QUALITY MANAGEMENT AND ENHANCEMENT COMMITTEE
Working Group on Professional, Statutory and Regulatory Bodies Report to
QMEC
Executive Summary
At its meeting of 1 July 2008, QMEC noted that the regularisation of the Annual
Monitoring process had highlighted the fact that there was currently no institutional
overview of accreditations by Professional, Statutory and Regulatory Bodies. QMEC
also noted that the requirements/burdens of PSRBs seemed (anecdotally at least) to be
increasing. QMEC therefore established a Working Group to review UCL’s existing
procedures and practice in relation to the accreditation of UCL degree programmes and
courses by PSRBs. The Working Group met on 5 December 2008 and resolved, in
accordance with its terms of reference, to develop and circulate a questionnaire to be
sent to all PSRB-accredited programmes. The Working Group met once more on 25
March 2009 to consider a report analysing the responses to the questionnaire and to
agree a set of recommendations to QMEC. This report to QMEC comprises:
-
An introduction outlining the creation of the PSRBWG, its main remit and the
development and circulation of the questionnaire [paragraph 1];
-
Key findings arising from the responses, including the level of faculty
involvement in PSRB events and the burden placed by PSRBs upon
programmes and departments [paragraph 2];
-
Other key points to note arising from the responses [paragraph 3];
-
Summary [paragraph 4];
-
Recommendations to QMEC [paragraph 5];
-
Next Steps [paragraph 6];
-
A table of PSRBs (as confirmed by the respondents to the questionnaire)
[Annex 1];
-
Full results and in depth analysis of all responses to the questionnaire [Annex
2];
-
Sample questionnaire [Annex 3].
Key to abbreviations used in this note:
AC
AAM
AM
A&H
FBS
DTC
ENG
FBE
Academic Committee
Augmented Annual Monitoring
Annual Monitoring
Faculty of Arts and Humanities
Faculty of Biomedical Sciences
Departmental Teaching Committee
Faculty of Engineering Sciences
Faculty of the Built Environment (The Bartlett)
FLS
FTC
HERRG
HoD
IQR
MAPS
MBBS
PSRB
PSRBWG
QMEC
Faculty of Life Sciences
Faculty Teaching Committee
Higher Education Regulation Review Group
Head of Department
Internal Quality Review
Faculty of Mathematical and Physical Sciences
Bachelor of Medicine, Bachelor of Surgery
Professional, Statutory and Regulatory Bodies
Working Group on Professional, Statutory and Regulatory Bodies
Quality Management and Enhancement Committee
1
INTRODUCTION
1.1
At its meeting of 1 July 2008, QMEC noted that the regularisation of the
Annual Monitoring process had highlighted the fact that there was currently
no institutional overview of accreditations by Professional, Statutory and
Regulatory Bodies. QMEC also noted that the requirements/burdens of
PSRBs seemed (anecdotally at least) to be increasing. QMEC therefore
established a small Working Group to review UCL’s existing procedures and
practice in relation to the accreditation of UCL degree programmes and
courses by PSRBs.
1.2
At its first meeting on 5 December 2008, the PSRBWG resolved to (i) develop
and agree a questionnaire to be sent to all programmes which were subject to
accreditation by PSRBs (ii) receive an analysis of responses to the
questionnaire, (iii) consider and agree any recommendations to QMEC arising
from the responses and (iv) follow up with those programmes/departments
who had expressed concerns about PSRB accreditation, particularly in terms
of the perceived burden or nature of the process. At its meeting of 25 March
2009, the PSRBWG considered an analysis of responses and a number of
preliminary proposals regarding UCL’s future procedures in relation to PSRB
accreditation with a view to agreeing a number of recommendations to submit
to the meeting of QMEC scheduled for 1 April 2009.
1.3
All faculties were sent details of all PSRBs (and the programmes they
accredit) of which the PSRBWG was previously aware and asked to check
these, notifying PSRBWG Officers of (i) any omissions or additions that
needed to be made and (ii) of any items which might be out of date or wrong.
1.4
Having received corrections/additions from faculties, it was ascertained that
154 UCL programmes are PSRB-accredited. The agreed questionnaire was
then circulated to these PSRB-accredited programmes.
1.5
Once responses to the questionnaire had been received, the Working Group
was able, inter alia, to discern the following:

that accreditation events were currently largely dealt with on a
departmental/individual programme basis, and to consider when (and
by what means) the parent faculty and/or UCL might be made aware
and take appropriate action if a programme were to lose its accredited
status;

Whether PSRBs had become increasingly interventionist since the
abolition of universal subject review and if they had, whether UCL
2
might offer institutional support to programmes/departments in the
face of increasing or excessive PSRB requirements by engaging in
dialogue with the relevant PSRBs.
1.6
A copy of the questionnaire circulated to all PSRB-accredited programmes is
at Annex 3. Programmes were asked to fill in a separate questionnaire for
each accredited programme unless the responses in the case of each
programme were identical. 49 questionnaires were returned, covering 133
(86%) of the 154 PSRB-accredited programmes. Table 1 below shows all
accredited programmes by faculty and the number of responses received for
those programmes.
Table 1 – UCL Accredited programmes by faculty
Faculty
Number of Accredited
Programmes (not including
stop-off points e.g. PgDip)
Arts & Humanities
Biomedical Sciences
Built Environment
Engineering Sciences
Laws
Life Sciences
MAPS
Total
1.7
Number of Accredited
Programmes for which a
response was received
5
23
16
63
9
6
32
154
5
23
15
43
9
6
32
133
The bar chart below shows the actual number of PSRBs by faculty, the
number of responses to the questionnaire by faculty and the total number of
accredited programmes that each faculty has.
70
60
50
40
No. responses
No. PSRBs
30
No. Programmes
20
10
0
A&H
FBS
FBE
ENG
LAWS
LIFE
MAPS
Bar chart comparison: Faculty PSRBs: showing the number of responses to the
questionnaire, number of PSRBs and number of accredited programmes for each faculty
1.8
The majority of PSRB activity is located within three faculties, Biomedical
Sciences, Built Environment and Engineering Sciences (although one PSRB
in Mathematical and Physical Sciences, the Institute of Physics, accredits a
large number of programmes).
