Substantive Change Request
Instructions Alternative Delivery Method (Distance Education,
Correspondence Education)
Use this form for:
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Initiation or expansion of distance education wherein 50% or more of the courses or
credits in one or more academic programs are provided through this method
Initiation or expansion of correspondence education wherein 50% or more of the
courses or credits in one or more academic programs are provided through this
method
If a new degree level or an academic program that is a significant departure from
those already offered by the institution is intended for this new delivery method, the
degree level or academic program must be separately approved through the
Substantive Change process.
Overview
Context
Accreditation or the reaffirmation of accreditation is granted to cover an institution as it exists at
the time of evaluation. MSCHE requires that substantive changes (defined in the Substantive
Change Policy Statement) be presented to the Commission for prior review and approval in order
for them to be included within the scope of an institution’s accreditation.
Institutions must submit a substantive change request for the initiation or expansion of distance
education or correspondence education wherein 50% or more of the courses or credits in
one or more academic programs are provided through the alternative delivery. The
Commission requires approval for the first two programs for which 50% or more of the academic
program(s) will be offered through distance or correspondence education. The predominant
mode of delivery is the deciding factor in determining whether a hybrid/blended program or
course is considered distance or correspondence education versus onsite/residential education.
Institutions offering alternative delivery are required by Federal regulation to have processes
through which they establish that the student who registers is the same student who participates
in and completes the course or program and receives the academic credit.
Terms
Distance Education is defined in Federal regulations as “education that uses one or more of
the following technologies to deliver instruction to students who are separated from the
instructor and to support regular and substantive interaction between the students and the
instructor, either synchronously or asynchronously: (i) the internet; (ii) one-way or two-way
transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber
optics, satellite, or wireless communications devices; (iii) audio conferencing; or (iiii) video
cassettes, DVDs and CD-ROMs using in a course in conjunction with the previous
technologies.”
Correspondence Education is defined in Federal regulations as “education provided through
one or more courses by an institution under which the institution provides instructional materials,
by mail or electronic transmission, including examinations on the materials, to students who are
separated from the instructor. Interaction between the instructor and the student is limited, not
regular and substantive, and is primarily initiated by the student. Correspondence courses are
typically self-paced. Correspondence education is not distance education.”
Identity Verification may occur in a number of ways, as noted in the Federal regulations: “ in
verifying the identify of students who participate in class or coursework the institution may make
use of a variety of methods, including, but not limited to: (i) secure login and pass code; (ii)
proctored examinations; and (iii) new or other technologies and practices that are effective in
verifying the identity of students. Such methods must have reasonable and appropriate
safeguards to protect student privacy. Institutions must notify students at the time of registration
or enrollment of any projected additional student charges associated with the verification of
student identity, such as separate fees charged by proctoring services, etc.”
Contractual Agreement – any contract involved with the site being submitted for review.
Contracts that are for leasing space or for the provision of less than 25% of the educational
programs at the site may be included with this substantive change request. Contracts for the
provision of 25% or more of the educational programs at the site must be submitted as a separate
substantive change request and will be reviewed separately.
Key Questions
Requests for approval of substantive change must contain sufficient evidence to assure peer
reviewers of the institution’s continuing compliance with all relevant Commission Standards.
Specifically, peer reviewers evaluate the following; therefore you should address the questions in
your submission:
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What is the institution’s rationale for this substantive change?
How does the proposed substantive change align with institutional mission and goals?
Who are the intended constituencies for this change and will they be served effectively?
Does the institution demonstrate the capacity to manage and operate following this
substantive change? Describe how the institution will engage in the periodic assessment
of the impact of the modality on the institution’s resources (human, fiscal, physical, etc.)?
Are there adequate technical and physical plant facilities, including appropriate staffing
and technical assistance, to support offerings delivered by the modality?
How does (or will) the institution evaluate the quality of instruction and services given
this new instructional modality to ensure comparability of quality to programs that use
other instructional modalities?
How does the institution ensure that there are adequate learning resources (such as a
library or other information resources) that are available, accessible, and adequate, and
are appropriate to the offerings at a distance?
How are faculty and other professionals appropriately prepared to ensure student success
given this new instructional modality? Does an ongoing program of appropriate
orientation, training, and support for faculty participating in this modality exist and how
does (or will) the institution ensure the success of such an ongoing program?
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If arrangements with consortial partners or contractors exist as part of the modality, how
does the institution ensure that such arrangements to not compromise the integrity of the
institution or of the program in which the modality is applied?
How is student achievement assessed for the programs proposed as part of this change?
How does (or will) the institution ensure that student achievement is of sufficient rigor
and breadth, regardless of modality?
How will the identity of students be verified? How does the institution regularly evaluate
its ability to verify student identity?
If any course materials or technology-based resources have been developed outside the
institution, how have these been reviewed and/or validated by faculty?
