of

neo-institutional theory, we introduce the notion of ‘‘institutional strategy,’’ and

show how German accreditation agencies strive for political leverage at the

European level in order to strengthen their standing within the national higher

education system. We then examine the limits of such a strategy.

The first section of this paper will develop a working definition of the term

‘‘European quality assurance’’ that takes into account the common denominators

and structural working principles of quality assurance agencies throughout Europe.

The second and third sections use neo-institutional theory to build an analytical

approach to the strategy of quality assurance agencies, while the fourth and fifth

sections give systematic, empirical insight into the working mechanisms of

European quality assurance by focusing on the case of German accreditation

agencies. Our findings are discussed in the last two parts of the paper. Although the

constraints to professional legitimacy and autonomy identified below are specific to

accreditation agencies in Germany, they exist, to varying degrees, all over Europe

(McClaran 2010; Gori and Volgo 2009; Bellingham 2008; Cheng 2010). Since the

German market of quality assurance may be considered the most liberal and

deregulated of the three types of regime we shall identify in the European Higher

Education Area, Germany presents an ‘‘extreme case’’ (Gerring 2007) that is

invaluable to understanding basic institutional constraints and barriers to agency

autonomy in all European higher education systems.1

1 ‘‘Extreme,’’ here, is used as Gerring defines it: ‘‘If most cases are positive along a given dimension,

then a negative case constitutes an extreme case. (…) It is the rareness of the value that makes a case

valuable, in this context’’ (Gerring 2007: 102).

K. Serrano-Velarde

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What is ‘‘European Quality Assurance’’?

Although quality assurance in higher education is generally defined as a set of

instruments that control for and ensure a quality standard in higher education

teaching, it is a fictive notion, since there is no single coherent understanding of

what it might be (Bernhard 2012; Schwarz and Westerheijden 2007). Instead, the

European Higher Education Area comprises a patchwork of quality assurance

regimes, which we define as distinct patterns of regulation and coordination in the

provision of quality assurance to higher education institutions (King 2007). In the

following part, we propose to spell out the characteristic features of these regimes

by concentrating on the interdependence between quality assurance agencies, the

state and the university system. We thereby identify three ideal-typical constella-

tions that reflect the variety of approaches to higher education governance in the

European Higher Education Area: market-type, centralist and corporatist quality

assurance regimes.

Market type regimes of quality assurance exist in relatively liberal settings where

quality assurance agencies are independent service providers that compete for

customers nationwide. Germany has such a regime, as did the Dutch accreditation

system in its early stages. In this type of regime, access to the market is regulated by

a central agency (the Akkreditierungsrat or the Nederlands-Vlaamse Accreditatie-

organisatie), but is open to foreign competitors. In centralist regimes, such as those

in France (Garcia 2008a), the United Kingdom (Cheng 2010) or Scandinavia

(Langfeldt et al. 2010; Segerholm 2009), quality assurance is provided and

coordinated through one national agency. In the early years of quality assurance,

these agencies were for the most part simply departments of the ministries of

education in their respective countries, but the policy guidelines for quality

assurance laid out by the Bologna Process required agencies to guarantee their

independence from the political decision-making process, and became autonomous.

Finally, corporatist regimes, such as Austria’s (Bernhard 2012), feature systems

coordinated from within the professional field. Austria’s regime was established

when its national rector conference decided to create and finance quality assurance

services for their member institutions in the first years of the 21st century. For nearly

a decade, the AQA (Austrian Quality Assurance Council for Universities) and the

FHR (Council for Polytechnics) provided accreditation services to their member

institutions. However, with the implementation of the 2012 Quality Assurance

Framework Law (QSRG 2012), Austrian accreditation agencies were merged into

the AQ (Austrian Council for Quality Enhancement and Accreditation), a

government institution. Broadly speaking, European quality assurance policy is

trending toward ‘‘centralist’’ regimes in an effort to reduce the structural complexity

of quality assurance across the European Higher Education Area.

For all their differences, these three regimes have several common attributes.

First, quality assurance agencies mediate between public interests and higher

education institutions, acting as ‘‘buffer organisations’’ (Neave 1992) or ‘‘interme-

diary agencies’’ (Braun 1993). As a result, they exist within an evolving relationship

between state and public institutions (Haynes 2003; Ferlie et al. 2008; Gray and

Jenkins 1995). Second, although their governance structures may differ, quality

Rising Above Institutional Constraints

123

assurance agencies generally provide two main ‘‘services’’ for the national higher

education system. First, they help hold public institutions accountable to those they

are intended to serve, a major theme in public service since the onset of New Public

Management reforms (Du Gay 2000; Hood 1991). In this role, quality assurance

may serve as a powerful steering tool for national policy-makers (Travers 2007).

Summative evaluations, for example, are increasingly used to inform funding

decisions in higher education (Sarrico et al. 2010; Garcia 2008b; Wijnen 2007).

Second, quality assurance agencies monitor the implementation of the new degree

structure set up by the Bologna Process, thus helping to restructure and regulate

higher education systems according to European standards (Heinze and Knill 2008;

Witte 2006).

