Substantive Change FAQs

Frequently Asked Questions about Substantive Change

I’m getting ready to submit a substantive change. Should I submit according to the previous policy or the revised (2020) policy?

Submissions dated January 1, 2021, or earlier and received shortly after the January 1, 2021, deadline should follow the previous policy.  Submissions dated after the January 1, 2021, deadline must follow the revised policy.

What is the recommended course of action for a program that DOES NOT qualify as a substantive change under the previous policy but DOES qualify under the revised (2020) policy?

The revised policy applies to changes implemented after January 1, 2021.  Do not submit notifications or prospectuses for substantive changes implemented before January 1, 2021, if not also required under the previous policy. For example, the revised policy requires notification for some new programs but the previous policy required neither notification nor approval; you should not submit notifications now for previously implemented programs. Note:  institutions are subject to Substantive Change Restrictions (explained in the policy) if placed on sanction on September 3, 2020 or later (i.e., at the September 2020 Board of Trustees meetings or later).

Were due dates for submitting substantive changes altered in the revised (2020) policy?

No, the due dates are unchanged from the previous policy. Due dates depend on the planned implementation date and whether approval, if required, requires Executive Council approval or full Board of Trustees approval. Consult the policy for specific dates and explanations.


I see references in the revised (2020) policy to “an institutional-level review.” Does that refer to an institution’s internal review process?

No, that refers to certain substantive changes that require a review of the specific change being proposed plus a review of related institutional-level characteristics.  For example, a prospectus for approval of an institution’s first program in which 50% or more of the content is delivered by distance education includes a review of the program plus a review of institutional-level characteristics such as faculty training to support distance learning, the institution’s distance learning budget, evidence of inclusion of distance learning in standing planning and evaluation processes, etc. Other types of substantive change that include an institutional-level review are off-campus instructional site approval by the extensive review pathway and competency-based education by the course/credit-based approach approval.

Did the policy name change?

Yes. The previous policy was Substantive Change for SACSCOC Accredited Institutions. The revised (2020) policy is Substantive Change Policy and Procedures. For clarity, it may be referred to as the SACSCOC Substantive Change Policy and Procedures, especially to differentiate the SACSCOC policy from an institution’s substantive change policy and procedures.


The revised policy now requires notification when adding a method of delivery (competency-based education, distance education, or face-to-face instruction) to a program. We’re delivering more programs through hybrid (also called HyFlex learning) delivery but that’s not one of the methods of delivery. Is notification required? (Added 01/21/2021; Updated 02/18/2021)

Method of delivery applies to how 50% or more of the content is delivered.  A program may have more than one method of delivery:  if a hybrid course is half face-to-face, half distance education, then it would have two methods of delivery.  If you’re adding a method of delivery to a program that results in 50% or more of the program being delivered by that method, then notification is required; if it is less than 50%, then notification isn’t required.


  1. If an institution currently offers a program by face-to-face instruction only and converts the program to 100% delivery by distance education, then that is considered adding a distance education method of delivery. (It’s also a closure of the face-to-face delivery which requires a teach-out and closure approval.)
  2. If an institution currently offers a program by distance education only and adds as an additional option 100% delivery by face-to-face instruction – i.e., students may complete the program by distance education or by face-to-face instruction – then that is considered adding a face-to-face method of delivery.
  3. If an institution currently offers a program by face-to-face instruction and converts the program to a hybrid delivery with 60% face-to-face and 30% course/credit-based competency-based education, then that is not considered adding competency-based education as a method of delivery because the majority of the course remains face-to-face.

This clarification will be added to the next update of the substantive change policy.


I know Substantive Change Restriction applies when an institution is on sanction and continues for three years afterwards. My institution was removed from sanction before the revised (2020) policy but less than three years ago. Does this mean my institution is now on Substantive Change Restriction? (Added 02/04/2021)

No.  Substantive Change Restriction applies to institutions placed on sanction in September 2020 and afterwards; for those institutions, Substantive Change Restriction will continue for three years after sanction is removed. However, there’s no reach-back provision for Substantive Change Restriction for institutions removed from sanction before September 2020.

I’m preparing a prospectus that requires the institution’s two most recent financial statement audits. In our state, public universities do not have annual independent financial audits; we are considered part of the system’s consolidated financial report. Can I provide the unaudited financial statements submitted to the system that are aggregated into the system’s consolidated financial report? (Added 08/02/2022)

No.  An audited/reviewed financial statement is required; unaudited is insufficient.  If your institutional financial statements are included as supplemental schedules to the opinioned system audit, that may be submitted as audit evidence.  The schedules must be a published part of the audit to be considered.  Additional institutional finance guidance, including audits, is available on the SACSCOC website; this guidance is in the context of compliance certifications and monitoring reports, but the core audit guidance applies to substantive change submissions, too.

Dual Academic Awards: We’re creating an option for doctoral students to concurrently earn a Ph.D. and an M.B.A. The revised policy says “Dual academic awards exclude completion or pathway options across credential levels.” Does this mean we can’t offer this option? (Added 02/18/2021)

No.  A completion pathway across academic degree levels is not prohibited.  But because it doesn’t meet the substantive change definition of a dual academic award, notification isn’t required.

However, if the institution opted to create a Ph.D./J.D. pathway or an M.D./Ph.D. medical scholars pathway, for example, that would meet the definition of a dual academic award because the programs are at the same degree level – the doctorate – and would require a substantive change notification.