1999 Edition

COMMISSION ON COLLEGES AND UNIVERSITIES

8060 165^th Avenue NE, Suite 100

Redmond, WA  98052-3935

Phone:  425/376-0596   www.nwccu.org

Policy A-2 - Substantive Change

The Commission on Colleges and Universities monitors proposed changes whenever an accredited or candidate institution plans a substantive change in its mission and goals, scope, control, area served or other significant matters.

Introduction. Accreditation or candidacy for accreditation of an institution applies to those units, programs, and other institutional activities which were included in the institutional self-study and were reviewed by an evaluation committee as required by the Commission on Colleges and Universities. Insofar as institutions are in a continual process of change, the Commission requires that all institutions be reevaluated periodically. Most changes, such as adding or dropping courses, developing new concentrations that are allied with existing offerings, and changing personnel, are not substantive and fall within the nature and scope of the institution as last evaluated. However, a change of such magnitude as to significantly alter an institution's mission and goals; the scope or degree level of its offerings; its autonomy, sponsorship, or the locus of control over it; offering academic programs for credit through contractual relationships with external organizations; offering programs for credit outside the NASC region; or adding a branch campus would constitute a major substantive change. Substantive changes initiated subsequent to the most recent institutional evaluation are not automatically included in the institution's accredited or candidate status. While the decision to make changes is an institutional prerogative and responsibility, the Commission is obligated to monitor the effect of a substantive change on the validity of the institution's accreditation status with the Commission.

Determination of Significance. The Commission on Colleges and Universities is concerned primarily with major substantive changes and relies upon the staff of the Commission to determine if a proposed substantive change is major, minor, or no change in nature. Careful consideration is sometimes necessary in deciding if an institutional change is substantive and, if so, whether it is major, minor, or no change in to institutions that qualify by maintaining internal mechanisms and safeguards thus assuring the Commission that its concerns regarding institutional change are adequately addressed in a consistent manner.

Criteria for Recognition of Level II Oversight:

Institutions qualifying for consideration for recognition of Level II oversight:

1. are accredited by the Commission on Colleges and Universities;

2. have not had a Warning or Probation imposed within the immediate past ten years;

3. have not been issued a Show Cause order within the immediate past twenty years; and

4. possess a successful history of adherence to the Commission’s policy on substantive change.

Institutions shall request prior approval from the Commission to conduct Level II oversight of institutional substantive changes. In requesting approval for Level II oversight, an institution must provide evidence to warrant the confidence of the Commission that it maintains appropriate oversight policies, procedures, practices, and documentation to ensure required items a through i of the major substantive change prospectus (see Prospectus below) are consistently addressed in a satisfactory manner. Notification. When considering a substantive change, an institution is required to notify the Commission early in its deliberations. Early notification enables the staff to provide information and advice regarding the effect of the proposed change on the accreditation or candidate status of the institution and the procedures to be followed in seeking approval.

Major Substantive Change – Oversight Levels I and II

Prospectus. In submitting a proposal for a major substantive change, the institution is required to complete a prospectus. The purpose of a prospectus is to enable the institution to set forth the activities constituting the change and the impact expected on the institution as a whole. The prospectus is to be single-spaced, printed on both sides, and submitted in six unbound copies. The Commission staff review the prospectus and request any further information that is needed. Although the scope and depth of information to be provided in the prospectus will depend upon the nature of the proposed change, responses to the following are required:

 a. Mission and Goals:

b. Authorization:

c. Educational Offerings:

Size, complexity, maturity, and experience of the institution in effecting significant change are important factors. Usually, it is possible for the Executive Director of the Commission to determine whether a change proposed by an institution is major, minor, or no change. If the institution disagrees with the decision of the Executive Director regarding the significance of the change, the matter may be referred to the Commission for reconsideration. A list of examples of major and minor substantive changes follows this policy.

Levels of Oversight. The Commission expects each accredited institution to meet all of the Commission’s Eligibility Requirements, Standards and Related Policies at all times. With this expectation, the Commission recognizes that institutional history and characteristics may warrant discretion in the procedures used to approve institutional changes. Level I, direct Commission oversight of institutional substantive changes, is the status granted by the Commission to all accredited and candidate institutions. However, the Commission may grant a more general level of oversight, Level II, d. Planning:

e. Budget:

For major substantive changes, a copy of the institution's most recent IPEDS financial report is required.

When an institution seeks approval to establish a branch campus, the prospectus must include a thorough response to each of e.1 through e.4 above to assist in an evaluation of the institution’s fiscal and administrative capacity to operate the additional location as required by 34 CFR 602.22. Revenues and expenditures must include a cash flow analysis. (See ** on page 7.)

 f. Student Services: 1. provision for student services to accommodate the change; and 2. implications of the change for services to the rest of the student body;

g. Physical Facilities: 1. provision for physical facilities and equipment;

h. Library and Information Resources:

i. Faculty:

Review of the Proposal. In order to expedite consideration of a major substantive change proposal, the Commission follows these procedures:

1. member and candidate institutions may submit a proposal for substantive change at any time during the year;

2. following receipt of a prospectus, Commission staff analyze the proposal and send a copy of the analysis with a copy of the prospectus to three members of the Commission for review;

3. on behalf of the Commission, the Commissioner-reviewers consider the impact of the proposed change on existing institutional programs, resources, and services and judge whether it is reasonable to expect that the Commission’s criteria for accreditation will continue to be met; and

4. Commissioner-reviewers submit their findings to the Executive Director of the Commission.

If the proposal is approved by all three Commissioner-reviewers, the institution is notified in writing to proceed with the change which is noted in the institution’s accreditation. The proposal is then noted as an information item on the agenda for the Commission's next regularly scheduled meeting. If one or more of the Commissioner-reviewers recommend the proposal be denied, the proposal is denied and the institution is notified in writing and given the reasons for the denial.

Request for Reconsideration. If approval of the major substantive change is denied, the institution may provide thirty-four copies of the original or a revised prospectus and request consideration by the Commission at its next regularly scheduled semi-annual meeting. If the matter is considered by the Commission, one of the following actions will be taken:

The president of the institution is notified in writing of the action taken by the Commission and the reasons for the action. If the proposal is approved, follow-up actions, if any, are determined by the nature of the change and any other factors deemed appropriate by the Commission. If the proposal is denied, the reasons for the denial are specified in the written notification.

Implementation of Unapproved Changes. If an institution implements a substantive change without prior written notice or if it proceeds to implement a substantive change denied by the Commission, the Commission may consider issuance of an order for the institution to show cause why its accreditation or candidate status should not be terminated.

Accreditation and Informal Candidacy at a New Degree Level. If the Commission approves a proposal to offer a program at a degree level not previously approved and listed for the institution in the Commission’s Directory, the institution is granted informal candidacy at the new degree level while retaining accreditation at the previously approved degree level(s). All other types of approved substantive change proposals are included under the accreditation of the institution.

Follow-up Oversight. Following approval of a major substantive change, the Commission may conduct follow-up oversight of the change. The nature of the oversight is determined by the nature of the change.

Informal Candidacy. When an institution has informal candidacy status at a new degree level, it is expected to conduct a comprehensive self-study of all degree levels of the institution and be visited by a full evaluation committee during the academic year following the graduation of the first class at the new degree level. The policies and procedures for comprehensive evaluations as listed in the current edition of the Accreditation Handbook will apply, and the action taken by the Commission following such evaluation will apply to the accreditation of the institution as a whole, not merely to the programs at the new degree level. The effective date of accreditation at the new degree level is September 1 of the academic year immediately preceding the academic year in which the evaluation took place.

Branch Campus. U.S. Department of Education regulations require an evaluation visit within six months following approval for the establishment of a branch campus by an institution with certain characteristics. (34 CFR 602.22)

Other Major Substantive Changes. For all other kinds of major substantive changes, the Commission may, as a condition of approval, request follow-up oversight, including the scheduling and conduct of an on-site evaluation. The nature of the change will determine the scope of any follow-up evaluation. Onsite Evaluations. The size and composition of the on-site evaluation committee will depend on the nature of the substantive change. The dates for the on-site evaluation are set by Commission staff in consultation with appropriate institutional officials.

Report. Prior to the visit, the institution will prepare and submit 34 copies of a concise report that assesses the effect of the substantive change. The report need not repeat material submitted in the prospectus but should provide evidence and analysis of:

a. effects of the change on the total institution;

b. desirable revisions in the change based on the first year's experience;

c. new program(s) not previously approved or existing program(s) offered at a new location(s),

Minor Substantive Change – Oversight Level I

The Commission recognizes the importance of purposeful constructive institutional change and does not want to inhibit such change. The Commission also recognizes that while some changes are substantive because they affect the mission and goals, scope, or form of control of an institution, other changes are limited in nature and the procedures that apply for a major substantive change are not appropriate. When Commission staff determine that a proposed substantive change is minor in nature, the Executive Director, on behalf of the Commission, is authorized to act on the institution’s proposal. Prospectus. A prospectus for a minor substantive change is expected to provide the same information as requested for a major substantive change (see Prospectus above). However, a copy of the institution’s most recent IPEDS financial report is not required for a minor substantive change proposal unless requested by Commission staff. Upon receipt of a minor substantive change prospectus, Commission staff analyze the proposal and send a copy of the analysis to the Executive Director who is authorized by the Commission to evaluate and take action on the proposal and the institution will be notified in writing of the resulting decision. If the proposal is approved, follow-up requirements, if any, are determined by the nature of the change and any other factors that may require further attention. If the proposal is denied, the institution may request the matter be referred to the Commission for consideration.

Minor Substantive Change – Oversight Level II

Notification. Prior to implementing an eligible institutional change, institutions with Level II oversight status notify the Commission in writing of the proposed change and certify that all required documentation for the change is available to the Commission for review. Commission staff review the notification with regard to the nature of change. If the change is judged to be appropriate with Level II oversight for the institution, the institution is approved to proceed with the change which will be included under the accreditation of the institution.

Subsequent Review. The Commission may, at any time, conduct a review of an institution’s documentation and procedures regarding Level II oversight of institutional changes. In particular, institutions granted Level II oversight status will undergo a careful review of institutional changes during regular fifth-year and comprehensive decennial evaluation visits.

Revocation of Oversight Status. If a review of an institution’s documentation or procedures finds inadequate or inconsistent compliance with policies, procedures, and documentation required for Level II oversight, the institution will be required to respond to the findings in writing. If the Commission does not accept the institution’s response, the institution’s Level II substantive change oversight status will be revoked and Level I oversight status will be reinstated. Following revocation of Level II oversight status, an institution is ineligible for a period of two years from the date of the Commission’s revocation action to reapply for Level II oversight consideration.

No Change – Oversight Levels I and II Notification. Prior to implementation, institutions notify the Commission in writing of the proposed change. Commission staff review the notification and determine the nature of change. If the change is judged to be consistent with the institution’s existing accreditation, the institution is notified that the proposed change constitutes no change and the change is included under the existing accreditation of the institution. If the proposed change is determined to be major or minor in nature, the institution is so notified in writing and referred to the appropriate procedure within this policy for approval of the change.
Examples of Major and Minor Substantive Changes for Oversight Level I/II Institutions

Nature of Change Level I Level II

1. Institutional mission and goals (other than minor refinements); Major Major

2. Legal status, sponsorship, form of control, or ownership including merger with another institution; Major Major

3. Addition of a degree program at a new degree level not listed for the institution in the NASC Directory; (See * below) Major Major

4. Establishment of a branch campus; (See ** below) Major Major

5. Offering courses/program(s) for academic credit outside the NASC region; Major Major

6. Contractual agreement with non-regionally accredited organization for the organization to provide courses and program(s) for academic credit on behalf of the candidate or accredited institution; Major Major

7. Offering program(s) for academic credit within the NASC region in a legal jurisdiction not previously reported and evaluated; Major Minor

8. Establishing a new degree program not closely related to other fields of study previously reported and evaluated; Major Minor

9. Offering a program or offering a degree-completion program by distance delivery;

(Requires response to Policy 2.6, pages 44-47, for first time use of a distance delivery infrastructure or for significant departure from a distance delivery infrastructure previously reviewed and evaluated.)

Major Minor

10. A change from clock hours to credit hours or vice versa or a substantial increase or decrease in the length of a program or the number of clock or credit hours awarded for successful completion of a program;

Minor Minor

11. Offering program(s) for academic credit in a legal jurisdiction previously reported and evaluated, but at a new site;

Minor No Change

12. Offering a new program on a trial basis or for a limited time, such as a summer session or for a special group;

Minor No Change

13. Establishing a new degree program closely related to well-established fields of study previously reported and evaluated;

Minor No Change

* Program. A systematic, usually sequential, grouping of courses forming a considerable part, or all, of the requirements for a degree or credential.

** Branch Campus: A location of an institution that is geographically apart and independent of the main campus and (1) is permanent in nature; (2) offers at least 50% of the courses of an educational program leading to a degree, certificate, or other educational credential; (3) has its own faculty and administrative organization; and Adopted 1972/Revised 1978, 1994, 1996, 2001.