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Higher Education in Europe

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Bologna and Beyond: A Comparative Study Focused on UK and Spanish Accounting Education
Jos Mara Gonzlez Gonzlez , Jos Luis Arquero Montao & Trevor Hassall Published online: 27 May 2009.

To cite this article: Jos Mara Gonzlez Gonzlez , Jos Luis Arquero Montao & Trevor Hassall (2009) Bologna and Beyond: A Comparative Study Focused on UK and Spanish Accounting Education, Higher Education in Europe, 34:1, 113-125, DOI: 10.1080/03797720902747082 To link to this article: http://dx.doi.org/10.1080/03797720902747082

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Higher Education in Europe, Vol. 34, No. 1, April 2009

Bologna and Beyond: A Comparative Study Focused on UK and Spanish Accounting Education
LEZ GONZA LEZ, JOSE MARIA GONZA LUIS JOSE O and TREVOR HASSALL ARQUERO MONTAN
The Bologna Process is fostering a change in higher education systems in order to attain the objectives of educational convergence, comparability and mobility of students and academics. As a consequence, the structure of degrees, syllabuses, pedagogy and evaluation and assessment systems (for students, teaching staff and programmes) must be revised. The present paper presents a comparative analysis from an accounting education perspective of the educational context in the United Kingdom (UK) and Spain identifying differences in their institutional characteristics, culture, etc. This paper evidences that a comparative analysis of the conditioning factors of the change will be necessary to facilitate any implementation.

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Introduction
By signing the Bologna Declaration in 1999 European Union countries faced an important challenge: the harmonization of their higher education systems through the establishment of the European Higher Education Area (EHEA). Many aspects of the existing higher education systems are being reviewed and modified in the European countries, in order to achieve the strategic objectives of the EHEA. These objectives are: (1) a comparable system of higher education degrees; (2) a two-cycle structure of the university studies; (3) the implementation of the European Credit Transfer System; (4) the quality assurance of higher education systems; and, (5) to foster the mobility of students and academics which will promote the free movement of human capital. Whereas the higher education systems of several European countries are well aligned with the requirements established by the Bologna Declaration, other countries must implement major changes in order to achieve convergence. In many cases, those countries that still have a longer way to go are adopting strategies developed by countries that are already nearer to the philosophy of the EHEA. The implementation of such solutions and the results obtained could be very different from the original outcomes due to the peculiarities of the new contexts in which they are being applied. In these circumstances, comparative studies of higher education systems that are converging to the EHEA become key tools, because they allow to us to analyze the differences between the concerned countries. They also enable a diagnosis as to whether the proposals to implement changes similar to those implemented by other countries might contribute to the achievement of the desired objectives. The aim of this paper is to create a comparative study of the higher education systems of the UK and Spain, focusing the analysis on accounting education. This study should, then, allow the identification of the differences and similarities that can guide the development of their broader strategies for achieving the final objective of the Bologna Declaration. The remainder of the paper is structured as follows: the next section is an individual
ISSN 0379-7724 print/ISSN 1469-8358 online/09/010113-13 DOI: 10.1080/03797720902747082
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description and analysis of the current situation for each strategic objective of the EHEA in the higher education systems of the UK and Spain; finally, the conclusions and recommendations arising are presented.

A Comparative Analysis of the British and Spanish Higher Education Systems

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The higher education system of the UK has developed over the last two decades to the stage where consideration can be given to higher education as an industry. According to Gammie and Gammie (2002), academic knowledge in the higher education sector has been re-organized along a utilitarian trajectory such that, at the macro level, the dominant legitimating idea of public higher education has changed from that of a social institution to that of an industry. The regulation of the higher education system of the UK, the Further and Higher Education Act of 1992 (UK Parliament, 1992), established universities as the single sector for higher education which increased the competition among institutions for customers, i.e. students. According to this perspective on universities, institutions that do not achieve a certain quality level will lose their students to the advantage of institutions with a higher quality level. This infers that the universities with lower quality standards will have to reduce their capacity or eventually might disappear. The Further and Higher Education Act the National Committee of Inquiry into Higher Education has also recently influenced the development of the higher education system in the UK through the recommendations collected in the Dearing Report (1997). Subsequently the guidelines established by the Bologna Declaration have influenced the agenda of higher education in the UK. In Spain, the first big step, the coming into effect in 1983 of the University Reform Organic Law (LRU), was instrumental in establishing the current position with regard to the Spanish higher education system (Ministry of Education and Science, 1983). The main changes brought about by the LRU are summarized by Mora (1999) and Mora and Vidal (2000) as follows:

N N N N

Universities become autonomous entities; Responsibility for universities is transferred from the government to the autonomous regions; The establishment of private universities is permitted; Power is shared: the central government, regional government and the universities.

