Innovations in higher education regulation and quality assurance in the Arabian Gulf: new directions...

Running Head: HIGHER EDUCATION REGULATION IN THE GCC 1

Innovations in higher education regulation and quality assurance in the Arabian Gulf: new

directions in policy implementation

Darbi Roberts

Teachers College, Columbia University

Master of Arts in Comparative Education – Integrative Project

April 10, 2011

HIGHER EDUCATION REGULATION IN THE GCC 2

Abstract

Significant growth in the higher education sector in the Arab Gulf States over the last two

decades has made higher education regulation and quality assurance a regional priority.

Regulation has become important not only to ensure the quality of the overwhelming number of

imported foreign universities but also to improve the quality of national institutions. Each

country has taken a different approach to regulation. Some have developed a national regulatory

framework based on the government’s strategic goals for economic and social development.

Some have utilized international standards to gain international legitimacy of their higher

education system. Others have relied heavily on regulatory structures of other countries, such as

the US. Each country’s policy decisions regarding regulation are based on a very specific role

that each government intends for regulation and quality assurance to play. This paper explores

regulation and quality assurance in the Arab Gulf States on two levels. First, it provides an

overview of the various regulatory frameworks in higher education existing in the GCC

countries. Second, it examines the origins of these regulatory frameworks with a focus on the

adaptation of foreign models and processes versus the use of innovation in developing new,

locally contextual policy towards higher education. This paper concludes with recommendations

for the development of future policy towards higher education regulation as a process contextual

to local political, economic, and social environments.


Acronyms & Abbreviations

ACE American Council on Education

ADEC Abu Dhabi Accreditation Council (UAE)

ANQAAHE Arab Network for Quality Assurance in Higher Education

AROQA Arab Organization for Quality Assurance in Education

CAA Commission for Academic Accreditation (UAE)

GCC Gulf Cooperation Council

HEAC Higher Education Admissions Centre

HEI Higher Education Institution

IBC International Branch Campus

INQAAHE International Network for Quality Assurance Agencies in Higher Education

KHDA Knowledge and Human Development Authority (UAE)

MOHE Ministry of Higher Education (Oman)

MOHESR Ministry of Higher Education and Scientific Research (UAE)

OAAA Oman Academic Accreditation Authority

OBHE Observatory for Borderless Higher Education

QF Qatar Foundation

QU Qatar University

SEC-HEI Supreme Education Council – Higher Education Institute (Qatar)

SQU Sultan Qaboos University (Oman)

UNESCO United Nations Educational, Scientific, and Cultural Organization

UAE United Arab Emirates

UQAIB University Quality Assurance International Board (UAE)

WTO World Trade Organization


Table of Contents

Page

1. Introduction……......…………………………………………………................. 5

2. Review of the Literature…….…............................................................................. 11

2.1 Higher Education Regulation in the GCC……............................................ 11

2.2 General Theoretical Perspectives on Regulatory Transfer……………....... 18

3. Regulation in the GCC: Overview and Analysis of Policy Origins........................ 23

3.1 Qatar - Reliance on foreign quality assurance............................................. 25

3.2 UAE – National & Emirate Policy Tensions…………………………....... 30

3.3 Oman – International Standards meet Local Needs……………................ 37

4. Conclusions & Recommendations.……………...................................................... 41

5. Appendix 1: Quality Assurance Organizations in the GCC…………………….... 51

6. References…………………………………………………………………............. 52


Introduction

The growth of the higher education sector internationally has caught the attention and the

imagination of researchers, practitioners, and a growing number of journalists over the last two

decades. Few regions in the world have matched the growth of higher education in the Arabian

Gulf, particularly in the last ten years. In this region domestic investment, governmental strategic

planning and investment, and the importation of foreign models has helped grow both the

national universities and the private sector in number and enrollment. The Gulf Cooperation

Council (or GCC)1 has attracted Western institutions, particularly those based in the US, while

simultaneously growing the region’s own indigenous models of higher education. As a result of

this growth in the overall higher education sector, regulation and quality assurance have come to

the forefront as critical issues to tackle in order to harness this rapid growth and use it

strategically towards labor force development and economic sustainability. Each country in the

GCC has approached regulation and quality assurance differently and for different reasons. The

primary focus of this paper is to use a comparative analysis of several GCC countries to

understand some of these differences in higher education regulation from country to country, and

to explain why some of those differences might exist.

National colleges and universities in the GCC, or those run by the government, have

existed in some GCC countries for over half a century and have played an important role in the

growth of the higher education sector. National institutions, sometimes wrongly equated with

public institutions in the US, are those that are administered, financed, and fully regulated by the

government of the country in which they exist. The Ministry of Education or Ministry of Higher

Education typically set the curriculum of these institutions as well. National universities have 1 The Gulf Cooperation Council (GCC) is a political and economic union established in 1981 consisting of six countries in the Arabian Gulf , including Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates. They are also often referred to as the “Gulf States.”


absorbed a large majority of the increase in higher education enrollment as a result of population

growth, increasing numbers of high school graduates, and an increasing demand for

postsecondary education both from the student as well as from the labor market. For example, in

Oman, the total number of students enrolled in postsecondary education doubled in less than ten

years, rising from 10,905 in 1998-1999 to 20,737 in 2006-2007 (Donn & Al Manthri, 2010).

The increase in enrollment has outpaced the increase in secondary school graduates, while the

number of students leaving the county to seek education abroad has actually decreased during

that time, boosting the overall absorption rate from 43% to over 50% during that period. The

UAE has seen similar growth in higher education enrollment. The Higher Colleges of

Technology, a group of vocational institutions in UAE, have reported similar phenomena, with

enrollment rising from 10,000 to nearly 20,000 between 2000 and 2011 (HCT, 2012). While

nation-wide historical enrollment data for most countries is largely incomplete, if available at all,

most institutions across the GCC have reported growth in enrollment figures that further support

this growth trend.

While national institutions have played an important role in the growth of the higher

education sector in the GCC, much of the attention of the media has been on the influx of foreign

universities into the region, or International Branch Campuses (IBCs). An “IBC” refers to an

institution whose origin is from outside of the country in which it operates. The Observatory for

Borderless Higher Education (OBHE) in 2009 reported the operation of 162 IBCs globally,

whereas the OBHE reported 200 IBCs globally in their most recently released report in 2011, a

23% increase (OBHE, 2011). In the OBHE’s 2006 report, the number of IBCs was only 113.

The US is the origin of the largest numbers of IBCs (78), and the UAE plays host to the largest

number of IBCs of any country at 37, with Qatar close behind as the fourth largest importer of


IBCs (OBHE, 2011). Dubai alone has 53 institutions of higher education, only three of which are

public national institutions run by the government and approximately half (25) of the “private”

institutions are IBCs of Western origin (Lane, 2010, p. 2). All but one of Qatar’s universities

are some form of international import, hosting the largest percentage of IBCs relative to the

overall size of the higher education system.

This growth in the higher education sector in the last quarter century has caused

educators, policy makers, and students alike to question the maintenance of quality amid

increasing enrollments, the facilitation of international student mobility, tightening operational

budgets, and flows of educational policy and practice. As the number of higher education

institutions (HEIs) grows internationally and the ease of their mobility increases over time,

countries that export and import HEIs need to be increasingly concerned with the quality and

regulation of these institutions. Along with the growth of the sector has come an increasing need

to regulate institutions in order to assure that quality education is being given to prepare their

graduates for productive roles in the labor force. Accreditation, licensure, and quality assurance

have become ubiquitous in international discourse on the growth of higher education. Quality

assurance can be an important step in guaranteeing the monetary worth of expensive degrees.

Quality assurance can also connote market value, consumer satisfaction, and other terms that

signify the entrance of higher education into a global marketplace as a commodity to be imported

and exported, traded and consumed. Increased control on quality of higher education equates to

potential increases in the value of that education not only to the consumer of that education, i.e.

the student, but the value of a particular type or area of education to specific labor sectors, as an

engineering degree would be valuable to oil extraction, energy, or construction companies.

Consumer satisfaction of the student and the industries in which they are employed are based on


the extent to which a degree prepares that student for their given industry, and whether or not

they enjoy their experience, both of which are aspects of an education that quality assurance may

regulate or control. As each country has begun to develop their own systems of higher education,

many countries have sought out regional networking in hopes of sharing political ideas,

“epistemological and value frameworks,” and even personnel in quality assurance (Findlow,

2005, p. 288). Organizations such as the Arab Network for Quality Assurance in Higher

Education (ANQAHE) and the Arab Organization for Quality Assurance in Education (AROQA)

do not give accreditation nor do they have any set of standards for accreditation or quality

assurance. Rather, they serve as consortia to share best practices. Many countries in the GCC

have used these networks to help develop their own regulatory systems2. However, competition

between Gulf nations to build or attract the biggest, the best, and the most prestigious

universities of their peers has undermined the effectiveness of these networks and thus attitudes

towards regional networks range from support to reluctance (Findlow, 2005).

The host governments under which these IBCs are functioning have taken various

measures to ensure quality, ranging in type of assessment and the degree of control on the part of

the host governments. The practices and procedures of each country in the GCC are diverse.

Even within each country, the policies might vary between regions or types of institutions. Some

governments have chosen to rely heavily on foreign systems of regulation and quality assurance,

especially the U.S. system. Other governments have chosen to develop their own regulatory

systems and policies based on their unique needs, goals, and nuances of their higher education

systems. Questions of the need for international standards of quality have risen as a result of the

vast array of approaches to regulation. Organizations such as the International Network for

Quality Assurance Agencies in Higher Education (INQAAHE) advocate specifically for 2 A complete list of quality assurance organizations in the GCC can be found in Appendix 1.


international standards, emphasizing the need for “the development of regional or international

quality standards as they focus on the role of higher education in the economic development of

individual countries” (Eaton, 2003, p. 12). While evidence points to significant differences in

regulatory policy and approach to quality assurance in the GCC on the national and subnational

levels, research is inconclusive as to the underlying reasons for these differences. Thus, the two

questions this paper specifically addresses are: (1) what are the differences in higher education

regulation that exist between countries in the GCC and (2) why do those differences exist?

Consequently, this paper will utilize a comparative analysis of three countries – Qatar, the UAE,

and Oman – to explore these two questions. This paper uses “regulation” as an overarching term

referring to any policy or procedure requiring any HEI to go through some sort of approval

process, including licensure or accreditation. “Licensure” refers to the approval of an institution

to confer degrees without the judgment of quality, whereas “accreditation” refers to the

subjection of a particular academic program to be judged on the basis of specific standards of

quality. “Quality assurance” refers to any process by which the quality of an HEI is judged,

including but not limited to accreditation.

While this paper does not speak directly to the definitions of internationalization and

globalization in higher education, it acknowledges that the main subject of this paper is very

much a large part of both of these processes. Internationalization and globalization have become

common buzzwords in the higher education sector as phenomena that not only shape trends in

the sector but are also states a university can achieve and toward which they should strive.

Internationalization can mean many things, but in the context of this paper, the working

definition used will be the extent to which a university has made efforts towards obtaining

“international” status both domestically through an increase in international students and


programs on the home campus as well as through partnerships with other institutions and

organizations outside of the home campus. Likewise, globalization will be used to refer to a

general trend within the higher education community and sector involving the movement of

people, ideas, and models from one country to the next. Two specific realizations of both

internationalization and globalization this paper will focus on are the transfer of (1) higher

educational models and individual institutions throughout the globe and (2) regulatory practices

for higher education institutions from certain countries or groups of countries to the Arabian

Gulf. This paper will start with a review of the literature regarding the practices of regulation in

the GCC as well as the general idea of transfer of regulatory systems and standards worldwide.

It will then consider three general trends in GCC regulatory practice – reliance on specific

foreign models, reliance on internationally benchmarked models, and the use of new innovative

models. The paper will then consider the relevance of regulatory policy origins – borrowed,

adapted, or innovated – in understanding and anticipating the effects of domestic implementation

of those policies. Finally, the paper will conclude with recommendations for future regulatory

policy considerations in the GCC and the rest of the world.


Review of Literature

While both domestic and foreign models of HEIs have been developing over the last

several decades in the GCC, the regulatory frameworks intended to keep them accountable have

only recently developed as a result of the hastening rate of expansion. As a result, much of the

structure and policy of regulation is reactive, and research is sparse on the documentation and

measurement of effectiveness of these systems. While this paper will attempt to present the

literature that examines regulation in the GCC directly, it also must utilize the broader literature

that examines the global transfer of regulatory practices.

Higher Education Regulation in the GCC

Examining the regulatory environment in which a university functions, both in the GCC

and most other countries globally, is one of the first key issue in understanding the university –

host government relationship. For both public and private institutions, including IBCs, the host

country is the main authority of law whereas the home country is often a secondary source. For

public governmental institutions, this may not be as big of a problem but for private institutions

such as foreign-origin IBCs, regulatory pressure from both home and host country could create

some interesting dynamics and complications for licensing and accreditation. The American

Council on Education (ACE) in 2007 created a classification system of regulatory frameworks

for IBCs on a scale of liberal to very restrictive in which they placed different countries

according to their requirements for licensing and general functioning. Bahrain was identified as

liberal; Kuwait was identified as moderately liberal; but the UAE was identified as very

restrictive because of governmental control over universities’ permission to operate within the

country’s borders (Green, Eckel, Calderon, & Luu, 2007). This control is highly localized within

each of the seven Emirates as well. Both the national (UAE) as well as each emirate’s


government have crafted extensive policies for regulation of higher education institutions,

although they experience constant change and variation as the number of IBCs grows (Lane &

Kinser, 2011). This often results in tension between the government and the universities,

although it is not evident as to the extent this tension has actually slowed the growth of private

higher education.

Tensions between governments and higher education institutions are particularly evident

in the balance between growth and regulation of the sector. According to Lane (2010), rapid

expansion of higher education in the GCC and the ensuing delay in governmental regulation

create challenges for situating regulation within state priorities and defining authority within the

higher education sector. While only three of the 53 postsecondary institutions in Dubai are part

of the national public higher education system while the rest are IBCs, all are necessary because

they absorb the increased demand for higher learning both from Emiratis as well as from

expatriate families (Lane, 2010). However, major challenges in accountability and regulation are

the result of the exact financial structures under which all of these IBCs have been sanctioned to

function, called “free zones,” which are “an economic development tool designed to exempt

companies from federal regulation” (Lane, 2010, p. 4). As a result of operating in these free

zones, IBCs are outside the jurisdiction of the government and have instead required a different

system of accountability for each free zone. However, these accountability systems only

measure the quality of their education against their “home campuses” instead of general quality

as does Dubai’s Commission for Academic Accreditation (CAA) (Lane, 2010, p. 4). The

government has not previously recognized the degrees from the IBCs in these free zones that are

not accredited by the CAA. Because Emiratis cannot use governmental financial aid at non-

CAA-accredited institutions, Emiratis’ choice of institutions is restricted and the institutions


themselves are limited in the amount of money they receive indirectly from the government

through student tuition (Lane, 2010, p. 5). Further to this issue, Lane (2003) points out that most

“quality assurance mechanisms” are designed for a higher education sector comprised of

indigenous institutions to serve indigenous students, a far cry from the reality in Dubai (Lane,

2010, p. 6). As will be explored later, there is great tension in “defining the limits of national and

local authority” in higher education as the UAE government attempts to align its regulation with

“strategic priorities” of the country (Lane, 2010, p. 1). Those strategic priorities may include

growth of the sector and development of the labor force, but attempts to regulate or assert

authority over international institutions, many of which holding international prestige, may

hamper that growth.

Workforce development has become an important factor in HEI regulation in the GCC.

Nationalization of the workforce, “an affirmative action quota driven employment policy that

ensures [UAE] nationals are given employment opportunities in the private sector,” puts pressure

on educational reform to serves the needs of a growing economy (Godwin, 2006, p. 8). While

significant gaps exist between the current skill set of a majority of Emirati nationals and the skill

set needed to be successful in the work place and continue the nation’s current development

trajectory, higher education is not a “panacea” for these problems (Godwin, 2006). Thus,

regulation to ensure certain levels of quality for those entering the workforce is needed in

addition to the educational opportunities themselves. Accreditation needs to be a part of this

reform process to ensure that universities are adequately preparing students for future success.

Governmental schools, while often more affordable, are only licensed through the Ministry of

Education and graduates from these universities seeking further education abroad are often

forced to repeat their studies. On the other hand, private universities are mostly unaffected by


these problems because they are often already accredited, and often by US accreditors, creating

significant advantages or disadvantages to studying at one type of university or the other.

Godwin (2006) suggests that this actively encourages highly qualified and highly capable

students to choose private universities over public ones, creating elitism and a localized form of

brain drain.

Finance and management of HEIs are another significant factor in regulation policy in the

GCC countries. This is an issue that is particularly important in understanding the broad range

of approaches within the GCC. Even within a given country, one set of institutions may be fully

funded by the government while others may be specifically restricted from receiving any money

at all. Johnstone (1998) offers suggestions on methods for and the responsibility of the process

of accountability through regulation, arguing that the government is responsible for articulating

transparent standards and for establishing the mechanisms to assess and to accredit institutions.

Like many, he believes that both public and private institutions should be held to the same

standards, regardless of funding structures (Johnstone, 1998). Budget reforms can often serve as

a means of ensuring efficient use of public revenues. While many might say that less

governmental involvement results in less regulation, alternatively “autonomy, deregulation, and

privatization are not incompatible with an important continuing quality control and ‘steering’

role of government” (Johnstone, 1998, p. 21). Authority for regulation should remain centralized

with the government, requiring “clarification of what authority and what operation decisions

belong to the institutions of higher education and which belong to the government” so as not to

create conflict between the two (Johnstone, 1998, p. 28).

Rapid growth of the higher education sector plays perhaps the most important role in the

development of national regulatory systems. Altbach and Knight (2007) speak extensively to


issues involved in the rapid development of higher education in the Gulf where private education

is financed by both governmental and foreign investors. They view accreditation not necessarily

as direct control or authority but rather as the main method of quality assurance and evaluation of

foreign institutions. They identify five different issues involved in the accountability process for

universities globally, including the lack of national systems to regulate, register, or evaluate

foreign universities; the process by which regulators would “ensure quality of the courses or

programs” offered by said universities; the role of accreditation in recruiting and creating

university reputation and branding; the lack of mechanisms to identify qualifications attained

through education; and the complications involved in establishing these regulatory systems in the

face of a vast diversity of institutions and their methods of teaching (Altbach & Knight, 2007,

pp. 301-302). Altbach and Knight (2007) emphasize that “quality assurance starts with the

deliverer,” but that accreditation processes involve many inherent cross-cultural challenges both

in working with a foreign partner as well as working in a foreign environment (Altbach &

Knight, 2007, p. 302). However, they give few concrete solutions for how to deal with the

difficulties they identify in their research.

Some scholars, like Van Damme (2001), portend that international higher education has

developed with a disregard to issues of quality, while, at the same time, quality is of central

importance in systems of higher education in their home contexts. There is a general “quality

challenge” in that “internationalization policies and practices face the limits of their development

unless [this challenge] is addressed in all its consequences” (Van Damme, 2001, p. 417). These

limits are being reached because resources are being stretched too thin, thus having the potential

to decrease the quality on a global scale. Van Damme (2001) suggests that aspects of the quality

challenge equation include practices, teaching, recognition of foreign degrees and diplomas,


transfer credits and study abroad transferability. While Van Damme (2001) does not explicitly

focus on issues of regulation, he makes a strong argument for the need of international quality

standards as a primary role of regulation.

US accreditation has often been used as the “international standard,” serving as either a

main provider of quality assurance or a significant influence in the development of local

standards in national regulatory frameworks, something that is evident in the context of countries

in the GCC. Altbach (2003) scrutinizes the specific role that US accreditation plays in the setting

of local standards. Obtaining US accreditation gives a substantial advantage to foreign

universities by increasing the relative value of a degree from that accredited university, causing

increases in student demand as well as higher standards for non-accredited institutions.

Requirements of programs, facilities, and policies needed for US accreditation may create

pressure upon foreign universities to “Americanize,” conforming to specific patterns of

educational organization (Altbach, 2003). This kind of external pressure for quality control

could constrain innovation in the development of higher education systems for fear of using new

models with little attractiveness. As public and governmental institutions seek out US

accreditation, their non-US-accredited competitors may be seen as less valuable or having worse

prospects for continued education in the US, causing students to choose their institutions on the

basis of accreditation alone.

Instead of US accreditation being sought as the highest international standard, sometimes

its use in regulatory policy in other countries can result from a general lack of understanding of

the accreditation process and the desire for marketing and branding (Brittingham, 2003).

Appropriate applications of US accreditation could include the use of US standards where the

institution identifies itself as being “American-style,” serving in a “consumer protection role” to


ensure that those students seeking an American-style education are actually receiving just that

(Brittingham, 2003, p. 14). Indeed, US accreditors have contributed positively by hosting foreign

visitors who desire to learn more about accreditation processes, serving on international

accreditation boards, making on-site visits to other countries, and helping others develop their

own accreditation systems (Brittingham, 2003). Though beyond the scope of this paper, it is

imperative to understand the limits of US accreditation by asking key questions such as “what is

American about American higher education” and whether or not US accreditors even have the

capacity to accredit in other countries due to a lack of knowledge of local language, regulations,

and culture (Brittingham, 2003).

While many universities – including both US-based institutions as well as those modeled

after an American curriculum – such as in the American Universities of Beirut, Sharjah, Cairo,

and Kuwait – may seek US accreditation outside of what is required of them, they are also held

to rigorous local governmental standards (Ghabra & Arnold, 2007). The question is not about

the need for regulation but rather whose standards should be used to assure quality and what

purpose regulation is serving overall. Ghabra and Arnold (2007) argue for Arab and/or regional

accreditation bodies that “can monitor and ensure the quality of institutions that claim to be

based on the American model” (p. 17). Seeking US accreditation should be less about ensuring a

quality reputation but could instead serve as a means of educating students and parents about the

differences between types of universities and ensuring that what those parents and students pay

for is in fact what they desire out of an educational experience.

In addition to US, British, Australian, and other Western accrediting bodies and agencies,

development organizations have also been involved in HEI regulation through accreditation.

UNESCO offered assistance through their Global Forum on Quality Assurance, Accreditation,


and the Recognition of Qualifications in Higher Education in 2002, particularly in the context of

international trade. While the World Trade Organization (WTO) has decreased restrictions on the

exchange higher education services, others, like UNESCO, have “raised serious concerns about

the danger of treating higher education and quality assurance as items of trade like other services

such as insurance, computers, or banks” (Eaton, 2003b, p. 14). Whether or not one believes it is

appropriate to treat higher education as an item to be traded, negotiations will still accelerate the

international debate over higher education regulation. Multiple views on accreditation and

regulation have emerged from this UNESCO conference. Some leaders in accreditation prefer

international standards which build common understanding and agreement about quality, while

others prefer national quality review procedures “because judgments and expectations of

education and quality are inseparable from the cultural and social contexts in which they

develop,” and still others prefer regional approaches in areas for whom the countries share some

of these contextual characteristics (Eaton, 2003b, p. 15). There is likely ample space for a range

of mechanisms and levels of standards to address these concerns over quality assurance through

regulation.

General Theoretical Perspectives on Regulatory Transfer

There are many plausible explanations and theoretical perspectives for why the

governments of GCC countries have chosen to pursue regulation differently. Much of the

difference can be traced back to the ultimate purpose a government has for the higher education

system in broader context of national development. As a result, several different interpretations

can be made. This paper will discuss some of the specific differences in section 3 and some of

the interpretations of those differences in section 4. This paper will use borrowing and lending

theory as the primary framework through which to view the transfer of higher education


regulation policies and practices to the GCC. Before applying this framework to the particular

case studies at hand, first the general theory will be discussed.

Higher education regulation policy is highly political, used as a means of control, as

borrowing and lending theory often interprets the phenomenon. This theory examines the

politics behind importing and exporting certain educational practices (Steiner-Khamsi & Quist,

2000). Comparativists in the educational transfer theory camp, or academics who use

comparison as the main mode of analysis, “are mainly interested in studying the international

convergence of education systems” using “studies on education transfer to explain why

educational systems in various parts of the world are becoming increasingly similar” (Steiner-

Khamsi & Quist, 2000, p. 275). One of the main reasons borrowing and lending theory is a

particularly good lens through which to view higher education regulation in the GCC is that it

looks more closely at how “local agents and stakeholders of educational reform encounter global

forces” (Steiner-Khamsi & Quist, 2000, p. 275). In particular, the three main elements which are

used to understand a particular instance of education transfer are the politics (or the “why”), the

process (or the “how”), and the agents (or the “who”) of the transfer itself. Agents include both

borrowers and lenders of education policy because they both “form part of [the] analyses which

seek to explore the processes which lead to universalizing tendencies in educational reform”

(Halpin & Troyna, 1995, p. 307). Educational policy often goes through a process of

“decontextualization” or “deterritorialization” in order to be adapted to the new environment in

which it is being used, challenging the “past conception of education as a culturally bounded

system” (Steiner-Khamsi, 2004, p. 5). Understanding policy transfer is not just about the

dominance of one country’s policy as being lent to another but is also encompassing of the

desires, goals, and local context of the borrowing country themselves. Thus, borrowing and


lending theory is a useful lens for understanding motivations behind the use of specific

regulation policies and practices. This theory focuses more on the political and economic

context of borrowing and lending policies, as well as the organizational culture of a particular

government as it influences the decision to import policies and practice. Because of this focus on

context, it serves as a better instrument for exploring nuances between and within countries that

share many political and economic similarities such as those in the GCC and yet may not always

adopt the same regulatory policies or implement those policies in the same way.

Policy borrowing and lending theory suggests that there are four stages of policy

borrowing in education: cross-national attraction, decision, implementation, and internalization

or indigenization (Phillips, 2004). This paper will focus mostly on the first stage in

understanding the relevance of policy origin in a country’s policy borrowing practices.

Generally, borrowing is dictated by a policy or practices “externalizing potential” in that those

policies borrowed from a foreign system are “borrowable” because their “’internalizing’

potential” depends on the “contextual receptability of the ‘borrower’ country” (Phillips, 2004, p.

57). The policy being borrowed is positioned within a number of contextual circumstances and

issues that impact the attraction of the borrowed policy as well as the implementation of the

policy and must be considered when analyzing the appropriateness borrowing that particular

policy. This is related but slightly different from the concept of “externalization,” which will be

considered in Section 4, in which an “imaginary international community” or a “concrete other…

is evoked as a source of external authority for implementing reforms that otherwise would have

been resisted” (Steiner-Khamsi, 2004, p. 203). Both play an important role, however, in the

regulatory policy borrowing in the GCC.


The first phase, cross-national attraction, involves the consideration of the conditions for

borrowing within a country, the impulses for borrowing, and the extrernalizing potential of a

policy as briefly described above. Conditions can include circumstances in a country that leads

the government or a ministry to look at practices in other countries that can be borrowed, the

contexts in the lending country that led to the creation of those policies the borrower is attracted

to, the “compatibility of the contexts” in the borrowing and lending countries, and the way in

which borrowed policy can be internalized (Phillips, 2004, p. 57). Impulses are simply the

stimuli or catalysts that create cross-national attraction and eventually lead to borrowing of

policies. These can include political change, collapse (i.e. the inadequacy of a current situation),

internal dissatisfaction by the users of the system, negative external evaluation usually through

studies by research institutes, new alliances or configurations either planned by political actors or

unplanned by such things as “globalizing forces,” innovation of knowledge or skills, or extreme

upheaval such as in war or disaster (Phillips, 2004, p. 54). Externalizing potential of a policy or

practice can be related to a guiding philosophy, ambitions or goals of a the agents of transfer,

strategies, enabling structures, processes, and techniques. This paper will utilize many of these

conditions, impulses, and externalizing potentials in understanding policy transfer in the GCC.

Decisions in the second stage are characterized in 4 different way. Theoretical borrowing

happens when ideas are taken from other countries that serve as guiding principles for change.

Borrowing that is phony happens when “political expediency results in lip-service being paid to

the attractiveness of features of education elsewhere, with little will [or time] for implementation

to be feasible” (Phillips, 2004, p. 58). Realistic or practical borrowing consists of implementing

policy that has been judged and predicted to be feasible and appealing for one or many reasons.

Finally, a quick fix decision to borrow happens when that policy or practice provides a quick way


to “satisfy internal criticism” but is in fact not necessarily appropriate contextually to adopt

(Phillips, 2004, p. 58). Most circumstances of regulatory policy borrowing in the GCC tend to

fall in the theoretical or realistic categories of decision making.

Implementation, the third stage, involves the adaptation of a borrowed policy, an

assessment of the suitability of contexts in both the borrower and the lender, the rate or speed of

change created by a policy being borrowed, and the actors or agents of transfer. Agents of

transfer, can exist in many different positions within the organizational, administrative, or

institutional structure of the borrowing process. They can be institutions themselves, but are

more often referred to as individuals who “have the power or opportunity to… either facilitate or

block new initiatives, using a variety of tactics such as inaction, delay, or what has been termed

‘non-decision’” (Phillips, 2004, p. 58-59). Implementation is another stage that this paper will

focus on because the adaptation, contexts, and actors are central to understanding the importance

of the origin on regulatory policies being borrowed in the GCC.

Finally, internalization or indigenization is the “process by which a new policy becomes

part of the borrower system” (Phillips, 2004, p. 59). What emerges is a new “synthesis” of

borrowed practice with new contextual circumstances under or to which the policy has been

adapted. The new “synthesis” sometimes presents its own set of deficiencies which do not

address the needs of a given country, thus creating a new set of stimuli for cross-national

attraction from other lending countries and beginning the cycle of policy borrowing over again.

This paper will return to this cycle of policy borrowing in Section 4. The components of

each stage will be discussed in the context of 3 different case studies to better understand the

importance of the borrowed regulation policy origins in the policy borrowing process. The next


section will first discuss the higher education system and current regulation policy of three

different countries in the GCC as the environmental context for policy borrowing.

Regulation in the GCC: Overview & Relevance of Policy Origins

Much of the literature and even more of the press coverage on higher education in the

GCC has tended to speak more to the similarities than differences in the sector. Little attention is

paid to understanding the differences and nuances which exist between each country’s approach

to the development of their higher education systems, contributing to the common misconception

that countries in the GCC can be studied as one collective group of higher education systems.

While many similarities exist in institutional type, student populations, and the challenges each

country faces in the development of their higher education system, the next section of this paper

explores some of the differences in GCC higher education systems and the regulatory policy

each country’s government employs for the sector.

The two main questions this paper examines are (1) what are the differences in higher

education regulation policy among countries in the GCC and (2) why do those differences exist.

This section will address the first question through a summary of the local regulatory

environment and the second question using the framework set out in the literature review. The

broad perspective of that framework, borrowing and lending theory, looks at the process of

taking policy from one context and using it in another by assessing the politics (why), the

process (how), the agents (who) of any given policy transference (Steiner-Khamsi, 2004). As

described previously, the policy borrowing and lending process (the how) happens in four stages

which incorporate the politics and the agents of the transfer beginning with cross-national

attraction, moving into a decision on which policy to use, resulting in the implementation of said

decision, and being finalized with internalization and indigenization of this newly implemented


decision. Cross-national attraction has two major components: impulses or stimuli that serve as

catalysts for change, like political change, collapse, dissatisfaction or negative evaluation; and

the externalizing potential of the policy being borrowed from the lending country, or aspects of

the policy that seem “borrowable” according to the “contextual receptability” of the borrowing

country (Phillip, 2004, p. 57). In the second stage, a decision can be theoretical, phony, realistic

or practical, or simply a quick fix. Implementation, the third stage, involves adaptation of the

policy, its suitability of context, the speed of change, and any significant actors in the policy

implementation process. Finally, in the internalization or indigenization stage, the borrowed

policy becomes a part of the borrowing country’s system through synthesis and evaluation.

Section three examines three countries according to the “why,” the “how,” and the “who”

of the borrowing and lending framework, focusing on the four stage process as it has played out

in each scenario. In particular, this section examines the origin of the implemented policies, or

the policy lender, as a primary source and explanation of difference between each country’s

newly developed approach to higher education regulation. The specific countries this paper

considers are Qatar, the UAE, and Oman. These three GCC countries share many characteristics

of their higher education systems including strategic privatization and use of foreign models and

institutions. However, each country has a different approach to regulation: Oman has a

centralized system utilizing policies that promote labor market preparation and economic

development; the UAE has a multi-layered system of national and emirate regulatory agencies

which exhibit varying levels of centralization and are heavily influenced by international

standards; and Qatar has a very decentralized system which relies almost exclusively on foreign

accreditation processes. The intention in using these three case studies is to exemplify their

differences in approach and try to understand those difference according to their cultural,


political, economic, and educational context. While using all three case studies illustrates the

great diversity in approach among Gulf State governments, an analysis of each also yields

different recommendations for the future or other countries. What can be learned from Oman’s

approach is different from what can be learned from Qatar or the UAE. These recommendations

will be discussed in the final section of this paper. In all three cases, the regulation policy being

examined specifically relates to quality assurance through licensure, accreditation, and auditing.

At its most basic level, educational quality is about optimizing a university’s resources in

order for students to obtain a degree in the “expected manner, effort, and time” (Al-Atiqi &

Alharbi, 2009, p. 6). Educational quality then involves various controls including “academic

standards, programme of study specifics, means of delivery, and above all, prediction or

attribution of educational outcome” (Al-Atiqi & Alharbi, 2009, p. 6). Quality assurance can

contribute towards sustainable development of an institution by adding value, determining an

institutions’ fit for its intended purpose, and transforming the institution into something that

meets the needs of society and drives innovation and change. Each country in the GCC holds

these lofty aims for its regulatory policies in higher education. However, they each go about it in

different ways as a result of many different factors that will be explored next. Specifically, why

did Qatar, the UAE, and Oman decide to borrow the policies they did, and why did they decide

to adapt those policies in such a manner? What did those decisions have to do with the origin, or

lender, of the policy, the agents of that transfer, what were the politics involved in that transfer,

and how was the actual policy adapted in the end to serve local needs?

Qatar - Reliance on foreign quality assurance

Qatar’s primary governing body for education is the Supreme Education Council, within

which sits the Higher Education Institute (SEC-HEI). The SEC-HEI administers four main


offices including and the Institutional Standards Office which “prepares the policies and the

criteria related to the quality of higher education […] prepares and updates the HEI list of

scholarship institutions… [and] licenses and accredits programs of higher education institutions

working in the state of Qatar” (SEC-HEI, 2012). However, there is no evidence of established

processes or guidelines for regulation on the website or in the limited literature on regulation in

Qatar or the GCC. Instead, it is evident from university websites and reports that responsibility

for quality assurance and regulation largely falls under the responsibility of the university itself

or the foundation under which the university is patronized, as in the case of the Education City

universities. This is indicative of significant decentralization in the higher education regulation.

Qatar University is the oldest university, established in 1973, and is also one of only two

“national” institutions, the rest being private and internationally imported. Lacking direct

government regulation, it has developed a system of internal quality assurance and assessment in

place of external regulations and standards imposed and enforced by a government agency. In

the late 1990s and early 2000s, Qatar University went through a process of reform that included

the implementation of accountability (Lezberg, 2003). Various university leaders worked with

accreditors from the US and UK to formulate a set of standards by which the university would be

evaluated, using the standards of the New England Association of Schools and Colleges as a base

upon which to build (Lezberg, 2003). The University Evaluation Committee was then formed to

consider pressing issues in evaluation such as credibility, greater use of non-administrative

faculty in evaluation, student-centered learning, and the imminent influx of reputable US

universities into Qatar Foundations’ Education City initiative as competitors for students and

legitimacy (Lezberg, 2003; Al Attiyah & Khalifa, 2009). These newly developed standards were

used in an accreditation process to remedy areas of “deficiencies” which the committee


undertook in an “American style” by looking at strengths and weaknesses of the university on

both an administrative and faculty level. The Quality Assurance Agency of the UK was then

approached to provide an outside assessment of the extent to which Qatar University was now

meeting its own standards (Lezberg, 2003). While Qatar University still developed its own set of

standards for internal quality assurance, it did so heavily dependent on the American model of

accreditation.

The other 14 “non-national” institutions of higher education are private institutions of

foreign origin, the concentration of which are in Qatar Foundation’s Education City. Qatar

Foundation is a governmental organization headed by the wife of the Emir of the State of Qatar,

whose purpose is to develop education, science and technology, and the community in general

through a broad array of projects throughout Qatar, including Education City as the flagship

program (QF, 2012). Within Education City, six universities are of US origin, one of British

origin, and one of French origin, while others outside of Education City are from these countries

as well as Canada and the Netherlands. Qatar Foundation brought these institutions to Qatar

under the condition that the degree offered in Qatar would be the same as that conferred in the

US and that each institution would obtain the same accreditation as its home campus. In addition,

each IBC is required by its home campus to undergo the same process of accreditation as the

home campus. In most cases, the Qatar branch is considered a “satellite campus,” “additional

instructional location,” or other similar status by the US accrediting agency of the home campus,

and is thus often included in the home accreditation process. These branch campuses are

accredited by the same standards as the home campus meaning that Qatar’s regulatory policy, at

least within the IBCs at Qatar Foundation, is dependent primarily upon the US accreditation

system. Qatar Aeronautical College is the only other national institution, which confers pilot and


aircraft maintenance licenses as well as bachelor’s degrees in engineering and aeronautical

sciences (QAC, 2012). Very limited information is available on the licensure and accreditation of

Qatar Aeronautical College outside of its own website.

Qatar’s Supreme Education Council acts as the Ministry of Higher Education and has an

Institutional Standards Office whose responsibility it is to “ensure quality” by granting licenses

and accrediting higher education institutions operating in Qatar. However, only news articles

from the SEC website indicate that such standards exist, having been disseminated in the form of

a booklet as early as November of 2008 (SEC-HEI, 2012; SEC-HEI, 2008). These guidelines

address the type of facilities, academic and administrative infrastructure, and other requirements

“based on domestic and international standards for licensing and certification” (SEC-HEI 2012).

No documentation can be found regarding the exact nature of these policies, perhaps due to the

disorganized nature of the SEC-HEI or the non-existence of the policies themselves. The private

IBCs, on the other hand, are not regulated by specific QF policy but instead are held responsible

to obtain the accreditation standards of their home campuses, an expectation by both the home

campus and QF. In addition, Qatar University went through an in-depth reform process in the

early 2000’s that involved the advisement of a regional US accreditor as well (Moini, Bikson,

Neu, & DeSisto, 2009). In both of these cases US accreditors are the primary lenders of higher

education regulation policy.

There are multiple potential explanations for why Qatar chose to use US regulation

policies. In the case of Qatar Foundation’s Education City, it seems contextually appropriate to

use the accreditation system of the home campuses of the IBCs it was importing to best regulate

quality of those programs. The US branch campuses were established under a contract that

required them to provide the same education experience as the home campus (Al-Misnad, 2009).


Thus, using US quality assurance standards seemed appropriate and much easier than

implementing a set of standards that wasn’t even well established at the time. This likely

pressured Qatar University to conform to a Western style of education as high school graduates

now had multiple options that were perceived to be of higher quality as a result of their Western

brand. One way to address this shift in demand from students was to conform to similar

standards in order to compete for enrollment. Because of the Education City project, and a

number of other initiatives on the part of the Qatari government not the least being military,

Qatar was developing a stronger alliance with the US and solidified this in the higher education

by focusing on the US model of education through importation of programs and quality

standards. In addition, the Qatari government and particularly Qatar Foundation envisioned

innovation through technology and skills development and saw higher education as a primary

method for achieving this (Qatar Foundation, 2011). Thus, the externalizing potential of US

accreditation policy was great.

The decision to focus on US standards can be viewed as realistic, theoretical, or a quick

fix scenario. The decision was realistic as described by borrowing and lending theory in the case

of Qatar University because the institution spent several years assessing the different types of

quality assurance through reflecting on national needs for quality assurance and doing pilot

studies within a steering committee (Al Attiyah & Khalifa, 2009). Qatar University’s decision to

adapt US standards was also theoretical because they used those standards as a guiding principle

in their overall quality assurance framework, not just as a directly borrowed set of policies. Qatar

Foundation’s decision to use US accreditation was meditated and planned in that they very

carefully chose which universities to invite to Education City and very carefully drew contracts

and negotiations with those institutions regarding their operation, but the decision to use US


accreditation to monitor them was perhaps an easy way to deal with the demand for an

accreditation and licensing system in Qatar that was not yet fully formed. Little support or

expertise from Qatar was needed to implement these standards as the universities would be

responsible to the accrediting organizing and home institution alone.

Qatar University went through a relatively arduous process of adapting the borrowed US

policy to its particular context, whereas Qatar Foundation did not. In partnership with the New

England Association of Schools and Colleges, QU was intentionally using US accreditation

standards to Americanize their curriculum to bring it up to par with the influx of new educational

opportunities (Lezberg, 2003). At the same time, it still kept very fundamental characteristics of

its own educational practices, including gender segregation in most classes. The school is still

struggling with the internalization process, as evidenced in the recent decision to revert some

classes back to instruction in Arabic. One of the primary outcomes of the reform process at QU

was to teach all subjects in English. Due to poor performance of students and high dropout rates,

they have changed this requirement for some subjects, indicating some conflicts in the adaptation

of US standards – like teaching in English – to the local context (Lindsey, 2012). Even the Qatar

Foundation struggles to “indigenize” the American model, as evidenced by the some negative

opinions about the presence of US universities in Education City. While public perception is

high among certain populations of Qataris, many groups are not as accepting or approving of the

“westernizing” effect of US institutions. In addition, the speed of change in higher education in

Qatar has been rapid, as it has been for most GCC countries, which has stressed the country’s

ability to appropriately adapt their imported education to local context.

UAE – National & Emirate Policy Tensions


The UAE has taken a diverse approach to higher education regulation. Accreditation and

licensure are controlled by a national agency, but some emirates have their own regulatory

agencies whose regulations sometimes usurp the authority of national policy in different ways.

The national government administers countrywide policy and runs the national universities. Each

emirate runs its own institutions with its own policies for regulation in addition to the national

regulations. Three national universities in the UAE serve the majority of students: UAE

University, the Higher Colleges of Technology, and Zayed University. Combined with an

additional 30 or more emirate institutions, publically funded universities serve approximately

40% of the national student population, while the private sector serves the rest of the student

population (Findlow, 2005). While Abu Dhabi and Dubai host the majority of higher education

institutions in the UAE, the difference in policies on the national and emirate level create tension

in “defining the limits of national and local authority” as the emirate governments attempts to

align their regulations with “strategic priorities” of the national government (Lane, 2010, p. 1).

The UAE’s regulatory framework is more established and centralized than Qatar. The

Commission for Academic Accreditation (CAA) within the Ministry of Higher Education and

Scientific Research (MOHESR) is the national regulatory agency in the UAE. It is directly

responsible for licensing (approving degree conferral) and accrediting (ensuring that programs

meet a minimum set of standards) all HEIs in the UAE (Lane, 2010). The CAA accredits an

institution only after it has been licensed by meeting 10 criteria outlined by the CAA (CAA,

2011). As of 2011, the CAA licensed 73 institutions and accredited 513 programs, although not

all institutions in the UAE are licensed or accredited by the CAA (Mahani & Molki, 2011).

While national law requires CAA licensure for all public and private institutions, universities

within “free zones” in Dubai are exempt. Because the emirate governments are the primary


importers of foreign universities, tensions and discord exist between national and emirate

strategies for developing higher education. The national government chose to develop its own

institutions whereas some emirates chose to rely on foreign institutions.

Some emirates have their own agency or organization to regulate HEIs. The Abu Dhabi

Education Council (ADEC) provides approval to institutions before they can seek CAA licensure

and accreditation (ADEC, 2011). The CAA even requires written approval by ADEC before

considering an HEI’s application for licensure. ADEC’s policy requires their approval before

commencing operations, even for institutions that have already obtained CAA approval in other

emirates (ADEC, 2009, p. 2). However, the three national institutions are exempt by national

policy from ADEC approval, signaling precedence of some national over emirate policy. ADEC

restricts importing institutions by requiring partnerships with “existing reputable institutions”

and financial support by the local partner (ADEC, 2009, p. 6). To date, ADEC has approved 19

institutions, including emirate and non-emirate public and private institutions, branches of

national institutions, and private IBCs (ADEC, 2012).

