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Institutional Resources
Substantive Changes

Substantive Change - Frequently Asked Questions
(July 2014)

Note:  words or phrases in blue are links to the indicated document

1. Why is SACSCOC interested in changes occurring at institutions that are already accredited?

The Southern Association of Colleges and Schools Commission on Colleges accredits an entire institution, including all of its programs and services, wherever they are located or however they are delivered.  The Commission is interested in significant changes that are occurring at member institutions because the scope of accreditation extends to the total college or university.  Significant changes are illustrated in the Commission’s policy Substantive Change for SACSCOC Accredited Institutions.

2. Please give examples of some of the most common substantive changes.

The most common substantive changes reported are new off-campus sites where 50% or more of the credits in a program are offered, offering for the first time 50% or more of an educational program delivered via technology-based instruction, and the addition of new site-based programs that are significantly different from current offerings (program expansion at the current level).

3. How do we inform the Commission of a possible substantive change?

Some substantive changes require only prior notification to the Commission, some require prior notification and submission of a prospectus for approval, and some allow for the submission of a prospectus for approval to serve as the only notification of the change.  In the Substantive Change Policy, changes requiring submission of a prospectus for prior approval are known as Procedure 1 changes, and those requiring prior notification but not prior approval are Procedure 2 changes.  These are detailed in the policy document Substantive Change for SACSCOC Accredited Institutions.

Correspondence related to substantive change, including letters of notification and prospectuses should be addressed to:

  Dr. Belle Wheelan, President
Southern Association of Colleges and Schools Commission on Colleges
1866 Southern Lane
Decatur, GA 30033

Letters of notification and cover letters accompanying prospectuses or other submissions must be submitted on the institution’s letterhead and signed by the institution’s president or designated representative.

In December, 2012, the Commission voted to dispense with many of the previously required letters of notification.  Currently, Procedure 2 changes that require prior notification but do not automatically require submission of a prospectus include cases where the institution intends to:

  • Initiate an off-campus site – including a dual-enrollment high school site -  at which a student may earn at least 25% but less than 50 percent of credits toward a program (please be sure to include the street address and starting date).
  • Move an approved off-campus instructional site within the same geographic area to serve essentially the same pool of students. The letter of notification must include the address of the old site, the address of the new site, and the starting date of the new site.
  • Offer for the first time credit courses via distance learning/technology-based instruction by which students can obtain at least 25% but less than 50% of their credits toward an educational program.
  • Initiate programs/courses delivered through contractual agreement or a consortium.  This provision does not apply to articulation agreements with other institutions, clinical agreements, or internship agreements.
  • Enter into a contract with an entity not certified to participate in USDOE Title IV programs if the entity provides less than 25% of an educational program offered by the accredited institution.  A copy of the signed agreement must be provided.
  • Repackage existing approved curriculum to create a new degree level, such as an institution that offers a full 120-hour baccalaureate program creating an associate degree from its lower-division offerings.
  • Initiate a dual degree program with another SACSCOC-approved institution

Examples of Procedure 1 substantive changes that require notification followed by submission of a prospectus include:

  • Expanding at current degree level (significant departure from current programs)
  • Offering 50% or more of at least one program’s credits at a new off-campus instructional site – including a dual enrollment high school site.
  • Initiating a branch campus
  • Initiating certificate programs that are significant departures from previously approved programs
  • Initiating a joint degree with an institution not accredited by SACSCOC
  • Relocating a main or branch campus

The above lists are not exhaustive.  See the text and table in Substantive Change for SACSCOC Accredited Institutions for more details.

4. What do we do if we are not sure if a proposed change is substantive enough for notification or approval?

When unsure what action, if any, is needed, an institution’s accreditation liaison might want to email or call the SACSCOC staff member assigned to the institution to discuss the situation.  If you do not know who this person is, the name can be found in our member database.  In some cases where a judgment call needs to be made (for example, whether or not a new program represents a significant departure from existing programs at the same level), the institution may want to send notification that includes details that help the SACSCOC staff determine whether or not a prospectus is needed.

5. Why can’t I send the notification and prospectus by e-mail?

We do not accept email substantive change submissions for two reasons:

1) the authenticity of the communication may not be assured; and 2) documents submitted in physical form to Dr. Belle Wheelan are logged in and tracked so that you are assured of a timely, authoritative response.  Emailed submissions are too easily lost, corrupted or misdirected, for instance to a spam or junk mail folder.

