Middle States Commission on Higher Education


Frequently Asked Questions

Substantive Change FAQs

Middle States Commission on Higher Education

3624 Market Street, Philadelphia, PA 19104. Tel: 267-284-5000.


Substantive Change FAQs


These are some of the frequently asked questions regarding substantive change. The answers provided below offer guidance, but they are not intended to replace the Commission's policy on Substantive Change or the Commission's Substantive Change processes.


Why do we need to submit a substantive change request?

When an institution is initially accredited, or when its accreditation is reaffirmed, the action applies to conditions existing at the time of the Commission’s decision. Although it is the institution’s prerogative to change afterwards, the Commission is obligated to determine the effect of any substantive change on the quality, integrity, and effectiveness of the total institution. Because approval cannot be retroactive, failure to obtain approval of the change prior to implementation can result in the loss of federal Title IV eligibility.


How do we know if something is a “substantive change”?

The Commission’s policy on substantive change is available online as described above under “Publications.”  It outlines the different types of changes that qualify under the substantive change policy, such as the establishment of a new additional location or branch campus, the first two degrees offered at a higher level, institutional closures, mergers, online delivery, 50 percent or more of a program online, changes in mission, and others. If you are unsure whether something is a substantive change, please contact the MSCHE staff liaison for your institution to advise you.


When should we submit a request for approval of a substantive change?

Institutions are required to submit a request prior to the substantive change. Institutions submitting requests should note the deadlines for receiving requests prior to each meeting of the Committee on Substantive Change to ensure that approval is granted before the substantive change occurs. It is advisable to inform the Committee well in advance of the change, because additional steps are sometimes required. The Commission cannot grant approval retroactively.

Are there any fees associated with a substantive change?

Yes. A fee will be charged to the institution, because any Commission decision requires considerable training, peer review, reviewing materials, follow-up on requested actions, and other staff work. If the substantive change requires a follow-up visit, additional fees and travel expenses for the visit will be charged to the institution. Substantive changes that are more complex may require legal, financial, or other review by a consultant. Additional fees may apply. A schedule of dues and fees is available in the Commission’s policy.


Must we obtain approval from our state’s education department before we submit the change to the Commission?

No. Although it is best to wait, the request can be made concurrently with a request made to the state’s higher education authority. The Committee can approve the change “conditionally,” pending state approval. The institution must notify the Commission upon receipt of approval.


We submitted a report to the state. Can I send the same report to the Commission?

You can use the same report submitted to state agencies as part of the documentation you provide to MSCHE. However, those reports might be different from those needed by the Commission, so please verify that all of the required information is included. It also helps the readers of the report if you provide a brief overview, following the MSCHE format, that refers to the appropriate sections of the report, or if you use the information to prepare a report that is arranged according to the MSCHE format.


We already reported the change in the Institutional Profile. Should we submit a request?

Yes, you must submit a request and obtain formal approval. 


We did not realize that we should have made a request for advance approval and the new program/additional location is already operating. Are we in trouble now?

If the program/additional location was not approved by the Substantive Change Committee in advance, it is not included within the scope of your accreditation, and the accreditation of your institution may be at risk. In addition, your institution may be at risk of having to repay the federal government for any Title IV student financial aid funds already paid to your institution for classes offered at unapproved sites. You should submit a request for review as soon as possible to ensure compliance and to prevent additional problems. Please note that repayment of Title IV funds is an issue between the U.S. Department of Education and your institution. The Middle States Commission on Higher Education is not directly involved.


If we already have more than three additional locations, should we submit a substantive change request?

Yes, you should submit a substantive change for every new additional location site in order for it to be included within your institution’s accreditation. However, after you have more than three additional locations, a visit to the location is usually not required unless the Commission deems it necessary as stated in its policies.


We plan to convert one of our additional locations to a branch campus. Should we submit a substantive change request even if the location already has been approved?

Yes, you must submit a substantive change request. The Commission is required by federal regulations to approve and visit every new branch campus.


We have an “instructional site” included within our accreditation, but it has expanded its degree program offerings so that it is now within the definition of “additional location.” Are we required to submit a substantive change request, or can we just notify the Commission?

