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Academic Accountability and University Adaptation: The Architecture of an Academic

Learning Organization
Author(s): David D. Dill
Source: Higher Education , Sep., 1999, Vol. 38, No. 2, Changes in Higher Education and
Its Societal Context as a Challenge for Future Research (II) (Sep., 1999), pp. 127-154
Published by: Springer

Stable URL: https://www.jstor.org/stable/3447930

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LA Higher Education 38: 127-154, 1999. 127
P 1999 Kluwer Academic Publishers. Printed in the Netherlan

Academic accountability and university adaptat


architecture of an academic learning organizatio

DAVID D. DILL
Professor of Public Policy Analysis and Education, University of North Carolina at C
Hill, Abernethy Hall, Chapel Hill, NC 27599-3435 (Phone: (919) 962-6848; Fax:
(919) 962-5824; E-mail: david_dill@unc.edu)

Abstract. Over the last decade universities have been subjected to various forms of a
accountability designed to maintain or improve the quality of their teaching and
A shared perspective of many of these accountability processes is that universiti
become skilled at creating knowledge for the improvement of teaching and learn
at modifying their behavior to reflect this new knowledge. In short, that universit
become "learning organizations." What are the organizational characteristics of an
learning organization? The paper will address this question by reviewing the adap
organizational structure and governance reported by universities attempting to imp
quality of their teaching and learning processes.

Introduction

In a now classic article in the Harvard Business Review David Garvin (1993)
defined a "learning organization" as "an organization skilled at creating,
acquiring, and transferring knowledge, and at modifying its behavior to
reflect new knowledge and insights" (p. 80). As Garvin argued, the definition
requires two essential conditions: first, for organizational learning to take
place new ideas are essential, but second these ideas must be a trigger for
organizational improvement - that is, the new ideas must lead to accompany-
ing changes in the way the organization's work is accomplished. These are
surprisingly stringent conditions and as Garvin noted they rule out a number
of obvious candidates as learning organizations including universities. For
example, most universities have not developed systematic processes either
for creating or for acquiring new knowledge to better their core processes
of teaching and learning or for applying new knowledge in improving
instruction.
As Garvin wrote, however, universities in many countries were coming
under increasing external pressure in the form of performance indicators,
teaching assessments, and academic audits designed to maintain or improve
the quality of teaching and learning. These new public policy instruments of

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128 DAVID D. DILL

the "evaluative state" (Neave 1988) are reshaping the environment in


academic institutions carry out their basic processes of teaching and l
While the specific mechanisms of academic accountability implemen
countries such as the UK, continental Europe, the Nordic Countries,
vary, they appear to embody similar assumptions about university b
That is, that: l)methods of measurement exist by which profes
determine that academic quality has been attained; 2)processes can be
mented to encourage the exchange and transfer of knowledge perti
academic quality; and 3)this knowledge can be applied to the improv
of teaching and learning. In short, the perspective on academic accoun
that is influencing the development of quality assurance policies in a
of countries appears to assume that universities - with regard to th
processes of teaching and learning - can become learning organizati
The traditional means of assuring academic quality within univer
were frequently passive and implicit. The university has been comm
characterized as a decentralized, "loosely-coupled" organization
professors are accorded a significant degree of autonomy in their wo
where the quality of teaching and learning was maintained principa
reliance on shared norms and disciplinary traditions (Clark 1983). H
there is emerging evidence that the traditional structures and gove
processes by which academic quality had traditionally been assured
changing under the influence of the new policy instruments of aca
accountability (Dill 1997).
One means of understanding the impacts of these accountability
on universities therefore would be to view them as organizational a
tions needed to adjust to a new, more competitive environment. Fro
perspective, the structural adaptations within universities relevant
improvement of teaching and learning may offer empirical clues as
essential design elements of an academic learning organization. If
been traditionally argued, the core academic processes of univer
what Burton Clark (1983) has usefully called the "shop floor" of aca
institutions - are everywhere the same, then knowledge about struc
and governance adaptations necessary to assure the quality of teach
learning in the new competitive environment may also have more g
applicability.
The purpose of this paper is to begin to define the organizational chara
istics of an academic learning organization, a new and emerging per
in higher education research. To that end the theory and research on
organizations will be used to analyze the changes in academic struct
governance reported by a sample of universities subject to the new
anisms of academic accountability. The universities are drawn from

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 129

of institutional cases developed as part of a project being conducted


Institute for Management in Higher Education (IMHE) of the OECD.1
case was written to illustrate the impact of academic quality assessm
institutional management and decision-making. The section to follow
review the theoretical and empirical literature on learning organizatio
means of clarifying the concept and developing a framework for the a
The succeeding section will apply the framework to analyze the repo
organizational changes in the sample of universities. The concluding
will explore the implications and limitations of the analysis.

The learning organization

Literature on the learning organization and organizational learning

The concept of the "learning organization" has recently received ext


emphasis in the organizational literature.2 While the term "learning o
zation" is relatively new, the concept builds upon an earlier more ex
literature on "organizational learning" (Cohen and Sproull 1996).
are important distinctions between the two literatures, however, an
differences warrant further clarification.
The literature on the learning organization, characterized by the
ings of Senge (1990a and b) attempts to define and create an ideal ty
organization in which learning is maximized. The literature has an a
orientation, in which there is a close association between generating o
zational change and studying the consequences of these changes. As a
the learning organization literature is often eclectic, evaluating idea
concepts according to their applicability rather than through theore
rigorous and grounded research studies. This applied orientation is ref
in the authors of the literature who are often consultants or senior m
in the field. Not surprisingly, a frequent criticism, even by those who sha
applied orientation (Garvin 1993), is that the literature is often too ab
and focused more on releasing human potential than on the unde
processes that are linked to organizational outcomes.
The literature on organizational learning, characterized by the many
ential writings of March (Levitt and March 1988; March 1991;
Sproull and Tamuz 1991), studies the phenomena of learning within o
zational contexts. This broader and deeper literature is oriented
acquiring knowledge about organizational learning and is consequent
more theoretical and in a number of areas much more empirically gr
than the work on learning organizations. The literature on organizat
learning has been usefully partitioned by Huber (1991) into four cons
or sub-fields - knowledge acquisition, information distribution, infor

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130 DAVID D. DILL

interpretation, and organizational memory.3 These categorizations a


in locating the intellectual foundations of the current concept of th
organization as well as in providing the basis for a framework wit
academic organizations may be systematically studied.

Conceptualizing the learning organization: Contributions of the


organizational learning literature

The broader literature on knowledge acquisition within organizatio


1991) provides a useful theoretical context within which to clarify the
of the learning organization. Organizations regularly engage in a
activities to acquire potentially useful knowledge. These include att
learn through direct experience within the organization, for examp
organizational experiments with new processes or products, or th
systematic study of core processes as a means of improving them,
currently fashionable technique of continuous quality improvemen
zations learn from outside the organization by systematically sea
potentially useful knowledge. The concept of benchmarking is an
of this purposeful process. As Garvin (1993) suggests, a major dis
between the general literature on organizational learning and the c
the learning organization, is that the latter is particularly concerne
purposeful and systematic acquisition of internal and external know
of the processes and structures that will promote these activities.
The organizational learning literature that explores how organi
acquire knowledge internally through direct experience is especiall
to the concept of the learning organization. Earlier theoretical w
experimenting or "self-designing" organizations (Wildavsky 1972;
Nystrom and Starbuck 1976), were important precursors to th
interest in the learning organization. This literature articulated the
ential line of reasoning that organizations which systematically exp
with internal structures and processes enhanced their adaptabilit
changing environments. Ironically, Huber (1991) writing at the sam
Senge's (1990a and b) work on the learning organization was first
noted:

The proposal that organizations should operate themselves a


menting organizations has had almost no effect on either prac
research. But the utility of many novel ideas is not immediate
nized - there may be instances or conditions in which experim
organizations do or might thrive and survive.... (p. 94)

The view that organizations can adapt themselves through their ow


ence subsequently became a cornerstone assumption of the "resou

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 131

view of the firm (Demsetz 1991). This literature argues that the c
titive success of an organization is influenced by how it configure
manages its resources, especially human resources. Researchers uti
a number of different perspectives have contributed to the resource-
framework. Theorists employing an evolutionary perspective (Nelson
Winter 1982) argued that organizational continuity was a product of org
tional routines, which evolve over time through organizational learning
studies of successful business organizations have highlighted the contri
to firm performance of core competencies (Prahalad and Hamel 1990),
are defined as the collective learning in the organization, or organiza
capabilities (Leonard-Barton 1992), which are defined as the knowledg
that distinguishes and provides a competitive advantage.
One important contribution of the resource-based prospective t
concept of the learning organization is its emphasis on the compa
advantage of organizational knowledge, accumulated as a by-prod
the production process. Researchers applying a production manage
perspective, which focuses on the relationship between organizat
learning and organizational productivity or efficiency, have sugge
particularly useful framework for understanding this relationship. In o
the earliest uses of the term "learning organization," Hayes, Wheelwr
and Clark (1988) noted a strong relationship between the success of m
facturing organizations and the "architecture" of a production system
architecture they meant the design of the core conversion process of
organization, the communication channels that help coordinate the co
sion process and provide the feedback necessary to make improvemen
the core process, and the rules and procedures used to guide them all
Henderson and Clark (1990) elaborated:
The distinction between the product as a system and the product
set of components underscores the idea that successful product de
opment requires two types of knowledge. First, it requires compo
knowledge, or knowledge about each of the core design concepts and
way in which they are implemented in a particular component. Seco
requires architectural knowledge or knowledge about the ways in w
the components are integrated and linked together into a coherent w
(p. 11).4

Research by Adler and his colleagues (1990, 1993) in the international


auto industry has provided further empirical support for the relationship
between the design and structuring of production management processes and
measurable changes in organizational productivity.
As academic institutions wrestle with adapting to a more competi-
tive environment, higher education scholars have attempted to apply the

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132 DAVID D. DILL

"resource-based view of the firm" to the design of organization and


ment structures in academic institutions (Dill and Sporn 1995; Gumpo
Sporn 1999). Clark's (1998) recent case studies of entrepreneurial univ
in Europe provide empirical evidence as to how academic institution
utilized direct experience to incrementally redesign their internal or
tions over time in order to better cope with a more competitive envir
The current study attempts to further develop this literature on or
tional design in higher education by studying the adaptations unive
are making in the "architecture" of their teaching and learning proc
application of concepts derived from research on production manag
systems in business and industry to colleges and universities may a
be questionable. But, as previously noted, the environment within wh
process of teaching and learning in universities is carried out is being rad
reshaped by more varied student cohorts who place strains on the tr
methods of instruction, by external mechanisms of accountability des
assure and improve academic quality, and by the emergence of new c
itors in the form of Internet-based distance learning programs. In th
context it is reasonable to expect that many academic institutions may
re-consider the basic organization and governance of their system for teac
and learning.

A frameworkfor the learning organization

Garvin (1993) has provided a framework for studying learning organ


that is derived from the insights of the research on organizational le
and the previously described production management perspective. G
suggests that organizations adept at translating new knowledge into i
tive ways of behaving actively manage six learning activities to ens
they occur by design rather than by chance. These activities are exp
for new knowledge - through systematic problem solving, learning
one's own experience, and learning from others' experience - experim
with new processes, transferring knowledge within the organizatio
measuring learning.
- Systematic problem solving involves the encouragement through
organization of the activity of observing and improving basic pro
This activity often involves teaching staff members new skills, as
organizations train their staff members in the analytical skills ass
with continuous process improvement (or total quality manageme
well as insist upon data-based problem solving.
- Learning from one's own experience involves the systematic revi
programmatic successes and failures in search of lessons to be le
the use of outside evaluations and consultants as a means of gener

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 133

useful knowledge, and internal "bench marking" - seeking ou


practices within the organization.
- Learning from others' experience involves seeking information on
practices from other organizations through carefully planned st
tours and "benchmarking," as well as through ongoing conversat
with external "clients" as a means of developing knowledge f
improvement of core processes.
- Experimentation with new approaches involves seeking new know
from experiments within existing programs as well as through d
stration projects, which are larger more complex experiments o
involving a new entity.
- Transferring knowledge involves moving new knowledge from sub
or groups that have developed it to other sub-units.
- Measuring learning involves systematic activities designed to asce
whether organizational learning - that is actual behavioral chang
occurring.
This framework contrasts sharply with that of writers such as Senge (1990a
and b) who discusses the learning organization in terms of ways of thinking
and human development. Garvin's framework views organizational learning
as a practical matter, and adopts a production engineering approach that
emphasizes those underlying organizational processes such as experiment-
ation, prototyping, and post audits that can be clearly linked to improved
organizational outcomes. In the following section this framework, derived
largely from industrial organizations, will be applied to case studies of quality
assurance in universities as a means of identifying the emerging architecture
of an academic learning organization.

The architecture of the academic learning organization: An analysis of


the university case studies

Introduction

Garvin's framework of the learning organization assumes that an organization


in a competitive context must constantly adapt its core productive processes
through the discovery and implementation of new knowledge. It is important
to contrast this perspective of organizational improvement through learning
with the perspective of "organizational control" that frequently pervades the
literature on academic accountability (Dill 1995). In the latter perspective,
new academic structures and processes for quality assurance within univer-
sities are often implemented as a means of bringing academic behavior into
conformance with stated academic standards or goals. An orientation toward

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134 DAVID D. DILL

Table 1. University case studies drawn from the institute


for management in higher education (IMHE) project on
the impact of academic quality assessment on institutional
management and decision-making

Ca' Foscari University of Venice, Italy (CFU)


Cardiff Unviersity of Wales, United Kingdom (CUW)
Delft University of Technology, The Netherlands (DUT)
National University of Mexico (NUM)
Open University, United Kingdom (OU)
Sheffield Hallam University, United Kingdom (SHU)
Universidad Aut6noma Metropolitana, Mexico (UAM)
University of Amsterdam, The Netherlands (UA)
University of Helsinki, Finland (UH)
University of Monash, Australia (UM)
University of Jysvaskyli, Finland (UJ)
Uppsala University, Sweden (UU)

control was clearly evident in the practices and processes presented i


of the university cases reviewed for this study.
For example, in the case of Sheffield Hallam University in t
(SHU), whose academic programs have been regularly assessed by the
Education Funding Council of England (HEFCE),6 the university ado
internal quality review process which mirrors the external process co
by the HEFCE and which is clearly designed to assure that each subje
scores well on its scheduled HEFCE assessment. While such a process
in fact lead to organizational learning and improvement in outcomes,
a danger that a focus on conforming to external assessments may enc
"culture of compliance" in which the production of high quality docu
policies, and procedures substitutes for the development and dissem
of new knowledge designed to improve the core processes of teachi
learning.
In contrast to this activity of organizational control the activities of a
learning organization focus on developing and implementing new knowledge
that will improve the core processes of an organization. In the analysis that
follows the experiences of a sample of the universities involved in the IMHE
study (Table 1) will be examined through the lens of Garvin's framework
as a means of identifying the emerging architecture of an academic learning
organization.

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 135

Systematic problem solving

One of the clear lessons from the quality management movement that recen
swept through industry and the universities is that new knowledge to impr
core processes can emerge from systematic study of those processes in
by those who carry them out. This insight motivated formal training s
in many organizations designed to develop skills among operational sta
objectively observing core processes and in working collectively to imp
them. Several US universities such as Cornell and Michigan have of
systematic training to their staffs in team problem solving and quality
ance analytical techniques such as Pareto charts, flow diagrams, and "
charts (Dill 1992). This approach to systematic problem solving has ge
ally bypassed faculty members within these universities, who have o
argued that such methods are not applicable to the improvement of aca
processes.
While the universities studied did not report applications of quality
management techniques to teaching and learning a number of the univer-
sities provided evidence of attempts to develop a comparable culture of
systematic problem solving within the academic community as a means of
improving processes of teaching and learning. In Finland, both the University
of Helsinki (UH) and the University of Jysvaskyli (UJ) noted a government
initiative to encourage "management by result" in public sector organiza-
tions and both universities provided illustrations of systematic attempts to
inculcate a "culture of evaluation" within their faculties. At UJ the language
and processes of evaluation were seen as a "magic tool" that helped faculty
members define issues of teaching and learning as functional problems rather
than as academic or scientific problems, and thereby provided an impetus
for the faculties to engage in developmental activities designed to improve
curricula structures:

In cultural terms, we see the nature of the evaluation as a process during


which the understanding of the university was created through and in the
discourse of assessment. The assessment discourse helped to define the
functional problems of the university, it supported the creation of mana-
gerial understanding of the university by focusing attention to irrational
and unfunctional elements in the university structures ..., and helped the
faculties to see the problems in doctoral training more clearly than before.
Finally, assessment discourse promoted the use of concepts shared by the
participants of the total evaluation process. This way, it promoted mutual
understanding of the University of Jysviskyla as [an] institution aiming
at the production of academic degrees (UJ: p. 32).

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136 DAVID D. DILL

A similar orientation to problem solving was also observed at t


University (OU) and the University of Monash (UM). At the OU s
on academic quality assurance approaches and techniques were
faculty members to raise awareness about quality improvement an
tional documents providing "A Guide to Quality Assurance" and a
Practice" were distributed to create a common language and set o
for addressing issues in teaching and learning. At UM a forma
Education Policy" was adopted and meetings by central administr
each faculty attempted to stimulate a "stronger culture of self-ev
the basis of evidence" (UM: p. 8).
At the Ca' Foscari University of Venice in Italy (UCF) the Inter
uation Unit created in 1995 developed objective data on facult
loads, which made it possible for the members of the University
agreement on redirecting resources to those faculties with the highest
teacher ratios.
An emphasis on evidence-based problem solving and systema
ation might be considered redundant in contemporary universities
to scholarship and scientific method. But as research on the cultu
disciplines has regularly revealed (Becher 1989; Braxton and Harg
the effectiveness of collective problem solving on academic issues
subject fields varies substantially. In faculties such as Business, En
and Medicine, where the norms of scientific method and/or the
application are more broadly observed, evidence-based problem so
academic matters appears to be more common. This reality is ref
the examined case studies where a disproportionate number of th
innovations in curricula and teaching occurred in these faculties. I
characterized by less structured subject fields and curricula, impro
teaching and learning often suffers from poor skills in collective
solving and team work among faculty members, as well as fro
that teaching is an "art" rather than a "science." These observatio
that encouraging a culture of problem solving within all academi
a critical and often underestimated first step in adapting universi
competitive conditions of the new environment.
In order for faculty members to be able to systematically address pr
in the core processes of teaching and learning, the structure o
sities must permit faculty members to effectively coordinate those
Academic specialization and traditions of professional autonomy,
often make it difficult for a faculty to work collaboratively to i
academic programs. One notable characteristic of the universities
was the structural changes being made to better align faculty
bility and control for instruction in subject fields. At UM and UJ

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 137

study programs were reorganized respectively into "academic committees"


with responsibility for designing and conducting masters and doctoral
programs and into more structured curricula tied to faculty research prior-
ities. A number of the universities that had traditionally relied upon the
"faculty" form of academic organization were now creating new structures to
encourage more cohesively designed and managed curricula. At both SHU
and UA various subject fields were organized into formal "schools" as a
means of assuring the quality of academic programs.
This relationship between academic quality and academic structure was
clearly articulated in the case study of UA where the low quality of certain
subject fields was perceived to be related to their lack of social cohesion - "the
[faculty] organization does not operate as a community in terms of a group
of people linked by a common mission statement and a common culture"
(UA: p. 24). Improvement of teaching quality therefore required addressing
the structural problems that were causing weak faculty accountability for
instruction:7

This situation has caused two main problems. In the first place, improve-
ment projects require coordination and management to maintain coher-
ence between all these initiatives. Of course, every project should
culminate in structural, lasting improvement. A supportive organizational
concept should provide the framework for these improvements. In the
second place, the diffuse organizational structure results in processes of
educational management and change where nobody wants to be - or can
be - held personally accountable for projects. Thus, for real progress in
the field of quality management and educational policy on the Faculty
level, an organizational change to overcome these two problems, seems
to be a prerequisite (UA: p. 30).
...the priority in the educational policy of the Universiteit van
Amsterdam for establishing schools within the various curricula can be
interpreted as a means for developing an institutional and organisational
framework that is more adequately adapted to combat general flaws
in education as became visible in assessments. The present organisa-
tional structure has proven to be too dispersed to guarantee a systematic
execution of educational policy ... (UA: p. 33).

A number of universities that did not restructure their basic academic units
reported related structural adaptations designed to increase curricula coordi-
nation within existing faculties. At UM each faculty was required to appoint
an Associate Dean for Teaching, at CUW each faculty appointed a Director
of Undergraduate Studies, while at CFU, UH and UU each faculty was asked
to form respectively an Internal Evaluation Unit, a Special Working Group on

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138 DAVID D. DILL

Quality, and a Teaching Development Workgroup. At DUT every facul


required to appoint a Curriculum Director. The stated role of the Cur
Directors at DUT, which is similar in function to the committees or
nators established at other universities, suggests how the new comp
pressures for increased academic quality were affecting the organiz
the core processes of the university:

The most important task of the Curriculum Director is to monit


coherence of the first three years of the study programme(s); coh
in structure and coherence in content. When necessary the Curr
Director is authorized to intervene in the organisation of the
programme in order to remedy bottle-necks. He or she is the adv
to the Faculty Board on the permanent improvement of the qual
the curricula and educational organisation and is responsible f
implementation of these improvements (p. 10).8

An important contribution of the quality management movement h


to emphasize that improved outcomes are less a product of the refine
made by individuals in their own work, and more a product of the co
collaboration of all the individuals involved in a complex production p
(Dill 1992). As in other organizations, faculty members can act both
vidually and collectively to improve the quality of their teaching, b
insightfully noted in the case study at UJ, effective collective problem so
in a university setting appears to require both a pervasive culture of e
based problem solving and structural configurations that promote c
communication within and collective responsibility for academic prog

If we assume that culture is born in social groupings which const


the meaning of their actions within the social relations that are fo
in communicating and producing together ..., then we must adm
total evaluation has given birth to new cultures: it has changed th
relations inside the university. What are these new groupings th
been promoted by total evaluation? These new social grouping
new curricula structures, new forms of tutoring and financing do
students, new research priority areas, and new departmental org
tions. All these new social reforms are promoted by the total evalu
that developed to define the need of reform (UJ: p. 32).

Learning from one's own experience

New knowledge about production processes derives both from the ex


ence of others and, consistent with the points discussed above under p

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 139

solving, from analysis of an organization's own experience. The lea


activities associated with internal knowledge discovery include system
ally assessing program successes and failures, the use of outside evalu
and internal bench marking, which is aggressively seeking out "best
tices" within an organization. Of these processes, the one most preval
in the analyzed cases was the use of external assessments of the quali
teaching and learning within subject fields.
In a number of countries, such as Denmark, the Netherlands, and the
external evaluations of academic subjects are systematically conducted
intermediary organizations under government mandate. But several o
university case studies, notably CUW, NUM, OU, SHU, UH, and UJ, rep
development of an internally managed process of subject evaluations
focused on improving the processes of teaching and learning. Most of
evaluation processes involved knowledgeable outside experts. The univer
based assessments were managed by newly formed university-wide f
committees such as the Academic Quality and Standards Committee at
the Assessment Committee at UH, and the Quality Assurance Panel at
OU.9
An additional structural support for organizational learning within univer-
sities was the creation of university-wide Centers for Teaching and Learning
in a number of the universities (e.g., UH, UJ). These centers typically
provided training in pedagogy, teaching evaluation, and student assess-
ment for interested instructors, and thereby developed skills of evaluation
and assessment among faculty members. While these centers clearly assist
individual faculty members in developing new knowledge by which they
can improve their own teaching processes, the dominant orientation of
these centers to individuals rather than to program or process improvement
involving groups of faculty members limits their contribution to "organiza-
tional" learning. This underscores a traditional distinction in the organiza-
tional learning literature between "individual learning" and "organizational"
learning" (Kim 1993). While organizations ultimately learn via their indi-
vidual members, specialized or individual knowledge alone is of limited
benefit to a firm, because if the individual leaves, this knowledge may be lost
to the organization. In contrast, learning that helps an organization improve
involves the integration of specialist knowledge into new knowledge about
processes encompassing more than one individual (Grant 1996), and which
thereby can be retained in the collective memory of the organization.
One example of a focus on organizational learning in these terms is the
use of internal "bench marking." In this process sub-units of the organization
seek out "best practices" in core processes by other sub-units and attempt
to transfer the processes for their own improvement. Despite the fact that

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140 DAVID D. DILL

faculties and academic units within universities essentially operate


pendent entities, and despite the fact that they engage in many com
processes - e.g., the evaluation of teaching, the evaluation of stu
there were no reported incidents of internal bench marking in the
sities reviewed. This may be in part because of the strongly differe
disciplinary cultures previously noted, which lead to the view that ac
fields such as linguistics and medicine have nothing in common. On
also argue that there is no reason to believe that individual academi
have successfully implemented processes worth copying. However, t
emerging evidence (Rothschild and White 1993; Shulman 1993) t
keen market for students and quality reputation in the US (and possi
in Europe as indicated in the OU case study) has led MBA prog
place a high premium on curriculum design, the evaluation of teachin
on innovative techniques for teaching and learning, and in this sens
distinguishable in quality from other masters programs within their own
tutions. As competition among academic programs more generally in
and as internal accountability for program improvement within univ
rises, we may see greater attention to internal bench marking as an
form of organizational learning within universities.

Learning from others' experience

Learning from the experience of others involves the activities of ex


"bench marking" - adopting successful processes from other organi
- as well as discussions with clients or those who are served as a means of
developing new knowledge to improve core processes.
Some universities have traditionally compared themselves to competing
institutions. The new Evaluation Secretariat at UJ developed data comparing
the outputs of the university's academic programs with other Finnish univer-
sities as a means of identifying areas for improvement. At the programmatic
level both NUM and UH reported formal study tours to other universities
by faculty teams in respectively engineering and medicine as a means
of identifying new knowledge for the reform of professional curricula. A
distinguishing trait of these processes of curricula reform, however, was
attention to curricula developments in other countries and to international
academic standards currently being defined in many professional fields as a
byproduct of international trading agreements such as the North American
Free Trade Agreement (NAFTA) (Peace-Lenn 1997). DUT, for example,
reported adopting in 1993 the strategic objective of international accred-
itation for all its programs and experimented with this process with an
external review of the quality of education and research in its Aerospace
Engineering Faculty by the American Accreditation Board for Engineering

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 141

and Technology (ABET) from the US. This increasing attention to interna-
tional standards reinforces Kerr's (1993) assertion that for the first time in
higher education a truly international world of learning is emerging in whic
academic quality must be defined in terms of merit against fast-moving,
world-wide competition.
A second and clearly new approach to seeking information from outsid
the university was the development of systematic means of learning abou
the job experiences of graduates as a means of informing the design o
academic curricula. At UH and UJ university support staff conducted survey
of recent graduates and their work experiences as a means of developing new
information for the development of professional curricula. At NUM and UM
external advisory committees were created for relevant academic programs
composed in part of recent graduates as well as potential employers, as an
ongoing means of developing knowledge for the improvement of curricul
and teaching methods.
These examples suggest how the new pressures of quality accountability
and program competition experienced by the surveyed universities are stim
ulating innovative methods for systematically accessing relevant knowledge
for improving academic programs from outside the institution.

Experimentation with new approaches

New knowledge about core processes is developed not only through obser-
vation of ongoing activities and through borrowing from others, but also
through carefully designed "experiments" or demonstration projects with
new programs or processes. Examples of controlled experiments in ne
teaching-learning processes at the reviewed universities included the "Paralle
Study Line," a new problem-centered learning curriculum implemented in
the Faculty of Medicine at UH, and a trial experiment in "assignment-based
laboratories in the Faculty of Psychology at UA. The capacity to develo
such demonstration projects within universities however is often limited b
academic decentralization, which means that academic units may lack the
resources or the expertise to develop and monitor true experiments as a mean
of creating new knowledge about core processes. This limitation appears t
be encouraging the creation of central support mechanisms for demonstratio
projects.
A number of universities (e.g., CUW, DUT, OU, UJ, NUM) have imple-
mented programs to fund and evaluate experiments with new modes of
teaching and learning. The Teaching Improvement Program at NUM, for
example, was created in 1993 to fund senior faculty members in the
"development of innovative approaches to teaching and improvement of the
teaching-learning process" (NUM: p. 18). The structures that support these

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142 DAVID D. DILL

types of programs are generally university-wide faculty committees;


proposals for new projects are reviewed by faculty peers assisted by ex
education experts. In contrast, at CUW the Pro Vice Chancellor for Te
and Learning controls a budget earmarked for educational develo
projects.

Transferring knowledge

As Huber (1991) emphasizes information distribution within the organization


is an important determinant of both the occurrence and amount of organi-
zational learning. Huber argues that an organization learns if any of its units
acquires knowledge that it recognizes as potentially useful, and that more
organizational learning occurs - what he terms "breadth" - when larger
numbers of organizational units obtain this new knowledge and recognize
its utility. Thus defined, knowledge transfer is related to the earlier discussion
of internal bench marking, and similar to the points made there, knowledge
transfer within organizations is frequently frustrated by the beliefs and values
of the receiving unit. But as recent research suggests, knowledge transfer is
also strongly influenced by characteristics of the knowledge transferred and
by the organizational context in which transfer occurs (Szulanski 1996).
Variations in academic quality among university sub-units in the past
might more easily be ignored because of the well known "halo effect" in
which all of the units of a prestigious university are generally perceived by
outsiders to be of high quality (Dill 1992). Changes in the environment of
higher education, however, have increased the cost to a university of tolerating
or ignoring ineffective units. As interdisciplinary research and teaching grows
in importance within the university, and more influential in defining new
fields of knowledge (Gibbons 1995), weaknesses in certain core disciplines
can retard the overall development of the university. In addition, as govern-
ments employ competitive mechanisms for allocating resources for research,
the low ranking of a critical field can also have significant financial impacts
on the overall university. Under these new conditions a number of leading
US universities have acted decisively to restructure low-rated academic disci-
plines (Trow 1983). This shift in attitude toward potentially weak units within
a university was clearly reflected in an early report by the University Quality
Committee at UU:

The need for a concerted approach to quality issues ... stems from our
mutual dependence in the face of outside appraisal of our activities, and
from the importance of an effective exchange of ideas and initiatives
between the different parts of the university. It is Uppsala University in
its entirety that may be rewarded or penalized via the funding system. In

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 143

this context it is undeniably true that a chain can be no stronger th


weakest link.... Just as one success story is a boost to us all, so too
we dragged down by shortcomings and mistakes, in whatever part o
University they occur (UU: p. 12).

Unfortunately, and all too typically, this call to collective accountabilit


knowledge transfer was not reflected in the quality management pro
actually implemented by the University of Uppsala, which instead em
sized decentralized responsibility and faculty autonomy in addressing q
issues. This problem was acknowledged in an external evaluation of th
quality assurance system subsequently conducted in 1995 by the Natio
Agency for Higher Education in Sweden. Of the three areas recomme
for future attention by the University Quality Committee, one was iro
"the systematic exchange of ideas within the university" (UU: p. 24).
Similarly the Academic Audit carried out on the quality assurance sy
at the OU by the Higher Education Quality Council specifically critici
communications across the university. In response the University estab
the Quality Assurance Panel (QAP) to provide greater central focu
quality assurance activities at the university. A specific responsibility
new QAP was the "Dissemination of 'best practice' with respect to qua
issues" (OU: p. 6).
Two of the few specific examples of a structural response to the pr
of information transfer among the examined cases were the Commit
Associate Deans of Teaching at UM and the Area Councils created
NUM in 1992. These councils were designed to be planning, evaluation
decision making bodies with responsibility for promoting linkages am
different levels, disciplines, and academic areas of the university.

Measuring learning

The final activity of a learning organization as defined by Garvin


measurement of learning, the assessment of whether the concept of
oping and applying knowledge to core processes is accepted by organi
members, and whether there is observable evidence of knowledge
improvement. Measuring learning therefore involves developing indicat
organizational performance, which can be used to evaluate whether lea
is actually occurring, and the use of processes such as learning aud
assess whether the concepts of organizational learning are in fact under
or supported.
One of the most obvious impacts of the new environment upon higher
education institutions is the rapid adoption of a number of student-related
performance indicators within the reviewed universities. While there is

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144 DAVID D. DILL

nothing exceptional about the indicators reported, several of the cases


clear that such measures of performance had not existed nor been sys
ically collected until the emergence of external accountability pressur
increased competition. The development and endorsement of these ind
by universities further facilitates the culture of assessment and eva
previously introduced by providing a common language for the disc
of improving academic practices. The indicators reported included:
- student demand for courses/programs (NUM)
- student graduation rates (CFU) (NUM) (UA)
- time to degree/"cycle times" (CFU) (NUM) (UA) (UH)
- student graduate placements/performance in the labor market
(CUW) (UH) (UM)
- measures of the student experience (DUT) (NUM)
Of particular interest were the indicators developed at DUT and NUM on
the student experience. At DUT these were classroom surveys designed to
assess not teaching, but the effects of teaching and the curriculum on the
students. Students were asked about the amount of time they spent on a
course, the nature of assignments, exam results, and the quality of the educa-
tion program as a whole. At NUM students were surveyed on issues such as
their class participation, interest in learning, degree of personal responsibility,
time devoted to studying after classes, and homework/project preparation. It
is important to note that these types of student-related indicators are not in
and of themselves measures of organizational learning. Rather, changes in
these indicators may provide a basis for assessing organizational learning,
as when a unit redesigns its curriculum in order to lower student time to
degree. The development and application by universities of such indicators
represents a significant contribution to organizational learning, because as
Grant (1996) suggests, the integration of specialist knowledge to perform
productive tasks within an organization is highly dependent upon the evol-
ution of social knowledge among its members including a common language
and set of norms that facilitate communication and collaboration.
In addition to these student-related indicators of performance, a number of
processes had been implemented in the reviewed universities for producing
information on the quality of teaching. The most common was the adoption
- e.g., at DUT, OU, UH, and UM - of student questionnaires evaluating
teaching performance. In the UK both CUW and SHU had also adopted the
processes of peer observation of teaching.
The most significant process for measuring organizational learning
developed at these universities was what Huber (1991) has termed "perfor-
mance monitoring." In this process organizations formally and routinely
assess how well they are meeting the expectations of external stakeholders

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 145

as well as their own standards. This activity involved the previously int
duced process of internal subject evaluations carried out at CUW, DU
OU, SHU, UAM, and UJ. Internal program review is a well develop
activity in US higher education (Mets 1997), but American program review
assess program quality more holistically evaluating faculty reputati
programmatic resources, and research as well as graduate and undergradu
curricula. The program reviews of the studied universities, reflecting t
climate of quality assessment in their respective countries, focused muc
more directly on teaching and learning processes, and applied the types
student-related performance indicators described above. In the case of t
DUT, the Executive Board of the university used performance indicators
similar to those outlined above to set explicit and verifiable "contracts" w
each faculty on expected performance in the next year.
Recent research (Szulanski 1996) on intra-organizational transfers
knowledge suggests that an organizational context that provides meaningf
performance measures, provides constant pressure to improve performan
and legitimates performance improvement through copying and adaptin
practices from other units, facilitates the development of new knowled
and ultimately its transfer. Conversely, an organizational context that neit
encourages organizational units to develop their learning capacities
fosters closer relationships among them, may prove barren to organizatio
learning. As the staff in one subject area in the OU reported, after receivi
a grade of "satisfactory" in the external subject review conducted by th
HEFCE:

... at the University level there remained problems of clarification of


responsibilities of committees, links between course approval, presen
tation and resources. The university was perceived as providing no re
pressure or academic scrutiny of faculties (OU: p. 11).

As noted in the section on learning from one's own experience the increasi
attention to the evaluation of units within universities has led to new
governance structures at the university level. Processes for auditing faculty
comprehension of quality processes as well as actual improvements made
were generally carried out by newly created university-wide faculty struc-
tures. These included committees such as the Committee on Quality and Eval-
uation of Education at UU, the Academic Quality and Standards Committee
at SHU, and the Quality Assurance Panel at the OU. The increasing impor-
tance assigned to improving the quality of teaching and learning has also
led to the creation of central administrative positions and support services to
provide leadership and technical assistance to the improvement of teaching
and learning processes. These included the Vice Rector of Teaching and the

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146 DAVID D. DILL

Evaluation Secretariat at the UJ, the Pro-Vice Chancellor for Quality


ance and the Institute for Educational Technology at the OU, and the
chancellor for Teaching and Learning at the CUW.
The development of a language of performance measurement
processes and structures for auditing the performance of academic u
clearly altered the decision making processes of the universities rev
and has encouraged the development of new knowledge for the impro
of core processes. As the case study of the UH noted:

... the University leadership believes that the assessments have pr


much information which is useful as a basis for future developm
Indeed, the procedure has helped, and sometimes even forced, Uni
leadership to commit itself to the development projects and also to
the information provided by the evaluations, as is reflected in the
strategy plans ... (UH: p. 54).

Conclusion

Universities have long been regarded as centers of knowledge creation and


application for the larger society, but not as learning organizations developing
and transferring knowledge for the improvement of their own basic processes.
The new competitive environment of higher education throughout the world
appears to be creating incentives for universities to become active learning
organizations in the terms defined in this study. There is substantial evidence
of the new environment leading to the adaptation of the internal structures
and governance processes of the universities reviewed. These changes can
be understood as a fundamental change in the architecture of academic
organizations (Table 2).
Before exploring the nature of these changes, there are a number of
important limitations to note about the present study. The cases reviewed
represent a collection of self-selected universities, in which many of the
cases were written by individuals directly engaged in and responsible for
quality assurance activities. Therefore the representativeness and validity of
the changes discussed are difficult to determine, although the universities
represent a wide range of countries. Similarly, while the individual cases
describe an impressive amount of internal change and offer some evidence
of improvement in university core processes, we do not have any objective
data for this group of universities as a whole that would enable us to evaluate
changes in their teaching and learning performance, evidence that would give
credence to the existence of organizational learning.

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Table 2. Activities and architecture of the case study universities

Activities Architectural mechanisms


Culture Processes Structu

* Management by results/evaluation
Systematic problem on the * Quality assurance policies/codes of
solving basis of evidence (UIl) (UJ) (UM) practice (OU) (UM)
* Seminars on teaching/learning quality
assurance issues (OU)

learning from own * Didactic training in higher education (UA)


experience * Teaching/learning program evaluations
(CUW) (OU) (SHU) (UAM) (UH) (UJ)
Learning from * Study tours to identify innovations for
others curricula reform (NUM) (Utl)
* Application of international standards for
curricula design (DUT) (OU) (Ul )
* Systematic surveys of graduates'
experiences as basis for curricula design
(U !i) (UJ)
Ixperimentation with * "Controlled experiments" with new *
new approaches curricula (UA) (Ull)

Transferring *
knowledge
*

Measuring learning Measures of student performance: * Student evaluation of teaching (NUM) *


(OU) (U!!) (UJ) (UM) (UU)
* Course demand (NUM) * Peer observations of teaching (CUW)
* Graduation rates (CFU) (NUM) (UA) (S IU) *
* Time to degree (CIU) (NUM) (UA) (UlI) * EIvaluation of student academic experience
* Placements (CUW) (NUM) (UlI) (CUW) (I)) ( (U) (SIIU)
* Performance in labor market (CFU) * Reviews of examination procedures (C
(CUW)
* "Contracting" with faculties on academi
performance (DUT)
* Internal reviews of program teaching/
learning quality (CUW) (OU) (SItU) (U
(Uil) (UJ)

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148 DAVID D. DILL

In addition, some might contest the theoretical assumptions a


for this study. Following institutional theories of organizations (M
Rowan 1977), it could be argued that the organizational behaviors r
here are a function of "organizational mimicry," in which universi
to copy the behaviors of other leading institutions as a means of m
ing sanctions from a variety of stakeholders. Organizational mimic
account for some of the observed changes, but as Huber (1991) note
review of the research on organizational learning, mimicry is a less
strategy for organizations in competitive and fast-changing enviro
Furthermore, theories of organizational mimicry tend to ignore th
established research on the "not invented here" syndrome (Szulansk
in which organizations resist adopting innovations they have not d
themselves. Also, in circumstances of a declining unit of resource,
was true for almost all the universities reviewed, the adoption of inn
processes has an opportunity cost in terms of existing academic act
foregone. Therefore we would expect faculties in this new environme
especially assertive in demanding evidence of the efficacy of recom
new administrative or organizational processes. Consistent with these
while the changes at the reviewed universities can - from, the conc
perspective introduced in this study - be seen to follow certain patte
specific organizational changes themselves vary from institution to instit
and appeared to have evolved internally, consistent with the tradit
experiences of each university.
The evidence from these case studies is impressive that the contem
university around the world is responding to its competitive envir
in a similar manner to successful industrial organizations by reconf
its internal architecture, the fundamental organizational design by w
produces its essential products and services (Henderson and Clar
While the focus in this study was on the core processes of teach
learning, a number of the cases reported similar changes in the architectu
research processes, suggesting that the points made here about the a
of organizational learning might be generalized to all the core process
moder university, including research processes and general adminis
processes.
With regard to the focal question of this study - what are the organizational
characteristics, the "architecture," of an academic learning organization - the
analysis has suggested a number of elements that appear distinctive to the
university sector:

1. Culture of evidence. It is singularly ironic that the most critical factor in


transforming the university into an academic learning organization may be

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 149

instilling a "culture of evidence" into academic problem solving. As S


Ashby (1963) trenchantly observed:

All over the country these groups of scholars, who would not mak
decision about the shape of a leaf or the derivation of a word or the auth
of a manuscript without painstakingly assembling the evidence, m
decisions about admission policy, size of universities, staff-student r
content of courses, and similar issues, based on dubious assumpt
scrappy data, and mere hunch (p. 93).

Successful problem solving on improving teaching and learning, partic


at the level of the basic academic unit, is highly dependent upon the q
of "social knowledge," which includes a shared evidence-based approac
problems and a common language of student performance. These chan
in academic culture appear fundamental and essential to improvin
core processes of the university. As Cohen and March noted in their
study of universities in the 1970s (Cohen and March 1986), organizati
learning in the university of that time was limited due to a context of
resources and poorly understood "technology" (i.e., knowledge regardin
operation of core processes). The contemporary competitive environme
the university has dramatically altered the resource situation, and through
efforts suggested above a number of universities are attempting to dev
shared norm of analytical problem solving and a university-wide lang
of academic performance through which they can begin to develo
knowledge for the improvement of core processes. A possible addi
means for improving problem solving on the core processes of teachin
learning would be to encourage all academic units to publicly defin
defend the measures of student learning upon which they are basing
teaching processes (Dill, in press).

