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Substantive Change for Regional Accreditation

  • Responsible Office: SACSCOC Accreditation Liaison, Office of the Provost
  • Current Approved Version: 10/14/2019
  • Policy Type: Administrative

Policy Statement and Purpose

The Southern Association of Colleges and Schools Commission on Colleges (SACSCOC) requires all accredited member institutions to notify the Commission of substantive changes and, when required, to seek approval prior to the initiation of the changes. Member institutions, such as VCU, are required to have a policy and procedure to ensure that all substantive changes are reported to the Commission in a timely and appropriate fashion. The purpose of this policy is to satisfy that requirement by detailing the responsibilities of university stakeholders.

This policy addresses compliance with SACSCOC only. Academic activities associated with substantive change often require notification or approval from the State Council of Higher Education for Virginia (SCHEV). Compliance with one agency does not constitute compliance with the other. Additionally, this policy does not address other internal and external reviews and approvals that may be required prior to implementation.

Noncompliance with this policy by VCU employees may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.

Who Should Know This Policy

All university members whose unit may be involved in a substantive change should know this policy and familiarize themselves with its contents and provisions.

Definitions

Branch Campus

A branch campus is a location of an institution that is geographically apart and independent of the main campus of the institution. A location is independent of the main campus if the location is

• permanent in nature

• offers courses in educational programs leading to a degree, certificate, or other recognized educational credential

• has its own faculty and administrative or supervisory organization and

• has its own budgetary and hiring authority

Educational Program

An educational program is a coherent course of study leading to the awarding of a credential (i.e., a degree, diploma or certificate).

Initiating Unit

An initiating unit is any academic unit or non-academic unit whose proposed activity involves a potential substantive change.

SACSCOC Accreditation Liaison

The accreditation liaison serves as the resource person on campus for SACSCOC accreditation questions and as the institutional contact person for SACSCOC personnel. Appointed by the president, the institution’s accreditation liaison reports directly to the chief executive officer and serves as a senior administrator or faculty member with a suitable degree of visibility on campus.

Significant Departure

A significant departure is a program that is not closely related to previously approved programs at the institution or site or for the mode of delivery in question. To determine whether a new program is a “significant departure,” it is helpful to consider the following questions:

• What previously approved programs does the institution offer that are closely related to the new program and how are they related?

• Will significant additional equipment or facilities be needed?

• Will significant additional financial resources be needed?

• Will a significant number of new courses will be required?

• Will a significant number of new faculty members will be required?

• Will significant additional library/learning resources be needed?

Substantive Change

Substantive change, as defined by SACSCOC, is a significant modification or expansion of the nature and scope of an accredited institution. Substantive changes can include academic and non-academic institutional activities.

Contacts

The SACSCOC accreditation liaison in the Office of the Provost officially interprets this policy. The Office of the Provost is responsible for obtaining approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to the SACSCOC accreditation liaison.

Policy Specifics and Procedures

Substantive changes can originate in academic and non-academic units. The nature of a particular substantive change determines whether an academic or non-academic process is required. Any unit whose planned activity may constitute a substantive change must comply with the applicable process before implementation. The SACSCOC accreditation liaison bears final responsibility for determining whether an institutional action qualifies as a substantive change.

Process for Academic Substantive Change

1. Review of Proposed Action and Identification of Substantive Change(s): Identification of academic substantive changes occurs (a) through the screening of a proposal advanced by an academic department/college/school, or other academic-related unit, that comes to the Office of the Provost in the course of a broader formal review and approval process; or (b) by an academic dean whose area is planning a significant modification or expansion that is not subject to an existing formal review and approval process, and therefore might not otherwise come to the attention of the SACSCOC accreditation liaison. 

 In the first case, the SACSCOC accreditation liaison will vet proposals for potential substantive changes as part of the Office of the Provost review and approval process. 

In the second case, the dean is responsible for proactively reviewing the unit’s intended action as a potential substantive change. If the dean identifies the proposed action as a potential substantive change, or if there is any question, the dean, not a designee, must submit an internal request for review to the SACSCOC accreditation liaison. The dean must do the following:

Step 1: Write a request containing: description of proposed action; potential substantive change(s) with rationale; desired date of implementation of the proposed change; contact information for the dean. 

Step 2: Email the request to the SACSCOC accreditation liaison with the subject line: “Potential substantive change for review.”

Step 3: Take no further action. Await direction from the SACSCOC accreditation liaison before proceeding.

If the SACSCOC accreditation liaison is uncertain whether a proposed action is a substantive change, the liaison will direct clarifying questions to SACSCOC staff. (Note: Communication with SACSCOC must originate from the president or SACSCOC accreditation liaison only.)

If the proposed action is not a substantive change as determined by the SACSCOC accreditation liaison, the SACSCOC accreditation liaison will prepare a justification for the decision. This justification will remain on file where accreditation records are stored and will be made available to SACSCOC staff upon request. The proposed action will remain subject to all other applicable internal and external review and approval processes. 

If the accreditation liaison determines that the proposed action qualifies as a substantive change, then the SACSCOC accreditation liaison will oversee the preparation of the required materials for submission to SACSCOC. 

2. Preparation of Materials. The SACSCOC accreditation liaison will oversee the preparation of materials for SACSCOC. The accreditation liaison will follow the applicable procedure and instructions located in the SACSCOC substantive change policy and published university accreditation processes. Materials may consist of a notification letter only, or a request for approval with a prospectus.

The initiating unit is responsible for providing to the SACSCOC accreditation liaison all needed data, documentation and human resources to support the timely preparation of a complete set of submission materials.  

3. Reporting to SACSCOC. The SACSCOC accreditation liaison, with the president, will send the submission materials to SACSCOC. 

4. Official Determination:  SACSCOC will send its official determination to the president and SACSCOC accreditation liaison. Upon receipt of the response, the SACSCOC accreditation liaison must take the following actions.

Step 1: Notify the provost and academic unit of the official determination with additional instructions, if applicable. Potential responses from SACSCOC include approval of request, request for additional information or denial of request.

Step 2: Maintain a record of the official determination. Post approved substantive change(s) to the VCU accreditation web page.

Process for Non-Academic Substantive Change

1. Informal Review of Proposed Action: The initiating unit, under the guidance of the area vice president, must carefully review the proposed action as a potential non-academic substantive change. 

2. Internal Request for Formal Review: If the area vice president identifies the proposed action as a potential substantive change, or if there is any question, the area vice president, not a designee, must submit an internal request for review to the SACSCOC accreditation liaison. The vice president must do the following:

Step 1: Write a request containing: description of proposed action; potential substantive change(s) with rationale; desired date of implementation of the proposed change; contact information for the area vice president. 

Step 2: Email the request to the SACSCOC accreditation liaison with the subject line: “Potential substantive change for review.”

Step 3: Take no further action. Await direction from the SACSCOC accreditation liaison before proceeding.

3. Formal Internal Review:  Upon receipt of the request, the SACSCOC accreditation liaison will:

Step 1: Review the request. The SACSCOC accreditation liaison may request additional information from the area vice president. The SACSCOC accreditation liaison may also confer with the president and/or direct clarifying questions to SACSCOC staff. (Note: Communication with SACSCOC must originate from the president or SACSCOC accreditation liaison only.)

Step 2: Determine the applicable procedure per the SACSCOC substantive change policy.

Step 3: Notify the area vice president of the internal determination of the SACSCOC accreditation liaison along with next steps. 

If the action is not considered a substantive change, the SACSCOC accreditation liaison will inform the area vice president that further SACSCOC action related to substantive change is not needed. The liaison will prepare a justification for the decision. This justification will remain on file where accreditation records are stored and will be made available to SACSCOC staff upon request. The proposed action will remain subject to all other applicable internal and external review and approval processes.

If the proposed action is a substantive change, the SACSCOC accreditation liaison will oversee the preparation of the required materials for submission to SACSCOC.

4. Preparation of Materials: The SACSCOC accreditation liaison will oversee the preparation of materials for SACSCOC. The accreditation liaison will follow the applicable procedure and instructions located in the SACSCOC substantive change policy and published university accreditation processes. Materials may consist of a notification letter only, or a request for approval with a prospectus.

The initiating unit is responsible for providing all needed data, documentation and human resources to support the timely preparation of a complete set of submission materials. The SACSCOC accreditation liaison will make this request of the area vice president, who may assign responsibility to a designee(s).  

5. Reporting to SACSCOC: The SACSCOC accreditation liaison, with the president, will send the materials to SACSCOC. 

6. Official Determination:  SACSCOC will send its official determination to the president and SACSCOC accreditation liaison. Upon receipt of the response, the SACSCOC accreditation liaison will:

Step 1: Notify the area vice president or designee of the official determination with further instructions, if applicable. Potential responses from SACSCOC include approval of request, request for additional information or denial of request. 

Step 2: Maintain a record of the official determination. Post approved substantive change(s) to the VCU accreditation web page.

Forms

There are no forms associated with this policy and procedures.

Related Documents

1. Substantive Change for SACSCOC Accredited Institutions: 
        http://sacscoc.org/SubstantiveChange.asp 

2. Published University Accreditation Processes:
        https://provost.vcu.edu/academics/accreditation/sacsreview/

Revision History

Approval/Revision Date              Title
07/26/2019   Substantive Change for Regional Accreditation - Interim 

FAQ

1. To whom should I direct questions about whether an action constitutes a substantive change?

Questions about whether an action constitutes a substantive change should be directed to VCU’s designated SACSCOC accreditation liaison in the Office of the Provost. 

2. May I contact SACSCOC directly to ask a clarifying question about substantive change?

No. Per SACSCOC procedure, only the university president or SACSCOC accreditation liaison may contact SACSCOC directly with clarifying questions about substantive change.

3. Is there a relationship between substantive change and SCHEV approvals?

Maybe. Some departmental actions that require SCHEV approval may also require SACSCOC notification or approval under the substantive change policy. Please contact schevliaisons@vcu.edu with any questions regarding SCHEV implications only. 

4. May we begin advertising or marketing our proposed activity prior to SACSCOC approval? 

Maybe. Consult the SACSCOC accreditation liaison for a determination.

5. Where can I locate the university accreditation processes mentioned in the policy specifics and procedures section?

Please consult the VCU accreditation web page.

6. What are examples of substantive changes?

The SACSCOC substantive change policy provides nuanced guidance on instances of substantive change. Examples of substantive changes may include, but are not limited to:

• Any change in the established mission or objectives of the institution

• Any change in legal status, form of control, or ownership of the institution 

• The addition of courses or programs that represent a significant departure, either in content or method of delivery, from those that were offered when the institution was last evaluated 

• The addition of courses or programs of study at a degree or credential level different from that which is included in the institution’s current accreditation or reaffirmation 

• A change from clock hours to credit hours 

• A substantial increase in the number of clock or credit hours awarded for successful completion of a program 

• The establishment of an additional location geographically apart from the main campus at which the institution offers at least 50% of an educational program 

• The establishment of a branch campus 

• Closing a program, off-campus site, branch campus or institution 

• Entering into a collaborative academic arrangement that includes only the initiation of a dual or joint academic program with another institution 

• Acquiring another institution or a program or location of another institution 

• Adding a permanent location at a site where the institution is conducting a teach-out program for a closed institution 

• Entering into a contract by which an entity not eligible for Title IV funding offers 25% or more of one or more of the accredited institution’s programs

7. What are NOT examples of substantive changes?

This question is complex. In some cases, one action that is not a substantive change triggers another action that is. For example, the change of a Classification of Instructional Programs (CIP) code does not usually count as a substantive change for SACSCOC. However, CIP code changes need SCHEV approval, and SCHEV may require a degree designation change (BA to BS). The latter could be a substantive change. Each action should be evaluated in relationship to other actions.