Twenty years of accreditation in Russian higher education: lessons learnt

Purpose – Thepurposeofthisarticleistoanalyzemainprinciples,formsandapproachestoeducationquality evaluation in the process of establishment, development and crucial changes in the state accreditation of educational institutions and study programmes in Russian higher education in the last 20 years. Design/methodology/approach – The major research method used in the paper is the qualitative analysis of legal and statistical documents, research papers and accreditation practices, which impacted the development and transformation of accreditation forms in Russia. Findings – The transformation process of state accreditation during the last 20 years was conditioned by the changes in the state education policy and socio-economic situation. In a short period, under the influence of internal and external factors, Russian higher education has experienced significant changes in the structure of higher education and quality assurance. This resulted in different approaches to accreditation: state and independent, mandatory and voluntary, national and international. Practical implications – The research outcomes may be applicable in the countries with developing accreditation systems and comparable scope of education. Socialimplications – Thestudyidentifiesthetendenciesinthedevelopmentofhighereducationandquality evaluation. Originality/value – The paper systematizes the tendencies of development in quality assurance and distinguishes specific features and diversity of forms of the quality assurance in one of the largest systems of higher education. state education governing body. Professional – public accreditation conducted by professional and public bodies and institutions serves as an alternative to state accreditation. International accreditation is a procedure for evaluation and recognition of study programmes in order to establishtheir compliancewith internationalstandards, and itisconductedinaccordancewith the methodologies developed by recognized international associations in the sphere of quality assurance. Joint accreditation is carried out according to the standardsand technologiesoftwo accreditation agencies of different countries, and two certificates are awarded.


Introduction
Accreditation in the sphere of education is a tool for evaluating the performance of educational institutions and study programmes, a factor of public trust and an indicator of the soundness of the country's social policy. It is also an effective mechanism for education management. The procedure of accreditation and its outcomes depend on what goals are pursued and whose interests are served. In highly centralized countries, such as Russia, any changes in the state educational policy have a direct impact on the content, structure and quality of education; and accreditation criteria can become either vectors for education development or limitations in the way of its progress.
The first state accreditation procedure in Russia was conducted in April 1997 by the state education governing body. The experience of over 20 years is sufficient for analyzing achievements and failures, adopting international good practice, searching for own solutions and testing different forms and methods of evaluation. Over the recent years, the situation in Accreditation in Russian higher education 33 Russia has witnessed considerable changes connected with economic and demographic causes, changes in the state educational policy and growing internationalization of higher education within the Bologna Process. This resulted in the transformation of the content and structure of the higher education system and was reflected in the education quality evaluation (Navodnov and Motova, 2015).
Initially the state introduced institutional accreditation as a mandatory form of quality assurance; in 2012, it was replaced by programme accreditation. Alongside obligatory state accreditation beginning in 2009, new forms of accreditation have started to gain momentum: professional-public, international and joint accreditation. Today, only in Russia, there is such a variety of diverse forms of accreditation existing independently of each other. The 20-year experience of accreditation and the analysis of the reasons for transformation of approaches and search for the most effective solutions in quality assurance of education are important for understanding the development prospects of the accreditation system.

Methodology
The analysis of the development of different forms of accreditation in Russia is based on the laws and regulations governing evaluation and accreditation procedures, long-term examination of statistical data submitted by Russian HEIs to the Centralized Data Bank of State Accreditation (1996)(1997)(1998)(1999)(2000)(2001)(2002)(2003)(2004)(2005)(2006)(2007)(2008)(2009)(2010), open information sources, findings of Russian and international research into the sphere of accreditation and personal experience and participation of the authors in the development of the national accreditation system. The purpose of this study is to identify the specific features of establishing the system and infrastructure of quality assurance in large-scale higher education; conditions and reasons for changing the mechanisms of higher education governing; and the impact of political, economic and social factors on the forms of evaluating the quality of education.
Russia's experience is unique in the sense that different forms of accreditation, tested through practice, coexist in the country: institutional and programmatic, mandatory and voluntary, state and professional-public. The data are compared on different bases: (1) The object of accreditation (educational institution/study programme); (2) The actor of accreditation (state/employer association/independent accrediting agencies); (3) Goals (national/international recognition).
Institutional accreditation involves a procedure of evaluation and recognition of an educational institution as a whole, including all offered study programmes. Programmatic (or subject-specific) accreditation is evaluation and recognition of a particular programme. At present, in accordance with the legislation, state accreditation is a function of the state education governing body. Professional-public accreditation conducted by professional and public bodies and institutions serves as an alternative to state accreditation. International accreditation is a procedure for evaluation and recognition of study programmes in order to establish their compliance with international standards, and it is conducted in accordance with the methodologies developed by recognized international associations in the sphere of quality assurance. Joint accreditation is carried out according to the standards and technologies of two accreditation agencies of different countries, and two certificates are awarded.