2
KEY FINDINGS
3
2A
The PSRB burden on programmes and departments
2A.1
From the information provided by the respondents to the questionnaire, it is
possible broadly to distinguish between those PSRB processes which are
less involved and might be defined as “light touch” and those which are
“extensive” and require a great deal of work for the departments and
programme(s). A broad definition of a “light touch” PSRB accreditation
process might be:




2A.2
Conversely, a broad definition of an “extensive” PSRB accreditation process
might be:





2A.3
requires minimum documentation and a short (if any), visit by the
PSRB audit team (less than 1 day’s duration);
minimal preparation time (less than 1 day’s duration);
may involve only one initial “set-up” accreditation process;
minimal, if any, follow-up process.
requires large amount of documentation (forms, statistical evidence
etc.);
may require detailed self-evaluation statement;
preparation time is lengthy and involves much collation of evidence
and documentation;
visit(s) take at least a day and involve meeting a number of staff and
students;
the follow-up process is thorough and may include provision of further
evidence, completion of action plans to fulfil recommendations or
periodic monitoring (possibly annual) of provision.
From these working definitions, a bar chart is presented below displaying the
faculties where responses fit the above definitions:
20
15
Light touch
Extensive
No. PSRBs
10
5
0
A&H
FBS
FBE
ENG
LAWS
FLS
MAPS
Bar chart comparison: Faculty PSRBs showing the number of responses to the
questionnaire which indicated either a “light touch” or an “extensive” accreditation process
2A.4
From the above bar chart it can be seen that those faculties where the
PSRBs create the highest concentration of extensive accreditation are the
Built Environment, Biomedical Sciences and Engineering Sciences. These
data do not give any indication of the size of particular programmes. For large
and complex programmes the PSRB accreditation process will often involve
much more staff time than would be the case with (eg) a small Masters
4
programme. Overall, the faculties of the Built Environment and Biomedical
Sciences expressed the most concern regarding the burden placed on their
programmes by PSRBs. In the case of the Faculty of the Built Environment,
difficulties arose as a result of those programmes (such as the BSc
Architecture) which are accredited by more than one PSRB, each with
differing demands and processes. In the case of the Faculty of Biomedical
Sciences, one programme (the MBBS) is of considerable size and represents
the bulk of the faculty’s provision. At its first meeting, the PSRBWG noted the
need to consider whether in the face of increasing or excessive PSRB
requirements, UCL might provide support by engaging in dialogue with the
relevant PSRBs and suggested that QMEC follow up comments made by
those faculties who noted a disproportionately heavy or increased burden
placed on them by their PSRBs, to discern whether such institutional dialogue
or intervention would be appropriate or helpful (see paragraph 5.1 (d) below.
2B
Perceptions of Increased Burden
2B.1
Interestingly however, overall, 35 (71%) responses indicated that there had
been no increase in the PSRB requirements with 12 (24%) of these
respondents stating that there had actually been a reduction.
2B.2
Only 6% of responses indicated that the burden placed on programmes and
departments from PSRBs had increased. These responses were from the
Faculty of the Built Environment and appeared to centre around two PSRBs
which accredited the programmes, but used a different process and required
different documentation.
2B.3
In the light of the above, it is interesting to note that 36 (73%) responses
stated that the PSRB had made no reference to the Concordat1, although
another 5 (10%) responses indicated that changes implied that attention had
been paid to it. Only 3 (6%) responses were certain that the PSRB had
referred to the Concordat (the PSRBs were the Royal College of Surgeons in
Edinburgh (2) and the British Psychological Society (1). Given the lack of
awareness of the Concordat demonstrated above, it is probably unsafe to
assume that its implementation has resulted in the perceived reduction in
burden, although this remains a possibility. The Working Group will
recommend that QMEC contact the HERRG to ask for clarification of how
they are monitoring the impact of the implementation of the Concordat (see
paragraph 5.1 (f) below).
2C
Faculty involvement in/knowledge of the outcomes of PSRB
accreditation events
2C.1
Although not invited to respond to a specific question regarding the level of
faculty involvement in the accreditation process, it can nevertheless be
inferred from responses to question 5 (‘please provide a brief summary of the
process’) that there is no specific faculty involvement in the process and that
it is handled almost exclusively by the programme or department.
1
In 2005 the Higher Education Regulation Review Group published the Hodgson Report,
‘Less Regulated, More Accountable’ setting out a framework of recommendations for a
“Concordat” between funding and inspection bodies in HE in England.
5
2C.2
It can likewise be inferred from the responses to questions 10 and 11 (see
Annex 2) (concerning the follow-up procedures employed by the PSRB) that
the parent faculty and/or UCL would not currently be automatically made
aware if a programme were to lose its accredited status. The responses
showed wide variation in follow-up procedures with 24 (49%) stating that
follow up procedures were dependent on the accreditation decision, with wide
variation in practice and time-scale. 5 respondents (10%) indicated that the
follow up process took place regardless of the accreditation decision, usually
involving an update request on progress and/or further statistical data on
students. 13 (26%) stated that there was no follow-up process. Around half
the responses, (26 or 53%) stated that the PSRB sent both an official letter
and a report with recommendations. 12 (24%) responses indicated that the
PSRB reported by letter only and 8 (16%) by a report only, with 1 response
each indicating that the outcome was reported orally or by e-mail. No mention
was made by any respondent of outcomes being either copied or reported to
the faculty.
2C.3
Officers have also checked the Summaries of FTC Proceedings (which are
submitted to AC) for 2005-06, 2006-07 and 2007-08 for any indication that
FTCs routinely discuss the outcomes of PSRB accreditation events as part of
their normal business and it would appear from this evidence that they do not.
3
OTHER KEY POINTS TO NOTE ARISING FROM THE RESPONSES2
3A
Positive aspects and benefits to the students of the accreditation
process
3A.1
A variety of responses were received and it should be noted that many
responses noted more than one benefit each. Most responses (55) indicated
that accreditation was positive because it either gave students professional
status or was itself a necessary step in that process, either through further
application or training. This included assisting in the attainment of chartered
status, or providing assurance that students had met standards for basic
practice competency.
3A.2
Some 10 responses indicated that accreditation afforded some international
recognition of the graduates of a programme, with obvious positive
implications for the recruitment of overseas students for those programmes.
14 responses indicated that the PSRB had a positive effect on the academic
provision of the programmes, including assuring standards, giving additional
feedback mechanisms for students and giving an external view of the
currency of programmes, which was helpful to their development.