6. A local business has asked us to offer our approved MBA degree program at their facility for a specific target audience.  Is this considered a substantive change?

Yes, the guidelines are the same whether a single cohort or a continuous program will be offered.  When an institution establishes an off-campus site at which 50% or more of the credits in a program can be obtained, a prospectus should be submitted 3 months prior to the start date. 

7. We started offering a few online courses several years ago.  Now it appears that students can complete a majority of their program online although that was not intended when we started.  Do we have to report this?

Yes, when an institution begins to offer electronically courses that lead to a degree, diploma, or certificate such that 50% or more of the credits can be obtained distance learning, the institution should notify the Commission of this development and submit a prospectus for approval.  Once the institution is approved to offer distance learning, it may offer other, approved programs via distance delivery without further notification.

The fact that the online offering was initiated without prior approval means that the institution is not in compliance with Comprehensive Standard 3.12 of the Principles of Accreditation.  The institution will be asked to submit its policy and procedure for timely reporting of substantive changes for review at the next meeting of the SACSCOC Board of Trustees.

8. At the present time, we offer a master’s degree in political science.  Do we need to seek approval from the Commission if we plan to begin a doctorate in political science?  Our institution has doctoral degrees in education and religion. 

Yes, the doctorate in political science is significantly different from the existing doctoral degrees in education and religion.  The institution should submit a prospectus to justify the new doctoral program at least 3 months before the intended starting date for approval of the program.

9. What is the difference between a prospectus and an application for level change?

An application for level change supports a request to offer courses or programs at higher or lower degree level from that which is currently approved. It consists of two parts: (1) “Institutional Summary Form Prepared for Commission Review” and (2) the “Application for a Member Institution Seeking Accreditation at a Higher or Lower Degree Level.”  Applications are reviewed by the SACSCOC Board of Trustees; they should be submitted by April 15 for review in June, or by September 15 for review in December.

A prospectus is required for approval of all other substantive changes that require approval in advance of implementation.  It provides a description of the proposed change and evidence that the institution has the resources to support that change.  A prospectus should be submitted at least 3 months before the starting date of the proposed change. 

10. Do we need to notify the Commission if we intend to close a program or an instructional site?

Yes, closing a program or a site is also a substantive change requiring notification and specific types of documentation showing how the institution will deal fairly and appropriately with students, faculty and staff affected by the closure.  Please see Procedure 3 of the policy document Substantive Change for SACSCOC Accredited Institutions.

11. What must we do if our institution has implemented changes that should have been approved in advance?

An institution that has implemented substantive changes that should have been approved in advance of implementation is not in compliance with Comprehensive Standard 3.12 of the Principles of Accreditation.  The institution should notify the President of the Commission immediately in writing concerning the unreported substantive change(s).  The institution will be asked to submit its policy and procedure for timely reporting of substantive changes for review at the next meeting of the SACSCOC Board of Trustees. Please see the Commission’s policy statement on unreported substantive change in the Commission document Substantive Change for SACSCOC Accredited Institutions.

12. Is a team visit required for most substantive changes?

An on-site committee visit is required within 6 months after initiation of the following changes: 

(a) the initiation of an off-campus site at which a student can earn 50% or more of the credits in an educational program (Note: If an institution has more than 3 approved off-campus sites and has demonstrated effective oversight of off-campus locations, the Commission may choose to delay a visit until the 5th year of the decennial review);

(b) the initiation of a branch campus;

(c) the initiation of a change in governance or ownership;

(d) the initiation of a merger, consolidation or other change in governance; and

(e) the initiation of courses or degrees at higher or lower level. 

Other changes may require a visit if a more in-depth evaluation beyond the prospectus appears to be warranted. 

13. Our college is interested in reconfiguring existing courses in an approved program to create a new degree.  Is this considered substantive to SACS?

In most cases, the re-packaging of existing courses does not constitute a substantive change.

14. Do we need to report collaborative programs with foreign institutions or consortia with institutions in our system?

If the institution is establishing a contractual agreement with another institution to offer credit instruction leading to a diploma, certificate or degree, a letter of notification should be sent to the Commission as well as a signed copy of the written agreement. 

For dual degrees or joint degrees, please see the Commission policy Agreements Involving Joint and Dual Academic Awards.

15. Do new continuing education programs need to be reported?

If these new programs involve credit instruction, they should be reported in keeping with the substantive change policy.  Non-credit programs that do not qualify for federal aid do not constitute substantive changes.



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