Structural changes in higher school as a result of state educational policy: a retrospective review This section discusses the main stages of changes in the structure and scope of higher education in Russia, socio-economic and political causes of these changes, challenges in the development of higher education and the reasons for the decline in its quality. The significant role of the Bologna Process in this transformation is highlighted, and certain aspects of the Bologna Declaration, which haven't been yet implemented in Russian higher education, are considered. Over the past 20 years, the Russian system of education has gone through tremendous internal transformation. Beginning from 1990s, the national system of education has expanded considerably. In 15 years, the total number of HEIs has more than doubled, and the number of programmes and students has more than tripled. The first in Russia Law 'On Education', adopted in 1992, facilitated the radical increase in the scope and the transformation of higher education (Gounko and Smale, 2007). The Law ensured the right and freedom to establish educational institutions of different forms of ownership: state, municipal, private. At the same time, procedures of state licensing (right to educational activity), attestation (assessment of quality of education and training of undergraduate and graduate students) and accreditation (recognition by the state) were made mandatory for educational institutions of all levels (Motova and Pykk€ o, 2012). Such state educational policy provided for the emergence of private education, which resulted in a great number of branches of state and new private HEIs and increase in the number of fee-paying students in state HEIs (Azimbayeva, 2017). By 2008, the number of students skyrocketed to 7.9 million, the number of educational programmes reached 36,000, the number of HEIs to 1,364 and the number of branches to 2,136 (Navodnov and Motova, 2015). This accelerated growth of the higher education sector was not supported by the relevant enhancement of educators' qualification and adequate financing of both private and state HEIs, which inevitably resulted in the division of HEIs and their programmes according to the quality of student training, and this, in turn, led to a fall in prestige and value of higher education. In fact, it produced the effect of an 'education bubble'. Higher education became accessible to the majority of Russia's population, though the quality of higher education was different. A certificate of higher education became an obligatory document for employment, which caused its devaluation: higher education degree holders were often employed as shop assistants, secretaries and manual workers.
However, it would be wrong to blame the system of education for the decline of education quality-the whole socio-economic and political system of the country underwent radical changes (Heyneman, 2010). Higher school managed to preserve the fundamental approach and research schools, at the same time fulfilling a very important social order: in the conditions of dramatic shrinking of the labour market, it ensured accessibility to higher education, thus diminishing social tension and unemployment among young people. Starting from 2009, the direction of expansion of higher education reversed. The number of applicants kept decreasing with the speed of 10 percent per year, and in 2011, the number reached its minimum. It was connected with the reform in secondary education: transition to 11-year school instead of the traditional 10 years; in 2012, the number of school leavers plummeted. In addition, a reform in higher education was implemented at this time, that is, transition to a four-year bachelor's degree training instead of educating specialists for five years. Already by 2016, the number of undergraduates went down to 4.7 million. As a result of the new state educational policy and economic factors, the number of HEIs was reduced to 896 (including the decrease in the private sector to 366) (Navodnov and Motova, 2015). Altogether in five years, about 1,000 HEIs and branches were closed. Never before has the Russian system of education experienced such an upheaval (Figure 1 and 2) (Bolotov et al., 2019).
Alongside the demographic crisis and change in education policy, Russia's higher education was impacted by the Bologna Process. Russia supported European initiatives in 2003, but the process of their implementation took a long time (Motova, 2016). It was only in 2011 that the national higher school changed over to bachelor and master training, and in 2013, a three-level system including doctoral studies was introduced. At the same time, the Accreditation in Russian higher education  new Federal State Educational Standards was developed. It required that the student workload should be calculated in credits. The new Federal Law 'On Education in the Russian Federation' (2012) envisages enhancing opportunities for student mobility and expanding cooperation between national and international institutions (the right to implement network educational programmes, the right of some HEIs to independently recognize educational documents awarded to foreign citizens and persons without citizenship, etc.). The Ministry's normative documents expanded opportunities of accessible education for special needs students and persons with disabilities. However, until now, Russia had been lagging behind in many directions of the Bologna Process, and some areas haven't been covered at all (Artamonova et al., 2015). For instance, until now, Russia hasn't had the officially recognized national qualifications framework, which is being developed and discussed at the moment to try to overcome numerous stumbling blocks.
Russian HEIs issue European Diploma Supplements only upon student request and often for a fee. Russia is one of the three countries (Serbia and Montenegro being the other two), that doesn't issue the Diploma Supplement to graduates automatically and free as required by the Bologna documents. The most indicative conclusion of the Implementation Report is the fact that Russia is one of the few Bologna member-countries which has state accreditation (European Commission/EACEA/Eurydice, 2018).

Three stages of accreditation development in Russia
The history of accreditation in Russia can be divided into three stages. The grounds for this division are changes in the state educational policy reflecting social and economic developments in the country. The first stage of innovation falls in the period of establishing the new forms of the country's governance immediately after 'Perestroika'. It is marked by the search of new forms of evaluating the education quality and the development of new evaluation methods on the basis of new information technologies. The second stage of internationalization is distinguished by the active position of the country in the process of integration with the European Higher Education Area, and participation in the Bologna agreements in the sphere of education quality assurance. The third stage of differentiation is defined by the division of the state functions of regulation in the sphere of education and quality evaluation. On the one hand, the state governing body tightened up control over education, and, on the other, delegated the responsibility for the quality of education to public bodies and organizations. This section discusses these stages in more detail.
The first Law 'On Education', enacted in 1992, stipulated that all HEIs should be accredited by the state. It is necessary to emphasize that Russia was one of the first European countries to introduce accreditation of educational institutions, to develop the methodology of education quality evaluation and to establish an entity separate from the Ministry of Educationaccreditation agency. The Russian technology of accreditation had been developed before the Bologna Process (1999), before the establishment of the European Association for Quality Assurance in Higher Education (2000) and before the development and approval of Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG) (2005). All these account for the fact that the Russian system of accreditation differs significantly from accreditation systems in other countries; it has its own specific features related to the size of the country, the state policy and public initiatives (Navodnov et al., 2008).
At the first stage (1995)(1996)(1997)(1998)(1999)(2000)(2001)(2002)(2003), in compliance with the current legislation, the system of accreditation was developed as a tool for the state regulation of HEI activities, and it was institutional in form and voluntary in nature. The stage of evolving and development of the accreditation system (1992)(1993)(1994)(1995)(1996)(1997)(1998)(1999)(2000)(2001)(2002)(2003) involved a lot of research and project work (Motova et al., 1998). During the second stage (2004)(2005)(2006)(2007)(2008)(2009)(2010), the Bologna Process started to exert considerable influence on the system of higher education evaluation (Gevorkian and Motova, 2004). Centralized mechanisms of direct assessment of learning outcomes, such as the Federal Internet Exam in the Sphere of Professional Education and feedback methodology in the form of Internet surveying of students, were introduced. The principle of information openness was implemented through Internet resources for the public and the applicants, through seminars and workshops for the academic community and through mass media and periodicals. In 2006, the Guild of Experts in Higher Education was established, and the system of training and support of experts participating in accreditation procedures began to emerge. A lot of effort has been put into aligning the Russian system of accreditation with ESG for internal and external quality assurance systems and accreditation agencies (Russian Federation National Report on Bologna Reforms, 2009). The National Accreditation Agency established by the Order of the Ministry of Education in 1995 in Yoshkar-Ola underwent all the required procedures of self-evaluation and external international review. In 2009, it was granted full membership in the European Association for Quality Assurance in Higher Education (ENQA).
The third stage of accreditation development began in 2010 with the differentiation of accreditation into state and public, the starting point being the RF President's Order of May 2009 (Order of the President of the Russian Federation, 2009), which decreed establishing and enhancing professional-public accreditation and extensive involvement of employers and public into accreditation procedures. The RF President's Order of 2012 (Order of the President of the Russian Federation, 2012) specified the task and facilitated new forms of evaluation systems for the social sphere: education, healthcare, culture and social security. In December 2012, the Law 'On Education in the Russian Federation' (Federal Law "On Education in the Russian Federation", 2012) introduced new tools for quality evaluation (independent evaluation of quality, public and professional-public accreditation), thus separating the responsibilities of the state and public bodies. The state retained the responsibility for licensing, including scheduled and random control procedures, federal state quality control (scheduled and random), federal state oversight of compliance with the legislation (scheduled and random) and also state accreditation of delivered educational programmes.
For the purposes of state accreditation, the goals, technologies, decision-making and follow-up procedures were changed. Accreditation of an educational institution as a whole was replaced by evaluation of educational programmes for compliance with the Federal State Educational Standards; consequently, institutional form of evaluation was substituted for programme accreditation. This approach made it impossible for the institution to change its status as a result of accreditation as before, for example, to change the status of institute to academy or even university, provided certain requirements were met (Motova and Pykk€ o, 2012). As a result, administrative responsibility was shifted to the department and faculty levels. At the same time, the government supported the differentiation of universities into federal, national research and flagship (regional) HEIs (Oleksiyenko, 2015). At present, the government assigns a university status on the basis of competition and provides for them additional funding. However, this process has nothing to do with state accreditation.
The self-evaluation procedure as part of state accreditation and collecting data for identifying the accreditation criteria have lost their importance as the current accreditation criterion is full compliance of the study programme with the state educational standard. The responsibility for noncompliance with the accreditation criteria has increased: the fact of accreditation failure is reported to the founder and the prosecutor's office. Besides, it results in such serious consequences as withdrawal of the education license (the right to carry out educational activity) and a ban on teaching activity (Federal Law, N 273-Φ3 (2012). Furthermore, we are witnessing increased activity on public and professional-public accreditation by the existing independent accreditation agencies. Now, HEIs have an Accreditation in Russian higher education opportunity and motivation to undergo international and joint accreditation in order to meet high quality standards (The Concept of Excellence in Higher Education, 2014). Under the current legislation, the system of independent quality evaluation of educational institutions and the assessment of student learning outcomes have started to emerge. Listing of Russia's leading HEIs in the world rankings is encouraged and financially supported by the government within the project '5-100'.
The main difference between the two approaches-state and public-is the obligatory nature of accreditation procedures in the former and voluntary in the latter. The primary goal of the state system of evaluation and regulation in the sphere of education is the protection of the country's citizens from low-quality education. The objective of public mechanisms of evaluation is quality enhancement, facilitating education development and recognition of achievements on the national and international levels.