Although it would seem at first glance that quality assurance agencies in the European

Higher Education Area are autonomous, state intervention and professional distrust

impose significant constraints on their formal working conditions. Even in market-type

regimes, as we will see in greater detail further on, quality assurance agencies are

supervised by the state, as they are considered too powerful a steering device to surrender

to a third party. Furthermore, quality assurance agencies have a difficult position in the

academic community, since they are seen by its members as yet another layer of opaque

bureaucracy to monitor and control them (Hoecht 2006; Power 1997).

Any examination of the ‘‘institutional strategy’’ of quality assurance agencies

therefore requires taking into account power imbalances at the national level, which

constrain the way services are provided and limit agencies’ professional autonomy.

Indeed, Bologna, as it provides these agencies political leverage at the European

level, may be seen as a means of overcoming some of these constraints at the

national level (Sandholtz and Stone Sweet 1998). Below, we will develop an

analytical framework that allows us to map the institutional strategy of quality

assurance agencies at both the national and European levels.

‘‘Institutional Strategy’’: A Neo-Institutional Approach to Agency Autonomy

Quality Assurance and Agency Autonomy

In public administration studies, the delegation of public tasks to private service

providers is a widely investigated phenomenon. The emergence of accreditation

agencies reflects the changing relationship between the state and universities (Braun

and Merrien 1999; Krucken and Meier 2006), and is just one example of the

advancement of New Public Management reforms in the public sector (Peters and

Pierre 2003). Two research traditions are of specific interest to our investigation: we

will touch on the ‘‘agencification’’ debate through our examination of political control

and autonomy of agencies in the era of devolution.2 We shall also refer to the literature

on the ‘‘managerialisation’’ of universities, in particular as we discuss the growing

conflict between managerial evaluation practices and professional autonomy in public

2 By devolution, we understand the delegation of power to entities that are legally separate from the state,

which often have a contractual relationship with the ministries on which they depend.

K. Serrano-Velarde

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institutions (Evetts 2003). Both of these research strands will be discussed before

moving to a neo-institutionalist approach to agency autonomy in higher education.

Agencification describes the delegation of political command and control from the top

down; here, by the state to autonomous, mostly public agencies. Agencification is part of

a new public management approach intended to boost quality, efficiency and

performance in the public sector (Pollitt and Bouckaert 2011). Agencification-driven

reforms have been pushed by both national governments and intergovernmental

organizations (Fitzpatrick and Fyfe 2002) as a panacea for red tape and public

mismanagement. Early critical approaches to this phenomenon used principal agency

theory (Krause 1996; Banks and Weingast 1992) to understand the agencies detachment

from the state, thereby questioning the role of intermediaries (Braun 1993) in the

governance and delivery of public services. Studies of this type abounded in the field of

science and research policy, and argued for public funding agencies’ utility in providing

indirect guidance in the regulation and governance of science (Geuna and Martin 2003;

Morris 2000; Morris and Rip 2006; Van der Meulen 1998). Whereas principal agency

scholars observe a gradual ‘‘hollowing out’’ (Milward and Provan 2000) of the state,

recent constructivist approaches to agencification emphasize the contextual embedded-

ness (Meier and Hill 2005; Moynihan 2006) and negotiation processes underlying the

‘‘complex trade off between agencies and the state’’ (Christensen and Laegreid 2007). By

questioning the nature of political control and autonomy (Egeberg and Trondal 2009) in

deregulated settings, these authors offer a nuanced understanding of the control

relationship, differentiating between ‘‘formal’’ autonomy (determined by law) and

‘‘real’’ autonomy (discretion in the decision-making process) (Yesilkagit and Van Thiel

2008, see also Bouckaert and Peters 2004). Advocates of this view argue that

agencification does not necessarily result in the complete abandonment of state

regulation; rather, it advances a new understanding of control and responsibility that

spans multiple levels of governance (Christensen and Laegreid 2007).

In many ways German accreditation agencies would seem to bear out the

arguments of the agencification approach. The state has delegated the work of

monitoring degree-granting programs’ quality and accountability to accreditation

agencies, although they continue to report to the state. Accreditation agencies are

also regulated and closely monitored by the state-supervised German Accreditation

Council. The constraints German accreditation agencies face are thus similar to

those described in the public administration literature. At the same time, however, it

should be noted that since both accreditation agencies and accreditation councils in

German are private entities, they cannot be qualified as ‘‘agencies’’ under Pollitt’s

original definition. The historical ‘‘path’’ (Pierson 2000) of state-agency relation-

ships in Germany differs from this definition and therefore does not fit into Anglo-

Saxon categorization framework (Bach and Jann 2010).3 For the purposes of this

study, we describe accreditation agencies in Germany as ‘‘agencies’’ because they

3 Germany does not fit for several reasons: first, it has been comparatively slow (Schroter 2007) to adopt

new public management reform. Second, agencification has a long tradition in the German federal

political culture and therefore draws on a set of assumptions and practices that differ from those

underlying current reform initiatives. Third – and most important – agencification lacks a coherent and

comprehensive policy framework, meaning that it comprises a wide variety of agency-‘‘species’’ (Bach

and Jann 2010).


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were established by governmental decree and are closely supervised by the state,

although legally they are private entities. Their institutional embeddedness (Cole

and Jones 2005) reflects a situation in which they enjoy formal autonomy but are

subject to political oversight.

