FAQs on Substantive Change

This page provides a list of frequently asked questions on topics of interest to the public (FAQs on Accreditation and FAQs on Third Party Comment) and to member institutions (FAQs on Substantive Change). Click on one of the links below to jump to the FAQ of interest.

Q. What is the purpose of the Commission's Substantive Change Policy?

ACCJC’s Substantive Change Policy is long-standing, first adopted in 1972 and revised several times since then. Many of those revisions have been motivated by the changes to the U.S. Department of Education (USDE) regulations; others have been developed through the Commission’s policy review procedures. In the last few years, the Commission has developed and circulated a Substantive Change Manual designed to inform member institutions of the process in seeking substantive change approval.

The area of substantive change is of particular concern to the USDE which sets the requirements of recognized accreditors and of institutions that participate in federal financial aid programs. The USDE regulations are often driven by concerns that have emerged with particular kinds of institutions, and in the case of substantive change, it is fair to say the USDE’s concerns stem from those institutions that have (in the past) rapidly developed new programs of questionable quality, and then closed those programs abruptly or even become insolvent due to the costs of such new programs relative to the revenue these programs generated. The USDE has steadily expanded its requirements of accreditors regarding substantive change review as a result of the emerging concerns and the subsequent impact on students.

. What are the kinds of institutional changes that require the approval of the ACCJC Substantive Change Committee?

The Substantive Change Manual, available on line at www.accjc.org under Substantive Change and Publications, clearly details the kinds of institutional changes that will require prior approval by the Substantive Change Committee. These include: a change in the mission, scope, or name of the institution (including change in degree level offered); a change in the nature of the constituency served (including closure); a change in the location or geographical area served (including establishing or closing an additional location or center); a change in the control of the institution (including merger with another institution or a change by a parent institution of one of its off-campus sites or centers into a separate institution); a change in credit awarded; a change in courses or programs or their mode of delivery that represent a significant departure from current practice (including addition of new courses/programs); the addition of courses, including general education to programs, certificates or degrees, in which 50% or more are offered through a mode of distance or electronic delivery, as well as other significant changes.

Q. What if a particular institutional change is not covered by the criteria set forth in the Manual?

Should an institution discover that a projected change is not described in the examples above or in the Manual, it should contact ACCJC staff for clarification. (Dr. Susan Clifford can be reached at sclifford@accjc.org.) Institutions should remember that institutional accreditation is extended to the institution, and not to a particular program. Consequently, everything conducted under the name of the institution is subject to the Standards of Accreditation, Eligibility Requirements and Commission policies.

Q. How often does the Committee meet, and how can institutions participate in the review of its application?

In the past two years with the increase of substantive change proposals, the Committee has tried to adhere to a schedule of monthly meetings. Institutions are urged to contact the Substantive Change staff for scheduling the proposal. When proposals are complete, the staff member will provide the list of names and addresses of Committee members where proposals should be sent. Completed proposals with supporting documentation need to be received by Committee members no later than one month before the scheduled review.

Q. How long does the approval process take from submission of the substantive change proposal application until Committee review and action?

The Commission has given the Substantive Change Committee, a committee of Commissioners, the authority to act on its behalf for requests that require the approval for substantive change. Normally, after a substantive change proposal has been reviewed, staff will inform the institution via e-mail within 1 week of the Committee’s action. A formal letter follows within 2-4 weeks. There will be instances when the Committee might wish to defer its decision for full Commission action. In that event, final action will take place at the next scheduled meeting of the Commission. The institution will be informed in every case. A list of the Substantive Change Committee meeting dates is provided on the ACCJC website.

Q. Are there particular kinds of applications that receive favorable Committee action more than others?

There is no one kind of proposal that will receive favorable Committee action over any others. In general, the Committee makes its decision based on the specifics of the institutional change that is being proposed and the accompanying documentation of evidence submitted with the proposal. It is important to stress that complete proposals with sufficient supporting data and documentation of evidence are less likely to experience a delay in Committee review and action. When a proposal is incomplete or lacks sufficient data and documentation, the Committee will seek additional information and table its decision until the next scheduled meeting of the Committee.

Q. Are there ways by which institutions can assure that applications submitted are sufficiently complete?

The staff member responsible for facilitating the substantive change process will review drafts of the proposal prior to the actual submission if contacted early enough in the process. Proposals should be mailed to the Committee members at least one month prior to the Committee meeting (see below). Consequently, if drafts need to be reviewed prior to the meeting, institutions are requested to plan accordingly. In every case, the institution remains responsible for the information submitted in the proposal.