Lessons of institutional accreditation and programme accreditation learnt
Each country establishes the forms of institutional and/or programme accreditation based on its own educational policy. The choice of this or that form does not depend on the size of the system of education. Besides, it should be mentioned that in the world practice, these forms periodically interchange or complement each other. The discussion below examines the reasons for changing approaches to accreditation in Russia.
Russia has a 15-year experience of institutional accreditation (1997)(1998)(1999)(2000)(2001)(2002)(2003)(2004)(2005)(2006)(2007)(2008)(2009)(2010)(2011)(2012); most of HEIs in the country underwent this form of accreditation three or more times if they wanted to change their accreditation status (Navodnov et al., 2008). The Law 'On Education' (1992) set a specific task of preserving the common education area in the conditions of disintegration of the Soviet system of education. There was a real danger of demarcation of the educational system within the former Soviet Union and also between the federal republics. Therefore, it was necessary to develop an evaluation technology, common for all HEIs, regardless of their form of ownership, location and specialization. Inexpensive evaluation technologies were developed that took into consideration the size of the country and financial resources, which were limited in the conditions of socio-economic crisis. They were based more on statistics, rather than on expert evaluation, which was more costly. Technical progress facilitated the development of modern information technologies, in particular, the technologies of efficient collection and analysis of data on the performance of all HEIs in Russia.
The state accreditation of an HEI involved collecting information in all areas of its activity in a specialized format. This information was compared with the performance indicators of other HEIs and accreditation criteria. Additionally, there was an external review of the HEI scrutinizing educational, research and extracurricular activities, teaching staff, learning resources, availability of postgraduate and further education programmes and so forth. The standards and criteria of accreditation were set with regard to the HEI's performance as a whole: the range and scope of educational activity, qualifications of the teaching staff, scope and effectiveness of research and methodological work. Alongside the cost-efficient expert and evaluation procedures, the institutional form of accreditation tackled a number of important issues: it enhanced the Rector's and the Rector's office responsibility for the quality and effectiveness of the HEI; it also contributed to establishing internal quality monitoring and assurance units, which resulted in the formation of an efficient governance mechanism at the national and institutional levels (Kells, 1988(Kells, , 1992Vroeijenstijn, 1995).
The year of 2009 faced cardinal transformation of accreditation procedures, which was secured by the law in 2012. An educational programme became the subject of accreditation, which was evaluated against the requirements of the state educational standards. Statistical and expert data were collected for every programme and included the teaching staff, material and technical resources, research and methodological work and internal documentation regulating the process of the programme implementation. Under the banner of quality control, the state governing body increased the pressure manifold on HEIs. The number of documents necessary for state accreditation skyrocketed. The number of involved experts multiplied.
Institutional accreditation was conducted by a review panel comprising no more than ten experts. The review covered a wide range of issues (e.g., social aspects, student selfgovernance and student support) and all levels of education at an HEI. At present, the number of experts involved in one accreditation procedure even at an average HEI can reach 50 people. However, there is no goal of presenting a holistic picture of an HEI's state and development and its place and role in the system of education.
Indeed, external evaluation of a study programme makes it necessary to put in order all the documents and reflect on those aspects of HEI's performance which need enhancement. External evaluation concerns not only the administration of an HEI, but also faculties, departments and even teachers. The HEI is not required to develop its own internal quality policy and evaluation procedure, monitoring and education quality assurance, as each programme will be closely inspected by an external reviewer. The availability of independent quality assurance policy of the HEI will be viewed by experts as incompliance with the state educational standards.
Increasing the number of experts involved in programme accreditation adds up to the burden of the controlling body itself in terms of organization and logistics of the procedures. It can impact the qualification of experts and the quality of the accreditation procedure itself. Moreover, the increase in the amount of documentation, which is not supported by specific information technologies, creates an obstacle to its analysis, systematization and adequate interpretation and often leads to voluntary and biased decision-making. Such a situation may raise serious concern regarding the effectiveness of state accreditation.
At the same time, programme accreditation has found its place and has been highly sought after in the procedures of professional-public accreditation. Taking into consideration the fact that the emphasis on such a procedure is put on the employers' opinion and labour market demand, it is very important to assess graduates' learning outcomes, if not in every single study programme, then at least in a field of study. Independence of professional-public accreditation from the state body of control and supervision ensures the flexibility of its content and procedures. In programme accreditation, opinions and facts about the quality of programme implementation and involvement of a wide circle of respondents and experts-students and alumni, administration and teachers, representatives of public community and employers-is more important than the review of documents. The experience of professional-public accreditation of study programmes has found an efficient and cost-effective review procedure-review of a cluster of study programmes, which is evaluation of a group of programmes carried out by one review panel comprising representatives of academic, professional and student communities. Many years of experience in accreditation confirmed that institutional and programme forms do not contradict, but, on the contrary, coexist and complement each other in the conditions of a large-scale and diverse educational system.