3A.3
A small number of responses (4) stated that the PSRB offered some kind of
student membership which allowed them access to additional libraries and
information and events and lectures with professionals and academics, as,
well as providing early networking opportunities.
2
The key points arising from the questionnaire responses to the main issues identified
by the PSRBWG are given above. Where possible, the number of respondents and
the percentage are given, however, to some questions, respondents gave more than
one answer which prevents conversion to percentages. Full analysis of the
questionnaire data is available at Annex 2.
6
3B
Main focus of the PSRB (academic standards, curriculum content,
fitness to practise etc.) and level of curriculum input
3B.1
Overall, the vast majority of respondents (45 and 92%) stated that the
PSRBs’ main focus was on maintaining and improving academic standards.
43 (88%) stated that curriculum was also a main point of focus. Fitness to
practise was also indicated as a focus by 34 (69%) of responses.
3B.2
Although there was variation in the actual practice (see Annex 2), 25 (51%) of
responses indicated that the PSRB had broad input into the curriculum with
programmes required to demonstrate some form of adherence or compliance.
A smaller number, 7 (14%) of responses indicated that there was stronger
involvement by the PSRB into the curriculum, which it largely determined.
3B.3
Given the potential impact of ‘fitness to practise’ issues on the institutional
disciplinary procedures, the Working Group will recommend that the
Academic Registrar should be asked to give detailed advice on whether
account is taken of PSRB requirements when designing UCL’s disciplinary
regulations and if so, how this is done (see paragraph 5.1 (e) below).
4
SUMMARY
4.1
At its first meeting of 5 December, the PSRBWG noted that ‘Professional,
Statutory and Regulatory Body’, as indicated by the name, was an umbrella
term, encompassing a variety of different roles, with some PSRBs taking a
regulatory role, some a statutory role and others a mixture of these. Some
were responsible for guaranteeing fitness to practise (eg the General Medical
Council) whereas others merely lent prestige to the programmes they
accredited. The nature and level of the interventions and the pressures on
departments from their various PSRBs were therefore very different and the
PSRBWG’s recommendations to QMEC would need to take account of this.
4.2
Most, (45 and 92%) responses to the questionnaire stated that accreditation
could be removed by PSRBs. A small number of responses also noted the
existence of additional sanctions, often withdrawal of professional status. It
was clear from the responses that the loss of accredited status would, in a
significant number of cases, have a catastrophic effect on the programme and
that many would be unable to continue if accreditation were withdrawn. In the
light of this, it would seem vital that UCL/faculties should be made aware at
an appropriately early stage of any issues noted by PSRBs which, if not
addressed might lead to loss of accreditation.
4.3
Also, although there have been to date no recorded problems with PSRB
accreditations of UCL programmes, it is acknowledged that since the
acquisition and exercise of its own degree awarding powers, UCL should
have a robust mechanism to ensure that any problems which might occur in
the future can be picked up in a timely fashion at faculty and institutional level.
Any mechanism would however, given the variation of role and purpose of
PSRBs noted above, need to be risk-based and proportionate.
4.4
It is therefore suggested that all reports/final letters from PSRBs should be
forwarded to (i) the Dean of Faculty as soon as these are received so that
these can be discussed at FTCs as a matter of routine and (ii) the ViceProvost (Academic and International)/AC Chair and the QMEC Chair. The
7
Working Group recognises that there would be resource implications if such
an institutional monitoring mechanism were introduced but feel that it is not
within its remit to comment further on this (see paragraph 5.1 (a) below).
4.5
Where responses have noted a significant PSRB burden, these seem to
indicate that the burden of external accreditation work is not the issue, but
rather, the combination of this with internal QME requirements such as IQR,
AM and AAM. However, given the enormous variation in type, purpose and
timing of PSRB accreditation events noted in the responses to the
questionnaire, it would not be realistic or helpful to attempt any institutionwide ‘mapping’ of accreditation events, nor integration of these with
schedules for IQR, AM and AAM. It is recommended instead that the
HoD/Chair of DTC’s overview AM report template should, in future, carry a
request for details of any PSRB accreditations in a manner similar to that for
AAM. In this way it will be possible for FTCs (to whom the overview AM report
is submitted for discussion) to build increased awareness at faculty level of
PSRB accreditation events (see paragraphs 5.1, (a) and (b) below). It is also
recommended that the definitive schedule of PSRB-accredited programmes
compiled for the purpose of the Working Group’s deliberations, be maintained
by UCL and published (see paragraph 5.1 (g) below).
4.6
For the purposes of IQR, departments are increasingly creating and
maintaining online databases of IQR self-evaluative statements and
supporting material. It is recommended that departments might also use the
material created and stored thus for PSRB accreditation events (adding or
altering where necessary). In this way, much supporting material can be reused wherever convenient and for either purpose as appropriate (see
paragraph 5.1 (c) below).
4.7
The Working Group noted that where supporting material has already been
prepared for a PSRB accreditation event, Heads of Department/Departmental
Contacts have always been encouraged to discuss and negotiate with the
Administrative Secretary (during the preliminary briefing prior to the
Department’s IQR) whether this material might also ‘map’ onto the
requirements for core IQR supporting documentation. Where material can be
shown to map appropriately, departments are encouraged to submit this. With
AM, the AM Guidelines state3 that in the case of departments who regularly
undergo accreditation by PSRBs, provided the core AM reporting
requirements are fulfilled, departments are at liberty to adapt the AM template
to accommodate any additional reporting requirements needed to support or
prepare for accreditation. However, given the vast differences in the burden of
accreditation events revealed by the responses (from the ‘light-touch’ filling in
of a form and exchange of emails to the ‘extensive’ series of inspections and
interviews – see paragraph 2A above) the PSRBWG considered it unrealistic
to recommend that the deferral of a scheduled IQR should be automatic
where the IQR coincided with a PSRB accreditation and agreed that the
existing arrangement, where deferral of an IQR was considered on a case-bycase basis, was still fit for purpose.
5
RECOMMENDATIONS TO QMEC
5.1
In light of the above, the PSRBWG makes the following recommendations to
QMEC:
3
See http://www.ucl.ac.uk/academic-manual/part-l/l7 section 12
8
(a) That all reports on outcomes/final letters from PSRBs should be forwarded to
(i) the Dean of Faculty as soon as these are received so that these can be
discussed by FTCs as a matter of routine (ii) the Vice-Provost (Academic and
International)/AC Chair and the QMEC Chair. The Working Group recognises
that there would be resource implications if such an institutional monitoring
mechanism were introduced but feel that it is not within its remit to comment
further on this (see paragraph 4.4).
(b) That the HoD/Chair of DTC’s overview AM report template should, in future,
carry a request for details of any PSRB accreditations in a manner similar to
that for AAM. In this way it will be possible for FTCs (to whom the overview
AM report is submitted for discussion) to build awareness at faculty level of
PSRB accreditation events (see paragraph 4.5). For institutional awareness
of accreditation events, see recommendation (g) below.
(c) That, in view of the fact that for IQR, departments are increasingly creating ad
maintaining online databases of IQR self-evaluative statements and
supporting material, it be recommended that they do likewise for the material
required for PSRB accreditation events (see paragraph 4.6). However, the
existing arrangement, where deferral of an IQR where the IQR coincides with
a PSRB accreditation is considered on a case-by-case basis, is still fit for
purpose and should remain. Where material has already been prepared for a
PSRB accreditation event, Heads of Department/Departmental Contacts will,
as previously, be encouraged to discuss and negotiate with the Administrative
Secretary (during the preliminary briefing given to the Department prior to the
Department’s IQR) whether this material might also serve as core IQR
supporting documentation (see paragraph 4.7).
(d) That QMEC follow up comments made by faculties who noted a
disproportionately heavy or increased burden placed on them by their PSRBs
to discern whether UCL might provide support by engaging in dialogue with
the relevant PSRBs where such institutional dialogue or intervention would be
appropriate or helpful (see paragraph 2A.4).
(e) That, given the potential impact of ‘fitness to practise’ issues on the
institutional disciplinary procedures, the Academic Registrar should be asked
to give detailed advice on whether account is taken of PSRB requirements
when designing UCL’s disciplinary regulations and if so, how this is done (see
paragraph 3B.3).
(f) That QMEC contact the HERRG to ask for clarification of how they are
monitoring the impact of the implementation of the Concordat (see paragraph
2B.3).
(g) That the definitive register of PSRB-accredited programmes compiled for the
purpose of the Working Group’s deliberations, be maintained by UCL and
published (see paragraph 4.5).
6
NEXT STEPS
9
5.1
QMEC is invited to consider the above report and recommendations. If the
recommendations are approved, Officers will draw up an implementation plan
and report all progress made to a future meeting of QMEC.
10
Annex 1
Table summarising PSRBs by Faculty
Name of PSRB
No. responses
received
(no.progs in
brackets)
Chartered Institute of Library and Information
3 (3)
Studies
Society of Archivists
1 (2)
Faculty
Frequency
of accrdtn
Visit
Paper
based
process
Academic
Standards/
Curriculum
Fitness
to
Practise
How
does
it report
Follow
up
Sanctions
A&H
5 years
N
Y
Y
N
A&H
5 years
Y
Y
Y
Y
Report
and letter
Report
Follow up
review
Next
Accreditn
Remove
accdtn
Remove/
suspend
accdtn
Remove
Licence
General Medical Council (GMC)
1 (1)
BMS
5 years
Y
Y
Y
Y
Report
and letter
Health Professions Council (HPC)
1(2)
BMS/
LIFE
Annually
Y
Y
Y
Y
Letter
and
possible
report
General Dental Council (GDC) – Joint Committee
for Specialist Training in Dentistry via Specialist
Advisory Committee for Restorative Dentistry
Faculty of General Dental Practitioners (FGDP)
2 (2)
BMS
5 years
Y
Y
Y
N
Report
2 (14)
BMS
Once only
N
Y
Y
N
Letter
Annual
update
required
Possible
action on
reccs/
annual
monitrng
Requires
action on
reccs
N/A
Royal College of Surgeons in Edinburgh
2 (2)
BMS
Once only
N
Y
Y
Y
Letter
N/A
General Dental Council – Royal College of
Surgeons (RCS)
British Academy of Audiology on behalf of the
Registration Council for Clinical Psychologists
(RCCP)
Architects Registration Body UK (ARB)
2 (2)
BMS
Once only
N
Y
Y
N
Letter
N/A
2 (2)
BMS
5 years
Y
Y
Y
Y
Report
and letter
1 (1)*
FBE
4 years
N
Y
Y
Y
Report
and letter
Requires
action on
reccs
Annual
monitrng
11
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
Accdtn
Name of PSRB
No. responses
received
(no.progs in
brackets)
1 (1)*
Faculty
Frequency
of accrdtn
Visit
Paper
based
process
Academic
Standards/
Curriculum
FBE
4 years
Y
Y
Y
5 (6) FBE
1 (6) ENG
1 (1)
FBE/
ENG
FBE
Annually
Y***
Y
Y
Y
5 years
Y
Y
Y
Y
1 (1)
FBE
5 years
Y
Y
Y
Y
Letter
1 (1)**
FBE
2-5 years
Y
Y
Y
Y
Royal Town Planning Institute (RTPI)
3 (4)
FBE
Annually
Y
N
Y
Y
Report
and letter
Report
and letter
Institution of Chemical Engineers (IChemE)
2 (12)
ENG
5 years
Y
Y
Y
Y
Institution of Mechanical Engineers (IMechE)
2 (8)
ENG
5 years
Y
Y
Y
Y
Report
and letter
Report
International Hydrographic Organisation (IHO)
and International Federation of Surveyors (FIG)
Joint Board of Moderators (Institution of Civil
Engineers, Institution of Structural Engineers,
Institution of Highways and Transportation,
Institution of Highway Incorporated Engineers)
1 (1)
ENG
8 years
N
Y
Y
Y
Letter
1 (9)
ENG
5 years
Y
Y
Y
Y
Report
and letter
Royal Institute of British Architects (RIBA)
Royal Institution of Chartered Surveyors (RICS)
Chartered Institute of Building (CIOB)
Chartered Institute of Building Service Engineers
(CIBSE)/Society of Light and Lighting (SLL)
British Institute of Facilities Management (BIFM)
12
Fitness
to
Practise
How
does
it report
Follow
up
Sanctions
Report
and letter
Annual
monitrng
& interim
visit after
2 years
Annual
meeting
Requires
action on
reccs checked
annually
Next
Accredtn
Next
Accredtn
Reviews
at board
meeting
None
Remove
Accdtn/
Condtnl
validtn
Report
and letter
Report
and letter
Prog
informs
PRSB of
changes
Next
Accredtn
Requires
action on
reccs
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
accdtn
Remove
Accdtn
Remove
accdtn
Name of PSRB
No. responses
received
(no.progs in
brackets)
2 (4)
Faculty
Frequency
of accrdtn
Visit
Paper
based
process
Academic
Standards/
Curriculum
Fitness
to
Practise
How
does
it report
Follow
up
Sanctions
ENG
4 years
Y
Y
Y
Y
Letter
Remove
accdtn
Institute of Physics and Engineering in Medicine
(IPEM)
2 (2)
ENG
5 years
Y
Y
Y
Y
Report
Institution of Engineering and Technology (IET)
1 (1)
ENG
5 years
Y
Y
Y
N
Joint Academic Stage Board of the Solicitors
Regulation Authority and the Bar Council – Law
Society/General Council of the Bar
British Psychological Society (BPS)
1 (9)
LAWS
N
Y
Y
N
3 (3)
LIFE
Once at
inception of
prog
5 years
Report
and letter
Letter
Requires
action on
reccs
Requires
action on
reccs by
following
session
Annual
report
None
Y
Y
Y
Y
Report
Requires
action on
reccs
Association of Child Psychotherapists (ACP)
1 (1)
LIFE
4 years
Y
Y
Y
Y
Report
Under
review
Royal Statistical Society (RSS)
1 (8)
MAPS
Annually
N
Y
N
E-mail
None
Royal Society of Chemistry (RSC)
Institute of Physics (IoP)
1 (3)
1 (21)
MAPS
MAPS
5 years
4 years
N
Y
N
(By email)
Y
Y
Remove
Accdtn/
lead to
prog
closure
Remove
Accdtn/
monitor
prog
Remove
accdtn
Y
Y
Letter
Report
and letter
None
Next
Accredtn
Royal Institute of Naval Architecture
(RINA)/Institute of Marine Engineers (IMAREST)
Total
49 (127)
13
Remove
accdtn
N/A
Remove
accdtn
Not known
Remove
accdtn
*ARB and RIBA both accredit programmes in a complimentary approach, but have been listed separately here as they follow different practice and
timescale
** RICS and CIOB/BIFM both accredit BSc Project Management/Facility and Environmental Management programmes, but have been listed separately
here as they follow different practice and timescale
*** This is for the initial accreditation – an annual process by paper is then followed
14
Annex 2
Analysis of results of responses to questionnaire
(1) How frequently is your programme(s) subject to PSRB accreditation?
Once only
1 year
2 -5 years
4 years
5 years
More than 5 years




6
12
1
7
22
1
Key points:
Variation in frequency often reflects type of accreditation:
“once only” answers were mainly received from dental programme responses,
which may focus on accreditation of the student rather than the programme
itself (i.e. it occurs once because only the student is accredited);
12 (24%) responses underwent annual accreditation;
29 (59%) responses stated that accreditation process took place at 4 or 5
yearly intervals (the majority of these responses indicated that this involved a
PRSB accreditation team visit, similar to the frequency of the QAA
institutional audit or the IQR programme).
(2) Does the accreditation process involve:
A paper-based process?
A visit from an accreditation team?
A combination of the two?
Annual meeting of programme staff with PSRB
Informal e-mail communication
41
30
31
4
1
Key points:
 Most (41 or 84% of responses) involve a paper based process - this may in
fact be higher as some responses were not always clear;
 Some 30 (61%) of responses indicated that a visit from accreditation team
was part of the PSRB process;
 Some 31(63%) of responses indicate that the accreditation process involves a
combination of a paper based process and a visit from an accreditation team;
 4 Faculty of the Built Environment responses also indicated that the
accreditation process included a specific meeting (“annual partnership
meeting”) of the programme staff with the PSRB (Royal Institution of
Chartered Surveyors) to discuss new and existing programmes. The
responses stated that a visit from the PSRB was conducted at the point of
initial accreditation;
 One response involved members of the programme staff attending an
accreditation meeting of the PSRB and one response indicated that a light
touch process was conducted entirely by e-mail (Statistical Sciences).
15
(3) How long does the accreditation process take?
Less than 1 day
1 day
2 days
2-3 days
1-4 weeks
1 term
Several months
1 year
18 Months
N/A
Not known
7
8
4
1
2
1
20
2
1
1
2
Key points:
 Responses which indicated less than 1 day for the accreditation process all
came from the Faculty of Biomedical Sciences with the majority dental
PSRBs/programmes. Some of the responses indicated that a very short
period of time was spent on the process, some 30 minutes to 3 hours;
 Altogether 20 (41%) of responses indicated that the accreditation process
took 1 week or less;
 The 24 (49%) responses which stated that the process took a number of
months or longer often indicated that this involved different stages of
completing the process;
 One of the respondents answering “not known” (MSc Environmental Design
and Engineering) further explained that the programme was in the application
process for accreditation and it was not yet clear how the process worked, its
length and the anticipated work-load (the PSRB was the Chartered Institute of
Building Service Engineers).
(4) How long does the preparation for the accreditation process take?
Less than 1 day
2 -5 days
1 week
1-2 weeks
2-4 weeks
1-2 months
3-6 months
6-12 months
N/A
Not known
3
12
8
4
3
4
4
1
6
3
Key points:
 Altogether, 15 (31%) responses stated that preparation took less than 1 week
rising to 30 (61%) of responses which stated that this took less than 1 month;
 9 (18%) respondents answered that preparation took longer than 1 month,
including the MBBS (PSRB the General Medical Council) – this often
indicated a multiple-staged accreditation process that was clearly not “light
touch”. Many of the responses from the Faculty of Built Environment also
stated that PSRB accreditation was a similarly involved process.
16
(5) Please provide a brief summary of the process.