Dubai’s regulatory system is less centralized than Abu Dhabi. Because Dubai’s private

HEIs do not fall under CAA authority, the Knowledge and Human Development Authority

(KHDA) was established in 2006 to regulate and license these private institutions (Rawazik &

Carroll, 2009). Institutions in Dubai’s “free zones” are exempt from both emirate and national

regulation, although some but not all are regulated by their home campuses. In response, the

KHDA established the University Quality Assurance International Board (UQAIB) in 2008 to

ensure the quality of these exempted institutions. The UQAIB has no minimum set of standards,

but instead requires “equivalency validation” which holds the IBC to the same quality of its

home campus (Rawazik & Carroll, 2009). There is no guarantee of an minimum level of quality,


and because most foreign institutions operate within free zones, there is a large variance in the

quality of education offered by private IBCs (Lane, 2010). In response, the MOHESR did not

recognize degrees from unlicensed HEIs and refused financial aid to students who chose to enroll

in them, encouraging many IBCs to independently seek CAA licensure and accreditation (Lane,

2010). However, the CAA and MOHESR have recently lifted this ban (Swan, 2012).

In sum, UAE national and emirate governments take different approaches to the

regulation of higher education. National quality assurance mimics other international

frameworks by requiring both institutional licensure and program accreditation to ensure the

quality of subject areas. Abu Dhabi emirate regulation coincides with national regulation while

Dubai’s emirate regulation lacks basic standards of quality in favor of facilitating the importation

of foreign models. The CAA and ADEC have developed their own standards of quality that are

influenced significantly by international benchmarks. Dubai, hosting the largest number of

institutions, is heavily reliant on home country accreditation for IBCs.

The UAE has imported institutions and policies not because of “synchrony between the

characteristics of the different education systems” involved in the borrowing and lending

process, but because it imports institutions and policies that carry ideologies associated with

Western education (Halpin & Troyna, 1995, p. 304). The CAA and ADEC have prioritized the

standards set by the International Network for Quality Assurance Agencies in Higher Education

(INQAAHE) in their Guidelines of Good Practice, using them to uphold a minimum level of

quality for “some commonality among all institutions in the country” (Lane, 2010, p. 6).

However, Dubai has opted to forego a minimum set of standards for institutions in the economic

“free zones,” which are all private and typically international institutions. Of the 53 HEIs in

Dubai, only three are public whereas the other fifty institutions are mostly of Western origin,


bringing with them a “strong international reputation” that suggests “a certain level of quality

within the broader education sector” (Lane, 2010, p. 2). Functioning within “free zones” exempts

those institutions from governmental regulation and thus Dubai’s KHDA and UQAIB

established regulations that only assess the degree to which an institution upholds the same

quality of its home campus (Lane, 2010). These equivalency standards seek to “provide

consumer protection to its citizens through a policy that makes judgments about the quality of

the programs” against their home institution (Fox, 2007, p. 11). Foreign HEIs were imported

because “they are valued in their original form” and so the UQAIB’s equivalency validation

process is meant to maintain the value of the foreign model for fear that subjecting them to local

regulation would somehow deteriorate that value (Rawazik & Carroll, 2009, p. 81).

Some institutions, both public and private, are seeking US accreditation on their own,

apart from what the government requires, led by The American University of Sharjah and Zayed

University. Obtaining accreditation from US or other Western quality assurance agencies

affiliates that institution with the perceived prestige and high quality of western education.

Affiliation with foreign quality assurance also provides a way to “establish high quality

educational provision in as short a time as possible, thereby supplying demand without having to

go through a lengthy evolution process” (Findlow, 2009, p. 293).

The development of the labor sector and the preparation of workers with skills and

education to adequately participate in rapidly growing industries have been major impulses for

national regulation reform. The MOHESR emphasizes quality assurance in order to “secure the

credibility and value of higher education” to the student as consumer and employers of those

consumers to ensure that the regulatory systems are addressing the “explicit priorities” of the

country (Jackson, 2009, p. 86). Because national HEI quality is equated with national self-


sufficiency, use of “internationally accepted standards of quality” will ensure that the higher

education system is serving the society well (Fox, 2007, p. 8). Regulations based on international

standards gain legitimacy for the strength of the higher education system within the UAE,

increasing the confidence of the labor market and private sector as well as reducing brain drain.

Governments receiving foreign HEIs need to be “clear about the objectives and expected

benefits” of importing HEIs such that “registration, quality assurance and accreditation processes

are in place to ensure high-quality provision that will contribute to national policy objectives”

(Knight, 2007, p. 145). The CAA and ADEC can use regulation to ensure that imported HEIs

will contribute to broader national economic development goals. Dubai’s free zones threaten that

control, challenging the current system to adequately and accurately screen institutions exempted

from government regulation (Fox, 2007). Thus, the UQAIB is critical to provide consumer

protection through equivalency validation as an alternative to more stringent regulation.

Building the reputation of the higher education system as a competitor in the global

higher education market is another impulse for the CAA’s use of international standards. Using

international standards provides a “basis for benchmarking standards against international

provision and confirm the status of institutions and higher education programmes” and fulfilling

the “general expectation that higher education in the Gulf States can compete in a global context

with other providers” in an effort to “promote ‘world class’ universities with a high reputation”

(Jackson, 2009, p. 86). By implementing and meeting certain internationally accepted standards

of quality in higher education, the UAE places itself in the company of other countries who have

internationally reputable programs of higher education, a major aim of many GCC countries.

The CAA’s and ADEC’s decision to use international standards has been primarily

theoretical. Because these sets of international standards are merely suggestions for good


practices in higher education, they can only be theoretically used as guiding principles as

opposed to being a set of borrowed policies from one lender to another. Even though the

UQAIB’s has no specific set of regulatory standards, preferring to impose those of the home

country, it by default enforces a range of standards from various international providers in

requiring each institution to be of the same quality as its home institution. While one can view

this as a theoretical-style decision on the part of the borrower, in reality it began as a quick fix.

Because of the influx of institutions into unregulated free zones, the government needed to put

policy into place quickly to address some of the free zones’ reputations as hosting lower quality

institutions that did not serve the public good. So many institutions were being established at

once that the UQAIB was established as a reactionary measure, even though there may be

disagreement about the appropriateness or rigor of the regulation it enforces.

While the CAA, ADEC, and UQAIB have all implemented international standards in

some form or another, the process of implementation has manifested differently. ADEC and the

CAA incorporated the INQAAHE’s Guidelines of Good Practice into national and emirate

regulation policy, using development goals as political context for the new policy (CAA, 2011;

Rawazik & Carroll, 2009). The UQAIB’s policy simply upheld the quality of the home campus.

This could be viewed as making no effort to adapt borrowed policy from abroad. However, the

UQAIB’s contextual environment of free zone economic sanctions required minimizing

governmental intervention and regulation, and thus bypassing domestic policy with foreign

policy was the most appropriate way to provide for quality assurance in this particular case. In all

cases, the speed of change in higher education was immense, putting pressure on the need for

quality assurance. The use of international standards is justifiable given the IBCs’ roles as major

actors in the process of quality assurance. The government had set out a trajectory of


development to become a regional hub for higher education, and thus using international

standards to judge quality ensured that the new higher education system would be the most

internationally attractive (Donn & Al Manthri, 2010).

Oman – International Standards meet Local Needs

Similar to other Gulf States, Oman’s higher education system utilizes both public and

private institutions. Oman’s HEIs fall under the administrative policy of the Council of Higher

Education (CHE), made of heads of various ministries within the national government. Among

the responsibilities of the CHE are creating policies for the Higher Education sector, regulating

admissions to HEIs, coordination between HEIs, studying trends and issues within higher

education in Oman and devising solutions to address them, and preparing annual reports

regarding performance of HEIs (Wilkinson & Al Hajry, 2007).

The administration and governance of universities and colleges is delegated among

various ministries within the government. Each of the 32 national public institutions is regulated

by the ministry of the industry for which the institution is meant to prepare its graduates. For

example the Ministry of Health governs all Institutes of Health, and the Ministry of Manpower

governs all Technical Colleges. Sultan Qaboos University is the only institution independent of a

specific ministry and is instead administered by the separate University Council. The Ministry of

Higher Education (MOHE) regulates all 28 private HEIs and the Colleges of Applied Sciences.

Because demand for higher education has outpaced the growth in public institutional capacity,

the government uses privatization as a specific strategy for developing the higher education

sector (Donn & Al Manthri, 2010). Private HEIs do not receive direct governmental funds but

instead receive other types of support through tax exemption, land grants, and other subsidies in

the form of tuition scholarships as a part of a privatization scheme (Al Shmeli, 2009). In


addition, all private higher education institutions are required by Oman’s accreditation agency to

have an academic affiliation with another international university (Oman MOHE, 2012). These

international partner institutions typically lend curriculum and quality assurance, along with

personnel in some cases, and originate from the US, Jordan, UK, India, Germany, France,

Lebanon, the Netherlands, Austria, and Australia. Nearly half of these private HEIs, 12 of 27,

were established between 2001 and 2004 while the most recent was established in 2009.