Existence of various forms of accreditation in different countries of the world depends on political and economic reasons. It is generally thought that the most effective tool of education system management is a combination of institutional and programme accreditation, as, for example, in the USA, where 7 regional accreditation agencies conduct institutional accreditation, and over 60 agencies conduct subject-specific programme accreditation (CHEA, 2019).
At present there are no institutional forms of education quality evaluation in Russia (except for the Ministry's control over the HEI's performance). But, the data obtained over the Accreditation in Russian higher education past 20 years (Motova and Pykk€ o, 2012;Navodnov and Motova, 2018) support the case for institutional accreditation, which could make the system of education more manageable, would increase the Rector's responsibility for the quality of the HEI's activity on the whole and would restore the importance of the HEI's internal management and quality assurance systems. Programme accreditation can stay in the domain of professional-public accreditation and focus on the evaluation of education quality in a field of study; it is also important for quality enhancement and development of quality culture (Marshall, 2016). Such a structure of evaluation of the quality of higher education would be more effective and plausible.

Compulsory and voluntary accreditation
One of the important issues of external quality evaluation is whether it should be mandatory or voluntary for educational institutions. This issue is closely connected with the balance of accountability and enhancement. The mandatory procedure of evaluation is imposed by the state, whereas the voluntary procedure is used by those educational institutions that choose this type of evaluation. In case of voluntary accreditation, it is impossible to produce a system-wide analysis and draw conclusions about the quality of education in the country on the whole. What follows is the description of the mandatory and voluntary practices of accreditation.
Initially, state accreditation was application-based and voluntary. For state educational institutions, it implied gradual (when they were ready) and consecutive procedures of licensing, attestation and accreditation. For private educational institutions, accreditation, on the one hand, was regarded as nonbinding, on the other hand, it might have important motivating effects. Upon successful completion of state accreditation, a private HEI virtually acquired equal rights as that of a state HEI, that is, a right to issue state format diplomas for its graduates and use a seal with the national symbols; additionally, students were granted deferment from military draft. The first version of the Law 'On Education' also stipulated equal budget funding for private state-accredited educational institutions. It is also important that both state and private HEIs were able to raise their status-from institute to academy or university, provided they met the required accreditation criteria. The decision on the change of status was made independently by the academic council of the HEI, and if the results of its performance complied with the established criteria, the change of status was approved by the collegial body of the Ministry of Education (Navodnov et al., 2008). Since 2000, the legislative regulations regarding state accreditation have been changed significantly. A new regulation was introduced, prescribing that all state-accredited HEIs should undergo state accreditation at least once in five years. In 2012, the current legislation introduced obligatory accreditation of educational programmes in compliance with the state educational standards and evaluation of this compliance by means of accreditation.
In the Federal Law 'On Education in the Russian Federation', the voluntary principle of accreditation has been preserved only with regard to public accreditation: educational institutions can undergo such accreditation in national and international organizations. But as far as professional-public accreditation is concerned, the voluntary principle may be interpreted ambiguously. According to the law, employers, their associations or bodies authorized by them have a right to conduct accreditation. For employers, it is a voluntary decision whether to conduct accreditation or not, but not for HEIs. Ambiguous interpretation of the Law on Education concerning who can conduct public and professional-public accreditation and whether the procedure is voluntary for a HEI leaves a number of questions unanswered. Are employer associations and professional unions really ready and capable of reviewing the quality of educational programmes? Will HEIs apply for accreditation without the Ministry's pressure? What if the evaluation procedure is too time-, effort-and money-consuming? Besides external incentives, one needs internal motivation. Only large HEIs and their ambitious staff can take it on. A voluntary decision about cyclical internal and external review of HEI's activity is a proof of maturity and responsibility of the staff, their desire to make public the results and quality of their performance. The principle of trust and voluntary participation should be the basic principle of any accreditation.
However, it is hardly reasonable to replace all the obligatory procedures with voluntary, as the state, according to the national constitution, is to ensure quality education to its citizens. Besides, the state has to control the efficiency of public budget expenditures. For this purpose, the state has in place a whole range of legislative tools: licensing and state control of education quality and oversight of legislation. Each of those includes regular and random check-ups. These procedures would be sufficient for control; accreditation, however, could be more effectively used for education quality enhancement.

State and independent accreditation
Another issue of quality evaluation in education is who accredits an educational institution. How important is the principle of independence in evaluation if we want to get an objective and fair result? This section considers this issue in the national and international context.
The principle of independence in quality evaluation is one of the basic principles in all systems of quality assurance in the world (INQAAHE Guidelines of Good Practice, 2016). It is understood as operational independence from governing bodies, HEIs themselves and other interested parties. The responsibility for content and organization of an evaluation procedure including decision-making and the outcomes is borne by an operating body, in this case, an accreditation agency with its qualified staff, resources and evaluation tools. All this is articulated in Part 3 of the Standards and Guidelines for Quality Assurance in the European Higher Education Area (Standard 3.3): 'Agencies should be independent and act autonomously. They should have full responsibility for their operations and the outcomes of those operations without third parties influence' (HEIs, Ministries or other stakeholders) (ENQA, 2015). A similar requirement is contained in International Network for Quality Assurance Agencies in Higher Education (INQAAHE) Guidelines of Good Practice-GGP (Section 3.5): 'The EQAA has policies and procedures in place that ensure a fair and independent decision-making process in the final review of the institution or the programme' (INQAAHE Guidelines of Good Practice, 2016). It means that the more transparent, responsible and independent the work of the accreditation agency, the more reliable and trustworthy the results of its activity, and the more credibility is entrusted to HEIs and programmes accredited by it.