PSRB selects programme(s) for review, receives submission from programme
then meets students and make decision on accreditation
PSRB first accredits programme through approval visit, then follows 2 year cycle
of review involving audit every second year. Programmes complete declaration to
confirm no changes or inform PSRB of major changes to programme (e.g. change
of tutor, new courses etc)
Submission of detailed documentation to PSRB, followed by visit(s)
Visit from PSRB accreditation team (including interviews), review of programme’s
written submission and documentation leading to decision
PSRB conducts questionnaire of placement supervisors and key stakeholders
and then reviews programme’s written submission, visits and interviews students
and staff, inspects teaching resources and samples of students’ work; considers
and makes decision
Submission of re-accreditation documents reviewed by panel in visit. Panel report
to PSRB committee for decision
Submission of paperwork confirming programme and/or institution accredited
Submission of documentation to PSRB for consideration at a formal validation
meeting. PSRB decides whether to request more information or make
recommendations for programme to implement (to be reviewed) or to accredit
Oral presentation to meeting with PSRB, submission of application documentation
for accreditation. PSRB considers decision in internal meeting(s)
Submission of paperwork (including self-evaluative statement) received by PSRB
who consider and make decision
Submission of annual statistics considered by PSRB then decision
Submission of paperwork mapping programmes to PSRB criteria followed by
further consideration and discussion
PSRB requests by e-mail details of any changes to programme(s), if none
received, automatically renews accreditation, if changes made, PSRB receives
documentation, reviews and then makes decision
Not known
4
1
4
11
1
2
5
2
6
1
1
3
1
7
Key points:
 There is some variation in specific practice for the accreditation processes
and the main responses are included above. However, there are two basic
patterns, as indicated in Q1 above of PSRB’s either using a paper-based
process or a process involving visit(s) and a paper-based process;
 For the paper based process excluding visits this ranges from submission of
documentation, statistical data, completion of specific forms and in some
cases self-evaluation statements. Altogether 12 (24%) response below
followed this pattern in some way;
 23 (47%) responses indicated that the accreditation process involved both
submission of some kind of paperwork and visits from a PSRB team;
 Other response included submission of documentation to the PSRB and an
oral presentation by the programme at a special meeting (6) and a very light
touch process involving accreditation using only e-mail (1).
(6) What are the positive aspects and benefits to the students of the accreditation?
Necessary for professional status for students
Membership of PSRB (or be qualified to apply for this)
Student Membership of PSRB (i.e. not full membership)
Registration with further national body (e.g. GDC) which in some cases may
17
27
14
5
4
require further specialist training/necessary for application to national body
Assists in application for chartered status
Gives credits for further study/training with PSRB or other recognised national
body (such as GDC)
PSRB Internationally recognised
To ensure programme meets requirements of the award and assures standards
To ensure that programme satisfies educational and (e.g., clinical) practice
requirements assuring standards for basic competency
Additional feedback mechanism for students to comment on the course
Provides external view of the programme, ensures curriculum is up to date and
assists in its further development
10
4
10
4
4
2
4
Key points:
 A variety of responses was given to this question and it should be noted that
many response gave more than one benefit each;
 Most responses indicated (55) that accreditation was positive for either giving
students professional status or being a necessary step in that process, either
through further application or training. This includes assisting in the
attainment of chartered status (often for Built Environment and some
Engineering Sciences PSRB/programmes), assuring that students had met
standards for basic practice competency (for many Life Sciences and
Biomedical Sciences programmes/PSRB).
 10 responses indicated that accreditation gave some international recognition
of the student and this had obvious implications for recruitment of overseas
students for those programmes;
 14 responses indicated that the PSRB had a positive effect` on the academic
provision of the programmes, including assuring standards, giving additional
feedback mechanisms for students and giving an external view of the
currency of programmes, which was helpful to their development;
 A small number of responses (4) stated that the PSRB (Royal Institution of
Chartered Surveyors) offered some kind of student membership which
allowed them access to additional libraries and information and events and
lectures with professionals and academics, as, well as providing early
networking opportunities.
(7) What is the PSRB’s main focus? Does it concern itself with:
academic standards
curriculum content
fitness to practise
Other - conduct of members
45
43
34
1
Key points:
 45 (92%) responses stated that the PSRB main focus was with academic
standards, with 43 (88%) also stating that this included focus on curriculum
content;
 Fitness to practice was also widely indicated by 34 (69%) respondents with
many programmes in Biomedical Sciences, Built Environment and
Engineering Sciences responding positively;
18
(8) Does the PSRB check these:
During the course of study
After the course of study
Both
PSRB monitors conversion rate, number of students registered
and number of graduates who apply for membership
PSRB only checks for curriculum content
Not known
YES
12
9
17
3
NO
13
13
1
5
Key points:
 There is wide variation in practice in when PSRBs check the main focus of
the accreditation process (see Q7 above), with 17 (35%) responses stating
that the PSRB conducted the process during as well as after the course of
study. This may be dependent on whether the PSRB uses follow-up
processes or monitoring of the programme’s provision.
(9) Where applicable, please indicate the level of input into the curriculum.
Light touch – but programme must demonstrate that it covers broad areas and
addresses key values and skills of PSRB
PSRB defines broad topics/standards/core subjects which programme must
comply with and requires curriculum to remain relevant to current practice
Curriculum determined by PSRB (produces substantial checklist it expects
programmes to map their curriculum onto in written submission)
Intended learning outcomes (e.g.” clinical fitness to practice”) are set by
PSRB/national accreditation bodies and must be adhered to by programme
External/Professional Examiners are required to verify that each candidate has
met the PSRB(s) criteria for competence to practice
PSRB advises on development of the curriculum if it can be accommodated by
the programme
None
Not known
13
12
3
4
4
2
5
6
Key points:
 25 (51%)responses stated that the PSRB had broad input into the curriculum
with programmes required to demonstrate some form of adherence or
compliance;
 7 (14%) responses indicated stronger involvement by the PSRB into the
curriculum, which it largely determined. This included some Biomedical
Sciences programmes (such as some of the Dental programmes) as well as
some Built Environment programmes;
 4 (8%) of responses stated that the PSRB checked the students competency
to practice through the use of external examiners, this included the BSc
Architecture programmes.
(10) How does the PSRB report?
By letter
By report with recommendations
Both
Oral confirmation of accreditation
By e-mail
12
9
26
1
1
19
Key points:
 Most 47 (96%)responses stated that the PSRB reported the outcomes of the
accreditation process either through an official letter or a report with
recommendations or both;
 The respondent answering that the PSRB (Royal Institution of Chartered
Surveyors) report was given as oral confirmation stated that this was the end
of the oral presentation meeting by the programmes;
 The e-mail report was the conclusion of this processes for the Department of
Statistical Sciences.
(11) What follow-up procedures does the PSRB employ and what is the time interval
for the follow up?
Reports to PSRB board, reviews any changes – timescale dependent on chosen
action
PSRB may request additional information and allows deadline (e.g. 28 days)
If changes to programme required, further action may be taken including possible
further visit or review – timescale dependent on chosen action
PSRB reviews report at next accreditation, except where accreditation had been
withheld, in which case it may specify a shorter timescale for evidence that action
has been taken on recommendations
Paper based annual monitoring and/or interim visit - timescale dependent on
chosen action
PSRB may require confirmation that action taken to address any issues and
follow this up (in some cases annually)
Written recommendations following the visit (2-6 months)
PSRB monitors and collects data on annual entry standards to programme –
timescale depends on outcome of monitoring (i.e. whether programme is
accredited)
PSRB requires that any changes to programme are implemented for the next
academic session
PSRB requires an annual update through action plan/change management plan
outlining progress on recommendations and good practice
PSRB requires annual report and list of graduates
PSRB may require follow-up review dependent on decision
Not known
None
4
1
10
3
5
2
1
1
2
2
1
2
2
13
Key points:
 24 (49%) of responses stated that follow-up to the accreditation process was
dependent on the decision to accredit, with wide variation in practice and time
scale (as listed above);
 5 (10%) indicated some kind of follow-up such as an annual report or update
(often with submission of statistical data on student numbers);
 13 (26%) stated that the accreditation process did not involve follow-up.
(12) What sanctions, if any, could the PSRB employ?
Removal of accreditation status
Programme withdrawn from PSRB’s list of approved programmes, degree
cannot then provide professional (e.g. clinical) training
Students not allowed PSRB membership/not allowed to practice
PSRB could deem institution to be below acceptable standard of delivery,
leading to further scrutiny and monitoring by PSRB
20
45
5
3
1
Removal of licence by GMC
N/A
Not known
1
1
2
Key points:
 Most, (45 and 92%) responses stated that accreditation could be removed by
PSRBs;
 A small number of responses also gave additional sanctions, often withdrawal
of professional status.
 It was clear from these answers that losing accreditation status would often
have a catastrophic effect on the programme, and many would be unable to
continue if it was withdrawn (e.g. MBBS and BSc Architecture programmes);
(13) What is the number and composition of the PSRB review team who undertake
accreditation events. (E.g., are they professionals, academics etc and is there a
student representative)?
Team members
Professionals/practitioners
Academics
Representative(s) of PSRB or national body (e.g. GDC)
Member of PSRB – non professional (Administrative or secretarial)
Student representative
Lay member
Not known
N/A
No.
35
29
18
11
2
2
3
3
Key points:
 Most responses indicated that professional or practitioners were members of
the review teams where visits were part of the accreditation process;
 Academic members of the team were also reported by many responses;
 About half of these responses stated that representatives from the PSRB was
in the team and slightly less that the PSRB often supplied a secretarial or
administrative member;
 A small number of response indicated other team members such as students
representatives and lay members.
(14) Does the PSRB identify good practice?
YES
NO
33
12

Not
known
4
Key points:
33 (67%) of the responses stated that the PSRB did identify good practice,
with 12 (24%) answering negatively
(15) Has there been any significant change in the PSRB's requirements in the last
five years? If so, has this resulted in an increased burden being placed on your
department?
Less intensive paper exercise and therefore less of burden on programme
Reduced from full accreditation process to a visit
21
8
4
On-going load increased (e.g. by recently introduced annual monitoring), but less
visits
Increased demand, two bodies involved request similar documentation but in
different format, hence larger burden on programmes
Requirements change every visit/accreditation
Length of visit changed
Not known
None
None but PSRB currently reviewing its accreditation criteria and processes
3
3
3
1
4
20
3
Key points:
 12 (24%) responses indicate that there has been a reduction in the
accreditation process in the last five years;
 3 (6%) responses, from the Faculty of the Built Environment, stated that the
burden had increased, largely due to the demands of two different PSRBs
(RIBA and the ARB) requiring different documentation;
 20 (41%) responses indicated that there had been no changes, but 3 (6%)
stated that this was under review;
 Overall 35 (71%) respondents altogether indicated that there had been no
increase in the burden from PSRBs in the last 5 years.
(16) Has the PSRB made any reference to the “Concordat”? 4
YES
NO
Not known
3
36
5
No reference but changes indicate that attention has
been paid to it
5
Key points:


36 (73%) responses stated that the PSRB had made no reference to the
“Concordat”, although another 5 (10%) responses indicated that changes
implied that attention had been paid to it;
Only 3 (6%) responses were certain that the PSRB had referred to the
“Concordat” (the PSRBs were the Royal College of Surgeons in Edinburgh (2)
and the British Psychological Society (1).
(17) Do the PSRB's requirements map onto UCL's internal QA requirements (eg.
Annual Monitoring/ Internal Quality Review etc and, if so, how?
Annual Monitoring
Internal Quality Review
YES
NO
In part
11
11
22
22
14
14
Not
known
2
2
Key points:

22 (45%) respondents stated that the PSRB requirements did not map on the
internal UCL QA requirements;
4
In 2005, the Higher Education Regulation Review Group (HERRG) published a report entitled 'Less
Regulated - More Accountable' – also known as the ‘Hodgson Report’. In the report, the HERRG sets as
its main priority the framing of recommendations to ensure better co-ordination of quality assurance,
data collection and consultation through the brokering of a better regulation ‘Concordat’ between the
funding and inspection bodies in HE in England.
22

However, around half 25 (51%) stated that they did map onto the
requirements, although 14 (28%) of these responses stated that they did so
only in part.
(18) Are there any other comments relating to the PSRB accreditation process that
you wish to raise?
“the attractiveness of our programme would certainly be reduced if it did not carry
SAC educational approval” (MClinDent in Endodontology & Affiliate Year of Study for
Membership in Restorative Dentistry)
“overall positive experience” (MSc/PG Dip in Audiological Science)
“the RIBA and ARB processes, taken together with institutional QA, UCL’s IQR and
other processes impact dramatically on our ability to undertake the actual business of
teaching and researching. More coordinated and streamlined processes would be of
immense benefit” (Bartlett Certificate in Professional Practice and Management in
Architecture (Architecture programmes)
“UCL is arguably the most prestigious university that RCIS deals with in the UK. The
relationship is important to both parties (MSc European Property Development and
Planning/MSc project and Enterprise Management/MSc/PGDip/PGCert Facility and
Environment Management ).”