How does the institution ensure that credits awarded for such courses are consistent with
credits awarded for courses taught in other formats? What processes does the institution
have in place to evaluate comparability of course quality across course formats?(If this is
a distance education course), how does the institution ensure that regular faculty-student
interaction is achieved comparable to that in other instructional modalities and that the
quality of such interactions are regularly evaluated?
If the program(s) does not adhere to the institution’s credit hour policy, justification for
credit hour assignments must be provided.
Submission Procedures
The purpose of this document is to facilitate submission of a request that contains all of the
information necessary for peer review and Commission action. Requests should be succinct and
analytical, not only presenting information but explaining how that information demonstrates
that the institution, including the proposed substantive change, will continue to comply with all
relevant Commission Standards. Attachments should be included only if they are referenced
within the text of the request. The ideal request provides all necessary information without
overwhelming volunteer peer reviewers.
It is possible that a single new initiative by an institution may require multiple submissions as
there may be different types of substantive change involved (for example, a new delivery method
that involves a contractual agreement for 25% or more of any educational program or related
service). Please consult with the MSCHE staff if you are unsure as to how to proceed. If a new
degree level or an academic program that is a significant departure from those already offered by
the institution is intended for this new delivery method, the degree level or academic program
must be separately approved through the Substantive Change process.
To be considered by the Commission, a request must be submitted on time, must be complete,
must be signed, and must include all of the following components:
 Cover Sheet
 Institutional Accreditation Overview
 Approvals
 Completed Request Form
Once the request is completed, you may delete the two pages of instructions and save the request
as a new file. Please include your institution’s name in the new filename. A request must be
submitted as an electronic file attachment in an e-mail addressed to sc@msche.org. File
attachments may be in MSWord, Excel, or PDF format.
Submission deadlines are as follows:
Submit request by:
January 1
March 1
May 1
July 1
September 1
November 1
for final approval by:
February 28
April 30
June 30
August 31
October 31
December 31
Substantive Change Request
Alternative Delivery Method
(Distance Education, Correspondence Education)
Cover Sheet
Please note that the shaded boxes will expand when text is entered.
Date of Submission:
Institution:
Name of person completing this request:
Title:
Phone:
E-mail:
Accreditation Liaison Officer (ALO) name and contact information (if different from above):
Name:
Title:
Phone:
E-mail:
Address of Institution:
For questions regarding this request, please contact (check the appropriate box):
The person submitting it
The institution’s ALO
Please identify the specific type of substantive change requested:
First Distance Education Program/Degree
Second Distance Education Program/Degree
First Correspondence Education Program/Degree
Second Correspondence Education Program/Degree
Anticipated start date of new mode of delivery:
Start date must be at least three months after the submission of this request. Approval is not guaranteed so please
plan accordingly. If this program/degree is already active and this request is to increase it beyond the 50%
threshold, the start date will be the date of final Commission approval and this field should remain blank.
Please sign by typing the names of the individuals identified in the space provided.
By signing and submitting this cover sheet, the individuals below indicate that they are
aware of this Substantive Change request in its entirety and agree to its review by the
Middle States Commission on Higher Education.
Signature of person submitting the request:
Signature of ALO (if different from above):
Signature of President or Chief Academic Officer:
Substantive Change Request
Alternative Delivery Method
(Distance Education, Correspondence Education)
Institutional Accreditation Overview
What is the date for the next regularly scheduled accreditation review
(self study or PRR) by MSCHE?
Is it a self study?
Or a PRR?
Is the institution currently on warning, probation or show cause by MSCHE?
If yes, please review the Commission’s Substantive Change policy
as it pertains to institutions on warning, probation or show cause.
Has the institution been asked to submit any follow-up reports (monitoring,
progress) to the Commission in the last three years?
If yes, please specify in the area at the end of this section the due date
and the topics/Standards that were or will be covered in the report(s).
NO
YES
NO
YES
Has any other regional, national or disciplinary/professional accrediting agency indicated concerns about
the institution or any of its branch campuses, additional locations or other sites
within the last three years?
NO
YES
Is the institution being monitored or reviewed by the US Department
of Education or other state or federal agency for any reason?
NO
YES
If the answer to any of the above questions is “Yes,” please explain fully below in the context of this
substantive change request. These factors will be considered in the review and decision making process.
Approvals
Please indicate any approvals required for the institution to operate this delivery method and the dates
approval was received or is expected.
Institutional (e.g., faculty, Board)
Date(s):
System approvals
Date:
State approval
Date:
Other (please specify:
)
Date:
Attach all approvals to the request as Appendix O.