2. Improved coordination of teaching units. Successful problem so


also appears to require alterations in the structure of basic units to inc
the potential for coordination, communication, and accountability am
faculty members responsible for an academic subject. As Grant (1996
suggested, in dynamically competitive contexts the critical organizat
capability is the integration of specialist knowledge. Therefore, organiz
seeking to improve their core processes design organizational structure
enhance the communication needed to achieve knowledge integration
performance of their productive tasks. This general observation is ref
in the structural adaptations observed in the reviewed universities such
appointment of curriculum coordinators, the creation of faculty comm
to coordinate the quality of teaching and learning within academic un

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150 DAVID D. DILL

and in a number of cases, the formation of "schools" as a means of


aligning academic control and accountability.

3. Learning from others. Seeking out knowledge from others is fund


to academic research, but has not been systematically applied
improvement of the basic processes of teaching and learni
implementation of subject reviews involving external reviewers prov
continuing source of new knowledge at the subject level, as does the
of external curriculum advisory committees. Still another process r
in the case studies is the systematic surveying of program graduate
source of information for redesigning academic curricula. Less typic
those universities that supported study tours by their faculties as a m
identifying curricula innovations that might be worth adopting and t
marking of professional curricula against international standards.

4. University-wide coordination of "learning". An additional archite


change is the development at the pan-university level of structu
providing more effective coordination, support, and accountability
systematic improvement of teaching and learning. These changes in
the development of university-wide faculty committees with a respon
for auditing on an ongoing basis the quality of teaching and learning
academic units. These committees also often have responsibility
allocation of funds supporting experiments and innovations in teach
learning, as well as for coordinating the work of various technic
that provide support for the improvement of teaching and learning
academic unit level. These units include teaching and learning c
curricula and program evaluation groups, and units that provide assis
assessing students and in surveying program graduates.

5. Transferring knowledge. Of all the activities observed fr


perspective of Garvin's (1993) learning organization framework, the
in evidence in the sampled universities was processes or structur
encourage the internal transfer of new knowledge for improvi
processes. This weakness is not restricted to academic institutions (Sz
1996), but the traditional decentralized structure of the university exa
the problem. On the other hand, those countries that have systema
conducted subject reviews within their university sector have inevi
discovered substantial variance in the quality of teaching and learnin
units within the same university. It is therefore likely that within most
sities there are better performing units that have knowledge about im
teaching and learning from which other units could learn. This

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ACADEMIC ACCOUNTABILITY AND UNIVERSITY ADAPTATION 151

suggests the value to be gained by devoting managerial attention to


of identifying best practices and moving them among university ac
units. Correspondingly, research on means of promoting intra-organi7
knowledge transfer within universities is much needed.
The results of this study provide further confirmation on the ad
responses of universities to the new environment. Recent research (
1998; Dill and Sporn 1995; Gumport and Sporn 1999) has consis
suggested that universities are restructuring themselves internal
adapting their basic organization to improve academic quality, foster i
tive interdisciplinary research, and increase their entrepreneurial cap
The activities by which this transformation is occurring may initially
arcane, but examined more closely they are easily understood by those
the university. They involve: systematic problem solving employing o
measures and the canons of scientific method; close observation o
processes as a means of understanding how they work and can be imp
seeking relevant knowledge from colleagues that can be used for fu
improvement; creating experiments to test hypothesized improvemen
operating in a context of peer accountability for the quality of wor
the rigor of one's thinking. Improving universities in this manner is
and incremental process, but one which characterizes an academic le
organization.

Notes

1. The IMHE cases, covering over 30 institutions in 14 countries, are available on the
Internet at: http://www.oecd.org/els/edu/imhe/instexp.htm
2. For some useful recent reviews of the literature on learning organizations, see Easterby-
Smith (1997) and Tsang (1997).
3. An important distinction can be drawn between information and knowledge (Patti
Gumport, personal communication). Knowledge implies the ability of an individual, unit,
or organization to interpret information, and through this interpretative capacity to be
able to change its behavior (Huber 1991). Garvin's definition of a learning organization,
introduced at the outset of this paper, adopts a similar perspective, stating that such an
organi7ation must be able to create, acquire and transfer "knowledge," which it can use
to solve problems and improve its organizational processes. Throughout this paper, I will
use the term knowledge in this broader sense.
4. The language of manufacturing in this quotation may appear particularly irrelevant to
academic institutions, but the distinction drawn between "component knowledge" and
"architectural knowledge" has an interesting parallel in Tony Becher's (1992) obser-
vations on the design of a system of academic quality assurance at the University of
Sussex: "...the most important consideration in quality assurance must be a holistic
rather than an atomistic one, namely the benefits students derive from the totality of their
degree programmes, rather than the satisfactoriness or otherwise of their interactions with
individual members of staff" (p. 58).

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152 DAVID D. DILL

5. Note that Garvin's activity of "transferring knowledge within the organizatio


sponds with Huber's (1991) second major sub-field of the organizational le
literature, "information distribution."
6. The subject reviews of the HEFCE are now being conducted by the new
Assurance Agency for Higher Education in the UK (QAA).
7. Restructuring to create clearer collective responsibility and accountability for
programs can be seen as a more general effect of increasingly competitive enviro
Many contemporary universities (including UM as noted in its case study)
experimenting with "responsibility-centered" or decentralized forms of budgeting
1996), which also leads to the development of more focused academic structures,
to the school structures reported here.
8. DUT's focus on curriculum coherence is consistent with an emerging body of
which suggests that students' learning of academic content and their cognitiv
opment is significantly associated with the "academic coherence" of their curr
That is, student learning is affected by the pattern and sequence of the courses i
they enroll, by curricula requirements that integrate learning from separate
and by the frequency of communication and interaction among faculty members
curriculum (Pascarella and Terenzini 1991). Therefore more systematic efforts to
the quality of learning outcomes often involve collective efforts by faculty mem
better coordinate the curriculumn, to redesign course sequences and requirements
to achieve greater academic coherence.
9. Another interesting example of the use of external evaluations for process impro
was reported at the school level in the OU case study. The OU Business School vol
sought to improve the quality of its core processes by systematically seeking the
ations of outside agencies such as the Investor in People (IiP) Program, a UK-wide
resource management accreditation agency, as well as from the Association of
European-based academic accrediting association.

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