Managerialization contrasts with agencification in its application, as it describes

intraorganizational processes. It refers to the dissemination of management

practices and ‘‘rationales‘‘ (Meyer and Rowan 1977) through what Mintzberg calls

‘‘professional bureaucracies’’ (Mintzberg 1979, 1983); that is, organizations like

universities in which professionals maintain authority and discretion over their

work. As organizational priorities are confronted with professional identities, and

vice versa, (Evetts 2011), conflicts arise, reflecting both a shift in the power

constellation (from professionals to the management) as well as a transformation in

universities’ work culture (Deem and Brehony 2005; Reed 2002). Scholars of this

tradition highlight the changing nature of the academic profession, which is under

increasing pressure to comply with managerial agendas (Coccia 2009). Although it

has been repeatedly argued that managerialization is likely to generate new

professional self-perceptions among academics – Clegg observes the ‘‘hybridiza-

tion’’ of academic work identities (Clegg 2008), while Whitchurch describes

academics as ‘‘blended professionals’’ (Whitchurch 2009) – most studies note the

conflictual nature of this transformation. Any form of outside interference or

oversight in academic core activities such as teaching and research is likely to

generate distrust and resistance among academics (Power 1997). In other words, the

academic profession is loath to accept the authority of accreditation agencies.

As a result, accreditation agencies face institutional constraints at the national

level in the form of political regulation and professional resistance. Below, we

provide a detailed account of these constraints through an empirical analysis before

discussing the strategies agencies have developed to circumvent or adapt to these

constraints.

‘‘Institutional Strategy’’

Our analysis of the institutional predicament of accreditation agencies provides an

explanatory framework for institutional agency that addresses both issues of

political control and professional resistance to accreditation services. To this end,

we define accreditation agencies as institutionally embedded agents in search of

legitimacy and autonomy (Lounsbury 2002; DiMaggio 1988). Network theory

(DiMaggio and Powell 1983; Powell 1996; Owen-Smith and Powell 2004) has made

the concept of ‘‘institutional embeddedness’’ a cornerstone of neo-institutional

theory (Owen-Smith and Powell 2008), according to which agents seek power,

status and economic advantage. The means and ends of their interests and agency,

however, are both enabled and constrained by prevailing institutions (Giddens 1984;

Sewell 1992), defined here as regulative, normative and cultural-cognitive

infrastructures for individual and collective behavior (Scott 1995). In their quest

for legitimacy and autonomy, quality assurance agencies develop strategies to

ensure their institutional compliance while attempting to buffer institutional

K. Serrano-Velarde

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influences on their core activities. We call a strategy ‘‘institutional’’ when the agent

takes institutional constraints and resources into account in order to optimize its

position in a given field. This analytical understanding of agencies and institutions

has certain similarities to institutional entrepreneurship theory, insofar as we see

organizations as behaving strategically when they mobilize resources in order to

overcome resistance and achieve their goals (DiMaggio 1988; Greenwood and

Suddaby 2006). We differ from institutional entrepreneurship theory in that we do

not see agencies as leveraging resources in order to create new institutions or

transform existing ones (Maguire et al. 2004). Instead, we believe that emerging

organizations, especially if they are entering highly professionalized fields such as

academia, must develop an institutional strategy to ensure their survival and

acceptance as legitimate and autonomous service providers. Agents, we argue, may

be constrained by institutional design, but are able to act upon that design in order to

achieve specific goals. ‘‘Strategy’’ in this context describes how agents work with

institutional constraints and resources to achieve their goals (Woll and Jacquot

2010). In our case, accreditation agencies seek to strengthen their political

autonomy and professional legitimacy. Quality assurance agencies achieve this goal

by avoiding open conflict with institutional structures at the national level while

seeking political leverage and approval at the European level.

Method and Data

The study is based on two data sets, a historically informed case study on the

emergence of the German system of quality assurance in higher education and a

qualitative study of the European reform process. The empirical data comprise a

series of qualitative interviews and a document analysis of legal texts and archival

data produced between 1994 and 2011.

When examining the case of German quality assurance agencies in the field of

higher education, it is important to note that Germany is one of only a few European

countries to allow competition among these agencies. Although this liberal model

has often been described as the cutting edge of Europe’s approach to higher

education assessment (DiNauta et al. 2004), competition among Germany’s ten

existing accreditation agencies is not wholly liberalized; it is constrained by market

conditions imposed by the country’s sixteen federal states. It is also subject to

systematic distrust on the part of client organizations and stakeholders. In 2006 and

2007, we conducted a series of 53 semi-structured interviews with members of these

agencies, their regulatory bodies (accreditation council, ministries, the Standing

Conference of the Ministers of Education and Cultural Affairs of the Lander) and

their stakeholders (German rector conference, professors and academic managers),

with a focus on the history and work of quality assurance agencies, and, more

specifically, on aspects of governance, agency autonomy and client relations. The

interviews, which lasted between 60 and 180 minutes, were transcribed and content

analyzed (Mayring 2000). In addition, we conducted an archival analysis to examine

the events leading to the establishment of a German accreditation council.


