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Operational Policy A – 2 |
Substantive Change |
The Northwest Commission on Colleges and Universities monitors proposed changes whenever an accredited or candidate institution plans a substantive change in its mission and goals, scope, ownership or control, area served or other significant matters.
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Introduction. Accreditation or candidacy for accreditation of an institution applies to those units, programs, and other institutional activities which were included in the institutional self-study and were reviewed by an evaluation committee as required by the Northwest Commission on Colleges and Universities. Insofar as institutions are in a continual process of change, the Commission requires that all institutions be reevaluated periodically. Most changes, such as adding or dropping courses, developing new concentrations that are allied with existing offerings, and changing personnel, are not substantive and therefore are categorized as minor changes. However, a change of such magnitude as to alter an institution's mission and goals; the scope or degree level of its offerings; its autonomy, sponsorship, or the locus of control; offering academic programs for credit through contractual relationships with external organizations; offering programs for credit outside the NWCCU region; adding a branch campus or 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 would constitute a substantive change.
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Substantive changes initiated subsequent to the most recent institutional evaluation are not automatically included in the institution's accredited or candidate status. While the decision to make changes is an institutional prerogative and responsibility, the Commission is obligated to monitor the effect of a substantive change on the validity of the institution's accreditation status with the Commission. |
Determination of Significance. The Northwest Commission on Colleges and Universities is concerned primarily with substantive changes and relies upon the staff of the Commission to determine if a proposed substantive change is a substantive change or a minor change . Careful consideration is necessary in deciding if an institutional change is substantive. Size, complexity, maturity, and experience of the institution in effecting significant change are important factors. Usually, it is possible for the President of the Commission to determine whether a change proposed by an institution is a substantive change or a minor change. If the institution disagrees with the decision of the President regarding the significance of the change, the matter may be referred to the Commission for reconsideration. Examples of substantive changes and minor changes follow this policy.
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Notification. When considering a substantive change, an institution is required to notify the Commission early in its deliberations and prior to the submission of a substantive change proposal. Early notification enables the staff to provide information and advice regarding the effect of the proposed change on the accreditation or candidate status of the institution and the procedures to be followed in seeking approval.
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Prospectus. In submitting a proposal for a substantive change, the institution is required to complete a prospectus. The purpose of a prospectus is to enable the institution to set forth the activities constituting the change and the impact expected on the institution as a whole. The prospectus is to be single-spaced , printed on both sides , and submitted in six unbound copies . The Commission also requests an electronic version of the prospectus. The Commission staff will review the prospectus and request any further information that is needed. Although the scope and depth of information to be provided in the prospectus will depend upon the nature of the proposed change, responses to the following are required:
| a. |
Mission and Goals:
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clear statement of the nature and purposes of the change in the context of institutional mission and goals; |
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| b. |
Authorization:
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evidence of formal approval by the governing board and by the appropriate governmental agency to offer the proposed existing and/or new program(s) at the proposed site(s). If the institution is located in, or operates in, a state that has only minimal requirements for chartering, but also a higher level of authorization to grant degrees, approval at the higher level is required; |
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| c. |
Educational Offerings:
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descriptive information of the educational offering(s); and |
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evidence of approval by the appropriate academic policy body of the institution; |
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| d. |
Planning:
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plans and descriptive materials indicating evidence of need for the change, the student clientele to be served; |
| 2. |
procedures used in arriving at the decision to change; |
| 3. |
organizational arrangements required within the institution to accommodate the change; and |
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timetable for implementation; |
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| e. |
Budget:
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projections (revenue and expenditures) for each of the first three years of operation; |
| 2. |
revenue and expenditures associated with the change itself; |
| 3. |
institutional financial support to be reallocated to accommodate the change; and |
| 4. |
budgetary and financial implications of the change for the entire institution. |
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Substantive change proposals should include a copy of the institution's most recent IPEDS financial report.
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When an institution seeks approval to establish a branch campus or additional site where 50 per cent or more of a program is offered, the prospectus must include a thorough response to each of e.1 through e.4 above to assist in an evaluation of the institution's fiscal and administrative capacity to operate the additional location as required by 34 CFR 602.24(a). Revenues and expenditures must include a cash flow analysis. (See footnote ** on page listing examples of substantive changes.)
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| f. |
Student Services:
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capacity of student services to accommodate the change; and |
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implications of the change for services to the rest of the student body; |
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| g. |
Physical Facilities:
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provision for physical facilities and equipment; |
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| h. |
Library and Information Resources:
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adequacy and availability of library and information resources; |
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| i. |
Faculty:
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analysis of the faculty and staff needed; |
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educational and professional experience qualifications of the faculty members relative to their individual teaching assignments; and |
| 3. |
anticipated sources or plans to secure qualified faculty and staff. |
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Review of the Proposal.
In order to expedite consideration of a substantive change proposal, the Commission follows these procedures:
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| 1. |
member and candidate institutions may submit a proposal for substantive change at any time during the year; |
| 2. |
following receipt of a prospectus, Commission staff analyze the substantive change proposal and send a copy of the analysis with a copy of the prospectus to three members of the Commission for review; |
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on behalf of the Commission, the Commissioner-reviewers consider the impact of the proposed change on existing institutional programs, resources, and services and judge whether it is reasonable to expect that the Commission's accreditation criteria will continue to be met; and |
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Commissioner-reviewers submit their findings to the President of the Commission. |
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If the proposal is approved by all three Commissioner-reviewers, the institution is notified in writing to proceed with the change which is noted in the institution's accreditation. The proposal is then noted as an information item on the agenda for the Commission's next regularly scheduled meeting. If one or more of the Commissioner-reviewers recommend the proposal be denied, the proposal is denied and the institution is notified in writing and given the reasons for the denial.
