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IRSC Substantive Change (SubC) Policy

What is a substantive change and how should it be handled?

Substantive change is a significant modification or expansion in the nature and scope of an accredited institution. Some changes, such as offering courses on-line that amount to less than 25% of the coursework needed to complete a degree, certificate or diploma, do not need to be reported to the Commission.

  • Others, such as offering from 25% to 49% of the coursework required for a program on-line, simply require that the Commission be notified in advance of the implementation of the change. The letter of notification should include the name of the actual change, implementation date, street address if it involves a new site, and the credential being offered.
  • Larger scale changes, such as adding significantly different programs to the academic curriculum or offering a majority of the coursework needed to complete a degree, certificate or diploma on-line, require written notification at least 6 months in advance and approval of a prospectus, which must be submitted at least 3 months prior to the anticipated implementation date.
  • Institutions seeking to offer coursework at a more advanced level than that for which they are currently approved must notify the Commission of their intent at least 12 months in advance, and submit an application for level change by April 15 for review at the June meeting of the Board of trustees or by October 1 for review at the December meeting.

Prospectuses and applications for level change should include a Faculty Roster (Faculty Roster Instructions), presenting the qualifications of each faculty member in the program to teach the courses they are assigned.

It is expected that the CEO or a designated representative of an institution will notify the Commission President of substantive changes at that institution. Every institution has an Accreditation Liaison whose charge is to ensure compliance with accreditation requirements. The Accreditation Liaison should take the time to become familiar with the Commissions policies and procedures, ensure that substantive changes are recognized and reported in a timely fashion, and consult with the institution’s COC staff member about any questions.

Certain types of substantive changes, such as adding branch campuses, level changes, mergers/consolidations, and changes in governance require a visit by a substantive change committee to determine continued compliance with the Principles of Accreditation: Foundations for Quality Enhancement. When a committee visit has been authorized by the President of the Commission, the institution will be asked to provide documentation of the impact of the change on selected requirements in the Principles of Accreditation.

IRSC Substantive Procedure:


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