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The second data set consists of a series of 17 semi-structured interviews with

European quality assurance experts from European institutions and stakeholder

organizations (2006–2008). We sought out practitioners and policy-makers who

were involved in both the European Association for Quality Assurance in Higher

Education (ENQA) and the Bologna Process. The interviews lasted between 60 and

120 minutes and discussed the European policy-making process in both the ENQA

and the intergovernmental policy framework of Bologna. In particular, we focused

in the integration of a European market of quality assurance agencies through the

constitution of a European Quality Assurance Register (EQAR).4

The final section of this paper will present the findings of this analysis in three

steps. First, we shall provide insights into the institutional embeddedness of quality

assurance agencies in Germany, showing that post hoc regulations and academic

mistrust in quality control have made it complicated for accreditation agencies to

deliver services and negatively affected their independence and legitimacy. Second,

we will investigate these agencies’ existence at the European level, identifying the

resources they employ to bolster political action and autonomy. We will then

discuss the institutional strategies of quality assurance agencies with regard to the

European policy framework and examine their chances of achieving agency

autonomy and legitimacy.

Accreditation Agencies in Germany: A Legitimacy Issue

In Germany, higher education policy falls under the authority of the Lander,

Germany’s provincial governments. Nationwide governance reforms in the 1990s

shifted significant responsibilities from the state to higher education institutions

(Goldschmidt 1991; Neusel et al. 1993). By strengthening the autonomy of

universities and polytechnics, the Lander hoped to stimulate organizational

performance and competition within and outside Germany. This, which Willke

describes as ‘‘supervisory’’ governance (1996), allowed the Lander to retain specific

and occasional regulatory power while leaving the bulk of day-to-day and strategic

decision-making to higher education institutions. A new range of policy instruments

(Lascoumes and Le Gales 2004) such as benchmarks, contracts and performance

4

Stakeholder Number of interviews

German quality assurance agencies Accreditation agencies (15) evaluation

agencies (16)

German governmental bodies (ministries, KMK) (13)

German stakeholder organizations (9)

European institutions and stakeholder organizations (12)

K. Serrano-Velarde

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indicators, were used to set targets to be met by public institutions. As the trade-off

that had previously existed between federal states and higher education institutions

was rearranged and deregulated, quality assurance agencies were called in to act as

referees or go-betweens. At the same time, they took on the important role of

gathering evidence of accountability in higher education, and thus became

responsible for providing reliable information to public authorities for the allocation

of resources in regional higher education systems (Serrano-Velarde 2008).

It is essential to note that Germany’s quality assurance system is built on an

artificial dichotomy between quality enhancement practices, such as, evaluation and

the certification of basic standards through accreditation (Bornmann et al. 2006).

These practices, while considered complementary, are seen as requiring separate

service providers, although in practice, there is almost no difference between an

evaluation and an accreditation procedure. German quality assurance is thus

characterised by structural duplication, and features two different and competing

types of organization, evaluation agencies and accreditation agencies (Teichler

2003).5 The latter will be examined more closely further on in this article. In the

meantime, it should be borne in mind that while evaluation was included regional

higher education starting in the 1990s, no strong policy program or financial

backing was implemented in the ensuing years. Over the years, this financial

situation led to the ‘‘death’’ (Hannan and Freeman 1989) of three out seven

evaluation agencies in Germany. In the words of one of Germany’s most prominent

evaluation experts, ‘‘Evaluation is a sector that remains quite uncoordinated. Each

region develops its own objectives. Mostly, these objectives are closely linked to the

budget restrictions of the Land. There is definitely no quality enhancement’’

(Interview partner 33a, senior manager of an evaluation agency).

Unlike the evaluation sector, the accreditation business is formally regulated by

national framework legislation on higher education and by the ‘‘Akkreditierungs-

rat,’’ or German Accreditation Council, which mediates the regulatory intervention

of the federal states. Accreditation was introduced via an amendment to the National

Framework Act in 1999 (BMBF 1999), simultaneously with a reform of the German

academic structure and the introduction of bachelors and masters degrees (KMK

1998). The implementation of the two-tier quality assurance system thus coincided

with the introduction of these new degrees, which – following national legislation –

had to undergo accreditation. In other words, from the beginning accreditation

agencies had significant demand from universities and polytechnics seeking to

increase their international profile by introducing standardized degree structures,

and in the past ten years the accreditation business expanded considerably.6 To date,

5 This unusual arrangement is due to the circuitous way in which regional evaluation systems were

created, as well as to the creation, in 1998, of a nation-wide accreditation market that used the same

working mechanisms as those used for evaluation (Serrano-Velarde 2008).6 The German accreditation market counts ten certified accreditation agencies:

ACQUIN (*2001): Akkreditierungs-, Certifizierungs- und Qualitatssicherungs-Institut

AHPGS (*2001): Akkreditierungsagentur fur Studiengange im Bereich Gesundheit und Soziales

AKAST (*2008): Agentur fur Qualitatssicherung und Akkreditierung kanonischer Studiengange

AQA (*2009): Osterreichische Qualitatssicherungsagentur

AQAS (*2002): Agentur fur Qualitatssicherung durch Akkreditierung von Studiengangen


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Germany’s ten certified accreditation agencies have accredited over 6,800 study

programs (Akkreditierungsrat 2011). Unlike evaluation agencies, accreditation

agencies have never lacked funding or political backing to expand their work, and

the institutional constraints they face regard problematic ex post market regulation

and a lack of professional legitimacy.

