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IIA. Substantive Change Policy and Procedures

Substantive Change Policy and Procedure 
Rhodes College

Approved by the President and the Executive Staff on 7.18.2022.

Rhodes College is accredited by the Southern Association of Colleges and Schools – Commission on Colleges (SACS COC) and all potential substantive changes – whether proposed by students, faculty, staff, or Board of Trustees – must be discussed with and reviewed by the SACS COC Accreditation Liaison, who is appointed by the Rhodes College President. It is the responsibility of the SACS COC Accreditation Liaison to ensure that potential substantive changes are reported to, and approved by the SACS COC, prior to implementation.

The purpose of this Policy and Procedures document is to comply with the Substantive Change for Accredited Institutions of the Commission on Colleges, Policy Statement, Institutional Obligations, Item #2, 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” (p. 1).


Substantive changes, including those required by federal regulations, include:

  • Substantially changing the established mission or objectives of an institution or its programs.
  • Changing the legal status, form of control, or ownership of an institution.
  • Changing the governance of an institution.
  • Merging / consolidating two or more institutions or entities.
  • Acquiring another institution or any program or location of another institution.
  • Relocating an institution or an off-campus instructional site of an institution (including a branch campus).
  • Offering courses or programs at a higher or lower degree level than currently authorized.
  • Adding graduate programs at an institution previously offering only undergraduate programs (including degrees, diplomas, certificates, and other for-credit credential).
  • Changing the way an institution measures student progress, whether in clock hours or credit-hours; semesters, trimesters, or quarters; or time-based or non–time-based methods or measures.
  • Adding a program that is a significant departure from the existing programs, or method of delivery, from those offered when the institution was last evaluated.
  • Initiating programs by distance education or correspondence courses.
  • Adding an additional method of delivery to a currently offered program.
  • Entering into a cooperative academic arrangement.
  • Entering into a written arrangement under 34 C.F.R. § 668.5 under which an institution or organization not certified to participate in the title IV Higher Education Act (HEA) programs offers less than 25% (notification) or 25-50% (approval) of one or more of the accredited institution's educational programs.  An agreement offering more than 50% of one or more of an institution’s programs is prohibited by federal regulation.
  • Substantially increase or decreasing the number of clock hours or credit hours awarded or competencies demonstrated, or an increase in the level of credential awarded, for successful completion of one or more programs.
  • Adding competency-based education programs.
  • Adding each competency-based education program by direct assessment.
  • Adding programs with completion pathways that recognize and accommodate a student’s prior or existing knowledge or competency.
  • Awarding dual or joint academic awards.
  • Re-opening a previously closed program or off-campus instructional site.
  • Adding a new off-campus instructional site/additional location including a branch campus.
  • Adding a permanent location at a site at which an institution is conducting a teach-out program for students of another institution that has ceased operating before all students have completed their program of study.
  • Closing an institution, a program, a method of delivery, an off-campus instructional site, or a program at an off-campus instructional site.

Other substantive change requirements, including those required by federal regulations, include:


General Requirements: General requirements universally apply to most or all types of substantive change. They address obligations and processes by an institution and by SACSCOC. Specific requirements are addressed by substantive change type, organized by institutional changes, off-campus instructional site / additional location changes, and program changes.

Submission deadlines: Substantive change prospectus, application, and notification submission deadlines depend on (1) the type of SACSCOC Board of Trustees review, if required (see also the Board review pathways explained below), and (2) the intended implementation date of the substantive change.

For a substantive change requiring approval by the full Board of Trustees (which meets biannually), to be implemented after the date of the Board meeting, the submission deadlines are

  • March 15 for review at the Board’s biannual meeting in June of the same calendar year, and
  • September 1 for review at the Board’s biannual meeting in December of the same calendar year.

For a substantive change requiring approval by the Executive Council of the Board of
Trustees (which meets year-round), the submission deadlines are

  • January 1 for changes to be implemented July 1 through December 31 of the same calendar year, and
  • July 1 for changes to be implemented January 1 through June 30 of the subsequent calendar year.

For a substantive change requiring notification only, it can be submitted any time before implementation. Once the institution has submitted notification, it may implement before receiving a response from SACSCOC. If there are deficiencies or additional information needed about the notification, the institutional liaison will be contacted at the time of review for resolution and before action is taken. This applies to notifications only, not to approvals: changes requiring approval cannot be implemented until approved by the SACSCOC Board of Trustees.

For a substantive change to close a program, site, program at a site, or method of delivery, a teach-out plan should be submitted as soon as possible after the decision is made to close (i.e., stop admitting students).

Identifying and reporting substantive change:
The President is responsible for:

  • Submitting substantive change notification letters and associated documentation to the President of the SACS COC and providing a copy of the letters and documentation to the Accreditation Liaison


  • Designating the Accreditation Liaison as his representative to submit substantive change notification letters and associated documentation to the President of the SACS COC

The President and Vice Presidents are responsible for:

  • Informing relevant personnel under their supervision about the existence of the SACS COC Policy on Substantive Change and the need to check with the Accreditation Liaison regarding any and all significant changes in policy to determine if they meet the criteria for a substantive change as defined in the policy
  • Consulting with the College’s SACS COC Accreditation Liaison regarding questions about substantive changes within their divisions
  • Providing sufficient time to notify the SACS COC prior to the implementation of any changes
  • Assisting with the writing of appropriate documentation and notification of substantive changes as needed by the SACS COC

The SACS COC Accreditation Liaison is appointed by the President and is responsible for:

  • Staying up to date with the SACS COC Substantive Change Policy Statement
  • Serving as the contact person and communication liaison between SACS COC staff and the College regarding substantive change matters
  • Meeting with the President and Vice Presidents yearly to review the policy and planned initiatives
  • Working with the appropriate Vice President to develop a plan of action and timeline for any substantive change actions requiring approval from the SACS COC
  • Preparing substantive change prospectus in collaboration with the appropriate administrators and faculty
  • Submitting substantive change notification letters and associated documentation to the President of the SACS COC as requested by the President
  • Maintaining a database of substantive changes, initiatives, action plans and their status