“It would be very beneficial on staff time if IQRs could be timed to take advantage of
the documentation assembled for the accreditation process” (BSc Project
Management for Construction)
“UCL has had a long relationship with SLL (and its forbears) over nearly 50 years;
current members of staff are active and hold senior positions in SLL. Both sides
would wish to retain our very close links.” (MSc Light and Lighting)
“Having been involved on it from both sides (been accredited and as an accreditor) I
would say that the approach of the Engineering PRSB is constructive and effective
and ensures a reliable standard of Engineering within UK engineering degrees” (MSc
Mechanical Engineering)
“A necessary chore…and a good chance to show off in detail to other academics and
consultants” (Civil Engineering programmes)
“From the Geomatics point of view the most important aspect is recruitment; even
though relatively few students go on to join the RICS most of them perceive it
important at the application stage, and many of them have been referred on to the
programmes in the first through the RICS” (Geomatic Engineering programmes)
“Accreditation is …. of much more use to us than the largely internalised local UCL
QA processes, which are carried out by non-experts in the field of study. It is
therefore our preferred process.
For this reason, rather than seek less PSRB involvement and more
internalisation, we believe that UCL should instigate a much lighter touch IQR
process for suitably accredited programmes than at present whereby this robust
external scrutiny is given insufficient credit.
This would be consistent with UCL’s international strategy to prepare our
students for global citizenship” (Chemical Engineering programmes)
23
“it is very straightforward, based on mutual trust and respect and we are very happy
with it – so if there are any changes in the pipeline, please allow the flexibility to carry
on with business as usual for programmes where this is working!” (Statistical Science
programmes)
“Teaching staff on the UCL Archives and Records management programmes
emphatically welcome the accreditation process. It is very important to us and to our
students. Not only does it allow us to “badge” our courses as professionally
recognised and as one of the essential steps towards a professional career, it also
gives us as university educators the opportunity to engage in a direct dialogue with
the Archives profession and employers about what we can offer them in terms of
curriculum development and professional engagement” (Archives and Records
Management programmes)
“in my experience the process has rarely been useful in identifying problems and in
suggesting solutions. In one case a Department has been put “on probation” (i.e.
they have been given provisional accreditation for two years instead of the usual
five), but with no significant consequences and ultimately no significant changes to
their curriculum or processes.
More seriously, there is NO attempt to assess the quality of our graduates five, ten or
fifteen years after graduation – thus, the accreditation process only assesses the
academic coherence of the curriculum and the robustness of our processes, but has
nothing to say about how good our graduates are at doing what they are expected to
do by their employers. If I made a statement to the effect that our graduates are the
best of all other universities in the world, no PSRB would have any data to prove me
wrong.” (Faculty of Engineering)
“The GMC is both a statutory and a professional body and as such has a justifiable
interest in the MBBS programme; however it is neither a funder of the programme
nor an employer of anyone who delivers it. Therefore the HEI also has an important
and legitimate role in quality enhancement.
It should be entirely possible to develop local arrangements that reduce the burden
and duplication of these dual processes while fulfilling the necessary regulatory and
quality enhancement roles.” (MBBS programme);
“We will appreciate the streamlined, “lighter touch” approach alluded to in the (BPS)
4th February letter”. (BSc Psychology)
“The change from an accreditation visit to a paper-based exercise means that the
accreditation team no longer meet and talk to the students. It also takes much longer
to explain everything in writing and to provide clarification.” (MA Diploma in Library
and Information Studies/ MSc/PG Diploma in Information Science /MA/PG Diploma in
Electronic Communication and Publishing)
“The IoP accreditation process is relatively straightforward, if somewhat time
consuming particularly if it coincides with the start of a new session” (Physics
programmes)
Key points emerging from the comments:


9 of the comments viewed involvement with the PSRB positively and
considered it to be very important for the programme(s);
1 comment was concerned that involvement with the PSRB placed a heavy
burden and had an impact on teaching and research;
24


1 response viewed the involvement with PSRBs negatively;
3 responses mention a desire to coordinate UCL’s internal QA processes,
particularly IQR with the PSRB reviews.
25
ANNEX 3
WORKING GROUP ON PROFESSIONAL, STATUTORY AND REGULATORY
BODIES (PSRBs)
QUESTIONNAIRE TO PSRB-ACCREDITED PROGRAMMES
Name of programme:
Name of PSRB:
(1) How frequently is your programme(s) subject to PSRB accreditation?
(2) Does the accreditation process involve:
A paper-based
process?
A visit from an
accreditation team?
A combination of
the two?
Other (please specify)
(3) How long does the accreditation process take?
26
(4) How long does the preparation for the accreditation process take?
(5) Please provide a brief summary of the process.
(6) What are the positive aspects and benefits to the students of the accreditation?
(7) What is the PSRB’s main focus? Does it concern itself with:
academic
standards
curriculum content
fitness to practise
Other (please specify)
(8) Does the PSRB check these:
During the course
of study
After the course of
study
Both
Other (please specify)
(9) Where applicable, please indicate the level of input into the curriculum.
27
(10) How does the PSRB report?
By letter
By report with
recommendations
Both
Other (please specify)
(11) What follow-up procedures does the PSRB employ and what is the time interval
for the follow up?
(12) What sanctions, if any, could the PSRB employ?
(13) What is the number and composition of the PSRB review team who undertake
accreditation events. (Eg, are they professionals, academics etc and is there a
student representative)?
28
(14) Does the PSRB identify good practice?
(15) Has there been any significant change in the PSRB's requirements in the last
five years? If so, has this resulted in an increased burden being placed on your
department?
(16) Has the PSRB made any reference to the “Concordat”? 5
(17) Do the PSRB's requirements map onto UCL's internal QA requirements (eg.
Annual Monitoring/ Internal Quality Review etc and, if so, how?
5
In 2005, the Higher Education Regulation Review Group (HERRG) published a report entitled 'Less
Regulated - More Accountable' – also known as the ‘Hodgson Report’. In the report, the HERRG sets as
its main priority the framing of recommendations to ensure better co-ordination of quality assurance,
data collection and consultation through the brokering of a better regulation ‘Concordat’ between the
funding and inspection bodies in HE in England.
29
(18) Are there any other comments relating to the PSRB accreditation process that
you wish to raise?
(19) Please provide the name of a member of staff within the department who would
be able to discuss these issues with the Working Group.
30