The Higher Learning
Commission
Chicago, IL
ncahlc.org
changerequests@hlcommission.org
A Commission of the North Central Association of Colleges
and Schools
Substantive Change Application, Part 1: General Questions
Distance Delivery
Note: Wherever distance delivery is mentioned it means distance or correspondence delivery.
Institution:
City, State:
Name of person completing this application:
Title:
Phone:
Email:
Requested Change(s). Concisely describe the change for which the institution seeks approval.
Classification of Change Request. Check all boxes that apply to the change.
Note: not every institutional change requires prior review and approval. Review the “Overview of Commission Policies
and Procedures for Institutional Changes Requiring Commission Notification or Approval” to make certain that current
HLC policy requires the institution to seek approval.
Change in mission or student body:
 change in mission
 change in student body
New additional locations:
 in home state
 in other state(s) or in other country(ies)
 new or additional campus(es)
Contractual or consortial arrangement:
 Outsourcing 25 – 50% of a contracted program
to an organization not accredited by a USDErecognized agency
 Outsourcing more than 50% of a contracted
program (the request will receive intense
scrutiny and will be approved by the
Commission only in exceptional
circumstances)
 Offering a program as part of a consortium of
institutions
Five or more courses:
 at a degree level not now included in the
institution’s accreditation
 at an out-of-state or foreign location
New academic program(s) requiring HLC
approval:
 certificate
 bachelor’s
 diploma
 master’s/specialist
 associate’s
 doctorate
Other:
 Request for access to Desk Review for
additional locations
 Request for access to Notification Program for
locations
 Substantial change in scope or level of
distance education activity
 Substantially changing the clock or credit
hours required for a program
Institutional Context for Substantive Change Review. In 1-2 paragraphs, describe the key dynamics —
institutional mission and internal or external forces — that stimulated and shaped the change.
Questions? E-mail changerequests@hlcommission.org or call 800.621.7440 ext. 137 or 139
Substantive Change Application: Distance Delivery
Special conditions. Underline YES or NO attesting to whether any of the conditions identified below fit
the institution. If YES, explain the situation in the box provided.
Is the institution, in its relations with
other regional, specialized, or national
accrediting agencies, currently under
or recommended for a negative status
or action (e.g., withdrawal, probation,
sanction, warning, show-cause, etc.)?
Is the institution now undergoing or
facing substantial monitoring, special
review, or financial restrictions from the
U.S. Dept. of Education or other
federal or state government agencies?
Has the institution’s senior leadership
or board membership experienced
substantial resignations or removals in
the past year?
Is the institution experiencing financial
difficulty through such conditions as a
currently declared state of exigency, a
deficit of 10% or more, a default or
failure to make payroll during the past
year, or consecutive deficits in the two
most recent years?
Is the institution experiencing other
pressures that might affect its ability to
carry out the proposal (e.g., a collective
bargaining dispute or a significant
lawsuit)?
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
Approvals. Check the approvals that are required prior to implementing the proposed change and attach
documentation of the approvals to the request. Indicate the file name of the documentation.
 Internal (faculty, board) approvals (file name: _____________ )
 System approvals (for an institution that is part of a system) (file name: _____________ )
 State approval(s) (file name: _____________ )
 Foreign country(ies) approvals (for an overseas program or site) (file name: _____________ )
 No approval required
Is the program approved by a specialized accreditor? If yes, please identify the accreditation and outline
the process and timeline for seeking the other accreditor’s approval.
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Substantive Change Application: Distance Delivery
Substantive Change Application, Part 2: Topic-Specific Questions
Distance Delivery
Note: Wherever distance delivery is mentioned it means distance or correspondence delivery.
Understanding Commission Expectations for Distance Delivered Courses and Programs
Whenever it comprehensively reviews an institution, the Higher Learning Commission examines the
institution’s capacity to provide education to its students and the quality of its performance in doing so,
whether via distance delivery or traditional face-to-face modes. Comprehensive reviews examine
curriculum, staffing, support services, access to appropriate laboratory and library resources, and all other
facets of quality higher education.