At the end of 2001, the LRU was replaced by the University Organic Law (LOU) (Ministry of Education, Culture and Sport, 2001). This new law has established several objectives for the Spanish higher education, including:

N N N N

The improvement of the quality of educational provision and research; The promotion of the mobility of students and teachers; The establishment of the distribution of responsibility between government and university institutions; The promotion of the integration of the Spanish higher education system into the EHEA.

However, this law has been the subject of numerous criticisms resulting in the initial resistance of the university community. Over the last few years, the LOU has been developed by several Royal Decrees and is currently undergoing a modification process.

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A Comparable System of Higher Education Degrees

The Bologna Declaration establishes that the higher education degree systems must be understandable and comparable among the countries belonging to the European Union. To facilitate this, one of the proposed measures has been the establishment of the Diploma Supplement. In the UK, higher education degrees are mainly: the Bachelors degree (or Bachelors Honours degree where studies are more specialized) for students that have completed their undergraduate studies which usually last either three or four years; Masters degrees which are conferred after one or two years study following the Bachelors degree. The final stage is the Doctorate of Philosophy, which is conferred after three years of further study beyond the Masters degree and the subsequent successful presentation of a thesis. The Diploma Supplement has not been implemented in the UK. However, since 2002/2003, institutions have been expected to provide a Progress File, which includes a transcript recording the students achievement (Eurydice European Unit, 2004). Specifically, according to the recommendations of the National Committee of Inquiry in Higher Education (1997), the guidelines for drawing up of the Progress File establish that this document must contain a transcript recording student achievement and a personal development plan by which students can monitor, build and reflect upon their personal development (Quality Assurance Agency for Higher Education, 2002). Therefore, the purposes of the Progress File in the UK and the Diploma Supplement for the EHEA are similar. Traditionally, in Spain, and until the regulation contained in the new Royal Decrees1 comes into effect, the higher education degrees are as follows: Diplomado, for students having completed three years of study concerning basic knowledge and general training. This is followed by the Licenciado2, which is conferred after five years of study and is concerned with a more specialized education. The final stage in the Spanish system is the Doctorate level, whose main purpose is to educate students about research techniques and skills in a specific area of knowledge. Unlike in the UK, in Spain a document similar to the Diploma Supplement or the Progress File does not exist. However, in accordance with the Bologna Declaration, the Royal Decree 1044/2003 (Ministry of Education, Culture and Sport, 2003a) established the procedure for the drawing up of the European Diploma Supplement to be provided by university institutions starting in 2003/2004. This Royal Decree specifies the eight sections that the Diploma Supplement must contain, including information about the degree level, the qualifications obtained, the function of the degree and details concerning the national higher education system. Currently, higher education degrees in the UK and in Spain are quite different: whereas students in the UK obtain the degree a Bachelors Degree when they complete their undergraduate studies, Spanish students can obtain the degrees of Diplomado or Licenciado for a similar level of studies. Undergraduate studies students in the UK can continue and obtain a Masters degree and a Doctorate, whereas Spanish students can only obtain the degree of Doctor after the undergraduate stage. The length of studies clearly differs between UK (three years to obtain a Bachelors Degree in Accounting)
These Royal Decrees are discussed in the next subsection. If students are Diplomado and wish to continue their studies in the same speciality, they have to complete only two years of study to obtain the degree of Licenciado.
2 1

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and Spain (five years to obtain the degree of Licenciado in Management and Business Administration or three years to obtain the degree of Diplomado in Business Studies). With specific reference to the Diploma Supplement, interest in this initiative had emerged in the UK before the Bologna Declaration, as can be evidenced in the recommendations of the National Committee of Inquiry in Higher Education (1997). However, it is clear that current progress towards the implementation of a Diploma Supplement in Spain is only at the planning stage.

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The Two-Cycle Structure

The Bologna Declaration structures higher education into two specific cycles: in Spain, it is the Grado and Posgrado, the cycle of Posgrado can be differentiated by the degrees of Master and Doctor; in the UK, higher education has been organized in two cycles for quite some time and it fits with the model established by the Bologna Declaration (Eurydice European Unit, 2004). The UK Bachelors degrees fit into the cycle of Grado, and the degrees of Masters and Doctorate of Philosophy fit in the cycle of Posgrado. We can identify several sources of authority that have influenced this development in the UK. Regarding accounting degrees, it is possible to identify five sources of authority. The first is the government, which specifies the framework of the higher education through regulation. Secondly, employers issue pronouncements and reports concerning higher education. In particular, employers highlighted a gap between what accountants do and what accounting educators teach. They have underlined the need for an improvement in the communication, intellectual and interpersonal skills of students. The Quality Assurance Agency for Higher Education (QAA) is the third source of authority, which issues the Subject Benchmark Statements (QAA, 2000). These statements describe the nature and characteristics of programmes in a specific subject; providing also general guidance for articulating the learning outcomes associated with the programme (although not detailed specifications for each subject). Professional and regulatory bodies3 are also a source of authority in higher education in the UK. These bodies establish the accreditation criteria that students must pass in order to qualify as a practising accountant. For instance, in order to qualify as a Chartered Management Accountant, applicants must complete the examinations and practical experience guidelines established by Chartered Institute of Management Accountants (CIMA). In this sense, CIMA assesses the professional competence of applicants. The final source of authority is the university itself, which establishes the university accounting curriculum. Universities consider recommendations from the other sources of authority and prepare their own university curriculum development policies. For example, Sheffield Hallam University (2003) establishes and carries out the following key principles of its curriculum development policy statement: the international context; equal opportunities; and the wider environment. In the case of Spain, the higher education structure does not fit with the model established by the Bologna Declaration. Thus, the Spanish system is currently structured in three cycles through which students can obtain the degrees of Diplomado, Licenciado and Doctor. The Royal Decrees 55/2005 and 56/2005 (Ministry of
3 In Accounting, the most influential professional bodies are: Chartered Institute of Accountants in England and Wales (ICAEW); Chartered Institute of Management Accountants (CIMA); Association of Chartered Certified Accountants (ACCA); Association of Corporate Treasurers; Association of Taxation Technicians; and Chartered Institute of Public Finance and Accountancy.

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Education and Science, 2005a, 2005b) were approved in Spain to establish and regulate higher education to facilitate the awarding of the degrees of Grado and Posgrado. These decrees structure higher education according to the Bologna Declaration, although they will not come into effect in Spain until the 20082009 academic year. With regard to sources of authority in the development of the curriculum it is possible to highlight only two sources in the Spanish context. The first of them is the government, who established two types of general guidelines: common guidelines which are concerned with all higher education degrees in general; and specific guidelines for each individual higher education degree. The education plans for obtaining the degrees of Licenciado in Management and Business Administration or Diplomado in Business Studies must conform to the common and specific guidelines established by the government. The second source of authority is the university itself, who establishes the specific curriculum for each degree within the requirements set by the general guidelines. A comparative analysis of the higher education structure in the UK and Spain evidences that important differences exist between them. Whereas the changes necessary in the UK will be reduced because its higher education system was traditionally structured in two cycles, a transitional period has been opened in Spain for introducing the new two-cycle structure. The main consequences of this change in the Spanish system are the modification of the higher education degrees. The Diplomado degrees will be suppressed, the length of higher education studies for obtaining the Licenciado degree will be reduced to four years study and the Masters degree will be established. Also, the government is currently reviewing and modifying the common and specific general guidelines to adapt curriculum to the new structure of higher education. There are important differences between the sources of authority for curriculum between UK and Spain. Employers, the QAA and professional bodies in the UK have authority through their pronouncements, subject benchmark statements and accreditation criteria respectively. In Spain, concerning accounting in particular, employers are not encouraged to participate in the design of the curriculum because education planning implies a political negotiation for the distribution of power among the respective academic departments and they do not want the participation of external agents. Noticeably, the National Agency of Assessment of the University Quality and Accreditation (ANECA) hasnt issued any statement similar to the subject benchmark statements issued by the QAA in the UK. Also in Spain there is not a professional association of accountants with the power to impose its criteria on the degrees in business. In Spain, the influence that these existing associations can exercise is minimal due to the political character of the negotiations concerning the education plans, except in the specific case of audit professionals. In order to be registered in the Official Register of Auditors for practising, auditing applicants must pass an examination of professional aptitude that is controlled by the Institute of Accounting and Auditing.

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Curriculum and European Credit Transfer System (ECTS)

The ECTS constitutes an educational model focused on the students work, which implies the orientation of education programmes and methodologies to the students learning combined with the establishment of an assessment system comparable within

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TABLE 1. TYPICAL EDUCATION PROGRAMME IN ACCOUNTING IN THE UNITED KINGDOM Year one Year two Mandatory units: Financial and business environment, information management, financial accounting, management accounting, quantitative analysis. Elective units (one from): Business and company law, language. Mandatory units: Applied management accounting, financial accounting and reporting, organizational behaviour, business and company law. Elective units (three from): Accounting information systems, auditing, credit analysis, e-business, financial institutions and markets, financial modelling, information systems development, management decision support, operations management, principles of investment, principles of marketing, taxation, language. Optional work placement is typically taken as a team member of either an inhouse finance department or in commercial accountancy practice both in smaller local accounting firms and larger international practices. Mandatory units: Business strategy and management accounting, corporate finance, financial decision-making, financial reporting, work-based learning. Elective units (two from): Audit and tax practice, creating effective information systems, e-commerce management, international financial accounting, corporate treasury management, international financial markets, management science applications, strategic management of information resources, takeovers, mergers and corporate restructuring, language.

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Year three Final year

Source: Programme in Accounting Degree of Sheffield Hallam University (UK), 2008.

the EHEA. In particular, the European credit is the unit of measurement of students work in completing the education programme. This unit takes into account the time devoted for students to practical or theoretical lectures, study, tutorials, seminars, works, practices and the examination preparation. The number of hours per credit will vary between twenty-five to thirty, so, for example, the number of credits necessary for obtaining the degree of Grado will vary between 180 and 240 European credits. In the UK, in order to obtain the Bachelors Honours Degree in Accounting, a typical programme4 is structured over three or four years, in which students must pass core and optional modules, students may also undertake a work placement (Table 1). In the UK, over recent years student numbers have increased while funding has decreased. In order to cope, many universities have decided to opt for a more independent learning approach. As regards pedagogy, teachers deliver a one-hour lecture to large groups of students and seminars to smaller groups. In these seminars students do exercises, case studies, cooperative learning and role-plays, and they may use the internet and interactive DVDs. The assessment system in the UK was traditionally focused on a three-hour written examination. This has developed to include continuous assessment with units containing between 25 per cent to 100 per cent coursework. This would include objective testing, the preparation of case studies, written reports and oral presentations both individual and group (Hassall, 2006). In Spain, there is a credit system, although the definition of the credit is different to the European credit. The new definition of the credit supposes a change in the lecture and seminar activities and also in the methodology and assessment. One credit in Spain is currently ten lecture and seminar hours. For this reason the Spanish government
4

The authors have considered as a reference the education plan of Sheffield Hallam University (UK).

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TABLE 2. TYPICAL EDUCATION PROGRAMME IN MANAGEMENT AND BUSINESS ADMINISTRATION IN SPAIN Degree Licenciado in management and business administration (Total credits: 334; Total mandatory credits: 252) Accounting Units Financial Accounting I Financial Accounting II Cost Accounting I Cost Accounting II Financial Accounting III Accounting Analysis Total mandatory credits: Auditing I Auditing II Tax Accounting Management Control International Accounting Accounting of societies Special Questions of Accounting ERP Systems Internal Auditing Total elective credits: Year 1 1 2 2 4 4 3, 3, 3, 3, 3, 3, 3, 3, 3, 4, 4, 4, 4, 4, 4, 4, 4, 4, 5 5 5 5 5 5 5 5 5 Credits 6 6 6 6 9 9 42 6 6 6 6 6 6 6 6 6 54 Character Mandatory Mandatory Mandatory Mandatory Mandatory Mandatory Elective Elective Elective Elective Elective Elective Elective Elective Elective

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Source: Programme in Management and Business Administration Degree of University of Seville (Spain) (2008).

approved the Royal Decree 1125/2003 which introduced the ECTS in Spain and established the assessment scale for higher education degrees (Ministry of Education, Culture and Sport, 2003b). According to this decree, the adaptation of the Spanish higher education to the ECTS must be carried out before 1 October 2010. Currently, each unit of the education programme for the degree Licenciado in Management and Business Administration has a credit number corresponding to lecture and seminar hours. The units can be mandatory or elective. We can observe an example of the accounting units5 in Table 2. From the mid-1980s, the Spanish system changed to become a mass higher education system that has conditioned the same pedagogical methods. Accounting education has been mainly based on practical or theoretical lectures gave by teachers and this has not changed in the current system. Many classes are delivered to more than 100 students and, therefore, methods that include active participation of students are not widespread. Given this kind of pedagogical method, the assessment results mainly in three or four hours written examinations in which teachers try to assess the students specific knowledge of accounting. Although the EHEA pursues a comparable system of degrees, the higher education plans in accounting in the UK and in Spain present important differences in relation to their content, pedagogical methods and assessment. Whereas the Spanish system is based on theoretical and practical lectures and written examinations, higher education in the UK has incorporated other activities such as seminars, case studies, role plays, etc. In addition, the assessment system in the UK incorporates both specific knowledge in accounting and communication, teamwork and interpersonal skills of students.
5

The authors have considered as a reference the syllabus of the University of Seville (Spain).

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Finally, although the educational objectives to be accomplished by the educational experience of students are similar in Spain and the UK (Hassall et al., 2005), there are differences in the personal characteristics between UK and Spanish students that could influence the effectiveness of the implemented changes in one context, even when those changes were successful in the other. For example, students in the UK and Spain display different learning approaches (Arquero et al., 1998) and profiles of communication apprehension (Hassall et al., 2000), which is essential for the design of education activities that require communicative abilities.

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Mobility of Students and Academics

The Bologna Declaration promotes the mobility of students through the ECTS that is common in the EHEA and for academics through the recognition and assessment of visiting periods in European institutions of research, education and training. Close to 12 per cent of higher education students in the UK, at the beginning of 2000s, came from other countries and this indicator has followed an upward trend in recent years (Higher Education Funding Council for England, 2004). Also, traditionally, students from the UK seek to attend universities situated outside their city of origin. The Spanish case is very different. The percentage of foreign students at Spanish universities is lower than in the UK, and students normally study in universities in their city of origin. This aspect is an important restriction for Spanish students when they choose their higher education degree. The higher mobility in the UK compared to Spain is also evidenced in relation to academics. Academics in the UK might well do their doctorate studies at a university other than that of their undergraduate studies. The way in which the contract of employment is structured also allows academics in the UK to transfer to other universities during their academic career. In Spain most academics complete their doctorate studies at the same university where they did their undergraduate studies. Although the LOU has promoted the recruitment of academics with corporate style contracts, traditionally the aim of Spanish academics has been to become a civil servant (tenure) because this status guarantees the possibility to stay at the same university throughout their academic career. Traditionally, the Spanish prefer their employment to be stable both in terms of the organization that employs them as well as in terms of geographic location. Similarly, academics have looked for this in Spanish universities and the Spanish university promotion system has contributed to perpetuate this tendency. There seems to be an implicit agreement among Spanish universities (that is to say, an agreement incorporated in Spanish university culture) which establishes that students who completed their doctorate and undergraduate studies at a particular university have priority for teaching contracts at that particular university. In summary, universities would rather contract or promote their own teachers than contract or promote teachers from other universities even if those present better qualifications. Contrary to evidence of a mobility culture of both students and academics in the UK, in Spain the permanence of residence in the city of origin is highly valued both by students and teachers.

Quality Assurance
According to the Bologna Declaration quality assurance entails the development of criteria and methodologies comparable throughout the EHEA. At the meeting in

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TABLE 3. QUALITY ASSURANCE IN HIGHER EDUCATION IN THE UK Process Internal quality assurance processes Institutional-level quality review Subject-level quality review Professional accreditation Research assessment Undertaken by The university or college, including external examiners, and internal validation and review of programmes QAA QAA (will end in 2005) Professional and statutory bodies Funding bodies using peer review

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Source: Higher Education Funding Council for England (2004, p. 14).

Berlin in 2003, the Ministers of the Bologna Process signatory states agreed to develop standards, procedures and guidelines for quality assurance. In order to achieve this they have counted on the collaboration of the European Association for Quality Assurance in Higher Education (ENQA). In 2005, this association published a report that presents European standards and guidelines for internal and external quality assurance of higher education as well as the European standards and guidelines for external quality assurance agencies (ENQA, 2005). In the UK, several organizations that take part in quality assurance in higher education (Table 3) can be identified. Each university is responsible for ensuring compliance with the standards of quality assurance. The QAA, which was established in 1997, and it is a member of ENQA responsible for reviewing academic standards and quality in higher education through a specific process, the institutional audit. University institutions publish standard information on the quality and standard of their programmes. The QAA verifies the reliability of this information as part of the institutional audit. Periodically, university league tables are published in which universities are ranked partly as a function of their quality level. This constitutes a reference point for students when they are choosing the university where they would like to study. Other funding bodies6 are responsible for assessing the quality of the university. Research assessments are carried out by panels of academics and experts approximately every five years through the Research Assessment Exercise (RAE). The RAE, whose objective is to provide ratings of the quality of research conducted at universities, considers principally the research strategy and research outputs (four per academic) which are then rated from A (highest) to D (lowest). The funding research is allocated as a function of these ratings. Normally only A and B ratings are subsequently publicly funded. In Spain, the LOU established the quality assurance of Spanish higher education as one of its main objectives. The National Commission of Assessment of the Research Activity (CNEAI) has been responsible for the research quality assessment since the beginning of 1990s. Similar to the UK, Spanish universities are responsible for internal quality assurance. The National Agency of Assessment of the University Quality and Accreditation (ANECA) is the organization responsible for assessing and verifying the higher education programmes and the education and research activities carried out by academics as well as the activities, programmes, services and management carried out by higher education institutions. Regarding research activity, academics can submit their research CV every six years to the CNEAI. If the assessment is positive teachers will get awarded a sexenio, which

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entails a short salary supplement. The assessment is carried out by eleven committees which each specialize in a specific knowledge area. The UK was one of the first countries to implement a quality assurance system for higher education. In the Spanish case, the interest in this aspect originated in the mid1990s, when the Spanish government approved the National Plan of Quality Assurance for Higher Education through the Royal Decree 1947/1995 (Ministry of Education and Science, 1995). However, quality assurance in Spain was not promoted until the LOU was approved. This law has promoted the implementation of an effective quality assurance system that has become widespread in all the regions of Spain. In general terms, it can be highlighted that QAA and ANECA are in charge of most of the responsibilities concerning the quality assurance of higher education in the UK and Spain respectively. Both QAA and ANECA are members of ENQA and therefore share the same general guidelines for developing their functions, which contributes to the homogenization of quality assurance in the two countries. However, there are also important differences specifically in relation to the accreditation process for academics. Academics in the UK are promoted mainly through an interview system within broad guidelines established by universities. In the case of Spain, academics must get the necessary accreditation of ANECA for a promotion. The ANECA accreditation assesses the education and research CV of each academic based on specific criteria established for each contract category. Concerning research activity, assessment systems exist in both countries the RAE in the UK and CNEAI in Spain but there are significant differences between them. The assessment period in the UK is five years and the RAE takes into account both the research strategy and the research outputs of the university; the assessment cycle in Spain is six years and the assessment process is specifically focused on selected research outputs of the individual academic.

