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Opinion/Report regarding the revision of the Legal Framework of Higher Education Degrees and Diplomas Decree-Law No. 65/2018 of August 16

Regarding the revision of the Legal Framework of Higher Education Degrees and Diplomas, Decree-Law No. 65/2018 of August 16, the following changes are highlighted:

It is guaranteed that the accreditation of study cycles leading to the Doctoral degree depends on the existence of appropriate high-quality research environments, notably considering the results of the evaluation of R&D units, regularly carried out by the Foundation for Science and Technology (FCT), I. P., and the broad integration of the faculty of that study cycle into units with a minimum rating of Very Good in the corresponding scientific area.

Thus, consolidating this culture of quality and merit and having concluded the initial 10-year period since the installation of A3ES, the time has come for the evaluation and accreditation of study cycles to evolve into a new phase of demandingness, including, notably, the verification of practices for strengthening scientific employment and the development of academic and scientific careers, as well as R&D capacity across all higher education institutions.

Considering the consolidation of the articulation between R&D activities and doctoral programs to be very important, and more specifically, the connection of the latter to R&D units, ensuring the integration of faculty and doctoral students in broad research contexts, the following is countered regarding the aforementioned changes:

  • If the current legislation is rigorously complied with, only institutions with research units rated “Very Good” or “Excellent” by the FCT will be eligible to teach 3rd cycle courses, thus forcing the closure of many doctoral programs, both in public and private institutions.
  • If this classification and, consequently, the multi-annual funding of research units are strongly conditioned by the existence of cut-off points for rigid percentage distributions, based on the available funding allocated, it is not reasonable for this FCT classification to be a decisive criterion for verifying the quality of advanced training in HEIs.
  • Similarly, and considering the qualitative result of the FCT evaluation of research units, it is not acceptable that a rating of GOOD, due to the inherent concept it conveys, is not sufficiently favourable to allow the creation of 3rd cycle courses.
  • It also makes no sense not to value research units external to the HEI submitting the proposal, which are well-rated by the FCT, and which include faculty from the proposed course, giving value only to the existence or non-existence of well-rated research units within the HEI itself. If the faculty members are researchers integrated into these external units, then it is in them that they develop their scientific production and, consequently, it is in these external units that they will develop the work leading to the doctorate of their advisees. If there is a commitment by these units to accept students as associate members while the work is underway, then the conditions will be guaranteed for integrated members (supervisors) and associated/collaborating members (advisees) to work in synergy and with common objectives. The fact that HEIs do not possess R&D units cannot be the limiting factor to their production of scientific knowledge, nor to their faculty’s capacity for advanced, quality human resource training. The FCT itself assumes this paradigm by allowing its doctoral scholarship holders to be linked to the research units of their supervisors, regardless of whether these are internal or external to the HEI that confers the academic degree.
  • If the evaluation and accreditation of doctoral programs stem from the ratings of R&D units—proposing, as mentioned earlier, that should this rule be maintained, it also apply to R&D units rated “Good”—then the evaluation and accreditation of doctoral study cycles by A3ES become indissolubly linked to the accreditation and evaluation of R&D Units by FCT. Consequently, the accreditation and functioning of a doctoral course follow directly from A3ES and start to follow indirectly from FCT, which introduces normative, temporal, and results duplication.

Should this principle be maintained, a model for evaluating doctoral programs would have to be defined jointly, or in articulation, between A3ES and FCT.

Also considering that: It is clarified that R&D activities integrated into the study cycle leading to the Doctoral degree may be carried out in any knowledge creation environment, including companies, technology interface centers, and healthcare units with relevant R&D activity, among other scientific and technological institutions, with a guarantee of adequate scientific guidance and without prejudice to the exclusive competence of higher education institutions to award academic degrees. (Decree-Law No. 65/2018 of August 16) and considering the diversity and specificity of some training areas, it is proposed:

  • The legislation contemplates the importance of R&D activities developed in national and international R&D contexts not accredited by FCT and that this applies to the evaluation and accreditation of doctoral courses where such a principle is justified.
  • Finally, and in summary, it is considered that the nature of the relationship between R&D units, evaluated by FCT, and doctoral programs is not clarified.

Is it a hosting relationship of the doctoral program by the R&D unit(s)?

Is it a principle of broad integration of the faculty of that study cycle into R&D units belonging both to the promoting institution of the program and to other institutions? In this case, should these other HEIs maintain some kind of link with the doctoral program in question? Or function, as currently, as institutions that integrate their supervising researchers and their advisees?

Will the lack of articulation (normative and practical) between the evaluations by A3ES and FCT continue?

Is it foreseen that a doctoral program can link to international research networks and not specifically those evaluated by FCT?

Regarding, yet and more specifically, the explicit claim in the draft revision of the Legal Framework of Higher Education Degrees and Diplomas, from 2018, it is intended to mention:

Considering that, currently, doctoral programs are sought by younger candidates, with an overall decrease in training in previous cycles, the implementation of a 1st curricular year, with an adequate number of Course Units (UC), contemplating a Seminar or Laboratory, seems appropriate. Attendance of the curricular year allows for greater integration and better monitoring of doctoral students, namely international ones, familiarization with research methodologies and specific themes, and, in many cases, the choice of supervisor.

July 2021, Isabel Babo, José Alberto Duarte, Gil Alcoforado