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Request for Reconsideration. If approval of the substantive change is denied, the institution may request consideration by the Commission at its next regularly scheduled meeting. If the matter is considered by the Commission, one of the following actions will be taken:
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| 1. |
accept the proposal without conditions, |
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accept the proposal with conditions, |
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defer action pending receipt of additional information, or |
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deny approval of the proposal. |
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The institution's chief executive officer is notified in writing of the action taken by the Commission and the reasons for the action. If the proposal is approved, follow-up actions, if any, are determined by the nature of the change and any other factors deemed appropriate by the Commission. If the proposal is denied, the reasons for the denial are specified in the written notification.
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Implementation of Unapproved Changes. If an institution implements a substantive change without prior written notice or if it proceeds to implement a substantive change denied by the Commission, the Commission may consider issuance of an order for the institution to show cause why its accreditation or candidate status should not be terminated. |
Accreditation and Candidacy at a New Degree Level. If the Commission approves a proposal to offer a program at a degree level not previously approved and listed for the institution in the Commission's Directory, the institution is granted candidacy at the new degree level while retaining accreditation at the previously approved degree level(s). All other types of approved substantive change proposals are included under the accreditation of the institution.
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Follow-up Oversight.
Following approval of a substantive change, the Commission may conduct follow-up oversight of the change. The nature of the oversight is determined by the nature of the change.
Candidacy. When an institution is granted candidacy status at a new degree level, it is expected to conduct a comprehensive self-study of all degree levels of the institution and be visited by a full evaluation committee during the academic year following the graduation of the first class at the new degree level. The policies and procedures for comprehensive evaluations as listed in the current edition of the Accreditation Handbook will apply, and the action taken by the Commission following such evaluation will apply to the accreditation of the institution as a whole, not merely to the programs at the new degree level. The effective date of accreditation at the new degree level is September 1 of the academic year immediately preceding the academic year in which the evaluation took place. |
Branch Campus. U.S. Department of Education regulations require an evaluation visit within six months following approval for the establishment of a branch campus by an institution. (34 CFR 602.24(a)(3)) |
Additional Sites. U.S. Department of Education regulations require an evaluation visit within six months following approval for 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. (34 CFR 602.22(a)(2)(vii) The Commission must determine if the institution has the fiscal and administrative capacity to operate the additional location. In addition, the Commission will visit within six months, each additional location the institution establishes, if the institution: |
(i) |
has a total of three or fewer additional locations; |
(ii) |
has not demonstrated, to the Commission's satisfaction, that it has a proven record of educational oversight of additional locations; or |
(iii) |
has been placed on warning, probation, or show cause by the Commission or is subject to some limitation by the Commission on its accreditation or preaccreditation status; |
(iv) |
adds a location abroad, regardless of the number of domestic additional locations, unless waived by staff. |
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The purpose of the visits to additional locations is to verify that the additional location has the personnel, facilities, and resources it claimed to have in its application to the Commission for approval of the additional location. |
| In addition, the Commission will conduct, at reasonable intervals, visits to additional locations of institutions that operate more than three additional locations. When an institution initiates its fourth off-campus site/location, the Commission may, at its discretion, authorize a site visit to review one or more of these additional locations. The Commission, however, may require visits to a representative sample of sites at the fifth-year interval between scheduled reaffirmations, if (1) the additional sites have been initiated since the last scheduled reaffirmation, and (2) the sites have not been visited. |
Rapid Growth. The Commission may, at its discretion, conduct visits to additional locations, to ensure that accredited and preaccredited institutions that experience rapid growth in the number of additional locations maintain educational quality.
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| Institutions contemplating rapid growth (or uncertain as to whether planned changes fall under this category) should be in contact with the Commission staff prior to submitting information to the Commission. |
Change of Ownership. U.S. Department of Education regulations require an evaluation visit within six months following approval for change in legal status, sponsorship, form of control, or ownership of the institution including merger with another institution. (34 CFR 602.24(b)) |
| Other Substantive Changes. For all other kinds of substantive changes, the Commission may, as a condition of approval, request follow-up oversight, including the scheduling and conduct of an on-site evaluation. The nature of the change will determine the scope of any follow-up evaluation. |
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Onsite Evaluations.
The size and composition of the on-site evaluation committee will depend on the nature of the substantive change. The dates for the on-site evaluation are set by Commission staff in consultation with appropriate institutional officials. |
Report. Prior to the visit, the institution will prepare and submit a concise report that assesses the effect of the substantive change. The report need not repeat material submitted in the prospectus but should provide evidence and analysis of:
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a. |
effects of the change on the total institution; |
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b. |
desirable revisions in the change based on the first year's experience; |
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c. |
new program(s) not previously approved or existing program(s) offered at a new location(s),
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adequacy of administrative, faculty, financial, library, and facilities support for the program's objectives, |
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evidence of the program's effectiveness; |
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plans for continuing assessment of the effectiveness of the change; and |
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impact of the change on the institution as a whole. |
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Notification: Prior to implementation, institutions notify the Commission in writing of the proposed change. Commission staff review the proposal and the President or his/her designee, acting on behalf of the Commission, determines whether the proposal is a minor change. If the change is judged to be minor, the President or his/her designee acts on the proposal and notifies the institution. If the change is judged to be substantive, the proposal is reviewed by a subcommittee of three Commissioners following the procedure outlined within this policy.
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Adopted 1972/Revised 1978, 1994, 1996, 2001, 2002, 2007, 2008 |
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