Separate Accreditation for Units of a Member Institution

The Commission on Colleges and Universities accredits an institution as a totality. This accreditation includes, in addition to the parent campus, all centers, branch campuses, campuses, or other sites of a degree-granting institution at which postsecondary degree work is offered. These centers, sites, or locations are referred to as off-campus instructional sites (OCIS). Commission-accredited institutions which offer courses or programs at multiple locations must declare one of these locations a parent campus for the purposes of accreditation. All branch campuses related to the parent campus through corporate or administrative control must (1) include the name of the parent campus and make it clear that its accreditation is dependent on the continued accreditation of the parent campus and (2) be evaluated during reviews for institutions seeking candidacy, initial membership, or reaffirmation of accreditation. All other off-campus instructional sites under the accreditation of the parent campus are included in the scope of such reviews and must be evaluated as appropriate.

If The Commission determines that a unit of the institution – including, but not limited to, an off-campus instructional site – is autonomous to the extent that the control over that unit by the parent or its board is significantly impaired, The Commission may direct that the extended unit seek to become a separately accredited institution. A unit which achieves separate accreditation should bear a different name from that of the parent. Failure to make adequate progress toward such accreditation may endanger the accreditation status of the unit as well as the accreditation status of the parent campus.

During the Application for Membership process, the entity seeking separate accreditation may not initiate any changes of a substantive nature without prior approval by The Commission President. If the entity is considering a substantive change during the Application for Membership process, it must notify The Commission to verify that the change does not preclude the entity from proceeding with the Application for Membership process. Should the

entity initiate a substantive change without prior approval by The Commission President before authorization to receive an Accreditation Committee visit, the entity may be required to submit a new application which includes the change. If an entity implements a substantive change after it has been authorized to receive an Accreditation Committee, its authorization may be revoked at the discretion of The Commission President, and the entity may be required to submit a new application which includes the change prior to Accreditation Committee reauthorization.

All management agreements, option agreements, or other contractual agreements with respect to the management and control of the entity, if any, must be in place at the time of submission of the application for separate accreditation and included for review in the application. After a unit becomes a separately accredited institution, it may not change ownership for at least three years following the date of accreditation as a separate entity without loss of accreditation. After the three-year period, if the institution changes ownership, it is required to notify The Commission and receive its approval, in keeping with the substantive change policy and procedures of The Commission.

There is no provision for candidacy in the process of accreditation for units of a member institution seeking separate accreditation.

A unit of a member institution may withdraw its application for separate accreditation at any time prior to a decision of The Commission Board of Trustees. If a unit of a member institution withdraws its application and later decides to again seek separate accreditation, it must submit a new application and follow the procedures outlined below as they apply to units of a member institution seeking separate accreditation status with The Commission.

An applying unit of a member institution bears the cost of application fees as well as the direct and indirect costs of visits. See the section of this policy entitled “Fees and Expenses.”

All final decisions regarding the accreditation status of a unit of a member institution seeking separate accreditation are made by The Commission Board of Trustees. Denial of the change of accreditation is an appealable action.

The Commission philosophy of accreditation precludes denial of membership to a unit of a member institution seeking separate accreditation on any basis other than failure to comply with the relevant standards of the Principles of Accreditation established by the College Delegate Assembly or failure to comply with the policies and procedures of The Commission. The Board of Trustees of The Commission uniformly applies the Principles of Accreditation to all applicant, candidate, and member institutions.

The completed application constitutes a primary source of information used by The Commission to determine apparent compliance with the requirements and standards included in the Application for Membership, which are basic expectations of institutions seeking authorization of an Accreditation Committee visit with The Commission. Compliance with these requirements and standards, however, is not sufficient to warrant initial membership. After an Accreditation Committee is authorized, institutions must demonstrate both continued compliance with these requirements and standards and compliance with all the remaining standards of the Principles of Accreditation included in the Compliance Certification For New Members.

Institutions are required to notify The Commission in writing if it does not intend to participate in title IV HEA programs per 34 CFR § 602.16 (b) and affirm that decision under this standard. All subsequent awards of accreditation status will note whether an institution has requested not to include participation in title IV HEA programs in its accreditation. Institutions not participating in title IV HEA programs are not required to document compliance with federal responsibilities, but are required to document compliance with state responsibilities, if applicable. See Title IV Program Responsibilities[. ]

If The Commission determines that separately accredited institutions within a system lack the autonomy for separate accreditation, The Commission may find those institutions to be out of compliance with standards related to governance and/or out of compliance with this policy. Institutions must address the noncompliance or must seek to be accredited as a single entity. See the policy statement on Mergers, Consolidations, Change of Ownership, Acquisitions, and Change of Governance, Control, Form, or Legal Status.

1. The unit notifies the President of The Commission in writing of its intent to seek separate accreditation. The notification and application must include authorization by the governing board of the parent entity and the appropriate governmental body (if required) for the unit to seek separate accreditation. The President of The Commission assigns The Commission staff member responsible for applicant institutions to review the application.
2. Representatives of the unit may, but are not required to, attend workshops designed to support institutions seeking The Commission accreditation. Information concerning registering for the workshop may be obtained by visiting The Commission website, www.sacscoc.org. The workshop acquaints attendees with the accreditation process and with the standards of the Principles of Accreditation.
3. The unit completes an Application for Membership and includes all documentation required to demonstrate compliance with the relevant standards of the Principles of Accreditation, as approved by The Commission Board of Trustees.
4. The Application for Membership is reviewed by The Commission staff.
5. If The Commission staff determine that the unit appears to have presented a sufficient case for compliance with all standards included in the Application for Membership, staff will refer the Application for Membership to The Commission President for action. The President may authorize the unit to complete the Compliance Certification for New Members addressing compliance with all standards and authorize an Accreditation Committee to visit the unit or may deny such authorization. If authorization is denied, the unit may request that its Application for Membership be referred to The Commission Board of Trustees for review.
6. If The Commission staff cannot determine whether the unit appears to have presented a sufficient case for compliance with all standards included in the Application for Membership, the unit will be offered the option of withdrawing the Application for Membership or requesting that it be referred to The Commission Board of Trustees for action. The Board of Trustees may authorize the unit to complete the Compliance Certification For New Members addressing compliance with all standards and authorize an Accreditation Committee to visit the unit, or it may deny such authorization. If authorization is denied, the unit may reapply for separate accreditation at any time that it wishes.
7. The Accreditation Committee visit must occur within two years of authorization (or after reauthorization if required due to the initiation of substantive changes without prior approval). After that time, Accreditation Committee authorization expires, unless an extension is approved by The Commission President.
8. The unit may not initiate other substantive changes during the time period between submission of the Compliance Certification For New Members through final action on The Commission accreditation.
9. The unit must include with its application the following financial information:
10. separate audits opinioned on the parent institution and opinioned on the extended unit for the most recently completed fiscal year ending prior to the date of the application. The Commission may require additional audits if needed.
11. an annual budget that is preceded by sound planning, is subject to sound fiscal procedures, and is approved by the governing board.
12. a statement of financial position of unrestricted net assets, exclusive of plant assets and plant-related debt (short- and long-term debt attached to physical assets) which represents the change in unrestricted net assets attributable to operations for the most recent year.

Further, throughout the remainder of the process the unit must provide a separate audit for the most recently completed fiscal year ending prior to any committee visit or Board of Trustees review for (re)authorization of an Accreditation Committee or initial Membership. All audits must be conducted by independent certified public accountants or an appropriate governmental auditing agency.

1. After authorization of an Accreditation Committee visit, The Commission staff member assigned to the unit will conduct an advisory visit to assist the unit in finalizing its Compliance Certification for New Members and discuss arrangements for the Accreditation Committee visit.

11.The chief executive officer of the institution will be invited to review the report[,] and the institution will be invited to prepare a written response to any recommendations made by the Accreditation Committee. The response must be submitted no later than the date requested by staff

12. After the Accreditation Committee visit, the report of the Accreditation Committee and the unit’s response to that report are forwarded to The Commission Board of Trustees for action.
13. At the discretion of The Commission Board of Trustees, the Board may schedule the institution to appear before a Committee on Compliance and Reports of The Commission Board of Trustees for a meeting on the record to provide evidence to further inform the decision of the Board regarding the institution,
14. The Commission Board of Trustees may award separate accreditation, continue the unit as an Applicant and authorize a second accreditation committee, or deny separate accreditation (an appealable action). The awarding of membership occurs if The Commission Board of Trustees judge that the institution has: 1) documented compliance with the standards of the Principles of Accreditation, 2) met the financial requirements listed above in this document, and 3) been in operation, i.e., has without interruption enrolled students in degree programs through at least one complete degree program cycle,
15. If The Commission Board awards separate accreditation, the newly-accredited institution will be required to submit a Fifth-Year Interim Report (without QEP Impact Report) five years after award of membership and have its accreditation reaffirmed ten years after the granting of membership (and every ten years thereafter). For reaffirmation of accreditation, the institution must document compliance with all standards of the Principles of Accreditation. The Commission Board of Trustees may award accreditation with a Monitoring Report, at its discretion, if the Board determines that the institution is non-compliant with a standard that can be resolved within six months. The Commission Board of Trustees may not award accreditation if the institution is non-compliant with a Core Requirement.
16. If The Commission Board continues the unit as an Applicant and authorizes a second Accreditation Committee, the unit must submit its original Compliance Certification for New Members, its original Response Report to the first Accreditation Committee’s report, and a new Focused Report addressing the standards identified in the action letter from The Commission Board of Trustees. The Accreditation Committee visit must occur within one year of authorization. After that time, Accreditation Committee authorization expires, unless an extension is approved by The Commission President.
17. If The Commission Board denies the separate accreditation of the unit, the unit may continue to be included under the accreditation of its parent campus. However, non-compliance in connection with seeking separate accreditation could possibly affect the accredited status of the parent campus. The unit may apply again as it wishes.
18. The unit seeking separate accreditation remains accredited under the parent campus until final action on separate accreditation is taken.

An Application Fee must accompany the application submitted by the entity seeking separate accreditation. It covers costs associated with the application review and consultation with The Commission staff. The institution will incur the actual cost of the initial accreditation committee visit. New member institutions are assessed annual dues using a formula based on enrollment and on educational and general expenditures beginning with the term in which membership status is awarded. Information regarding application fees and membership dues is provided in the Dues, Fees, and Expenses policy.