Between comprehensive reviews, Higher Learning Commission policy requires an institution to seek the
Commission’s prior approval if the institution anticipates a shift from its current level of activity in delivering
courses and programs via distance delivery to a substantially higher level. When such a transition is
anticipated, an institution must submit a substantive change request describing the characteristics and
projected magnitude of the change, and including appropriate documentation that it has the capacity to
continue to provide quality education using distance delivery at the higher level.
An institution violates the Commission’s accreditation requirements if it increases its distance delivery
activity to a level higher than that for which it is currently approved—whether intentionally or accidentally—
without first seeking and receiving Higher Learning Commission’s approval.
Commission Definitions
The Higher Learning Commission uses the following definitions for the purpose of applying this policy to
its accredited and candidate institutions:
Distance delivered programs are those in which 50% or more of the required courses may be
taken as distance delivered courses. (For more details and FAQs, see defining distance-delivered
programs.)
Distance-delivered courses are those in which all or the vast majority (typically 75% or more) of
the instruction and interaction occurs via electronic communication, correspondence, or
equivalent mechanisms, with the faculty and students physically separated from each other. (For
more details and FAQs, see defining distance-delivered courses.)
Substantive change in distance delivery is defined through the chart below as initial entry at
Level 1 or a shift from any numbered level to the next highest level, based on at least one
condition in that level being met.
Level of
development
or activity
4
3
Conditions for Determining Level
% of total institutional
credit hours in distancedelivered courses
% of degree programs
delivered as distance
delivery
More than 50%
More than 35%
50% or less
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35% or less
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Organizational Structure
separate organizational
component identified (e.g.,
online division, office of
distance education, virtual
campus)
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Substantive Change Application: Distance Delivery
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25% or less
15% or less
1
5% or less
5% or less
Thus, if 35% (or more) of an institution’s degree programs are available through distance delivery, an
institution is operating at level 4—regardless of other conditions. Similarly, an institution advertising an
“Online Program Center” is operating at level 3, even if it only offers 5% of its programs and fewer than
10% of its courses via distance delivery.
Submitting Your Substantive Change Request
Attach the “Substantive Change Application–General Questions” as page one of your application. That
completed form and your answers to the questions below will constitute your request for approval of a
substantive change. It will be provided to future HLC review processes.
The questions are designed to elicit brief, succinct, detailed information, rather than a narrative or
references to extensive supporting documents. Do not attach other documents unless they are
specifically requested in the questions. Your total submission should be no more than 8-10 pages.
Submit your completed application as a single electronic document (in Adobe PDF format) emailed to
changerequests@hlcommission.org.
Name of Institution:
Part 1. Characteristics of the Change Requested
1. At which of the four levels defined above do you currently operate distance delivery?
2. At which of the four levels defined above are you requesting permission to operate distance delivery?
3. Provide the following information regarding the distance delivery you are requesting permission to
operate:
a.
Specify if it is Distance or Correspondence Education.
b.
The modality.
c.
The Classification of Instructional Programs terminology (CIP codes). CIP codes are
established by the U.S. Department of Education’s National Center for Education
Statistics. More information is available at http://nces.ed.gov/ipeds/cipcode/.
d.
The program level.
e.
Program name if different from the CIP code.
4. Do you currently have a separately identified unit for providing or marketing your distance delivery
education? ( ) Yes ( ) No
If yes, what do you call it?
5. Are you planning to begin operating a separately identified unit for providing or marketing your
distance education? ( ) Yes ( ) No
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If yes, when?
Under what name?
6. If you are planning any involvement by external organizations (other than accredited higher education
institutions) in key operations as identified below, provide the information requested for each planned
involvement. (Note that such involvement by a parent company or by one of its subsidiaries external
to the institution in any of these operations should be reported.)
Name(s) of external
organization(s)
Type of involvement
% of Involvement
A. Support for delivery of instruction
B. Recruitment and admission of
students
C. Course placement and advising
of students
D. Design and oversight of
curriculum
E. Direct instruction and oversight
7. If you are planning any involvement with other accredited higher education institutions in key
operations identified above, provide the name(s) of the other institutions and the nature of the
involvement.