The growth in private higher education created a need to regulate the influx of

international institutions. The MOHE established the Oman Academic Accreditation Authority

(OAAA) in 1999 for this purpose specifically (Al-Atiqi & Alharbi, 2009). The OAAA and the

MOHE drafted a strategic plan for higher education reform in 2000, including the “licensing and

accreditation system; standards-based accreditation; and accreditation and recognition systems

for degree programs,” resulting in a more centrally administered licensure and accreditation

process for both public and private institutions (Al-Atiqi & Alharbi, 2009, p. 8). All public

universities must first be licensed by the MOHE, after which an institution can be quality audited

and accredited every two to three years. Licensing in Oman is simply the “formal approval to

operate as a higher education provider” which is based on assessment of a set of standards and

requirements for governance (Al-Atiqi & Alharbi, 2009, p. 8). In accreditation, the second phase

of regulation, the OAAA verifies that a “locally developed or adopted” institution has a basic set

of “capabilities, capacity and competencies” for quality education (Al-Atiqi & Alharbi, 2009, p.

8). The OAAA’s accreditation standards are based primarily on international standards of good

practice (MOHE, 2005; Al-Atiqi & Alharbi, 2009). Private schools in partnership with a hosted

international institution are subjected to a different process. They must be accredited by an

international agency before they can undergo “recognition” by the OAAA to conduct business as


an educational institution. Oman is the only case of these three examples that exercises a

cohesive national policy of direct governmental regulation upon all types of institutions. Because

of the nature of regulatory policy, all types of institutions are subjected to a set of international

standards, whether directly or indirectly. However, some authors point to the lack of knowledge

and expertise among authorities in the OAAA to implement and carry out these standards of

quality and practices of quality assurance (Al Lamki, 2006). Some authors have even suggested

the need for intervention and service by international agencies in providing accreditation services

until greater expertise can be developed on the local level (Al Lamki, 2006).

Oman’s higher education sector has had a relatively unique trajectory of growth in

comparison to its rich GCC neighbors. Because the country has more limited resources to put

into infrastructure and attracting prestigious foreign institutions to set up branch campuses on its

soil, Oman has had to approach the development of the sector in a unique way. Oman has

retained the traditional public/private dichotomy with most public institutions being government

developed, run, and funded. However, in the private sector they have approached cross-national

attraction of institutions with a partnership model that puts more emphasis on economic and

labor market development. The development of the private sector, like many of its GCC

neighbors, was strategized specifically to meet the demands of a growing number of students

graduating from secondary school and the inadequacy of the public system to absorb all of these

graduates (Al Lamki, 2006). Oman did not, at least explicitly in any of its planning documents,

aim for higher education sector development with a goal of developing regional or international

prestige of its universities. Instead, many of the international institutions that were attracted for

partnership are community and technical colleges focused on labor skill development. Impulses


included not only the dissatisfaction with the current system’s ability to meet demands but the

inadequate standards of the current system itself.

Oman dealt with these two different pressures by creating a dual system of regulation,

similar to but still unique from that of the UAE. INQAAHE’s guidelines were incorporated into

the OAAA’s regulatory standards for accreditation and licensing of the public or national

universities. Alternatively, the private colleges that offer international degree programs must first

be accredited by an international accreditor before they can go through “program recognition”

given by the OAAA. The application of international standards through OAAA’s regulatory

policy is primarily a theoretical application of those standards as they served more as a guiding

philosophy than the specifics of the policy itself. In addition, requiring institutions to obtain

quality assurance from a credible external source as a precondition for bringing the program to

Oman was established because the programs are “valued in that form” (Carroll, Razvi, Goodliffe,

& Al-Habsi, 2009, p. 24). Subjecting these institutions to an additional set of potentially

conflicting standards would “damage their integrity” (Carroll et al, 2009, p. 24). Thus, the role of

the OAAA with international programs is not to enforce the OAAA’s standards but to make sure

the international program is in fact meeting and upholding the “standards by which it is

legitimately approved in its place of origin” (Carroll et al, 2009, p. 24). This integration of both

foreign and local accreditation processes to regulate the quality of private institutions in Oman is

a unique approach to quality assurance unmatched in the GCC countries.

The OAAA implemented their dual system of higher education regulation with careful

attention to context. Many of the OAAA’s planning and policy documents, which are more

widely available than its GCC counterparts, address the needs of the both the growth in demand

as well as the need for economic development. Thus, context of government development goals


has played a key role in the policy adaptation. The rate of change has still been rapid, with 18 of

26 private international programs being established in Oman since 2000 and the largest single

year of import in 2001. The MOHE in Oman even intentionally used privatization and the

importation of foreign degrees as a way to increase the speed of growth within the higher

education system because the MOHE did not have the resources to do so, using the program

recognition requirements to preemptively and proactively address quality issues for imported

programs instead of approaching quality retrospectively. Some parallels may be drawn with the

UAE’s multiple levels of accreditation particularly within Dubai, however the UQAIB has never

implemented adherence to standards. While the OAAA has required some external accreditation

procedure, enforcing other sets of institutional standards, the UQAIB has only required that the

institution internally is the same as the home campus without the use of specific standards of

quality. While the OAAA served as a primary actor within the regulation policy implementation

process, the international institutions have played a role indirectly by creating a need for external

validation measures as well as implementing international standards within local policy for

public schools in order to match the quality of those programs being imported. Ultimately, for

Oman as well as for most other countries in the GCC, importing foreign institutions and

programs has put pressure on governments and local institutions to reconsider quality standards

and regulation procedures which has in many cases improved the quality of governmental

institutions overall.

Conclusions and Recommendations

An examination of the politics behind, the adaptation process of, and the actors involved

in the transfer of higher education regulation policies to the GCC reveals that the type of policies

borrowed are highly contextual to the goals of the government, the broader purpose of the higher


education system, and the type of institutions that make up the educational landscape of a given

country. Each country presented here has different goals for the development of their higher

education system. Qatar focused primarily on importing foreign branch campuses to offer what

the MOHE and the one national university were not prepared to provide. Thus, they have relied

heavily on foreign regulation procedures and the accreditation of those imported institutions

from their home countries. In the UAE, the federal and emirate governments have developed the

higher education system by investing in both national and private institutions from within the

country and abroad. While the MOHESR has invested in improving the quality of federal-run

universities by using international standards, they have also imported foreign institutions to offer

alternatives to national universities to meet demands as well as diversify the programs offered.

The combination of international standards and equivalency standards has allowed autonomy for

these foreign universities while still keeping them accountable. The Omani government, with a

much smaller budget for education, has pursued a more conservative growth plan, including the

use of international standards for national university development while also requiring local

partnerships with private universities for those institutions from abroad wanting to offer

education that would otherwise be unaffordable. While there is a general trend towards the use of

international standards for the regulation of both locally developed as well as imported higher

education, the way in which those standards are used and adapted to achieve regulation vary as a

result of the goals of each government. Different governmental goals lend different

recommendations and lessons learned that could be applied to other countries and scenarios, to

which this paper now turns.

Given the media’s propensity to view all countries within the GCC primarily in terms of

their similarities, new ways of viewing higher education systems and the diversity among them


are needed to help frame some of the issues presented in this paper. One potential way to do this

is to view higher education regulatory policy on several spectrums according to the reliance on

foreign standards for their own regulatory practice, as well as the centralization of a country’s

regulatory policies. When combined, these spectrums create a diagram illustrated in the figure

below, grouping countries according to shared characteristics of their regulatory environments.

Oman has moderate levels of international influence with a highly centralized national regulatory

framework, whereas Qatar has high levels of international influence and a highly decentralized

regulatory framework. The UAE is split into three different entities because of some of the

differences in policy and environment discussed in the last section – UAE national, Dubai


federal, and Abu Dhabi federal. These groupings are highly correlated to each government’s

approach to policy.

Quadrant I includes Qatar and Dubai, both relying almost exclusively on the home

country of the institutions it is importing. Either explicitly stated in regulatory policy or

implicitly assumed or expected, in both cases institutions are kept accountable primarily by the

accreditors of their home institutions, exemplified in the cases of universities at Education City

and within Dubai’s free zones. Quadrant II contains Oman, which has chosen to augment its

national institutions with foreign institutions but which has chosen a much more stringent

regulatory policy towards those institutions. Consequently, Oman has created a dual system of

regulation for national institutions and international institutions whereby national institutions are

held to specific standards and international institutions must first be externally validated before

being internally licensed and approved. Quadrant III includes the UAE on the national scale and

Abu Dhabi on the federal scale, which have a lower presence of international institutions and

have chosen to implement a set of blanket standards that all institutions must meet. What is

interesting to note in Quadrant III is that a high percentage of non-international institutions in

both cases have chosen to seek accreditation from international accreditation agencies. Within

the scope of this paper’s analysis, no countries experience a low number of foreign institutions as

well as a decentralized regulatory framework. While some countries in the GCC may fall in

Quadrant IV, this paper has not focused on them for the reason that these countries’ higher

education systems are likely less developed and robust. Countries in Quadrant IV may start there

but may later move to other quadrants after a national strategic plan had been implemented to

develop the higher education system.


On another level, each Quadrant could correspond to the vision each country’s

government and ministries of education has for the purpose of the higher education system, and

for particular institutions within that system. The countries in Quadrant I have perhaps received

the most attention for attempting to internationalize their higher education systems. For Qatar’s

Education City, the emphasis has been primarily on the American model of higher education,

importing both institutions as well as relying on US accreditation to regulate those institutions.

The use of US standards outside of the US thus assumes the acceptance of particular teaching

and learning pedagogies that could create a pressure for other universities to “Americanize,” thus

conforming to US organizational structure of institution and curriculum. Foreign universities’

adoption of US accreditation may have the greatest impact on other local institutions that do not

choose to participate, as the US accredited local universities and their students will receive the

greatest prestige – as well as the greatest chances of graduate studies in the US and the greatest

employability – and drain other universities of their talent pool. Qatar University actively sought

to implement American-style education and quality standards to reform the university in the

early 2000s as a response to the influx of US universities to the country. Other institutions in the

UAE have sought out US accreditation either because they are already an “American-style”

institution or because they aspire to become one, as is the case with Zayed University and

American University of Sharjah. If the purpose of developing the higher education system is to

increase the reputation of the institutions and the country through those institutions, to increase

the mobility of those students and their fluency in international markets, and to gain legitimacy

within the broader international political context, importing foreign systems and their

accreditation practices would also carry with it a perception of quality and a prestigious

reputation. However, if the purpose of developing a higher education system is to simply provide


a basic level of education needed for labor force development with an emphasis on growing the

economy from within, like those countries which might fall in Quadrant II or III, the government

may focus more on importing programs which match the labor market needs over those which

bring prestige and perceived quality on an international scale.

These observations based on the figure provided can help guide policy development for

countries currently pursuing the development of their own higher education systems. India, for

example, has long been plagued with higher education system saturated with highly qualified

students. Many, lacking enough opportunity in India to pursue a university education beyond

secondary school, have chosen to go abroad. China is facing the same issue. Both countries are

the two greatest contributors to the international student population in English-speaking

countries, and both are looking to further develop their higher education system. If their goal is

to build prestige and compete against the highly ranked universities of the US and UK, they may

choose policies more similar to those in Quadrant I. If their goal is strictly labor market

development and capacity building, they may decide to use policies more typical of universities

in Quadrant III. Each case study within this figure provides a potential resolution for other

countries trying to do the same with their higher education system.

The importance of the types of institutions that make up the educational landscape in the

development of regulatory policy should not be overlooked; each country’s regulation policy is

directly related to the types of institutions that exist within the national higher education system.

Because the institutions in Qatar Foundation’s Education City are primarily US branch

campuses, it seems fitting that the quality assurance processes used to monitor those institutions

are of US origin. Not only does Qatar Foundation place requirements upon these institutions to

achieve US accreditation, but the home campuses of IBCs are in often requiring accreditation if


the branch campus is not already being assessed as a part of the accreditation of the home

campus itself. However, Qatar Foundation does not require its British and French institutions to

undergo US accreditation, nor does Qatar’s MOHE require other IBCs throughout Qatar to

achieve US accreditation. This is similar to Oman’s model whereby foreign institution are

required to be regulated by their home countries first before establishing themselves within the

Sultanate. A country like the UAE, with institutions from no less than a dozen different countries

around the world, has opted for a more internationally generalized set of standards because of the

diversity of educational models and pedagogies within the UAE’s higher education system. In

addition, some non-international private institutions within the UAE have a significant cohort of

Americans and other international administrators, staff, and faculty. Those actors also put

pressure on these institutions to obtain international standards of quality and accreditation

because of the assumptions and experience they carry in their own educational background and

biases. Finally, the gravitation of some local private institutions towards an American or Western

model of education then puts pressure on other institutions to do the same in order to attract top

students and their money.

Given the amount of diversity in higher education regulatory policy within the GCC and

the political, economic, and pedagogical contextuality of that policy, it is difficult to give broad

recommendations for all countries in the GCC or elsewhere regarding policy development other

than to remain contextual. The prominence of international standards and the international work

of certain quality assurance agencies in the region and the global higher education sector are

simultaneously a threat and an asset to the regulatory policy debate in the GCC. Issues of

globalization have created a pressing need for quality assurance agencies operating in various

countries around the globe to work closer together such that national quality assurance is


accompanied by cross-border exchange in ideas and practices (El-Khawas, 2006). This exchange

becomes increasingly an issue as more international students seek undergraduate and graduate

study abroad, especially bright students coming from the Gulf. The establishment of the

INQAAHE in 1991 has facilitated much of this exchange. International cooperation is needed

most in professional fields like engineering and business where professionals and institutions

tend to “operate on a global scale” (El-Khawas, 2006, p. 28). Much of the emphasis on higher

education development and the addition of programs have been in the business and engineering

fields to meet labor market demands, thus justifying cross-national work as Qatar, the UAE, and

others have carved out a niche in the global economy in these areas specifically. International

standards can be helpful to ensuring the quality of programs is upheld when transferred to a

country other than that of the institution's origin (Van Damme, 2001). Practices and policies of

internationalization may find their limits if issues of quality are not addressed. In particular,

when models of higher education flow from one country to the next, taking with them certain

practices, policies, and teaching pedagogies, it is essential to ensure that those models are still

being held to a high standard. The movement of students creates particular problems in the

transferability of credits through study abroad and the recognition of foreign degrees and

diplomas for equivalency to pursue further education in other countries.

On the other hand, international standards for academic quality can undermine the

aforementioned importance of contextuality. In place of international standards, regional quality

networks may be an alternative. The appropriateness of international quality assurance

mechanisms depends on national-level quality assurance agencies and entities coupled with

regional cooperation (Eaton, 2003). Organizations like the World Bank, UNESCO, and other

international development organizations have actually favored regional standards that focus on


higher education’s role in the development of economies within specific countries. Regional

networks for groups of countries that share physical, ideological, historical, and cultural

commonalities may allow for a more contextual interpretation of quality and its incorporation

into the regulation process. In early 2012, the Sultanate of Oman proposed a Gulf regional

quality network approved by the Committee of Higher Education and Research Ministries of the

GCC (Sawahel, 2012). The purpose of the network would be to “promote awareness of quality

management and quality enhancement practice, dissemination of best practices, and stronger

liaison between quality assurance bodies in different GCC countries” while also providing a

forum for agencies, institutions, and policy makers to share ideas and experiences (Sawahel,

2012). Public response has been mostly receptive to the proposal, as there are two other regional

“network” organizations that currently exist for quality assurance in the Gulf, the Arab

Organization for Quality Assurance in Education and the Arab Network for Quality Assurance in

Higher Education. Both are member-based organizations and neither provides standards or

quality assurance procedural support to its members. Thus, the new network would help to

“achieve control over 136 private higher education institutions” within the GCC in hopes of

discussing issues of equivalence of higher education degrees, much like what the Bologna

process has done for Europe on a much larger scale. While this could be one very important step

towards advancing a regional conversation on what quality means in the context of the Gulf and

its specific economic and political contexts, opponents of the idea are concerned with

practitioners’ and policy makers’ lack of knowledge and expertise in higher education quality

assurance. This lack of knowledge and expertise may hinder progress in conversations about

quality assurance and regulation as well as prove precarious if decisions are made about quality


that impact all types of institutions without full understanding of the repercussions of the

decisions and how to implement them.

Ultimately, quality assurance and regulation needs to be a matter of the state if the higher

education systems are to serve national priorities, goals, and objectives. The “public good” of

higher education has been a long-standing function of universities and while this assumption

goes largely unexamined in the international context, there is an implicit assumption that the

development of higher education in the GCC would contribute to overall national economic and

social development. Because the local context of each country is unique, even though many

similarities are shared, each country has both the responsibility and the right to develop their own

national regulatory framework. Many may debate whether help from other countries or

international or regional networks is appropriate, but the influence of these entities is inevitable

due to the internationalization goals and strategies countries in the GCC employ. The trick for

these countries will be balancing this international influence with needs and the desires of the

local Ministries of Higher Education, the systems of education they develop, and the students

those institutions serve.


Appendix 1

Quality Assurance Organizations by Country in the GCC

Country Agency Website

Bahrain Quality Assurance Authority for

Education & Training (QAAET)

http://en.qaa.bh/

Kuwait Private Universities Council (PUC) http://www.puc.edu.kw/en/index.php

Oman Oman Accreditation Council (OAC) http://www.oac.gov.om/

Qatar Higher Education Institute, Supreme

Education Council

http://www.english.education.gov.qa/secti

on/sec/hei/

Saudi

Arabia

National Commission for Academic

Accreditation & Assessment

(NCAAA)

http://www.ncaaa.org.sa/english/adefault.a

spx

UAE Commission for Academic

Accreditation

https://www.caa.ae/caa/DesktopDefault.as

px


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