In the Russian system of education, the term independence is interpreted differently: it refers to any external procedure conducted, among others, by state governing bodies. Consequently, state accreditation, state control and supervision can be also viewed as independent procedures, in this case from HEIs. The issue of trust in the objectivity of the results of state evaluation is relevant only for the HEI itself. The general public, however, has trust only in the state procedures of evaluation and recognition: state format diplomas, certificates, awards and titles. At the same time, the state procedures of recognition vary. Thus, obligatory control and regulating procedures are conducted by the state bodies represented by public officials or authorized persons. And if these procedures are voluntary and competition-based, as, for example, awarding academic titles or state prizes, the public committees are established, and their decisions are approved by the state bodies. The system of independent quality assurance could be formed using the following approach: be voluntary for educational institutions, have public nature and offer new opportunities.
We cannot talk about independence with regard to state accreditation: by law it is a service rendered by the state, governed by the state regulations and executed by a civil Accreditation in Russian higher education servant of the state controlling and supervising body. Therefore, the content, procedure and decision-making, as state functions, may not be delegated to any other organizations. Nevertheless, the international practice of conducting evaluating procedures testifies to the effectiveness of organizations independent from the state. For instance, in the USA, the accreditation of educational institutions and study programmes is undertaken by accreditation agencies independent of the U.S. Department of Education, from the departments of education of the states and also from HEIs. This practice is over 150 years old. Testing of student learning outcomes has also been conducted by the organizations independent of the federal governing bodies, the largest being Education Testing Service. Certification of qualifications for licensing authorizing professional activity is conducted by special professional unions and associations. University and programme rankings are not compiled by the state governing bodies either (not even under their supervision), but by mass media, for instance, The Times Higher Education World University Rankings (THE). This approach is conditioned by the necessity of obtaining objective and reliable information. The more well-grounded the evaluation is, the more trustworthy and demanded by the general public it is. Besides, in order to ensure objectivity, it is necessary to observe interests of all stakeholders, which means involving not only representatives of the academic community, but also employers and students, in the evaluation procedures. A variety of opinions and consideration of different interests is an essential condition for both objectivity and independence (Motova and Navodnov, 2012).
Independence and objectivity of evaluation procedures are influenced not only by the degree of distancing from the governing bodies, but also by a possibility of using independent evaluation procedures for administrative purposes. For Russia, these will be the right to award their graduates state format diplomas or informing the prosecutor's office about the negative outcomes of accreditation. Since the outcomes of state accreditation are vitally important for HEIs, it is obvious that they will be highly motivated to meet its requirements by all means, even by embellishing their performance on paper, and thus enabling corruption. Not only administrative resources but internal and external motivation mechanisms are essential for voluntary independent evaluation. It is the HEI's decision to undergo an independent accreditation procedure and how to deal with its outcomes. The most effective solution would be motivation from the state for HEIs to undergo regular independent accreditation conducted by a certified accreditation agency, followed by the publication of accreditation results.

Public and professional public accreditation
The section focuses on the analysis of specific approaches to accreditation in Russia, which are dependent on legislation. Involvement of professional associations and employer associations to quality assurance is not new in the world practice. For example, in the USA, subject-specific accreditation is conducted by professional associations, such as the Accreditation Board for Engineering and Technology (ABET). Similar approaches are used in the practice of specialized agencies in Germany (Foundation for International Business Administration Accreditation-FIBAA), France (Engineering Degree Commission-CTI), Belgium (Music Quality Enhancement-MusiQuE) and others.
Russian legislation allows for a broad variety of accreditation forms: alongside the obligatory state accreditation, there is also public accreditation, which can be conducted by public bodies and associations, and professional-public accreditation, which can be conducted by employers and their associations in accordance with occupational standards. The enactment of the Federal Law 'On Education in the Russian Federation' provoked a lot of controversy, which is still going on: there have been a few deliberations in the State Duma Committee on education and coordination of certain provisions of the law with the relevant ministries. And this is because the situation opened a Pandora's box. Some of the most important issues are whether the professional-public accreditation is voluntary for HEIs; whether it can be regarded as independent even if it is conducted by one of the stakeholdersthe employer; whether it could become another, even a stricter, controlling procedure, initiated by employers. Overdependence of evaluation on the opinion of professional associations may result in artificial constraints for admission to profession and recommendations to reduce the number of students, because of tough competition in the labour market and excess of supply over demand, which may cause the fall in the prestige and pay in the field. At first sight, it stands to reason that the labour market is the major customer in the system of education. However, there are students who pay their own tuition fee. If the state allocates budget places for training specialists for the benefit of socio-economic and technical development of the country, it has a right to control how effectively the funds are used by means of the oversight of education quality and the supervision of compliance with the legislation. If employers or an association of employers claim the right for control and accreditation of educational programmes, then, following this logic, they should finance training of specialists in those programmes, or, at least, conduct evaluation procedures at their own expense and also ensure employability of all graduates of accredited programmes.