Ex Post Market Regulations

As stated above, the introduction of quality assurance in higher education took place

within a context of ambitious governance reform intended to redistribute

responsibilities in the public sector (Ostermann 2002). Although the reform’s

stated goal was modernization, it lacked a coherent implementation program

(Schimank 2005), meaning that the accreditation market was affected from the

outset by the regulatory ambitions of the federal policy-making system. One

administrator explained that this resulted in top-down, piecemeal adjustments and

amendments: ‘‘When [one Land] observes behavior that is inconsistent with KMK7regulation – and this observation is backed up by evidence in the other Lander, […]

the KMK gets together and a new regulation is born’’ (Interview partner 19b, public

administrator KMK). Thus, what started as a free market was caught up by the ad

hoc regulation of the federal states. Federal states are able to exert influence on the

accreditation business indirectly, through the Akkreditierungsrat, the central

regulating agency for accreditation matters. The Akkreditierungsrat is a foundation

of public responsible for the implementation, monitoring and control of the German

accreditation market. Since it receives its assignments directly from the Lander’s

common policy-making body, the KMK, it is, in effect, a ‘‘back door’’ through

which federal states are able to regulate accreditation agencies, which, of course,

undermines their autonomy:

‘‘We think that the relationship between the accreditation council and the

agencies ought to be decided once and for all: either the council considers the

agencies as subordinate agents that need constant control. (…) Or the council

decides to accredit the agencies for a certain time period – say eight years –

and leaves the agencies alone. For the moment, the council tends to do both’’

(Interviewee 27b, senior manager of an accreditation agency).

Footnote 6 continued

ASIIN (*2002): Akkreditierungsagentur fur Studiengange der Ingenieurwissenschaften, der Informatik,

der Naturwissenschaften und der Mathematik

Evalag (*2009): Evaluationsagentur Baden-Wurttemberg

FIBAA (*2002): Foundation for International Business Administration Accreditation

OAQ (*2009): Organ fur Akkreditierung und Qualitatssicherung der Schweizerischen Hochschulen

ZevA (*2000): Zentrale Evaluations- und Akkreditierungsagentur Hannover

* year of certification by the German Accreditation Council.7 The Standing Conference of the Ministers of Education and Cultural Affairs of the Lander, or KMK, is

the Lander’s common policy-making body.

K. Serrano-Velarde

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While the federal states are strongly represented in the governing board of the

Akkreditierungsrat and finance the whole accreditation process (GV. NRW 2005),

accreditation agencies have no political leverage to enforce their own interests.

National accreditation policy follows a top-down regulation structure, from the

federal governments to the Akkreditierungsrat to the accreditation agencies, and

provides for no formal path of intervention from the bottom up. Accreditation

agencies must comply with the regulations the federal states decide upon at the

Standing Conference of the Ministers of Education and Cultural Affairs of the

Lander (KMK).

Professional Legitimacy

Quality assurance agents also have difficult relationships with their clients, which

are often characterized by fear and distrust. The German academic world follows a

professional code that emphasizes the ‘‘academic freedom’’ of teachers and students

(Liedmann 1993; Pritchard 1998), and quality assurance is perceived as an incursion

on that freedom (Calhoun 2009) and an attack on the professional autonomy that has

been the bedrock of academic work for the past two centuries (Henkel 2000).

Interviews and policy documents reveal that academics resent the intervention of

quality assurance agencies. During a debate in the parliament of North Rhine-

Westphalia, a university president argued,8

‘‘Accreditation agencies are basically working on a mandate. Yet they do this

without any form of control. They do this without any form of legal support or

framing. Before the reform, universities had legal grounds to dispute the

decisions of the ministry. Nowadays, there is no legal recourse against

accreditation agencies. (…) Indeed, we are witnessing the emergence of an

industry that behaves very much like a lobby group’’ (Landtag 2006: 21).

It is clear that the professional culture in place is highly resistant to accreditation

agencies. Agencies respond to this resistance through ‘‘co-optation strategies’’

(Selznick 1948); that is, by including universities in their membership structure and

adapting (at least in appearance) to the professional cultures of their client

organizations, portraying themselves as ‘‘scientific bodies’’ (Interviewee 26b,

manager of an accreditation agency). They participate in conferences, write articles

and cultivate an academic discourse. One accreditation agency manager put it this

way:

‘‘Well, of course there have been questions: where does our legitimacy come

from? Where does the competence come from, to evaluate and assess study

programs? We say: we account for it by publishing the results, as is done in all

scientific institutions’’ (Interviewee 27b, senior manager of an accreditation

agency).

8 Quality assurance is a politically charged issue in most European countries. In his qualitative study on

trust relations and audits in British academia, Hoecht concluded that many of his interviewees ‘‘felt that

they were less trusted and more controlled than they had been in the past, although they did not perceive

this control as being voluntarily exercised by their immediate academic managers’’ (Hoecht 2006: 556).


