They’ve been trying for years to cut back the paperwork. But according to the universities, a previous attempt (the introduction of the ‘institutional quality assurance test’) didn’t achieve much. Which is why they came up with a new plan: the so-called ‘institutional accreditation’. In this system, the institutions will review their own degree programmes, with the NVAO merely certifying that they have followed the correct procedures.

The previous government had already prepared an experiment with this form of accreditation, but coalition member VVD in particular wasn’t too keen on the plan. This resulted in a compromise: three universities and three universities of applied sciences wanted to assess their education programmes, but NVAO would be tasked with checking each programme individually with regard to a few points. The trial went underway in September 2018.

Pressure of work

To improve insight into the “experienced regulatory pressure in relation to quality assurance”, Van Engelshoven commissioned a study into this issue. On Friday, the Minister presented the results to the House of Representatives. Research shows that the pressure of work is mainly due to excessive regulation. People working in higher education are not only expected to take the formal legislative framework into account, but also regulations at the institutional, faculty and programme levels.

In addition, staff are confounded by the open way in which various legal provisions and regulations have been phrased. “Within this scope, you need to be fairly sure of yourself to organise quality assurance programmes that aren’t too demanding,” according to the Minister. But as becomes clear from the report, that’s exactly where the problem lies: “They pull out all the stops during an accreditation. It shows that these institutions have insufficient trust in their own vision and quality.”

What’s more: the ‘unpredictability’ of the NVAO panels and constant adjustments to the requirements further aggravate the experience of regulatory pressure. The Minister will be meeting with the NVAO head to discuss whether the assessments couldn’t be made more predictable. The Minister also wants to shed light on which options degree programmes have to ‘read between the lines’.


In addition, Van Engelshoven has commissioned a comparative study into experiences with institutional accreditation in other countries. Her letter also presented the results of this review. According to Van Engelshoven, one of the positive effects of this approach is that institutions feel a stronger ‘ownership’ when it comes to their assessment. In her view, this forms a “more effective safeguard for quality than a finely meshed complex of third-party regulations.”

Moreover, institutional accreditation seems to help in alleviating the experienced regulatory pressure, since the associated activities are felt to be more constructive. Although in fact, this approach probably won’t relieve the pressure of work. On the contrary: according to the report the workload could even increase further.

And institutional accreditation also creates risks of its own. Because how can you be sure that the experts responsible for assessing the degree programmes are truly independent? If a programme turns out to be substandard, it remains to be seen whether the institution’s board will intervene in time. And it’s quite possible that institutions adopt a single centralised quality assurance policy rather than handle this matter at the level of individual programmes. And it will become even harder to compare similar degree programmes offered by different institutions.

“Viewing the results of this orientation, I am in favour of introducing institutional accreditation as a complement to the existing forms of accreditation,” says Van Engelshoven. To make sure that the members of the assessment committees feel free to maintain a critical perspective and speak their mind, the Minister believes it is important to have other options to fall back on. By mid-2020, she expects to come with concrete plans that also take due account of the risks.