Editorial

The new Royal Decree on the organisation of qualifications: not the way!

Martí Casadesús · AQU Catalunya's Director

Over the last few months the Spanish Ministry of Universities has sent out different drafts related to the amendment they are preparing with regard to Royal Decree (RD) 1393 on the organisation of university education. This is a key regulation that governs how university degrees are organised and evaluated in Spain.

Most notable among the different proposals made public is the inexplicable desire to eliminate the 180 ECTS-credit degree programmes, which are clearly the majority in the rest of Europe. This is by no means a minor issue and could lead to conflict, as it would make it impossible for universities to offer interuniversity programmes with centres that offer 3-year degrees, such as Belgium, Finland, France or Switzerland, something that the EU is promoting through its European Universities initiative. Three- and four-year degree programmes coexist in most of the European Higher Education Area, with only ten states allowing only four-year degrees: Albania, Armenia, Belarus, Bulgaria, Cyprus, Georgia, Greece, Kazakhstan, Russia and Turkey. From where we stand, it makes no sense to regulate the duration of degree courses, as their design is a purely academic matter. Universities should be free to organise the courses they offer, and, like in the rest of Europe, allow quality agencies to accredit them on the basis of the results obtained.

However, the concern raised by this issue, which is sure to remain highly controversial, pales in comparison to the alarm bells that go off when we analyse the regulation's ten articles on quality assessment in detail. Without delving too deeply into the matter, we can highlight three general aspects:

Alignment with European standards: Despite what its preamble states, it is clear that this regulation is not at all aligned with those being carried out throughout Europe. This is not only in regard to the duration of the degrees, but also, for example, in how they fail to be organised with the same "knowledge, skills and competencies" in mind as in the rest of the world's qualification frameworks. Nor are the new degrees organised on the basis of learning outcomes, as is the norm. For its part, the regulation makes a point to further differentiate "competencies" (specific, interdisciplinary, etc.), a distinction which, and pardon my ignorance should this not be the case, I believe does not exist anywhere else. In fact, in all the international projects in which we at AQU Catalunya participate, we are continually having problems aligning our standards to those of the rest of the countries. To put it simply: "they don't understand us", and apparently, we are going to make sure they never do.
Monitoring qualifications: It appears that monitoring qualifications and their subsequent assessment by the agencies will now be mandatory and on an annual basis. Not only is it obvious that this will create an insurmountable workload for the quality assurance agencies and universities, but it also obviously makes no sense. For AQU Catalunya, this would mean an additional 1,500 reports per year; utter madness that is unlikely to improve the quality of anything. The monitoring of degree programmes should form part of the internal quality assurance system of each educational institution and should be organised as each institution sees fit. External agencies should not be involved, least of all on an annual basis and for each degree programme.
Knowledge areas: A new set of knowledge areas have been defined to which the degree programmes will have to be adapted. These areas will include a set of basic competencies that will have to be attained. We are talking, for example, about "Chemistry" or "Earth Sciences". Apart from the fact that this will involve modifying all the bachelor's and master's degrees in Catalonia, over 1,000, the most important aspect is the return to a kind of degree catalogue. This is a trend that runs completely counter to that of the European Higher Education Area, which leaves universities free to organise their programmes as long as they are subsequently accredited by recognised external quality agencies.

In addition to these important issues, the proposed Royal Decree includes new processes such as reports by the autonomous governments and new processes for the modification of programmes, which would increase the complexity of the quality assessment process. Although the theoretical aim of the decree is to reduce bureaucracy, there is no doubt, based on the drafts to which we have had access and bearing in mind what I have mentioned, that it will do the opposite.

We at AQU Catalunya have conveyed our opinion on the various drafts of the Royal Decree through all the relevant instruments and channels. It is clear that our message has not been received, as each new version has added more complexity, worthless bureaucracy and rigidity to the system.

As the president and I recently explained in an article, our proposal for regulation is based on the idea of building trust in universities and quality agencies, respecting the autonomy of universities, regulating the minimum necessary (just take some of the best European university systems, for example the Danish or Dutch, and adapt them to work here), and introducing robust accountability mechanisms. Our aim must be Europe; we must aim for simplicity, efficiency and effectiveness of action. Sterile bureaucracy should not be sown in the name of quality, because it consumes countless resources that we do not have and only breeds discouragement.

AQU Catalonia will do everything possible to improve this decree, to make our opinion, which is the opinion that is shared in Europe, heard, because we certainly cannot be satisfied with later on saying: "we told you so".