SECTION BH.1

LOCAL GOVERNANCE
PROCEDURES FOR REPORTING SUBSTANTIVE CHANGE

Procedure

---

INTRODUCTION

The purpose of this procedure is to describe the process Navarro College will use to identify, manage, and report substantive changes to the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC). Substantive changes are defined in the Navarro College Substantive Change Policy and the required reporting and notification procedures are described at https://www.navarrocollege.edu/attachments/board-policies/bh1-substantive-change.pdf

Navarro College represents itself accurately to all U.S. Department of Education recognized accrediting agencies with which it holds accreditation and informs those agencies of any change of accreditation status, including the imposition of public sanctions.  The Vice President of Academic Affairs, who also serves as SACSCOC liaison, is responsible for notification of accreditors when a change in accreditation status occurs.

---

PROCEDURE STATEMENT

Navarro College will maintain compliance through the timely reporting of all substantive changes to SACSCOC. In accordance with SACSCOC Substantive Change Policy and Procedures, the College’s Substantive Change Committee will formally review all substantive change requests by the deadline established for each type of substantive change listed below. Changes which are determined to be substantive change and require a SACSCOC procedure will be returned to the initiating academic or administrative unit(s) with instructions regarding the preparation of a prospectus or documentation for notification. If a prospectus is required (see charts below), it must be completed and submitted to the NC Substantive Change Committee by the designated date indicated in the charts below. Changes that are determined not to be substantive change will be returned to the initiating academic or administrative unit(s) for continued monitoring, processing, and potential implementation.

 

SACSCOC BOARD REVIEW PATHWAYS

Approval, or denial of approval, of proposed substantive changes is granted by (1) the full SACSCOC Board of Trustees, or (2) the Executive Council of the SACSCOC Board of Trustees on behalf of the full Board.

The types of substantive changes reviewed by the full SACSCOC Board versus the Executive Council of the SACSCOC Board are defined in the section of the Substantive Change Policy and Procedures that addresses specific substantive changes. Exceptions are noted below.

Exceptions:

There are exceptions, based on the conditions or characteristics of an institution, which require review and action by the full SACSCOC Board of Trustees rather than the Executive Council of the Board.

Review by the full SACSCOC Board of Trustees is required if any of the following apply:

a.  An institution is on sanction (Warning, Probation, or Probation for Good Cause) at the time the substantive change prospectus or application is submitted.

Exceptions: 

i.  If an institution submitted a substantive change prospectus or application and is subsequently placed on sanction, the proposed change may be referred to the full Board of Trustees or may at the sole discretion of SACSCOC staff be reviewed by staff and referred to the Executive Council of the Board for action.

ii.  A substantive change 1. to close a program, a site, a program at a site, or a method of delivery; 2. for an institutional contingency teach-out plan; or 3. for an institution closure may be reviewed by staff and referred to the Executive Council of the Board for action even if the institution is on sanction. The institution’s sanction status is disclosed to the Executive Council at the time of review.

b. An institution has recently been removed from sanction for non-compliance with Standards 13.1 (Financial resources), 13.2 (Financial documents), or 13.3 (Financial responsibility).

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.

Navarro College Deadlines for Submitting Substantive Change Proposals Requiring Approval by the Full SACSCOC Board of Trustees

TO IMPLEMENT SUBSTANTIVE CHANGE PROPOSALS JULY 1 - DECEMBER 31 REQUIRES APPROVAL BY THE FULL SACSCOC BOARD OF TRUSTEES
STEP 1 NC Substantive Change Form Due to NC Substantive Change Committee	STEP 2 First Draft of Prospectus Due to NC Substantive Change Committee	STEP 3 Prospectus and Related Documents Due to SACSCOC	STEP 4 Implementation
NOVEMBER 1	JANUARY 15	MARCH 15	JULY 1 - DECEMBER 31

 

TO IMPLEMENT SUBSTANTIVE CHANGE PROPOSALS JANUARY 1 - JUNE 30 REQUIRES APPROVAL BY THE FULL SACSCOC BOARD OF TRUSTEES
STEP 1 NC Substantive Change Form Due to NC Substantive Change Committee	STEP 2 First Draft of Prospectus Due to NC Substantive Change Committee	STEP 3 Prospectus and Related Documents Due to SACSCOC	STEP 4 Implementation
MAY 1	JULY 1	SEPTEMBER 1	JANUARY 1 - JUNE 30

 

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.

Navarro College Deadlines for Submitting Substantive Change Proposals Requiring Approval by the Executive Council of the SACSCOC Board of Trustees

TO IMPLEMENT SUBSTANTIVE CHANGE PROPOSALS JULY 1 - DECEMBER 31 REQUIRES APPROVAL BY THE EXECUTIVE COUNCIL
STEP 1 NC Substantive Change Form Due to NC Substantive Change Committee	STEP 2 First Draft of Prospectus Due to NC Substantive Change Committee	STEP 3 Prospectus and Related Documents Due to SACSCOC	STEP 4 Implementation
AUGUST 15	OCTOBER 15	JANUARY 1	JULY 1 - DECEMBER 31

 

TO IMPLEMENT SUBSTANTIVE CHANGE PROPOSALS JANUARY 1 - JUNE 30 REQUIRES APPROVAL BY THE EXECUTIVE COUNCIL
STEP 1 NC Substantive Change Form Due to NC Substantive Change Committee	STEP 2 First Draft of Prospectus Due to NC Substantive Change Committee	STEP 3 Prospectus and Related Documents Due to SACSCOC	STEP 4 Implementation
FEBRUARY 1	MAY 1	JULY 1	JANUARY 1 - JUNE 30

 

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)

Deferral:

A substantive change submission reviewed by staff may be deferred for additional information or explanation from the institution. If, after review and two deferrals, staff in its sole judgment does not have a sufficient basis to accept notification or recommend approval, then the notification, prospectus or application will be referred to the full Board of Trustees at its earliest possible regularly scheduled biannual meeting. The institution has a maximum of 180 days to respond to a deferral; otherwise, the submission is rejected. The institution may revise and resubmit at its discretion.

 

Disclosure:

At the time a substantive change is submitted, the institution is required to disclose if the institution is currently on provisional certification for participation in federal financial aid programs as defined in 34 C.F.R. § 668.13.

 

Implementation dates:

The implementation date is when an institution begins the material, public, non-reversable, or other significant actions of a substantive change. Examples include changing an institution’s measure of student progress to completion, admitting students to a new program, starting instruction at a new off-campus instructional site, and others.

The intended implementation date is an institution’s forward-looking good faith estimate of when it will begin a substantive change. The intended implementation date is provided by the institution when a substantive change is submitted for review.

If a substantive change has already been implemented when an institution submits a substantive change, or if the institution implements a substantive change after submission but before receiving approval, then the change is considered an unreported substantive change and the institution is non-compliant with Standard 14.2 (substantive change). Refer to the Non-compliance section of this policy for additional guidance. If a substantive change has already been implemented at the time a notification or prospectus is submitted -- i.e., the institution is submitting a known unreported substantive change -- then the institution should report the actual implementation date as the intended implementation date in its submission.

Although SACSCOC may approve a substantive change after implementation as an unreported substantive change, approval is not retroactive to the actual implementation date. For mergers/consolidations and acquisitions and changes in ownership, implementation must occur within 30 days of the SACSCOC Board of Trustees approval.

 

Implementation time limit:

Approved substantive changes – except for those changes that must be implemented within 30 days as defined in policy – must be implemented within two years of the approval date. If an institution does not implement within two years of approval, then a new prospectus or application must be submitted and approved prior to implementation. An institution may request an implementation extension for cause, subject to SACSCOC Board of Trustees approval; see Implementation Extension in the SACSCOC Substantive Change Policy and Procedures for guidance.

 

Maintaining off-campus instructional site / additional locations accuracy and completeness:

An institution is obligated to maintain an accurate record with SACSCOC of off-campus instructional site names and addresses. A site name or address change is submitted to SACSCOC as a substantive change notification. Updating site names, addresses, or closures on the Institutional Summary Form submitted as part of reaffirmation or fifth-year interim reviews is insufficient; the institution is responsible for submitting a substantive change to maintain site records. If the institution identifies an error in a site record, the SACSCOC staff will work with the institution to resolve.

 

Marketing, advertising, recruitment, and admissions:

Substantive changes are subject to SACSCOC’s Advertising and Student Recruitment policy. Admission applications may be taken for substantive changes pending approval, but admission offers – including contingent offers – should not be made until the substantive change is approved by the SACSCOC Board of Trustees.

 

Non-enumerated changes:

SACSCOC reserves the right to consider an institutional change, or a group of changes, as constituting a substantive change even if not specifically enumerated in Substantive Change Policy and Procedures. SACSCOC may require an institution to submit materials related to the change(s) for review by staff and for possible review and action by the SACSCOC Board of Trustees. A substantive change committee visit may be authorized.

 

Notification vs. approval:

Upon favorable review of a proposed substantive change, either

a. notification is accepted by staff, or

b. approval is granted by the SACSCOC Board of Trustees.

SACSCOC cannot accept notification or approve changes not identified and required in policy. Institutions should not submit changes that are not identified in policy as requiring notification or approval; no action will be taken.

 

Possible non-compliance:

If the review of a substantive change notification, prospectus, or application suggests material non-compliance with any of the Principles of Accreditation or SACSCOC policies, SACSCOC reserves the right to further review. An institution may be required to submit materials related to the possible non-compliance for review by staff and for possible review and action by the SACSCOC Board of Trustees. Further review may be warranted even if the related prospectus or application is withdrawn or if the substantive change is denied approval.

 

Right to reject:

Substantive change submissions for which an institution's documentation (a) does not match the substantive change type or (b) is materially insufficient may, at the sole discretion of staff, be rejected. An institution may revise its materials and submit the substantive change again.

 

Systems:

Because SACSCOC accredits institutions and does not accredit systems, a substantive change must be submitted by an institution. Systems or state coordinating boards cannot submit a substantive change on institutions’ behalf. System coordination across institutions is encouraged where practicable, yet individual institutions are responsible for their substantive change submissions.

 

Submission authority:

A substantive change may be submitted by the institution’s chief executive office or accreditation liaison only.

 

Submission process:

All substantive changes (unless otherwise directed) must be submitted through the Institutional Portal.

 

Withdrawal:

An institution may withdraw a substantive change application, prospectus, or notification at any point during the review process. If a substantive change has been approved or notification accepted, it cannot be withdrawn.

 

---

PROCESS

a. The SACSCOC Liaison is responsible for monitoring all potential substantive change needs and will direct appropriate personnel to initiate a Substantive Change Request Form (available on MyNC) when necessary.

b. Once completed, Substantive Change Request Forms will be routed to the NC Substantive Change Committee. The NC Substantive Change Committee is co-chaired by the Vice President of Academic Affairs (VPAA) and Vice President of Student Success (VPSS). The NC Substantive Change Committee reviews the required form to determine whether a proposed change is substantive in nature and what procedure is necessary. If needed, the VPAA contacts SACSCOC staff for consultation. The NC Substantive Change Committee advises the initiator regarding preparation of required SACSCOC substantive change notification or prospectus within the required time frame.

c. The NC Substantive Change Committee reviews and coordinates the preparation of documents.

d. The SACSCOC substantive change notification or prospectus is presented to the appropriate internal authority for approval.

e. The substantive change notification or prospectus is then submitted to SACSCOC for approval.

f. The College will defer implementation on substantive changes requiring approval.

g. An inventory of substantive change submissions and outcomes will be maintained by the VPAA office.

 

---

SPECIFIC REQUIREMENTS BY TYPE OF SUBSTANTIVE CHANGE

Specific information regarding the procedures for the following types of substantive change are located at https://www.navarrocollege.edu/attachments/board-policies/bh1-substantive-change.pdf

Institutional Changes:

Institutional Changes	Requires	Approval Body	Committee Visit	Fee	Subject to Substantive Change Restriction
Acquisiton	Notification and Approval	Full Board of Trustees	Required	Yes	No
Change in Measure of Student Progress to Completion	Approval	Exec. Council of the Board	No	Yes	No
Competency-based Education by Course/Credit-based Approach – Institutional-level Approval	Approval	Exec. Council of the Board	No	Yes	No
Distance Education – Institutional-level Approval	Approval	Exec. Council of the Board	No	Yes	No
Governance Change	Notification and Approval	Full Board of Trustees	Required	Yes	No
Institution Closure	Aproval	Exec. Council of the Board	No	No	No
Institution Relocation	Approval	Exec. Council of the Board	No	Yes	No
Institutional Contingency Teach-out Plan	Approval	Exec. Council of the Board	No	No	No
Level Change	Approval	Full Board of Trustees	Required	Yes	No
Merger / Consolidation	Notification and Approval	Full Board of Trustees	Required	Yes	No
Mission Change	Approval	Exec. Council of the Board	No	Yes	No
Ownership, Means of Control, or Legal Status Change	Notification and Approval	Full Board of Trustees	Required	Yes	No
Prison Education Program - Institutional-level Approval	Approval	Exec. Council of the Board	Required	Yes	Yes

 

Program Changes:

Program Changes	Requires	Approval Body	Committee Visit	Fee	Subject to Substantive Change Restriction
Clock-Credit Hour Conversion	Approval	Exec. Council of the Board	No	No	No
Competency-based Education by Direct Assessment - Approval	Approval	Full Board of Trustees	Required	Yes	No
Competency-based Education by Direct Assessment - Notification	Notification	Accepted by Staff	No	No	No
Cooperative Academic Arrangement with Title IV Entities	Notification	Accepted by Staff	No	No	No
Cooperative Academic Arrangement with Non-Title IV Entities - Approval	Approval	Exec. Council of the Board	No	Yes	Yes
Cooperative Academic Arrangement with Non-Title IV Entities - Notification	Notification	Accepted by Staff	No	No	Yes
Correspondence Education	Approval	Exec Council of the Board	No	Yes	No
Dual Academic Award	Notification	Accepted by Staff	No	No	No
Joint Academic Award with non-SACSCOC Institution(s) or Entity(ies)	Approval	Exec. Council of the Board	No	Yes	No
Join Academic Award with SASCSCOC Institution(s)	Notification	Accepted by Staff	No	No	No
Method of Delivery - Approval	Approval	Exec. Council of the Board	No	No	Yes
Method of Delivery - Notification	Notification	Accepted by Staff	No	No	Yes
New Program - Approval	Approval	Exec. Council of the Board	No	Yes	Yes
New Program - Notification	Notification	Accepted by Staff	No	No	Yes
Program Closure	Approval	Exec. Council of the Board	No	No	No
Program Designed for Prior Learning - Approval	Approval	Exec. Council of the Board	No	Yes	Yes
Program Designed for Prior Learning - Notification	Notification	Accepted by Staff	No	No	Yes
Program Length Change	Approval	Exec. Council of the Board	No	Yes	Yes
Program Re-open	Notification	Accepted by Staff	No	No	No

 

 

Off-campus Instructional Site / Additional Location Changes:

Off-campus Instructional Site / Additional Location Changes	Requires	Approval Body	Committee Visit	Fee	Subject to Substantive Change Restriction
Off-campus Instructional Site Notification	Notification	Accepted by Staff	No	No	No
Off-campus Instructional Side Approval (including branch campuses) Extensive review-Approval method one	Approval	Full Board of Trustees	Contingent	Yes	Yes
Off-campus Instructional Side Approval (including branch campuses) Extensive review - Approval method two	No action by the institution
Off-campus Instructional Side Approval (including branch campuses) Limited review	Approval	Exec. Council of the Board	Contingent	Yes	Yes
Off-campus Instructional Site Relocation - Non-branch Campus	Notification	Accepted by Staff	No	No	No
Off-campus Instructional Site Relocation - Branch Campus	Approval	Exec. Council of the Board	No	Yes	No
Off-campus Instructional Site Name or Address Change	Notification	Accepted by Staff	No	No	No
Implementation Extension	Approval	Exec. Council of the Board	No	No	No
Off-campus Instructional Site Closure	Approval	Exec. Council of the Board	No	No	No
Off-campus Instructional Site Re-open	Notification	No	No	No	No

 

Other Changes:

Additional information regarding the following topics can be found at  https://www.navarrocollege.edu/attachments/board-policies/bh1-substantive-change.pdf

· Substantive Change Restrictions

· Committee Visits

· International Off-Campus Instructional Sites,

· Fees and Expenses

· Review Fee

· Substantive Change Committee Visit Fee and Expenses

· Unreported Substantive Changes

· Review Procedures,

· Staff Options

· Options of the Committee on Compliance and Reports Following Review of the Prospectus or Application,

· Preparation for a Substantive Change Committee Visit,

· Options of the Committee on Compliance and Reports Following Review by a Substantive Change Committee

· Teach-outs

· What to Submit for Approvals

· Common Content

· Institutional Changes

· Program Changes

· Off-campus Instructional Site/Additional Location Changes

· Other Changes

 

---

Approved: 2014
Updated: 2019, 2021, 2022, 2024
Reviewed: