Language Issue in German Higher Education Internationalization: Ideologies, Management and Practices for English-Medium Instruction

Employing document analysis and corpus-assisted discourse analysis, this study examines the language ideologies in German higher education internationalization policies and strategies, across European, German federal and university levels. It further investigates how these policies and strategies relate to the English-medium instruction practices in German universities, adopting Spolsky’s (2004, 2009) framework for language policy analysis. Results show that all institutions at the three levels recognize the role of EMI in promoting the higher education internationalization, but their policy documents adopt evasive attitudes towards EMI to varying degrees. The internationalization policies at the European level show the most tendency to evade the language issue, especially English, while the German federal internationalization documents include more contents about language, even EMI, and they are concerned about promoting the German language alongside English. At the university level, the welcoming attitudes towards EMI are displayed most overtly in the internationalization strategies and the rapid development trend and the predominant English-only type of EMI programs. The study underscores the potential benefits of a multilayered analysis of higher education internationalization policies and EMI practices, and the universities’ important role in balancing the English and the national language in the higher education domain.


The Problem
With the momentum of globalization, "internationalization has become a central concern in policy discourse surrounding European higher education and figures prominently in various agendas at European, national and university levels" (Wächter, 2008, p.1). The European tertiary sector endeavor to promote the internationalization process in which English-medium instruction (thereafter EMI) plays a predominant role. EMI, "the use of the English language to teach academic subjects in countries or jurisdictions where the first language of the majority of the population is not English" (Dearden, 2014, p. 2), has become a phenomenon spreading rapidly throughout Europe's higher education (thereafter HE) field, the number of identified EMI programs going up from 725 in 2001, to 2,389 in 2007 and 8,089 in 2013 (Maiworm & Wächter, 2014). In 1996, BP was designed to harmonise higher education across Europe to promote mobility and to increase the attractiveness of European higher education institutions, which represents the "greatest change European universities have gone through in the past few decades" (Lasagabaster, 2015, p. 260), and the Erasmus program undoubtedly has paved the way for the BP (ibid). The outcomes of the Erasmus program are included in its annual reports, and the BP, its communiqués. At the German federal level, the BMBF, DAAD and HRK together take the responsibility of the management and evaluation for EMI programs. The BMBF is mainly responsible for enacting educational policies at the national level and providing funding, but the practical implementation or supervision is often left to the other two institutions. The DAAD provides various funding, marketing support and prizes to universities that contribute to internationalization. HRK, the union of German universities, functions as the voice of universities in its dialogue with the BMBF. At the university level, the internationalization strategies are drawn up by most German universities, which embed their attitudes towards EMI and reflect the influence of HE internationalization policies at higher levels. But few studies have been carried out to analyze the language consequences that these policy documents at these three levels can result in.
In recent years, EMI policies and practices in HE have become a central aspect of language policy and planning (thereafter LPP) in non-English speaking contexts (Dang et al., 2013). Spolsky's (2004Spolsky's ( , 2009) framework for language policy analysis has become the most widely-used theoretical framework in EMI studies. However, this topic is underinvestigated in German HE context. This paper fills the gap by reporting on a study which investigates the language ideologies in German higher education internationalization policies and strategies, across European, German federal and university levels, and how these policies and strategies relate to the EMI practices in German universities, adopting Spolsky's framework.

Spolsky's Framework for Language Policy Analysis
According to Spolsky's framework for language policy analysis (2004,2009), language policy comprises three components: language practices, language beliefs and ideology, and language management or planning. Language management refers to "the explicit and observable effort by someone or some group that has or claims authority over the participants in the domain to modify their practices or beliefs" (Spolsky, 2009, p. 4). Language practices refer to "observable behaviors and choices-what people actually do" (ibid). Language ideology refers to "the beliefs about language and language use" (Spolsky, 2004, p. 5).
These three components are not only interrelated but interact with one another in complicated and dynamic ways. First, language ideology derives from and influences language practices (Spolsky, 2004). Second, language ideology provides a basis for, and can be modified by, language management (Spolsky, 2009). Third, language practices provide the linguistic context and instrument for language management and are themselves the target of language management (Spolsky, 2004(Spolsky, , 2009). Finally, language management can turn language ideology into language practices. They together make up forces that help account for language choice.

Internationalization of European HE and EMI
Many researchers have recognized that internationalization is the key to the survival for higher education institutions (thereafter HEIs) (Costa & Coleman, 2013), which in turn have contributed to the expansion of English becoming the language of HE par excellence worldwide (Brumfit, 2004). Coleman (2006) argued that the global status of English has impelled its adoption in HE, which would, in turn, advance the internationalization of HE, promoting the growth of English-medium education not only in Europe but also worldwide. Phillipson even pointed out directly that "internationalization in HE has become synonymous with the introduction of EMI programs" (Phillipson, 2008, p. 4). Cots (2013) also pointed out that universities in Europe have crossed the point of no return linguistically in their decision to offer courses, modules and entire degree programs through the medium of English in their attempts to internationalize. That is to say, English plays the role of both the driver and the consequence of the internationalization of European HE.
Erasmus as the most influential initiatives and noticed some main policy actors at the German federal level, such as the influence of BMBF, DAAD and HRK's policy documents on EMI, but they have mainly chosen one or some universities to explore the influence and have made no systematic attempt to analyze their institutional language ideologies. Also, the study concerning the interrelationship between these institutional language ideologies and the actual EMI practices in German HEIs in general is lacking.
The present study aims to contribute to this growing literature and extend existing knowledge by taking as its basis Spolsky's framework. Specifically, the study will seek the answers to the following three research questions: Research question 1: What are the ideologies of HE internationalization policies and strategies at the European, German federal and university levels?
Research question 2: What are the EMI practices at the German university level?
Research question 3: What are the consistencies and discrepancies between the policies and practices in German EMI development?

Policy Documents at the European Level
The documents about European internationalization policies were collected from two projects, the BP and the Erasmus/Erasmus+ program. Nine BP communiqués and additionally, the Declaration on the EHEA in 2010 were collected from the EHEA official website (See Table 1). The BP corpus consists of ten texts, which contains 2,251-word types and 22,498-word tokens.   All of the documents listed above were collected between April 2019 and June 2019.

Policy Documents at the German Federal Level
At the German federal level, the policy documents related to EMI programs mainly come from three institutions, the BMBF, DAAD, and HRK.
Texts from the BMBF are a total of 6 pieces of reports which consist of the document about the European Year of Language and 5 reports about the internationalization of studies in Germany from 2005 to 2016, downloaded from the BMBF official website (See Table 4). All the documents are written in German and translated by the author. The BMBF corpus contains 6,010-word types and 184,457-word tokens. Data from the DAAD are a total of 10 pieces of annual reports from 2009 to 2018 (See Table 5), downloaded from the DAAD official website. The annual reports before 2009 are not available on the website. All the texts are written in English. The DAAD corpus contains 16,083-word types and 404,789-word tokens.  Texts from the HRK are its annual reports from 2003 to 2016, downloaded from the HRK official website, totally 9 pieces (See Table 6). All the texts are written in English. The HRK corpus contains 9,941-word types and 265,809-word tokens.   The internationalization strategies were downloaded manually from the official websites of all the 171 German universities that have introduced EMI programs. The number and types of EMI programs and language requirements for admission were collected through searching their official websites. All these data were collected between May and July 2019. But it needs to be clarified that the website of a university may include much information about internationalization, so the criterion to select the texts is what included in its Internationalization Strategy, or depicted in the International Profile (if Internationalization Strategy is not available). Altogether, the corpus of internationalization strategies or international profiles of 171 universities contains 9,606-word types and 211,744-word tokens. Language practices refer to the overall development of EMI programs in Germany, including the data about the number, types and language requirements for admission. These data were collected from the three most comprehensive investigations about European EMI by far, prepared by the Academic Cooperation Association (ACA) (Maiworm & Wätcher, 2002 and the DAAD official website.

Methods
Document analysis and corpus-assisted discourse analysis were adopted in this paper to analyze the collected data. Documents of all types that "help the researcher uncover meaning, develop understanding, and discover insights relevant to the research problem" can be the sources of analysis (Merriam, 1988, p. 118). In this paper, the documents consist of the policy documents, annual reports, Communiqués and internationalization strategies. The corpus analysis toolkit AntConc3.2.4w developed by Laurence Anthony was also used to analyze the collected data. This paper mainly employed this toolkit's function of keywords, collocates and concordance plot. In this paper, the concordance hits and concordance keyness of "English", "language/linguistic" and "multilingual(ism)/plurilingual(ism)" of the documents of the three levels were analyzed. And the collocation analysis tool was used to ascertain how these words are used. Also, the data collected about the number and types of EMI programs as well as the English and German requirements for admission were analyzed through descriptive statistical analysis.

Mobility-Led European Internationalization Policies
The language issue does not form a great concern in the European internationalization documents. In the BP documents, "European higher education" appears 122 times and "mobility" 103 times, while "language/linguistic" is mentioned 4 times, "multilingualism" only once and "English" not mentioned at all. The Erasmus documents mention "language" 143 times, "English" 24 times and "multilingual(ism)" 13 times. By contrast, "higher education" appears 835 times and "staff/student mobility" 732 times. Thus, the BP and the Erasmus documents are clearly about the HE internationalization. The internationalization of European HE began in terms of legislation in 1992 through the Treaty on European Union, which stimulated the cooperation between the HEIs of European countries: "the Community shall contribute to the development of quality education by encouraging cooperation between Member States by supporting and supplementing their action". From the economic perspective, the HEIs are described by the Lisbon Strategy as the chief engine of Europe's becoming "the most dynamic and competitive knowledge-based economy in the world by 2010 capable of sustainable economic growth".
Through further document analysis, it's found that mobility promotion has been regarded as an essential strategy for pursuing internationalization and language issue does not play a prominent role in European institutions' coping with the HE internationalization. Mobility promotion has been associated with promoting HE quality, personal development and employability, linguistic pluralism and cooperation and competition. The following extract from Leuven/Louvain Communiqué (2009) illustrates mobility and internationalization are explicitly linked within the discourse of European higher education: We believe that mobility of students, early stage researchers and staff enhances the quality of programmes and excellence in research; it strengthens the academic and cultural internationalization of European higher education. Mobility is important for personal development and employability, it fosters respect for diversity and a capacity to deal with other cultures. It encourages linguistic pluralism, thus under-pinning the multilingual tradition of the European Higher Education Area and it increases cooperation and competition between higher education institutions. Therefore, mobility shall be the hallmark of the European Higher Education Area (Leuven/Louvain Communiqué, 2009).
Thus, in the European internationalization policies, the language issue is rarely made explicit reference to, revealing that European institutions, in general, show little explicit concern about language issues in the context of HE internationalization.

Language Policies at the German Federal Level
EMI is seldom mentioned in the policy documents at the European level, but it is much more common in the texts at the German federal level. "English" and "language/linguistic" are not uncommon in these documents and, occurring 266 and 498 times respectively while the occurring frequency of "multilingual(ism)/plurilingual(ism)" is much lower (28). Still, discrepancy exists among the three institutions. Compared with the DAAD and BMBF, the HRK is much more evasive about EMI, devoting fewer lines to EMI-related issues in its annual reports. Though the concordance hits of "English" in its annual reports are 75, it is interesting to notice that 62 of them come from the same document (2010-2011 Annual Reports), while the rest of the documents contain only 13 hits. The result showed that there are totally 53 sentences that have mentioned EMI, and 26 of them have equaled EMI with internationalization, 15 of them high quality, and 17 of them have mentioned the negative influence of EMI on the German language. Further document analysis of such discourse will be displayed below.

EMI Promotes Internationalization
According to the Evaluation of Internationally Oriented Courses of the Demonstration Program published by the DAAD and HRK, the aim of introducing EMI programs is to "test the potential of EMI programs to foster internationalisation in the HE sector" (DAAD & HRK, 2001, p. 2). After the introduction of EMI programs, courses in English are depicted by the BMBF as one of "the most important elements" (BMBF, 2005, p. 5) for attracting international students, thus establishing the close relationship between EMI and HE internationalization. Similarly, the Action Program of the DAAD for the Internationalization of Universities also points out that "EMI program is a central component in stimulating and driving internationalization in the German HE system" (DAAD, 2002, p. 1), and also explicitly defines internationalization as synonymous with the introduction of EMI programs (ibid). Though EMI is seldom mentioned in the HRK annual reports, it is implicitly referred to in the statements about internationalization or mobility promotion. For instance, the outlook statement of the HRK in 2013 expresses its commitment to "internationalization of German universities", "continuous international exchange" and "internationalization […] in dialogue with our partners worldwide" (HRK, 2013, p. 4), all of which will indirectly foster EMI, considering the need for a shared language for communication in these activities.

EMI Equals High HE Quality
The ideology of equaling EMI with high HE quality can be found in the EMI discourse. For example, the BMBF 2008 report emphasizes that: Building world-class universities of HE requires more efforts of universities in their process to Internationalisation, […] and the highly sought-after English language courses can be expanded for attracting more international students (BMBF 2008, p. 2).
According to this extract, EMI programs can not only attract international students, but also are important for German HEIs to excel in the global HE field. Similarly, the DAAD annual report of 2011 mentions the contribution of EMI: This put Germany in third place-behind Canada and the UK-on the list of countries where American students have gone abroad to pursue full-time study. These positive developments can be attributed to successful marketing on the part of German universities and the expansion of their English-based degree programmes (DAAD, 2011, p. 62).
It can be found from the extract that the large admission of American students symbolizes the excellence of the host country, which is attributed to the EMI programs.

EMI Hampers German Language
With the increasing importance of English in the domain of German HE, institutions at the federal level realize that EMI can hamper German language as the academic language, which can be found in DAAD's 2010 annual report: The best way to promote German as an academic language, is academic excellence at German higher education institutions. Study programmes in English ought to offer more German modules alongside the courses in order to boost the social integration of the foreign guests at institutions (DAAD, 2010, p. 39).
This statement sets demands on EMI programs, emphasizing the importance of German language study alongside English, so as to promote the status of German. This can reveal DAAD's intention to protect the status of German in the academic field.
Similarly, the HRK is also concerned about the German language issue in EMI programs. For example, the Code of Conduct issued by the HRK (HRK, 2009) requires the universities provide German language courses both before and during students' study in EMI programs, or information about German language training for students. The 2011 annual report of HRK makes a detailed description of the Language Policy for German Universities: To promote multilingualism and to ensure that German remains a language of science and scholarship, there needs to be a reflective approach to decisions pertinent to language policy (HRK, 2011, p. 58). ijel.ccsenet.
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Since the Figure 1).  Vol. 10, No. 6;2020 "multilingual(ism)/plurilingual(ism)" in the internationalization strategies or international profiles of all of the 171 universities (see Table 8). The result showed that 119 of them have mentioned "English", the total concordance hits of which add up to 336. And 125 of them have mentioned "language/linguistic", the total concordance hits adding up to 1,072. In contrast, the concordance hits of "multilingual(ism)/plurilingual(ism)" are only 25, significantly lower than those of "English" and "language/linguistic". Then, the collocation tool was used to find out the collocations of the three words, the collocations of each with the top 5 highest frequency are also listed in Table 8, but the collocations of "multilingual(ism)/plurilingual(ism)" are too few to generate any result, with all collocations occurring only once. The common collocations of "English" in the internationalization documents of these 171 universities include "language", "German", "courses", "taught", and "international". The common collocations of "language" include "courses", "German", "English", "foreign" and "skills". It can be found that "English language" enjoys equal concordance hits with "German language". However, some HEIs construe English as "foreign language" instead. Then among the 56 collocations of "English" with "German", more than 91 percent of them are presented in the form of coordinating relations, e.g. German and/or English. It can be revealed from such data that the universities have tried to expand the use of German in EMI programs, in response to the ideology of protecting the German language at the federal level.
Moreover, EMI can find its expressions in the form of "English-taught programs/courses" or "English-language courses/programs". Thus, these collocations were searched to analyze the contexts. Altogether, there are 210 concordance hits of such expressions, among which 169 are mentioned by the universities as a strategy of attracting international students and staff, 104 are mentioned as a strategy of sharpening the international profile of the university, and 87 are described as important for HE quality improvement. EMI is valued by more than 70% of the 119 German HEIs as a strategy to promote the international attractiveness of the universities. For instance, the University of Potsdam states: To make the University of Potsdam increasingly attractive for international students, we intend to offer more English-language lectures and seminars, new English-language Master programs, dual-degree programs, and fast-track doctoral procedures (University of Potsdam, 2015, p. 2).
More than 60% of German HEIs hold the view that EMI can sharpen their international profile. For instance, the strategy of the University of Regensburg states: Double Degree programs, English taught Master programs, as well as degree programs with a strong international focus, enhance the international profile of UR (University of Regensburg, 2018, p. 1).
More than 63% of the universities believe that EMI programs are equal to high quality. For instance, the University of Münster states that it is the University's aim to achieve a top position amongst the world's leading universities through: "multilingual(ism)/plurilingual(ism)". The advocation of EMI is shared in the ideologies/attitudes at these three levels, which can be verified by the discussions about ideologies at each, displayed in the preceding section. However, similar attitudes towards EMI are embedded in different discourses, which also make some differences. The concordance hits and keyness of "English", "language/linguistic" and "multilingual(ism)/plurilingual(ism)" in documents at these three levels are displayed in Table 9. The texts of European internationalization policies contain 183,876-word tokens and the concordance hits of the word "English", "language/linguistic" and "multilingual(ism)/plurilingual(ism)" are 147, 24 and 14, with the keyness of 710, 29 and 130. Distinctions are found between internationalization documents at different levels. In comparison, the keyness of "language/linguistic" and "English" are significantly lower in European policy texts than those at the other two levels, while that of "multilingual(ism)/plurilingual(ism)" is generally the same. The keyness of both "language" and "English" decreases from the European level to the federal and university levels.
But "language" has the highest keyness at the German federal level while "English", the university level. It indicates that the language issues are more overtly mentioned at the German federal level while the universities tend to focus directly on the more specific "English" issue. In general, in the context of HE internationalization, European institutions show least concern about language issues, while the German federal institutions, in practical implementation of internationalization, give more attention to language issues, but relatively abstract, and the universities concentrate more on the specific "English" language issues, and even "EMI", whose synonymous expressions appear 210 times at the university level.

Discussion
The data analysis results suggest that the policies and practices towards EMI have revealed the institutional language ideologies at different levels both explicitly and implicitly. Language issues do not feature in European mobility-led internationalization policies. In light of the ideology of equaling mobility as HE internationalization and high HE quality, EMI development has been implicated in the mobility discourse. BMBF, DAAD and HRK have generally agreed that EMI is one of the primary means for HE internationalization and high HE quality, thus enhancing the competitiveness of its tertiary education in the global arena. EMI hampering German language promotion has also been acknowledged in its discourse. Universities' attitudes towards English are predominantly positive and the introduction of EMI programs is equal to international attractiveness, international profile of the universities and high HE quality. The five-fold increase (from 214 in 2008 to 1,463 in 2019) in the number of EMI programs in the past decade and the predominant English-only type of EMI programs can also demonstrate the German HEIs' welcoming attitudes towards EMI programs.
Thus, these three levels are consistent in recognizing the positive roles that EMI plays in developing HE internationalization with high HE quality. But the discourses at three levels mention language-related issues and EMI with different extent of implication. It indicates that the internationalization policies at the European level show the most tendency to evade the language issue, especially English, while the German internationalization documents include more contents about language and even EMI, construing English as "foreign language" can also be found, and they are concerned about promoting German language alongside English. At the university level, the welcoming attitudes towards EMI are displayed most overtly in the internationalization strategies and the development trend of EMI programs. The results of this study are in line with the previous multilayered studies in that discrepancies exist between different levels (e.g., Halonen, Ihalainen, & Saarinen, 2014;Soler-Carbonell, Saarinen, & Kibbermann, 2017).
On the surface, the BP is not directly related to language, but its implementation requires a lingua franca in the field of education in order to achieve mobility, which solidifies the importance of English among the transnational and cross-language flow of international students (Rose & Galloway, 2019, p. 194). The higher education internationalization policies of the EU and other supranational institutions are not specific to language, but they in fact function as implicit language policies (Piller & Cho, 2013;Ljosland, 2014;Saarinen, 2014;Macaro et al., 2019). They have a "trickle-down" effect on the EMI policies and practices at the level of European states and universities. Costa and Coleman (2013) even think that the Bologna process has practically resulted in the Englishization of the curriculum, which has undermined the policy objective of European multilingualism or the "mother tongue plus two other languages", thus leaving little room for foreign languages other than English.
The European states used to shoulder the sole responsibilities for national education policies, but since the beginning of the 21st century, in response to the acceleration of globalization and internationalization, the supranational policymaking at the European level has become increasingly important. The Bologna Process is a case in point. Yet European states are different significantly in cultures and structures, the national states have to engage with the local interpretation of those European initiatives and give more explicit guidelines as regards the English language and the national language specific to their circumstances.
Also, universities are increasingly reacting to market forces rather than only to national initiatives and they face more implementation problems in language issue. German universities have set up EMI programs not only for international mobility programs, but also the overall trend of globalization and internationalization. Because of this trend, English has established itself as the most used language in lingua franca context (Crystal, 1997;Graddol, 1997) and the dominant language for international communication (Graddol, 1997;Seidlhofer et al., 2009). In the German context, as is the case in the rest of Europe, English has permeated into nearly all domains of German society. According to the report from Education First which investigated English proficiency of adults in more than 100 non-English speaking countries/regions, Germany ranks at the highest band of "very high proficiency" (Education First, 2019). According to the report of Federal Bureau of Statistics in Germany (2018), in the 2016−2017 school year, around 7.2 million primary and secondary students learned English in Germany, which corresponds to 86% of the total student population, whereas only 17.6% learned French, the second most widely learned language. Thus, it's quite natural for universities in Germany to adopt English as the teaching medium. Germany, and the other non-English-speaking European countries are undertaking a process of introducing EMI as a means of overcoming any competitive disadvantage resulting from their linguistic situation (Maiworm & Wächter, 2008, p. 15).
From the policy documents analyzed in this paper, a key emerging sociolinguistic concern is how to balance between the status and use of the English language and the German language. The relationship between the English language and the national language has always been a concern among scholars (e.g., Björkman, 2013;Lasagabaster, 2015). The heart of the question seems to be that universities are regarded by many as the guarantors of the maintenance and development of national cultures and languages, though at the same time they are expected to operate and be competitive on an international scale (Cots, Lasagabaster, & Garrett, 2012). As seen from the analysis, the European and German federal levels have increasingly emphasized the important role universities can play in balancing the English language and the national language, and promoting linguistic diversity. Actually, EMI originated in the European ideal of plurilingual competence for EU citizens, and the European language policies of multilingualism or linguistic diversity, which is held to be vital both for the inheritance of European cultural assets and personal development of European citizens. The European Action Plan 2004-2006 specifies that higher education institutions play a key role in promoting societal and individual multilingualism (European Commission, 2004, p. 8). In the report of the European Higher Education in the World, the European Union urges universities to balance the dominance of English and promote multilingualism at the university level (European Commission, 2013). In Bologna Process 2020, linguistic diversity is the expected outcome of the higher education internationalization. Thus, universities have been increasingly aware of their importance of carrying out their own language planning at the university level.

Conclusion and Implications
Employing document analysis and corpus-assisted discourse analysis, this study has examined the management, ideologies and practices for EMI in German higher education internationalization, across European, German federal and university levels, adopting Spolsky's (2004Spolsky's ( , 2009 framework. Results have shown that the German EMI development has been shaped by the joint forces of activities at the level of European, German federal and university levels. The present study has the following implications. Theoretically, Spolsky's tripartite framework can provide a useful analytic perspective on the interrelationship between policies and practices in the study of EMI programs in German HE. This study has shown that the language management, practices and ideology are analytically distinct, yet interconnected and interdependent. Also, the multi-layered examination of these three dimensions at European, German federal and university levels illuminates the real EMI phenomenon in Germany, which can contribute to the illumination of the connections across the various levels of LPP, the "perennial challenge" (Hult, 2010) for the LPP field.
Practically, while this study focuses on the EMI situation in German HE, the results certainly have implications for other contexts, where English is being used increasingly as the teaching medium. It's widely acknowledged that globalization has prompted a wide range of policy borrowing in the field of higher education globally (Rizvi & Lingard, 2010), and the prevalence of EMI programs in German universities is a good example. But globalization is not a top-down homogenization of politics and cultures, education policies resulting from globalization is reinterpreted and reconstructed through the educational structure at the national and local levels.
To international universities, they have to balance the demands of globalization and internationalization and their own interests, which is not an easy task. Especially at present there is a simple understanding of equaling HE internationalization with EMI and a lack of deep understanding of the real meaning of HE internationalization, much work is necessary at multiple levels in order to create a space that can more fully support the potential of sound EMI development in the higher education sector.
This study also has some limitations which can be improved in future studies. Firstly, this study fails to gather all documents needed to explore the interrelationship among BMBF, HRK and DAAD. The absence of annual reports of the DAAD before 2009 makes the analysis about the development of the DAAD and its longitudinal comparison with the BMBF and the HRK less enlightening. Secondly, this study has failed to analyze the EMI data in a stratified fashion, for example, domestic vs. international students, which can be improved in the future. Finally, because of the practical limitation, this study hasn't collected stakeholders', such as teachers' and students' attitudes towards EMI through questionnaires and interviews, which can be conducted to get a fuller picture of the language practices.