Yes, you must submit a substantive change request. In addition, Commission policy requires that we visit the first three additional locations and the first international additional location.


We are starting a new program. Does that constitute a substantive change?

The Commission reserves the right to review any program offered by an institution, even though it accredits the entire institution rather than its individual programs. Usually, the introduction of a new program is not a substantive change unless it falls within one of the other areas covered by the substantive change policy, such as being one of the first two programs with 50% or more of the courses offered online, a new degree level, or professional doctorate. However, if a new program will have a substantive impact on the institution’s resources or mission, it might be deemed a substantive change. For instance, a program might be deemed to be a substantive change if it is offered at an additional location or branch campus where resources might be more limited. In some cases, the U.S. Department of Education requires institutions to verify that the new program is included within the scope of accreditation. The institution's Accreditation Liaison Officer should be in touch with the Commission office. Therefore, a program in an area that is new or unusual for the institution might also be a substantive change even if it is not technically a change of the institution’s mission (e.g., a specialized business school starting a nursing program). If you are unsure, please consult with your institution’s MSCHE staff liaison.


We already offer several Ph.D. programs. Should we submit a substantive change request if we want to offer a professional doctorate?

The Commission approves institutional degrees at the Doctor's Degree-Research/Scholarship, Doctor's Degree-Professional Practice, and Doctor's Degree-Other levels. The Commission uses the definitions of the National Center for Education Statistics (NCES). The requirements and expectations for professional doctorates are different from those for academic doctorates. For instance, they might require internships, practical training, equipment, and specialized certifications. Therefore, a substantive change should be submitted for the first professional doctoral program offered.


Our institution’s scope of accreditation does not include certificate programs, but we are planning to start one. Should we submit a substantive change request?

The Commission requires the submission of a Substantive Change request for Title IV-eligibile certificate programs that are not related to existing degree programs or that represent a significant departure from the existing offerings of educational programs. For details, please see the policy on Substantive Change.

We just revised our institutional mission statement. Does this constitute a substantive change?

Not necessarily, but it might. If you simply revised your mission statement to clarify or update the mission without changing the nature of the mission substantially, then the change is not substantive. However, other changes may be significant. For example, a business school that expands its mission to include the health sciences has changed its mission substantively.


Can we submit a substantive change request if we are currently on Warning, Probation, or Show Cause?

The Commission reserves the right to decline to entertain a substantive change request by any institution that is not in compliance with MSCHE  accreditation standards, requirements of affiliation, policies, guidelines, and practices, including those institutions subject to Warning, Probation, or Show Cause. If a substantive change is necessary while under these actions, especially to make improvements necessary to meet the accreditation standards or requirements of affiliation, the institution should contact its MSCHE staff liaison.


We are preparing a substantive change request to submit to the Commission. What information should we include?

The Commission’s substantive change policy is available on-line as described earlier. It provides detailed guidance about the format and type of documentation needed for the report. However, Committee members reading the request are not always familiar with the institution. Therefore, descriptions, examples, and documents that can help the readers to better understand the institution’s ability to support the change should be included. For instance, an institution submitting a request for its first on-line program might note previous experience with on-line courses, technical support, and on-line services available to students. In addition, it might provide information about the outcomes assessment process and the library’s ability to support the needs of on-line students. If you are planning to submit a Substantive Change request for a new Additional Location or Branch Campus (domestic or international), reclassification of an existing site, or relocation of an existing Additional Location or Branch Campus, you should use the Commission's new form. The form and instructions are available by clicking here. If you are planning to submit a Substantive Change request for the closure of an Additional Location or Branch Campus, you should use another of the Commission's new Substantive Change forms. That form is available by clicking here.


Can we submit a substantive change request electronically?

Yes, you can submit the request as an electronic file attachment in an e-mail addressed to sc@msche.org.. File attachments may be in MSWord, Excel, or PDF format. Attachments should include any necessary supporting material normally included with the request.


Rev. 2/12/2008; 2/17/10; 1/19/11; 6/16/11; 4/13/12