Substantive Change FAQs

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Frequently Asked Questions

I have noticed new stages within the Institutional Portal for my submissions. What do these new stages mean?

(Added 11/03/2025)

Ready for CEO is a new stage that was added when the Executive Council of The Commission Board of Trustees made the decision to delegate approval of some types of substantive changes to The Commission President (allowed under federal regulations). If you see a submission with the stage = Ready for CEO, it means that The Commission President is reviewing the submission and making a determination. Once the stage changes to Approved CEO it means they have given their approval. If the stage says Rejected CEO it means they have returned the submission to the Substantive Change office to provide more information. When the letter is ready in your institutional portal, the stage will change to Completed – CEO.

When I submit a substantive change question to subchange@commissioncu.org, is the response that I receive AI-generated?

(Added 03/21/2025)

No. Your question is reviewed and answered by a substantive change staff member. You will not receive an AI-generated or AI-assisted response.

Can I register for a substantive change webinar even though I'm not with a Commission-accredited institution?

(Added 02/07/2025)

Yes. Our webinars — live and on-demand — are free and open to everyone without restriction. Registration requires a valid email address, but it does not have to be a “.edu” address. Institutional partners, legislative staffs, other accreditors, state higher education agencies, federal employees, and the public are welcome to participate.

Can I upload a submission created as a PDF Portfolio file?

(Added 08/28/2024)

No. Folder and file names in a PDF Portfolio cannot be renamed. When uploaded, the resulting path + file names can exceed Microsoft’s maximum (256 characters). This leaves your submission unreadable. There are other technical issues with PDF Portfolio files. Instead of PDF Portfolio, we suggest you: (1) create a single file submission, or (2) zip (compress) multiple files into a single uploadable (.ZIP) file. Ensure embedded navigation links work after being unzipped by testing the file on a different computer (hint: always use relative paths, not absolute paths).

When I review my substantive changes in the institutional portal, each submission shows a "Stage." Can you explain what that means?

(Added 08/16/2024)

Yes. Stage is the current status of your substantive change review. The review process is divided into a series of discrete stages. As the review progresses, the stage updates in real-time in the institutional portal. A one-page reference — Substantive Change Committee Review Stages [PDF] — is available with a brief description of each stage and the typical review sequence from start to finish.

We've had a prison education program and prison site approved and operating for many years. Do I have to submit a Prison Education Program - Institutional-level Approval prospectus now even though we're not doing anything new?

(Added 07/31/2024)

Yes, if your incarcerated students will be offered access to Pell grants.

No, if your incarcerate students will not be offered access to Pell grants.
There’s a difference between what an institution may call its prison education program (used generically) and the federal Prison Education Program or PEP (used to reference the federal financial aid program implemented in 2023). PEP, as used in The Commission substantive change policy, refers to the federal Prison Education Program (PEP) only.

I created an Off-campus Instructional Site-Notification. All items under "What to submit" in policy are entered on the screening form. Do I really need to upload a document with the same information?

(Added 07/15/2024)

Yes, you need to upload a document for now even though it seems redundant. We know it’s extra work, but it’s necessary to have both your online answers and an institution-written document. This helps ensure adequate documentation of your off-campus instructional sites.

I created a substantive change submission in the institutional portal. A Case ID was created. However, when I try to upload my document, there's no upload step or icon for that Case. What happened?

(Added 07/09/2024)

You probably didn’t finish all the steps; i.e., there were more questions to be answered or screens to be read. Keep going until you see and click the “Submit” button at the very end. If you stopped too soon, you’ll have to start over with a new submission. Don’t worry — the unfinished one (i.e., no upload) will be automatically deleted.

Tip: An assigned Case ID doesn’t mean you’re finished — keep going and “Submit.”

Intended vs. actual implementation date: Is it possible to begin a new program earlier than the intended implementation date noted in the prospectus if The Commission Board of Trustees has approved the program?

(Added 06/20/2024)

Yes.

Regarding the revised language in the June 2024 sub change policy: Can marketing a new program (or new site) begin prior to submitting a prospectus if it includes the disclaimer statement as required in the Advertising and Student Recruitment policy?

(Added 06/20/2024)

Yes. However, do not admit, conditionally admit, or matriculate until approved by The Commission Board of Trustees.

If an institution is planning a program closure and needs institutional governing board approval, can I submit the Program Closure teach-out plan before receiving governing board approval?

(Added 06/20/2024)

Yes. In your teach-out plan, note that governing board approval is required but is pending. When your teach-out plan is read by a Commission staff member, we’ll defer the review by asking you for approval documentation which you’ll upload when you’ve received it. Keep in mind that deferrals are for a maximum of 180 days; if you don’t have approval by then, then you’ll need to start over.

The substantive change policy was revised in June 2024. Is the prospectus I'm planning to submit by the July 1, 2024, deadline expected to conform to the June 2024 policy?

(Added June 2024)

Yes. As a rule, policies are effective the date they are approved by The Commission Board of Trustees. Carefully review, using the redline version of the policy changes, any new or different requirements for the substantive change type you’re submitting and ensure your submission addresses the current policy requirements.

Wait – what? Where are the FAQs I've seen here before?

(Added 04/26/2024)

We’re refreshing the FAQ page content. Some of the prior questions were, well, infrequently asked now so we’re starting over and adding more timely FAQs received from institutions. Let us know what questions you’d like to see here and we’ll do our best to answer them.

Are all substantive changes now submitted through the Institutional Portal?

(Added 04/26/2024)

Yes. Submit your substantive change through the portal only; don’t mail, ship, or email. For guidance, refer to the Documents Submitted for SACSCOC Review policy, viz., Appendix A (Electronic Submission of Documents). An Institutional Portal User Guide is available in the portal.

I’m preparing a prospectus that requires the institution’s two most recent financial statement audits. In our state, public universities do not have annual independent financial audits; we are considered part of the system’s consolidated financial report. Can I provide the unaudited financial statements submitted to the system that are aggregated into the system’s consolidated financial report?

(Added 08/02/2022, affirmed 04/26/2024)

No. An audited/reviewed financial statement is required; unaudited is insufficient. If your institutional financial statements are included as supplemental schedules to the opinioned system audit, that may be submitted as audit evidence. The schedules must be a published part of the audit to be considered. Additional institutional finance guidance, including audits, is available on The Commission website; this guidance is in the context of compliance certifications and monitoring reports, but the core audit guidance applies to substantive change submissions, too.