At present, this approach is partly implemented through a mechanism of qualifications certification for their compliance with the requirements of professional standards. It is financed by physical persons-applicants or an interested company-and entails admission to the profession. In many cases, it is done with the resources of the system of education: only few large businesses can afford special structural quality units on evaluating and recruiting personnel. Evaluation of study programmes involves external review procedures with regard to legal persons (HEIs), and should take into consideration specific features of their activity. Implementation of professional study programmes is an integral part of the educational system as a process of education and training for the benefit of the personality, society and state. The state or a region initiates the opening of a programme, which is financed from the federal, regional, municipal or household budget. The quality of their implementation is regulated by the state through the State Educational Standards. Consequently, the accreditation of study programmes should not ignore the interests of the society, state and individual. Thus, it is important to keep in mind that since 2011, the higher education system has ceased being professional and, on a mass scale, has started to train bachelors, and specialists are trained only in a limited number of programmes (Pukharenko et al., 2017). There's no point in expecting strict compliance with professional standards from bachelors. The right to conduct professional-public accreditation stipulated by the law for the sphere of education and supported by the administrative resource of the National Council for Professional Qualifications under the Government of the Russian Federation opens up broad possibilities for emergence of new structures and organizations in this field. According to www.accredpoa.ru, there are currently over 100 such organizations. However, their experience, reliability, professionalism and availability of resources give some reasons for concern. A loud name and ambitions cannot replace specific knowledge and competencies in the sphere of quality assurance .
Unfortunately, no lessons have been learnt. The system of professional education has had the experience of introducing professional requirements, for instance, ISO 9000 Standards originally developed for quality management in industry. But there is no valid confirmation that this influenced the quality of education, particularly teachers' work and students' performance. Unsupported by the knowledge of the subject and expertise in the field, the attempts of creating independent voluntary accreditation would only lead to blowing up the 'accreditation bubble' and discredit the very idea of accreditation. The new Law 'On Education in the Russian Federation' is an important step towards developing independent accreditation mechanisms; this is an opportunity and an impetus for involvement of academic Accreditation in Russian higher education and professional community in education quality evaluation. But, in fact, it could bring about negative consequences: if only employers have a right to conduct such accreditation and only for compliance with professional standards and labour market demands, then it is going to be a barrier rather than an impetus to the development. The labour market demands are dictated by the present day, and sometimes by yesterday. Higher education occupies a special place in the modern world. It should not serve economy, but create and develop it. The experience of foreign accreditation agencies carrying out accreditation procedures in compliance with ENQA's standards has shown that broader involvement of stakeholders in the external review procedures is required rather than replacement of the academic review with professional review (ESG, Standard 2.4).

National and international accreditation
Last but not least, the issue which is now being actively discussed by the academic community of the country is the necessity and importance of recognition of education quality not only at the national but also at the international level. Russia's labour market is fairly large, and the internal mobility in the country is not high. The majority of HEIs train specialists for regional and national labour market. And only the leading HEIs set the goal of integration in the world educational area. Without international evaluation-accreditation, ranking, comparative research-an HEI or a programme won't be recognized from the point of view of quality of education.
National accreditation by definition is conducted according to the national standards, and its results are recognized within the country. The basis for such recognition is the national legislation. International accreditation is conducted according to international standards and evaluation technologies established by international organizations. Accreditation results are recognized by all member-countries of international organizations (associations, unions, networks). If a country joins or is planning to join an international association, it assumes responsibility to follow international agreements and is committed to introducing changes in the national legislation. Russian legislation contains no reference to international cooperation in the sphere of quality assurance and accreditation. However, the law makes provisions for cooperation in the sphere of education and research and also for accreditation of HEIs by the national bodies and organizations (Federal Law, N 273-Φ3 (2012)).
Since the time of Russia joining the Bologna Process, the country slowly but surely has been carrying out reforms aimed at internationalization of national education. The reforms concerned the content and structure of higher education, but not the system of evaluation and accreditation of study programmes or HEIs. The above-mentioned document Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG), adopted by the ministers of education in 2005 (revised version in 2015), is used in all countries that are part of the Bologna Process, but could not find a place in Russian legislation. As stated in The European Higher Education Area in 2015: Bologna Process. Implementation Report prepared for the European Ministerial Conference in Yerevan, Armenia: ESG 'are designed to be applicable to all higher education institutions and quality assurance agencies in Europe, irrespective of their structure, function and size, and the national system in which they are located' (European Commission/EACEA/Eurydice, 2018). And further in the document: 'the ESG do not include detailed 'procedures'. . . rather the ESG recognize the primacy of national systems of higher education, the importance of institutional and agency autonomy within those national systems, and the particular requirements of different academic subjects' (European Commission/EACEA/Eurydice, 2018). ESG recommend that approaches to quality assurance should be harmonized and evaluation methods should be made more transparent, objective and independent. It is necessary in order to ensure trust in education quality between national education systems.