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Accreditation agencies’ expertise is neither formalized nor recognized, meaning that

their acceptance into academia is contested at best. Both evaluation and

accreditation agencies rely extensively on the expertise of academic peers to

evaluate the content of study programs, meaning that, for the most part, their

‘‘expertise’’ consists of coordinating the activities of reviewers with those under

review, writing protocol and issuing final reports. Other than on-the-job learning,

there are few possibilities for formal training in the field. As a result, early

accreditation practices relied a great deal on intuitive learning (Crossan et al. 1999)

and mimetic strategies (DiMaggio and Powell 1983). Moreover, the client-agency

relationship is highly dependent on the people working for the quality assurance

agency. Quality assurance agents are trained academics. Many of them have a PhD

or PhD-equivalent experience and have prior work experience in academia (working

on research projects or as research coordinators, for example). Moving from a

traditional academic career into quality assurance is considered problematic by

university members, and quality assurance agents may meet with animosity from

peers working in universities, who often refer to them as ‘‘failed academics.’’

Taken together, these two sets of constraints are significant barriers to the

autonomy of accreditation agencies. In Germany, quality assurance agents have few

institutional resources at their disposal to cope with political interventionism and

client distrust. In 2010, agencies encountered a new impediment to their autonomy

when the SRH Hamm, a polytechnic institute was refused accreditation on two

separate occasions and challenged the jurisdiction of the accreditation agency on the

grounds that freedom in scientific research and teaching were constitutional rights

(Grundgesetz §5). The case is currently being heard in the constitutional court

(Muhl-Jackel 2010). If other higher education institutions in other European

countries follow suit, this will compound an already pressing issue of legitimacy

faced by accreditation agencies throughout the Higher Education Area.

European Leverage for Quality Assurance Agencies

The Rise of a European Policy Platform for Quality Assurance: ENQA

International trends have exerted increasing influence over national higher

education reforms in the past decade (Hahn 2003; Martens et al. 2010; Robertson

et al. 2006). In 1998, the Sorbonne Declaration on the Harmonisation of the

Architecture of the European Higher Education System (Sorbonne Declaration

1998) launched a transnational reform process known as the Bologna Process,

which now involves policy-makers from 47 European countries. Over the years, the

Bologna Process has issued detailed recommendations regarding study program

structure, degree recognition and quality assurance, which have been fully endorsed

by national ministries. Beyond its arsenal of recommendations and guidelines,

however, the Bologna Process has provided an open arena in which stakeholders,

NGOs and international organizations such as the European Commission may

participate in the formulation of policy guidelines (Capano and Piattoni 2011;

Gornitzka 2010; Ravinet 2008). Over the years, the Bologna Process has established

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and implemented a fully-fledged policy agenda for quality assurance. The main

driver behind this development is the European Association for Quality Assurance

in Higher Education, or ENQA, which was established on the recommendation of

the European Council in 1998. Its state goal is to enhance international cooperation

among quality assurance systems in higher education (European Council 1998).

Although it lacks a legal framework, the ENQA network quickly became an

important player in European politics. As early as 2001, the Prague Communique

provided a visible role for ENQA:

‘‘Ministers called upon the universities and other higher education institutions,

national agencies and the European Network for Quality Assurance in Higher

Education (ENQA), in cooperation with corresponding bodies from countries

which are not members of ENQA, to collaborate in establishing a common

framework of reference and to disseminate best practice’’ (Prague Commun-

ique 2001).

Two years later, ENQA was officially included in the Bologna Follow Up Group (or

BFUG), the standing committee in charge of organizing and preparing meetings and

relevant policy documentation. In a short time, ENQA had become a dynamic

federation of quality assurance agencies (for both evaluation and accreditation) with

a direct influence on the Bologna process.9 On the occasion of the 2003 Bologna

meeting in Berlin, national ministries mandated the ENQA to set guidelines for

quality assurance in Europe (Berlin Communique 2003). 2005, at an intergovern-

mental conference in Bergen, the European Standards and Guidelines (ESG) were

adopted by the education ministries of all countries in the European Higher

Education Area, and are now part of national legislation (ENQA 2005) in those

countries. The ESG stipulate working principles for evaluation and accreditation

agencies, and thus have a crucial role in the development and standardization

(Brunsson and Jacobsson 2000) of quality assurance as a professional field. In

addition, recent efforts to organize a reliable, comprehensive system of quality

control for the European Higher Education Area have led to the creation of EQAR,

the European Quality Assurance Register for Higher Education (EQAR 2008).

EQAR lists agencies that substantially comply with European standards for quality

assurance, acting as a gatekeeper to the European accreditation and evaluation

market. Though the use of meta-accreditation to prevent illegal accreditation

practices has been discussed in international forums since the 1990s (Mause 2010;

OECD 2005; Van Damme 1999), it only came into existence with the Bologna

Process, and was finally implemented following the London Conference of

Ministers in 2007, after several years of heated debate among Bologna stakeholders

over the legal implications of such an organization. According to the London

communique, agencies have to comply with the ESG to be included in the register.

Higher education institutions in Europe must now choose agencies listed on the

register to carry out their evaluation or accreditation. The register currently counts

9 In 2011, the political success of the informal ENQA network led to the founding of an international

organization classified as a nonprofit under Belgian law (ENQA 2011). The ENQA currently has its

headquarters in Brussels and has three full-time employees on its payroll.