Substantive Change Request Form
Alternative Delivery Method
(Distance Education, Correspondence Education)
Please provide succinct and analytical answers to the following questions in the space below
each question. Your answers should not only present information but explain how that
information demonstrates that the institution, including the proposed substantive change, will
continue to comply with all relevant Commission Standards. If any question does not apply to
this request, please indicate “N/A.” If it is necessary to attach documentation, please label each
attachment with the letter that matches the corresponding question. For example, the first
attachment for question B should be labeled “Attachment B1” (even if Attachment A does not
exist); the second attachment for question B should be labeled “Attachment B2,” and so forth.
Please limit attachments to documents that are directly referenced in the text of the request. It is
acceptable to include attachments that are excerpts from existing documents as long as the
information provided fully addresses the question asked.
A.
What academic academic program(s) will be offered using the alternative delivery
method? Include a summary of the required program length in credit hours and
calendar and curricular sequence. Please note for each the percentage that will be
offered using the new delivery method. Please note that any program that is at a new
degree level or is a significant departure from those programs already offered by the
institution will require a separate Substantive Change request.
B.
Provide evidence documenting and explaining the need for the proposed substantive
change and how it aligns with the institution’s mission and goals.
C.
Describe the student population that will be served by the proposed substantive
change. Attach three-year enrollment projections (labeled “Attachment C1,”
“Attachment C2,” etc.).
D.
Provide a financial plan, based on realistic, justifiable assumptions, as well as an
analysis of the impact of the proposed substantive change on the finances of the
institution. Attach three-year financial projections with sufficient detail so the
reviewers can evaluate projected revenue sources and uses of expended resources.
Are there adequate technical and physical plant facilities, including appropriate
staffing and technical assistance, to support offerings delivered by the modality?
E.
To ensure academic quality, describe faculty needs (including number of full- and
part-time faculty and credentials they must hold) for the academic program(s) to be
offered. How will the institution ensure that faculty will be qualified to teach their
assigned courses? If any faculty members have already been identified, attach a list
that includes their credentials to teach the courses they will be assigned. Describe
how faculty and other professionals are appropriately prepared to ensure student
success given this new instructional modality? If any course materials or
technology-based resources have been developed outside the institution, how have
these been reviewed and/or validated by faculty?
F.
How will the institution provide oversight of this delivery method? What are the
titles/qualifications/credentials of the person(s) assigned by the institution to be
responsible for providing administrative oversight and how will the person(s)
communicate with and be supported by the administration of the institution? Where
do these positions fit in the institution’s organizational structure?
G.
How is student achievement assessed for the programs proposed as part of this
change? How will the institution ensure that student achievement is of sufficient
rigor and breadth, regardless of modality. Describe how, if at all, these outcomes
will be assessed differently for the distance or correspondence offerings. If an
academic program is offered and it includes general education requirements, what are
the general education curriculum’s key learning goals and how will they be assessed?
Describe how such plans are equivalent to the assessment of general education at the
main campus. How does the institution ensure that credits awarded for such courses
are consistent with credits awarded for courses taught in other formats? What
processes does the institution have in place to evaluate comparability of course
quality across course formats? If this is a distance education course, how does the
institution ensure that regular faculty-student interaction is achieved comparable to
that in other modalities and that the quality of such interactions are regularly
evaluated? If the program(s) does not adhere to the institution’s credit hour policy,
justification for credit hour assignments must be provided.
H.
Describe how the institution will engage in periodic assessment of the impact of the
modality on the institution’s resources (human, fiscal, physical, etc.)? Describe how
the institution will evaluate the quality of instruction and services given this new
instructional modality to ensure comparability of quality to programs that use other
instructional modalities?
I.
Describe how students will receive services that are comparable to those offered in a
traditional setting. Examples include academic advising and support, course
registration, financial aid, library access, technology support, bookstore, counseling
and health services, career services, accessibility and developmental education.
Describe how the institution will ensure that adequate learning resources that are
available, accessible, and adequate, and are appropriate to the offerings at a distance?
J.
Does an ongoing program of appropriate orientation, training, and support for faculty
participating in this modality exist and how will the institution ensure the success of
such an ongoing program?
K.
Describe the methods used by the institution to ensure that the student who registers
for a course taught using the proposed method is the same student who participates in
and completes the course or program and receives academic credit. How will the
identity of students be verified? How does the institution regularly evaluate its ability
to verify student identity?
L.
Note any fees that are related to student identity verification and how students are
informed of these fees.
M.
If this request involves a contractual agreement with another organization for the
provision of less than 25% of any educational program or related service, please
include the executed agreement as an attachment. If this request involves a contract
for the provision of 25% or more of any educational program or related service, a
separate Substantive Change request must be submitted for that contract. If
arrangements with consortial partners or contractors exist as part of the modality, how
does the institution ensure that such arrangements do not compromise the integrity of
the institution or of the program in which the modality is applied?
N.
Is there any additional information that will assist the Commission and the peer
reviewers in thoroughly evaluating this request? If so, please specify: