Substantive Change: Understanding
Middle States Policy and Process
Debra G. Klinman – Vice President
Ellie A. Fogarty – Vice President
MSCHE Annual Conference
December 2011
Overview
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Federal Requirement
Twelve Types of Substantive Change
Review Process
What Peer Reviewers Look For
New Developments
Substantive Change is a
Federal Requirement
• Accreditation decisions apply only to existing
institutional conditions
• USDE requires that MSCHE determine the
impact of any Substantive Change on the
quality and effectiveness of the total
institution
• Changes undertaken without appropriate
review threaten the accreditation status of the
entire institution
Substantive Change is a
Federal Requirement
• Institutions must inform the Commission in advance
and follow procedural guidelines. Prior approval is
required.
• MSCHE can approve, reject, decline to act, or rescind
approval of any Substantive Change.
Policy Statement:
www.msche.org/documents/updated-Substantive-Change-policy11-18-10.pdf
Procedural Guidelines:
www.msche.org/documents/Substantive-Change-Processes-NewVersion-January-2011.pdf
Types of Substantive Change
• Any change in the established mission or
objectives of the institution
• Any change in the legal status, form of control,
or ownership of the institution
• Initiation of a contractual arrangement
wherein 25% of one or more educational
programs is provided by unaccredited entity
Types of Substantive Change
• Addition of courses or programs representing
a significant departure from existing offerings
of educational programs, or method of
delivery
• Addition of programs at a new degree or
credential level
• Institutional closure or institutional status
requiring a teach-out plan for approval
Types of Substantive Change
• Change from clock hours to credit hours in
one or more programs
• Substantial increase or decrease in number of
clock/credit hours for program completion
• Initiation/expansion of distance or
correspondence education where 50% or
more of courses/credits in an academic
program are provided through alternative
delivery
Types of Substantive Change
• Establishment of a branch campus, including a
branch campus acquired from another
institution
• Establishment of domestic and international
additional locations
• Planned closure or relocation of additional
location/branch campus (teach-out plan for
approval)
Substantive Change Review Process
• Substantive Change Committee
– Submission deadlines are the first day of January,
March, May, July, September, November every year
– Peer reviewers; chaired by Commissioner
– Conference call format
– Substantive Change Committee makes
recommendations to Executive Committee of
Commission for approval
– Institution receives formal notification of decision
from the Commission
What Peer Reviewers Look For
• Type of change (be specific)
• Relationship to institutional mission and goals
• Readiness for review; are all supporting documents
included?
• Evidence of sufficient resources, assessment of
student learning outcomes, appropriate oversight,
appropriate planning, and realistic projections,
budget, other information as appropriate
• Analysis of impact on institution and assurance of
continuing compliance with Standards
New Developments
• Templates for Substantive Change proposals
– Additional Locations (Domestic)
– http://www.msche.org/publications/SubstantiveChange-Application-Form-Jan-2012.dot
– Other templates to follow
• Electronic submission of materials –
evaluationservices@msche.org
• Peer reviewers visit additional locations
• Contact Jeff Ewing, Director for Volunteer and
Accreditation Services (jfewing@msche.org)
Questions?
Middle States Commission on Higher Education