The National Commission for Further and Higher Education (NCFHE) is an independent body under the Education Act. One of its functions is to accredit educational entities, including prospective universities.
Much has been made about the submission of an application for the accreditation of the American University of Malta (AUM), as well as about the changes recently made by the government in the Legal Notice that regulates such accreditation.
The judgement which will be reached about the accreditation of the AUM will be made by my Board independently after thorough and rigorous due process. There will be no lowering of standards. The methodology being adopted will be correct and within the rules set down under the law.
Second, my commission is carrying out the accreditation process with the same due diligence as it would apply to any other further or higher education institution, with the most rigorous scrutiny and standards in line with accepted practice throughout Europe.
Third, my commission is neither qualified, nor required, to consider land-use environmental issues. It ensures that the proposed tuition premises are fit for purpose and have the relevant planning permits.
Fourth, it is important to put the application of AUM in the wider context. It is the government’s policy to encourage pluralism in education and the internationalisation of education providers with a view to raising standards of higher education in Malta, creating greater choice and sharper competition. Importantly, this should stimulate further investment in the education sector to the benefit of the wider Maltese economy. This is where the national interest lies.
The original Legal Notice, designed in 2012, catered for a particular kind of university provision, rather like the University of Malta. That was then our template.
But this excluded other forms of university that are successfully operating today around the world, such as the technical universities in Germany that do not offer PhDs, or small universities that have a defined focus, such as law, business or the arts and design.
Time has moved on. Malta must also move on.
The changes in the Legal Notice were designed well before the application from the AUM came to the notice of the Commission.
They were intended to allow for a wider definition of university in line with international practice, without reducing the essential high standards of accreditation we demand.
There will be no lowering of standards
As to Regulation 47 of the Legal Notice, about which there has been some misplaced comment, this is not about the minimum provision that applicants for university accreditation need to have in Malta. Its purpose is to present seven due diligence tests of eligibility in terms of the background of the applicant as a higher education provider. The applicant has to pass these tests for the application itself even to be considered.
For example, Barts, whose accreditation was processed under the former version of the Legal Notice, is providing only one course in Malta. But it was eligible for accreditation on the basis of its already established provision in the UK.
In the revised Legal Notice, one of these tests of eligibility requires an applicant for university accreditation to offer at least four programmes between Level 5 and 7 on the Malta Qualifications Framework as well as evidence of the capability to offer a programme at Doctorate Level.
An additional clause in the Legal Notice allows the commission to consider applications from entities whose combination of programmes on offer differ from those specified in the regulations.
These changes were made specifically to cater for the different forms of universities that already exist internationally, which we are seeking to attract here. This is not about the quantity of programmes (whether 10 or 5), but the need to ensure quality of academic standards. On this, my commission is unwavering.
What happens to the application once received? The application for university status is made subject to an evaluation by a panel of three independent experts established by my Quality Assurance Committee (QAC), whose responsibility is to implement the accreditation and quality assurance regulations. This is what is already under way in the case of the AUM.
The panel makes its recommendations to the QAC, which may approve or request further clarifications. The QAC then makes its recommendations to my Board, which may or may not endorse the application. Thus, there is a seamless and continuous system of checks and balances to ensure rigour and thorough due process.
Accreditation is an iterative process – a process that bats back and forth between applicant and QAC panel.
As a matter of normal procedure, my Commission staff support all applicants in revising and improving their applications so that the required standard laid down is reached.
If, in the final analysis, the application is turned down by my Commission, the AUM would be able to re-submit an amended application and we would re-start the accreditation process until the high standards we have set are reached.
In conclusion, it is completely incorrect – and irresponsible – to state that standards of accreditation have been reduced to accommodate the AUM, or any other institution that may apply. This legal notice has been under discussion for the past few months and was not introduced in order to favour any particular application for University status.
It is the policy to attract universities to Malta, and rules had to be aligned to ensure the policy was successfully implemented without undermining standards.
The legal notice only touched the criteria to be eligible to apply. Quality is not linked to the quantity, amount or number of programmes offered by a university. It is an absolute canard to say that the quality criteria have been compromised.
Martin Scicluna is chairman of the National Commission for Further and Higher Education.