123

28 national quality assurance agencies and is administered by a standing committee,

which includes members nominated by Bologna’s four stakeholder organizations

ENQA, ESU, EUA and EURASHE, as well as its social partners (Business Europe

and Education International). The introduction of European standards for quality

assurance in higher education and the creation of an agency register means that

European policy both affects the educational reform process at the national level

while furthering institution-building at the supranational level.

The ‘‘European’’ Strategy of German Quality Assurance Agencies

Having discussed the place of quality assurance and the arrival of the ENQA in the

European policy-making process, we will now turn to the institutional strategy of

German quality assurance agencies with regard to the Bologna Process. German

quality assurance agencies have been active members of the ENQA since its

inception. Eight out of the 42 quality assurance organizations represented in the

ENQA are German, giving Germany far more weight than many other European

countries (for comparison, Ireland has one agency in the ENQA, and Poland has

three). German representatives are involved in the ENQA’s board activities and

executive structure, giving them a strong say in its political agenda. ENQA

membership may therefore be seen as a way for quality assurance agencies from a

given country to increase political visibility and leverage:

‘‘I think you need to be active in these committees. You don’t need to be the

leader in all of them, in order to decide about the general orientation. You

need, however, to be present. Only then do you know what happens. There is

no other forum, no other way to get the information (…). [ENQA

membership] costs money and it is a lot of work. (…) But it is necessary,

because you get to work together’’ (Interviewee 19b, senior manager of a

German accreditation agency).

In other words, participation in European activities requires significant financial

outlay (in addition to internal meetings, ENQA is active in different political

processes and platforms), but the investment is seen as worthwhile. Not only do

German agencies perceive European activities as increasing their political influence

on the policy-making process, they also see international activity as conferring

additional legitimacy to the services they provide:

‘‘We consider those international processes as a means to increase our

visibility within the German system. German universities are quite interested

in this question. They want to know whether what we do is internationally

recognized. When we refer to [international] standards, it helps us to

strengthen our standing’’ (Interviewee 13b, senior manager of a German

accreditation agency).

The fact that quality assurance agencies can promote their own agenda on the

European level allows them to exert indirect influence on the policy-making process

in their own countries. While quality assurance agencies are unable to exert political

K. Serrano-Velarde

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influence within institutionalized structures in their own countries, ENQA

membership guarantees their voice will be heard in the Bologna process, giving

them access to political leverage from the European level. At the same time, the

creation of the European Register for Quality Assurance Agencies and European

Standards and Guidelines in order to achieve professional standardization and

international visibility may be seen as an attempt to enhance the overall legitimacy

and authority of quality assurance in the academic world.

Limits to the ‘‘European’’ Strategy

While leverage on the European level would at first glance seem an effective

remedy to autonomy and legitimacy issues at the national level, a closer look at the

situation reveals a slightly different picture. This section discuss the two main limits

of agencies’ institutional strategies with regard to the political embeddedness of

quality assurance in the Bologna Process and the problems attendant on the creation

of an integrated European market for quality assurance agencies.

The first limit to German agencies’ ‘‘European’’ strategy is that the political

embedding of quality assurance at the European level is somewhat precarious.

Although quality assurance is now an important item on the Bologna agenda, the

ENQA’s overall impact on the implementation of the Bologna Process remains

indirect and not very visible. Because of its mandate, the ENQA plays a powerful

role in the preparation of policy documents (Zito 2001), but communiques are

usually signed by the European ministers responsible for implementing reforms, and

the ENQA has only a minor influence on the actual decision-making process and on

national implementation. Beyond policy-making at the European level, the ENQA

has no political visibility, and therefore no leverage. The ENQA’s influence has

been further attenuated by the Bologna Process’s overall loss of momentum. After

their initial euphoric commitment to the three-cycle structure, quality assurance and

the modularization of study structures, European countries are now beginning to

show signs of ‘‘reform fatigue.’’ Student protests across Europe in 2009 and 2010

(Morgan 2009; Menke and Titz 2009; Perucca 2009) made clear that discontent was

widespread among academics, university staff, and students, and pointed to deep

problems within the European reform project. This was confirmed by developments

at the European level: the most recent Bologna communiques (Budapest-Vienna

Declaration 2010; Leuven and Louvain-La-Neuve Communique 2009) included no

further developments of reform principles; indeed, they did little more than reiterate

the original commitment to reform on a two-year cycle. This raises doubts as to

Bologna’s political sustainability and future as a policy tool. Though quality

assurance agencies use the ENQA to exert pressure in favor of implementing the

Bologna Process, the ENQA has little direct influence at the national level, and can

only act as a mediator within the complexly imbricated structure of a top-down

policy process that lacks public visibility and is beginning to lose popular support.

