Substantive Change

Substantive Change

When an institution makes a significant change to what it offers, where it operates, or how it is structured, The Commission reviews that change. This section explains what to report, when, and how.
Submission Deadlines

What is Substantive Change

Accreditation is granted based on what The Commission has reviewed. When an institution changes significantly — by adding programs at a new degree level, opening an instructional site, changing how it delivers instruction, or altering its ownership or governance — the accreditation decision no longer describes the institution as it now exists. Substantive change review is how accreditation keeps pace. Some changes require notification; others require approval before they take effect. The Substantive Change Policy and Procedures is the governing document, and it specifies which is which. Institutions are encouraged to raise a planned change early. Review that happens alongside a change is far simpler than review that happens after it.

Submission Deadlines

All substantive change submissions are made through the Institution Portal.

DEADLINE FOR
September 1, 2026 Changes requiring review by the Board of Trustees at its December 2026 meeting
February 1, 2027 Changes to be implemented July 1 through December 31, 2027, requiring notification or approval by the Executive Council

Not every change requires Board review. Depending on the change type and the institution’s status, a change may be reviewed by the Executive Council or by senior staff on a year-round basis. See “Board review pathways” in the Substantive Change Policy and Procedures.

Recent Changes to the Process

Reduced-Credit bachelor's programs

A framework allowing institutions to offer bachelor’s degrees requiring fewer than 120 semester credit hours in high-need, career-focused fields. Approval is sought through substantive change.
[ Policy ] [ Guidelines ]

Revised Substantive Change Policy & Procedures

Approved by the Board of Trustees June 11, 2026, effective immediately.
[ Policy ]

Faster approvals for some change types
Final approval for a selected set of substantive change types is now given by the President, shortening determination times. New Portal stages reflect this.
Off-campus instructional site recategorization
Sites previously approved only for certificate programs now carry full approval. Institutions may offer any part of any program at these locations without additional approval.

Getting Help

Send all substantive change questions to subchange@commissioncu.org. Inquiries are routed to the staff member best suited to answer, and replies come from the same address.

Note: Add this address to your safe senders list. It is also used to send deferral notices when additional information is needed to complete a review, so those messages need to reach you.

Substantive Change FAQs ⟶

Resources

Substantive Change Links
  • SACSCOC has developed a new policy establishing a framework for reduced-credit hour bachelor’s degree programs, giving SACSCOC member institutions the ability to create a more direct and efficient path for students to complete bachelor’s degrees in high need career-focused fields. The revised policy provides guidance for institutions seeking to offer bachelor’s degree programs requiring fewer than the traditional 120 semester credit hours. Under the framework, institutions must seek approval through the Substantive Change process. Read the policy here, guidelines here, and FAQ here.
  • SACSCOC has revised its Substantive Change Policy and Procedures. The Board of Trustees approved revisions on June 11, 2026.  The revised policy takes effect immediately.
    • Two documents are available:
      • the  revised policy
      • and a markup version with,
        • a summary of all changes,
        • redlines of each change, and
        • select comments and explanations of changes.
    • To view the changes to the Substantive Change Policy that were approved on December 7, 2025 that included the elimination of numerous substantive changes, please see the December 2025 Policy and the December 2025 Markup version. 
    • A press release provides an overview of this and other policy and procedure revisions, including reduced-hour baccalaureate degrees:  Major SACSCOC Policy Revisions Boost Institutional Agility (December 17, 2025).
    • Important: To ensure you’re seeing the latest revision, refresh your browser page after you’ve opened the document.  You can confirm you have the current version of the policy by checking the revision date (December 2025) at the bottom of the document in the “Document History” sections.
  • “Changes at Substantive Change”:  OCIS Recategorizations – Effective immediately, Off-campus instructional sites previously approved only for certificate programs are being upgraded to full approval. Now institutions can offer any part of any program at these locations without needing additional approval.
  • “Changes at Substantive Change”:  Faster Approval Times and New Stages – As a result of Board action, a select number of substantive change types will now have final approval given by the SACSCOC President.  With increased efficiency in mind, this action will cut down on the time it takes to receive a determination on select types of substantive changes. As a result, you will see new stages within the Portal to show the progress of your submission. These new stages include Ready for CEO, Approved CEO, Rejected CEO, and Completed-CEO.Updated information on all Substantive Change Committee Review Stages can be found HERE.
    Note: Hit your browser’s refresh button to ensure you’re seeing the current version (dated 11/11/2025)
  • Second Chance Pell:  Presentation slides from the USDE’s Transitioning from the Revised Second Chance Pell Experiment to Prison Education Program(s) (PEP):  Understanding the PEP Application Requirements webinar on August 20, 2025, are available in the PEP resource folder. #Tip: Sort by date to see newest items; sort by name to see similar items.
  • New feature: You will now receive an email alert when a substantive change response letter is available for download in the Institutional Portal.
  • Prison Education Program (PEP) alert:  The Vera Institute has released The Best Interest Determination Toolkit: Guidance for Oversight Entities. This can also be accessed from SACSCOC’s PEP Resource Folder.
  • subchange@sacscoc.org:  To help us serve you better and quicker, we’re simplifying how you contact us about substantive change.
    • Your inquiries will be automatically routed to the person best suited to answer your question.
    • You’ll receive our replies from this same email address, so please add it to your safe senders list to prevent messages from going to spam.
    • This email address will also send important notifications when we need more information to complete a review — i.e., deferrals — so it’s crucial these messages reach you.
  • Substantive Change Committee Review Stages [PDF]:  a one-page reference of review stages, definitions, and typical sequence
  • Prison Education Program (PEP) information
    • A publicly available PEP resource folder contains information from multiple sources for your reference. New and recently added items are noted.
    • Multiple on-demand PEP webinars are available. SACSCOC webinars are free and publicly available without restriction.
    • The Substantive Change Policy and Procedures is the guiding document for SACSCOC’s roll in PEP reviews and approvals. PEP requirements continue to evolve; monitor the substantive change policy for new or different requirements.
    • The U.S. Department of Education (USDE) has a comprehensive and regularly updated PEP questions and answers webpage for your reference.

Note: All Substantive Change submissions must be made using the institutional portal.

  • September 1, 2026: Deadline to submit substantive changes requiring review by The Commission Board of Trustees in December 2026.  Carefully review the Substantive Change Policies and Procedures to determine if a substantive change type or the institution’s status (viz., sanction) requires Board review at a regularly scheduled biannual meeting (usually in June and December; also referred to as “C&R”) or if the change can be reviewed by the Executive Council of the Board or Senior Staff (year-round).  See also “Board review pathways” in the substantive change policy.
  • February 1, 2027: Deadline to submit substantive changes to be implemented July 1, 2027, through December 31, 2027, requiring notification or requiring approval by the Executive Council of The Commission Board of Trustees. Refer to the Substantive Change Policies and Procedures for guidance for a specific substantive change type.
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