The National report is available by the link.

Prepared by the Belarusian Independent Bologna Committee, the Ad Hoc Committee of the Belarusian National Platform of the Eastern Partnership Civil Society Forum, the Belarusian Student Association and  the Youth Labour Rights 

1. Qualifications Framework.

Despite the fact that the Report says about successful completion of the stage of work on the National Qualifications Framework for Higher Education (HE NQF - BelQF) and the approval of the project by Minister of Education, we would like to draw attention to a very formal approach to such a serious document development:

- the status of the document is questionable, it is not even approved by Order (or Resolution), but by a simple stroke of the pen of Minister of Education, and, of course, the Minister himself proclaims his ministry as the "Republican body ... which carries out the development and management of the BelQF ..." which violates the procedural order and legislative requirements of the adoption and approval of national level documents;

- BelQF approved by the Minister on 12/30/2019 (at the last moment of the outgoing year) became available on the website http://edustandart.by/ only on February 20, 2020. Earlier, the BelQF project was not fixed on this site;

- The Report states that the BelQF project was "... finalized taking into account the comments and suggestions received, resubmitted for discussion at the intra-republican and international levels" ", including at the intra-republican level" ... through the “specialized Internet platform https: // www.edustandart.by / ... ".

However, no traces of BelQF broad discussions results (comments, suggestions, etc.) were found either on this “platform” or in other sources of information. Also Internet portal for informing those interested in the development of the higher education system of the Republic of Belarus and Bologna instruments implementation (http://by-ehea.info), where this document was supposed to be placed for public access, has not yet been working.

- in p.1.6. of Work plan for 2019 it was stated “Submission for approval … of agreed upon with interested parties ... (BelQF). ”

But besides Minister of Education signature there is no indication this national level document was agreed with anyone from these “interested parties” (Ministry of Labor, Ministry of Economy, etc.).

As for the National Higher Education Qualifications Framework (BelQF) itself, it should be noted that:

- it doesn’t contain short-cycle qualifications that were provided for by the EHEA Qualifications Framework adopted at the Paris Conference of EHEA Ministers of Education on May 24-25, 2018.

- it is not entirely clear how the educational levels that are inherent in EQF LLL appeared in BelQF, while in EHEA QF this corresponds to the qualifications of the first, second and the third cycles.

The logical question is: And where are BelQF HE is the 1st, 2nd ... 5th level of education?”

If this is “harmonization of the national classification system of educational programs (State Specialties and Qualifications Classification of the Republic of Belarus 011-2009) with the International Standard Classification of Education, which includes links to educational programs BelQF HE and QF-EHEA” (table 1-4), then this document should be called BelQF LLL, but not BelQF HE.

ECTS

The Report (p. 1.7.) says that the New Application Procedure Credit System), Academic Hours and Number of Credits  for higher education educational programs was developed and posted  for nation-wide public expert assessment on a special online platform https: //edustandart.by / ... ". However, it was absent there and therefore it is not possible to find the aforementioned document, get acquainted with its contents and evaluate its compliance with the revised “ECTS User Guide 2015”.

2. Quality Assurance

2.1. Although in Working plan 2019 it was planned to “provide information about the current system of higher education quality assurance in the Republic of Belarus to ENQA”, the report shows that the information was provided only to selected international experts and specialists. Nothing is known about the presentation of such information in ENQA. Therefore, there is no reason to consider this paragraph of the plan fulfilled.

2.3. The work plan provided for “Elaborating the program of further development of the national higher education quality assurance”. However, the report doesn’t contain information on such a program. Instead, the National Report refers to the development of the Concept of the National Agency for Quality Assurance of Higher Education as part of a joint project of the Ministry of Education and the World Bank. The implementation of this concept applies to the period until 2025, although previously the Strategic Action Plan provided for such implementation until 2022.

3. Recognition of Qualifications

3.1. The report of the Ministry of Education indicates that mutual recognition of qualifications has been signed or prepared with Zimbabwe, Serbia, China, Iraq, Moldova, Cuba and Sudan. With the exception of China, student exchange is absent or at an insignificant level with these countries. Therefore, progress in ensuring direct recognition on a bilateral basis should be considered insignificant.

3.2. The English version of Updated information for the country page on the ENIC / NARIC website mentioned in the National Report couldn’t be found there. Almost all the information is still in Russian. https://www.enic-naric.net/belarus.aspx#anc03_6

The English version of the NIHE site is still not informative enough. Only general information about the tasks of the ENIC office is available. There is no transition to the page with the requirements for the applicant for recognition of qualifications in English (http://nihe.bsu.by/foreign-diplomas-and-degrees-recognition). A 3-language PDF application form is available at this link.

3.3. “Developing methodological guidelines for recognition of refugees ’education” scheduled for 2019 was postponed indefinitely due to the study of the European experience of such recognition and work in the TPG-LRC project. Ministry report indicates that certain developments are underway to optimize, accelerate, and increase the transparency of recognition procedures. There is no available information neither about the concept of the Belarusian part of the project, nor about the performers, nor about the results.

4. Transparency Tools

- Development of educational and program documentation

The Report indicates that in accordance with p.4.1 «Developing curricular and methodological provision for Cycle II specialties (Master’s degree programs)»

of the work plan for 2019 there were developed a number of educational and methodological documents, as well as educational standards.

Of course, some work has been done in this direction. But in the development of these materials the current (obsolete in contents) Code of Education was used, as well as the Instructions for calculating the complexity of educational programs of higher education using the credit system of 2015, the provisions of which do not fully comply with the ECTS 2015 User Guide.

- Diploma Supplement

As for the development and implementation of the European Diploma Supplement, according to the 2019 Report, work was carried out jointly by BSU, RIHE, etc. However, in 2019, as in 2018, the visible results of this work were not recorded: Neither the project nor the proposals on the layout format of the multilingual European diploma supplement (Diploma Supplement), including in digital form, nor the concept were found in other public access on the websites of MoE, NIHE Bologna process,.

- According to p.4.4 of the Report 2019, a practice-oriented seminar "Prospects for the digitalization of higher education: improving educational tools, teaching methods and diploma supplements" was held on the basis of the Voronezh State University on September 26-27, 2019. The final materials and results of this seminar were not found in the public domain.

All this indicates the failure to fulfill these points of both Working 2019 and the Strategic Plans and a formal approach to the provision of reporting materials.

5. Mobility of Higher Education Teaching Staff and Students, Internationalization

5.3. This paragraph of the report contains incomplete information on the first international competition for the provision of study grants to foreign citizens at universities of Belarus. Its results can hardly be considered satisfactory: for 100 grants, 43 applications were submitted, of which 19 were satisfied. This means that 81% of the places for free training for foreigners were not in demand. The reason for the failure was the lack of adequate information support.

5.6. This paragraph of the report contains information on the development of a draft conclusion of a standard agreement on the creation of joint programs (“standard resolution on joint faculties (institutes)”). Due to the lack of a document in the public domain, it is difficult to say to what extent it complies with the provisions of the Strategic Plan on the creation of a legal framework for the implementation of joint educational programs and double diploma programs.

The report (as well as the Plan for 2019) does not contain information on the development of mechanisms for recognizing of academic mobility outcomes  and  incorporating  academic

mobility semesters (“mobility windows”) in the new educational standards provided by the Strategic Plan.

7. Fundamental Values

- P. 7.1. of state youth policy development draft strategy until 2030, published on the website of the Ministry of Education on February 14, 2020 (https://edu.gov.by/proekty/proekt-strategii-razvitiya-gosudarstvennoy-molodezhnoy-politiki/), cannot be considered as a contribution to the implementation of fundamental academic values.

The draft does not provide for any state guarantees of academic freedom and institutional autonomy in higher education.

The youth policy strategy is in clear conflict with Belarus’s commitments to ensure inclusive education. Although the authors of the Strategy claim their document follows the principle of non-discrimination and inclusion, in reality this is not so. The Strategy ignores the objectives of ensuring access to education for most vulnerable youth groups. (The exception  people with disabilities and youth serving various types of sentences in correctional institutions).

In essence, the presented strategy in this regard contradicts even national legislation.

In particular, Article 17 of Law No. 65-Z of December 7, 2009. "On the basics of state youth policy." The law provides for additional state support in obtaining education for young citizens from large families, from among the disabled, living in settlements located in rural areas, orphans, children left without parental care, persons from among orphans and children without parental care, as well as youth who have achieved particular success in their studies, culture, art, sports and community service. The strategy focuses only on supporting gifted youth and ignores the tasks of ensuring access to quality education for rural youth, youth from families with low socio-economic status, and other vulnerable groups. Both official statistics and the results of PISA 2018 indicate that the non-inclusion of both higher and secondary education in Belarus is only exacerbated.

The obligation of the Strategic Plan to create   additional measures for organising  public associations is also not ensured. In particular, the section “Public Participation” of the Draft doesn’t provide for a transition from a licensing procedure for registering public associations to a notification one.

Therefore, the Strategy should be brought in line with Belarusian legislation and it should include measures to support vulnerable youth groups, as well as state guarantees of academic freedom and institutional autonomy.

- p.7.4. provides not entirely reliable information on the participation of students as members in commissions for conducting state accreditation of HEIs. The link to the seminar materials does not contain confirmation of such participation. The statement on the inclusion of students in the accreditation commission as members is contrary to the current legislation.

- p.5 of the REGULATIONS on the procedure for conducting state accreditation of educational institutions, other organizations that have been granted the right to carry out educational activities in accordance with the law, and confirming state accreditation, available on the Ministry’s website https://edu.gov.by/sistema-obrazovaniya/ kontrol-kach / polozheniya /

- p.11.1 of METHODICAL RECOMMENDATIONS on conducting state accreditation (confirmation of state accreditation) of educational institutions, other organizations that are granted the right to carry out educational activities in accordance with the legislation (approved on 08.29.2018) (https://edu.gov.by/sistema-obrazovaniya/kontrol-kach/metodicheskie-rekomendatsii/) don’t provide for student participation.

On the contrary, it is stated that when the Department forms the Commission for Accreditation or confirms accreditation, it includes employees of government bodies, educational institutions, organizations that order personnel, depending on the type of educational institution, other organization, number of specialties and the specifics of training.

Judging by what is presented on the website of the Ministry of Education, no changes were made to these regulations.

In order to fulfill the obligations to include students in the accreditation commissions, it is necessary to make the appropriate changes to these regulations.

The context of Bologna reforms implementation

Apart from reformation processes Belarusian Ministry of Education demonstrates complete negligence in relation to the global coronavirus pandemic, refusing to quarantine HEIs and exposing students and their loved ones to danger.

In such conditions, each HEI independently chooses reaction measures. But until recently, many students were not available remote education.

In addition, there was a case of expulsion of a BSA board member which we consider as a clear case of political motivated expulsion. Here is a description of the situation.

As Lisaveta Prakopchyk, former student of Minsk State Linguistik University, says we have long suspected of being excluded. For example, in early February, she have passed a gym class exam, which is a mandatory subject. But the rector canceled it claiming she didn’t fulfill the required number of hours and bribed the teacher. This was the first case of cancellation of credit MSLU and as far as we know in the whole country.

Some teachers told Lisaveta the Dean's office keeps asking about her all the time.

Officially, she was expelled for skipping classes. She have received first disciplinary action this academic year when she was attending ESU Board Meeting in Malta, second in February for gym classes, and third in March when she fought for a University quarantine and called for people to strike.

The facts below allow us to consider the expelling a political one:

#1: the second reprimand she received on the same day when she held a public campaign with the distribution of masks. She and colleagues distributed them to inform students about the strike and check people's readiness for it.

#2: The official rule of 3 disciplinary actions needed for the expelling and are applied selectively. E.g. the head of MSLU Belarusian republican youth union received more than 5 disciplinary actions over the year, as well as does not always pass the exams in one take, but this is never lead to an expulsions.

Lisaveta is going to appeal expulsions to the court and the Ministry of education, but we don't have high hopes. If the court finds the University's decision valid, then Lisaveta will have to pay the University about $ 7,000 for the education