The second limit comes from the fact that, while the European Register for

Quality Assurance Agencies was created to regulate access to the European market

for quality assurance, most Bologna countries do not actually allow foreign quality


123

assurance services to work within their borders. Although quality assurance has

become a key element in the integration of European higher education systems, its

function is ultimately defined and regulated by national requirements and

expectations. A German accreditation agent, referring to the European market for

quality assurance, described foreign accreditation markets as ‘‘closed shops’’

(Interviewee 17b, senior manager of an accreditation agency). Today, quality

assurance agencies export their services mainly to small countries, such as Croatia

or Luxembourg, that cannot afford their own quality assurance systems. Overall

demand for international quality assurance services is very small, as illustrated by

the fact that the only services German accreditation agencies provide elsewhere in

Europe are to their German-speaking neighbors, and they have had only limited

success even there. While demand for German accreditation services in Switzerland

and Austria was enthusiastic in the early 2000s, it is now on the wane. Even in the

Netherlands, where higher education institutions are free to choose any provider

from the EQAR list, contracts remain scarce. While purchasing the services of a

‘‘registered’’ quality assurance agency may provide added value for a higher

education institution, such services are generally more expensive than quality

assurance provided by national agencies. It is hardly surprising, then, that this type

of accreditation is not an investment priority for higher education institutions, faced

as they are with dwindling economic resources. Indeed, one might be justified in

wondering what purpose is actually served by a register that regulates access to a

fictive market.

Discussion

Our analysis of the institutional strategy of quality assurance agencies in the

European Higher Education Area shows that agencies are able to achieve greater

autonomy by acting upon the institutional designs that constrain them. German

accreditation agencies live in a complex institutional environment that spans over

two levels: The national and the European. Whereas institutional constraints are

dominant at the national level, the European policy framework set up by the

Bologna Process actually opens up institutional resources for those agencies who

dare to invest time and money in European politics. From the moment German

ministries decided to create a national market for quality assurance agencies, the

provision of this service has been constrained by both post hoc regulations and the

professional resistance of academics. As a result, German accreditation agencies are

embedded in an institutionally entrenched environment, where mobilizing political

power or establishing professional credibility is at best difficult. The situation

changed, however, with the political success of the Bologna reform and the

subsequent expansion of the reform agenda to quality assurance matters. Since

2003, quality assurance has been one of the European Higher Education Area’s

main reform priorities, and over the years, quality assurance agencies have become

active players in the Bologna Process. By drafting policy documentation and

proposing standards and guidelines for quality assurance practices, European quality

assurance agencies have – to some extent – been able to regain some of the political

K. Serrano-Velarde

123

influence they lack on the national level. Their active participation in European

policy-making, as well as the codification of quality assurance practices through the

ESG and the creation of the European Quality Assurance Register for Higher

Education would lead us to believe that involvement in policy-making on the

European level is a way for quality assurance agencies to attain both political

leverage and professional legitimacy back home.

And yet political leverage they gain at the European level does not really offer a

sustainable means of renegotiating the ‘‘rules of the game’’ (North 1990) at the

national level. Rather, agencies’ involvement in policy endeavors at the European

level should be seen as what Brunsson and Jacobsson called a ‘‘politics of

standardization’’ (2000), where standards are understood as statements of how the

world should be organized in the eyes of their authors. Such statements do not come

with a system for enforcing them, nor with tools for furthering their implementation

or clarifying responsibilities. Furthermore, since standards represent voluntary

forms of coordination, they cannot be directly responsible for any impact they may

have (Timmermans and Epstein 2010). Put another way, ‘‘standardisers’’ have no

power or authority to impose the standards they create. That power lies in the hands

of other parties, such as governments or regulatory agencies. No matter the

standards, the ‘‘standardizer’’ is not responsible, or even accountable, for their

implementation. This somewhat paradoxical situation means that the political

leverage currently enjoyed by German quality assurance agencies at the European

level is quite fragile. They have created no political visibility, nor do they have any

concrete enforcement mechanism that would enable them gain autonomy or respect

in their own country.

Thus, the institutional strategy of German accreditation agencies, which aims at

strengthening their autonomy and professional legitimacy at the national level by

developing political leverage at the European level, has its limits. However

successful accreditation agencies are in negotiating quality assurance politics at the

European level, they remain dependent on the ministries and universities with

regard to the implementation.

Conclusion

We examined the case of German accreditation agencies, which, though they face

institutional constraints originating from political regulation and professional

resistance at the national level, are able to achieve some level of political leverage

by working within the policy structure put in place at the European level by the

Bologna Process. We have seen just how difficult agency autonomy is to achieve in

a setting where policy-makers increasingly rely on indirect steering instruments in

higher education (such as competition-based funding formulas, benchmarking or

contracting). The regulation of accreditation agencies remains inconsistent and

incoherent, and is distrusted by academics, who feel at odds with this new form of

supervision. Our explanatory framework, by providing different levels of analysis,

has allowed us to develop a historically informed and comprehensive understanding

of quality assurance as a multilevel phenomenon. Examining German accreditation


123

agencies has illustrated the inherently contradictory nature of the Bologna Process,

which fulfils a powerful ordering function with regard to the educational agendas of

member states without managing to institutionalize these structures of influence at

the national level. As a result, any political influence and professional legitimacy

German agencies achieve through the European policy process fails to right the

power imbalances they experience at the national level. Finally, by using a

relational understanding of agency autonomy, this paper reveals the need for more

comparative research on the institutional embeddedness and the evolution of quality

assurance agencies. Whatever autonomy quality assurance agencies in Germany

have managed to carve out through their participation in the Bologna Process and its

attendant reforms, their utility and authority remain contested at home. Their

experience illustrates a question haunting the increasingly globalized world of

higher education: is it really possible to impose meaningful standards in such a

field?

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