The national state accreditation practised in Russia is limited by strict requirements of the law, and it uses the same methods as state control and supervision, which means that, in fact, it cannot comply with international agreements until they are introduced in the law. But national professional-public accreditation, being established by employers' associations, doesn't take into account international experience either. It is worth noting that the state educational policy of the recent years has been encouraging internationalization of HEIs by increasing the number of foreign students and listings in international rankings. However, the indicators of international rankings differ from the indicators of state accreditation and effectiveness monitoring annually conducted by the Ministry of Education. It vividly reveals contradictions in the state educational policy. A similar situation can be observed with regard to accreditation. State accreditation doesn't account for the ESG either in the content, or evaluation methodology or structure, thus putting national and international approaches in opposition. For example, some provisions of the Statement of the Fourth Bologna Policy Forum adopted in May 2015 are not observed. 'We [the Ministers responsible for Higher Education and Heads of Delegation] will in particular give priority to: . . .Developing cooperation in quality assurance, with a view to further developing mutual trust in our education systems and their qualifications. We will encourage quality assurance agencies from participating countries to work towards inclusion in the European Quality Assurance Register (EQAR)' (Statement of the fourth Bologna policy forum Yerevan, 14-15 May 201514-15 May , 2015. Joining EQAR by two Russian accreditation agencies NCPA and AKKORK was not encouraged by the state; moreover, it is completely ignored by the state governing bodies. The official listing of an accreditation agency in EQAR involves regular (every five years) external evaluation, which confirms that the agency works according to international standards and evaluation methodology and the agency itself meets all the requirements. Thus, regardless of the fact whether the agency is national or international, its evaluation outcomes, that is, the quality of accredited programmes and HEIs, are recognized both nationally and internationally.
Another current tendency is joint accreditation or a joint process of agreeing standards and conducting evaluation procedures by agencies of two countries. Accreditation decisions are made separately by each agency. Such accreditation is preferable when an HEI implements double degree or joint programmes, and it is beneficial for HEIs participating in academic mobility programmes and enroling international students. This approach is much in demand now. The international accreditation of study programmes based on agreed standards may enhance the competitiveness of the national system of higher education and quality assurance of training highly qualified specialists. The process of higher school internationalization will gain momentum. And it is not so much policy as economy: international students are a good source of income, which means that international accreditation is going to be in high demand. In accreditation, as in all spheres of higher education, there is a tendency to internationalization and globalization. Therefore, striving of countries and HEIs for international cooperation will be expanding, and there will be interest in international and joint accreditation procedures.

Conclusion
Twenty years of accreditation in Russia is a sufficient period for analyzing the situation, but it is still early to draw final conclusions. During this time, different approaches have been tested, and sometimes these approaches contradicted each other. At present, there is a controversy whether it is possible to do without state accreditation altogether. Does state accreditation ensure the quality of education and is it the function of the state? The law Accreditation in Russian higher education provides for a variety of accreditation forms, and they are implemented in practice. Can they replace state accreditation? Professional-public and international accreditation evolved as evaluation of study programmes. Later on, the institutional approach was used, and since 2011, state accreditation of programmes replaced state accreditation of institutions. At present, there are two parallel forms of accreditation, each with its own goals and objectives: state and public/professional-public. They are also different in their key characteristics: (1) Mandatory/voluntary basis of accreditation procedures; (2) Subject of evaluation: compliance with the state educational standards in state accreditation: compliance with the standards of professional-public accreditation, and in case of international public accreditation, compliance with ESG or other international standards; (3) Composition of expert panels: representatives of academic community only, representatives of professional community only or representatives of all stakeholders including international experts; (4) Accreditation procedure: particular attention to documents, to learning outcomes (for example, employment) or to expert opinion about the quality of the teaching and learning process; (5) Accreditation decision and its consequences: in case of a positive decision of state accreditation, an HEI conforms its compliance with the Federal State Educational Standards; in case of a negative decision, the HEI loses a lot, even the right to carry out educational activities. The positive decision of professional-public accreditation increases trust and confidence of the state and employers in the quality of education; international accreditation enhances student mobility, makes the study programmes more recognized at the national and international levels and increases the export potential of study programmes.
State accreditation oversees the execution of the state order on training specialists. It will take the political will and time to legally eliminate discrepancies of this procedure with international procedures and to get rid of duplicating procedures of state accreditation, state control and state supervision. Professional-public accreditation carried out by an employer is certainly important for the programme graduates. But certification of qualifications for admission to the profession and position is even more important for them. An HEI will be interested in such accreditation only if the employer assumes not only the role of a controller, but also of a partner and an investor. International accreditation is important for an HEI for positioning itself at the international level, for raising its competitiveness and for attracting international students and teachers. International accreditation opens up opportunities for expanding international projects and academic mobility programmes. Which form is more effective and viable is hard to decide yet. It has to be understood that it is impossible to develop quality culture and quality assurance in education by administrative measures. The most urgently needed first step is to initiate a wide discussion of the issues identified above.