3.2. Substantive Change Policy and Procedure


Oglethorpe University is accredited by the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC or “the Commission;” see Sec. 2.5.). Comprehensive Standard 3.12 of The Principles of Accreditation: Foundations for Quality Enhancement states, in part: 

“When an accredited institution significantly modifies or expands its scope, changes the nature of its affiliation or its ownership, or merges with another institution, a substantive change review is required. The Commission is responsible for evaluating all substantive changes to assess the impact of the change on the institution’s compliance with defined standards. If an institution fails to follow the Commission’s procedures for notification and approval of substantive changes, its total accreditation may be placed in jeopardy.” 

Further, the Commission’s policy statement related to Substantive Change for SACSCOC Accredited Institutions indicates that: 

“Member institutions are required to have a policy and procedure to ensure that all substantive changes are reported to the Commission in a timely fashion.” 

The purpose of this policy is to assure compliance with the above requirements. 

All potential substantive changes—whether proposed by students, faculty, staff, administration or board of trustees—must be discussed with and reviewed by the SACSCOC accreditation liaison, who is appointed by Oglethorpe’s president. Once informed of impending potential substantive changes, it is the responsibility of the accreditation liaison to ensure that potential substantive changes are reported to and, when warranted, approved by SACSCOC according to timeframes and relevant protocols established by the Commission. 

What is a substantive change?

Substantive change is a significant modification or expansion in the nature and scope of an accredited institution. Under federal regulations, substantive change includes: 

  • 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 percent 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 degree program or a joint degree 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. 

What are the procedures for reporting substantive change?

SACSCOC has identified three procedures for addressing the different types of substantive changes. These include: 

  • Procedure One, for the review of substantive changes requiring notification and approval prior to implementation, 
  • Procedure Two, for the review of substantive changes requiring only notification prior to implementation, and 
  • Procedure Three, for closing a program, site, branch campus or institution. 

The different types of substantive change, the specific procedure to be used for each, their respective approval notification requirements and their reporting timelines are included in the policy statement on Substantive Change for SACSCOC Accredited Institutions (available at https://sacscoc.org/app/uploads/2019/08/SubstantiveChange.pdf). 

Procedures for the institutional changes such as mergers, acquiring or adding programs, or changes in governance or legal status can be found in a separate document, Mergers, Consolidations, Change of Ownership, Acquisitions, and Change of Governance, Control, Form, or Legal Status (available at https://sacscoc.org/app/uploads/2019/08/Mergers.pdf). 

The initiation or revision of programs not offered for academic credit and that are not eligible for federal financial aid does not 

Identifying and reporting substantive change

Oglethorpe’s president is responsible for: 

  • Designating the accreditation liaison as his/her representative to submit substantive change notification letters and associated documentation to the president of SACSCOC or submitting such letters and documentation him/herself (while providing copies of all such correspondence to the accreditation liaison). 

Oglethorpe’s president and vice presidents are responsible for: 

  • Informing relevant personnel under their supervision about the existence of the SACSCOC policies concerning substantive change and the need to check with the accreditation liaison regarding any and all significant changes in policy to determine if they may meet the criteria for a substantive change as defined in the policy. 
  • Consulting with the University’s accreditation liaison regarding questions about substantive changes within their divisions.
  • Providing sufficient time to notify SACSCOC prior to the implementation of any changes.
  • Assisting with the writing of appropriate documentation and notification of substantive changes as needed by SACSCOC. 

Oglethorpe’s accreditation liaison is appointed by the president and is responsible for: 

  • Staying up-to-date with SACSCOC policies and requirements related to substantive change.
  • Serving as the contact person and communication liaison between SACSCOC staff and the University regarding substantive change matters.
  • Meeting with the president and vice presidents yearly to review this policy and planned initiatives.
  • Working with the appropriate vice president to develop a plan of action and timeline for any substantive change actions possibly requiring approval from SACSCOC.
  • Preparing substantive change prospectus in collaboration with the appropriate administrators and faculty.
  • Submitting substantive change notification letters and associated documentation to the president of SACSCOC, as authorized by the president.
  • Maintaining a record of substantive changes, initiatives, action plans and their statuses.