8. Operational Data
Operational Data
Last year
(actual tallies)
This year
(estimate)
Next year
(projected)
A. Total annual (academic year
+ summer) student credit hours
generated
B. Total annual student credit
hours generated in distancedelivered courses
C. Percentage of student credit
hours in distance-delivered
courses (B/C, or B divided by A,
rounded up to the nearest
integer)
D. Total number of academic
programs (i.e., counting
different majors at all levels)
E. Total number of programs in
item D above available via
distance delivery (i.e., 50% or
more of courses available as
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distance-delivered courses)
F. Percentage of programs
available via distance delivery
(E/D, or E divided by D,
rounded up to nearest integer)
Part 2. Institution’s History with Distance Education
9. Briefly describe your institution’s experience with distance education.
10. If the Higher Learning Commission approves you to operate at the next highest level, what future
growth do you anticipate (e.g., in the next six months, three years, 10-20 years) for distance delivery?
11. How do you plan to manage this growth?
Part 3. Institutional Planning for Distance Education
12. What impact might the proposed program(s) have on challenges identified as part of or subsequent to
the last comprehensive visit or reaffirmation panel and how has the institution addressed the
challenge(s)?
13. How do you determine the need for a distance-delivered course or program? If you offer a traditional
program now, how do you decide whether to start offering this program via distance delivery?
14. How do you plan for changes and future expansion of the role distance delivery plays in your
institution? Who is involved? How do new ideas and initiatives originate, and how are they examined
and evaluated?
15. How do you ensure that financial planning and budgeting for your distance-delivered courses and
programs are realistic? What are your projected revenues and expenses?
16. How do you assure that promotion, marketing, and enrollment of your distance-delivered courses and
programs stay in balance with your actual resources and technical capabilities?
17. What controls are in place to ensure that the information presented to students in advertising,
brochures, and other communications will be accurate?
Part 4. Curriculum and Instructional Design
18. How do you assure good instructional design in your distance-delivered courses and programs? How
are your faculty and quality control mechanisms involved in the instructional design process?
19. What processes and procedures will you use for technology maintenance, upgrades, back up, remote
services, and for communicating changes in software, hardware or technical systems to students and
faculty?
20. How do you ensure that you provide convenient, reliable, and timely services to students or faculty
needing technical assistance, and how do you communicate information about these services?
21. What is your institution’s experience, if any, in collaborating with other institutions or organizations to
provide distance-delivered education?
22. If you are planning partnerships or agreements with external organizations or institutions as identified
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in Questions 5 and 6, how will you ensure that students can use these services effectively?
Part 5. Institutional Staffing and Faculty Support
23. How do you staff distance-delivery courses and programs? How does this differ from your processes
for staffing traditional courses and programs?
24. What is your process for selecting, training, and orienting faculty for distance delivery? What special
professional development, support, or released time do you provide for faculty who teach distancedelivery courses and programs?
25. How do you assure copyright compliance and keep distance delivery faculty aware of institutional
policies on using others’ intellectual property?
Part 6. Student Support
26. How do you assure that distance-delivery students have access to necessary student and support
services (e.g., institutional information, application for admission, registration, tutoring or academic
support, advising, financial aid, tuition payment, career counseling and placement, library resources,
complaint processes)? How do you provide them information about using these services, and how do
you monitor and evaluate their use of these services?
27. How do you measure and promote interactions among distance delivery students and faculty (e.g.,
email, online chats, discussion groups, phone or streaming audio, “office hours,” cyber
buddies/mentors and tutors)?
28. How do you assure that the distance delivery students you enroll and to whom you award credit and
credentials are the same ones who did the work and achieved your learning goals? How do you
protect student identity and personal information?
Part 7. Evaluation and Assessment
29. How do you assess, review, and evaluate quality in distance-delivered courses and programs?
30. How are the measures and techniques you use for distance-delivered courses and programs
equivalent to those used to assess and evaluate traditional face-to-face courses and programs? If
there are difference, why are these differences appropriate?
31. How do you assess the learning of the students you educate in your distance-delivered courses and
programs to ensure that they achieve the levels of performance that you expect and that your
stakeholders require?
32. How do you encourage and ensure continuous improvement of your distance-delivered courses and
programs?
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