Conclusions
In recent years educational systems, particularly in advanced economies, have been the subject of substantial reform at all levels: primary; secondary; and university levels. In the latter case, one of the main aims of the development process has been the improvement of the quality of educational provision and the reduction of the gap between higher education programmes and the requirements of employers. This paper has analyzed in a comparative way the higher education system of the UK and Spain, in general, and accounting higher education in particular, following the structure of strategic objectives established in the Bologna Declaration. These strategic objectives are deeply inter-related and are an integral part of efforts towards achieving the EHEA, which will be implemented in 2010. The results suggest that the convergence process of higher education in the UK is currently more advanced than the Spanish one. Two aspects have contributed to this evolution. First, the traditional characteristics of the higher education system in the UK fit with the requirements for the implementation of the EHEA. Thus, higher education in the UK had already introduced a similar document to the Diploma Supplement (the Progress File), it was structured in two cycles, and the learning methodology and the assessment system are
6 They are: Higher Education Funding Council for England; Higher Education Funding Council for Wales; Department for Employment and Learning; and Scottish Higher Education Funding Council.

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oriented towards the requirements for the implementation of the ECTS. Also, the UK has been one of the first countries to consider quality assurance of their higher education system. Second, some factors in the context and culture of higher education in the UK have also facilitated the convergence process. For example, the mobility of students and academics in the UK has historically been promoted and is culturally well accepted. Also, the change of the higher education system in the UK from that of a social institution to that of an industry is in accordance with the higher competitiveness required by the implementation of the EHEA. In Spain, the movement of the higher education system towards the EHEA has been fostered as a result of the coming into effect of the LOU in 2002 and the subsequent normative developments; where the two-cycle structure of higher education, the Diploma Supplement and the ECTS are regulated, several factors negatively affect the implementation of such changes. One major factor is that, contrary to the UK, mobility in Spain is not as culturally accepted. In the area of quality assurance and assessment, the ANECA was constituted in order to guarantee and assess the quality and the competitiveness of the Spanish higher education. However, there is no tradition of such kinds of evaluations. The accounting profession internationally has been involved in a process of harmonization created by the global financial market (International Federation of Accountants (IFAC), 2002). The creation and implementation of standards has been the focus of considerable professional and academic activity. However, it is clear that comparably little interest has been shown in the harmonization of standards for the education of accountants. Needles et al. (1992, p. 211) state: Gaining an understanding of the various practices in the education of accountants throughout the world may provide insight into the differences in applying accounting and auditing standards. More importantly they then continue: But a fundamental issue arising in the efforts to harmonise standards for accounting and auditing relates to the extent to which the differences in the application of these standards may exist due to the differences in the education and qualifications of accountants and auditors (p. 211). Whilst the above comments were predominantly aimed at professional qualifications there will inevitably be a consequential impact on the content and format of the education that future accountants receive during their studies. Albrecht and Sack (2000) stated in their recent report that university accounting education in the USA has problems in the areas of, course content and curricula, pedagogy, skill development, technology, faculty development and reward systems and strategic direction. There are currently important differences between accounting education in the UK and Spain (e.g. the inexistence in Spain of a specific accounting degree and professional associations of accountants with the power to impose their criteria on the degrees in business or on professional accreditation). The implementation of the EHEA will entail a change of the learning methodology and the assessment system in accounting education, similar to the change that have been already implemented by universities from the UK; where the learning methodologies are more active and the specific knowledge and other skills of students are assessed. This proximity of certain educational systems to the objectives proposed by Bologna is one of the main reasons leading to universities located in countries where the gap to adopt educational solutions that are effectively working in their original contexts is bigger. However, there could be sound contextual and cultural differences, suggesting

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that: (a) importing solutions without taking carefully into account the specific context in which those changes are going to be implemented might not be the answer; and (b) a prior knowledge of environmental conditionings (personal, cultural and organizational) is essential. For example, in Spain the LOU is trying to promote the mobility of students and teachers in order to achieve the aim proposed by the Bologna Declaration. The Spanish government has to design a financing system to achieve this aim and they can take as a reference the efficient British financing system. The problem is that the mobility of students and teachers doesnt depend only on this financing system but also the mobility culture among teachers and students. Before implementing this financing system it is necessary to also change the settlement culture that exists among teachers and students in the Spanish university system. If the Spanish government does not try to change this culture, it is probable that the implementation in Spain of a financing system similar to the one in use in the UK will not be successful.

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