In our last installment, The Waiting Game, we tackled a common misunderstanding about substantive change notifications, the notion that institutions must wait for SACSCOC to “accept” a notification before moving forward. We clarified that, in those cases, institutions may implement immediately after submission.

But there’s a flip side to that story and it’s a critical one. This time, the lore is that you can move forward before approval on substantive changes that actually require it. That’s not just lore it’s a compliance risk.

What the Law Actually Says

Under SACSCOC policy, certain substantive changes require formal approval before implementation.

These include, but are not limited to, major program expansions, new off-campus instructional sites, and degree level changes. The reason is simple: these changes affect the institution’s scope of accreditation and, therefore, must be reviewed and approved before they take effect.

If an institution implements such a change before receiving SACSCOC approval, it is out of compliance with both SACSCOC policy and the Principles of Accreditation.

And that’s not just an internal policy issue, it can have significant federal financial aid implications. Implementing before approval may jeopardize Title IV eligibility for students enrolled in the unapproved program or site. In short, early implementation doesn’t just break the rules, it can cost students access to aid and put the institution at financial risk.

What You Can Do

While institutions cannot admit, conditionally admit, or matriculate students into a program or site requiring approval before that approval is secured, they are permitted to advertise and recruit as long as every communication clearly states “Pending SACSCOC approval.”

That disclaimer matters. It signals transparency to students and compliance with accreditation policy while allowing institutions to prepare for launch once approval arrives.

So yes, you can market.
Yes, you can plan.
But you cannot operate.

Where the Lore Comes From

Confusion often arises because the approval and notification pathways look similar on paper but carry very different timelines and consequences. When institutions see that some changes can move forward after submission, it’s tempting to assume the same flexibility applies everywhere.

But in the case of approval-required changes, the safeguard is deliberate. The approval process ensures that institutional capacity, academic quality, and financial stability align with the proposed change before students are affected.

That’s not red tape, it’s responsibility.

Law vs. Lore

✅ Law: Substantive changes requiring approval may not be implemented until SACSCOC approval is granted.

❌ Lore: Institutions can implement approval-required changes immediately after submission, just like notifications.

The Pruitt Perspective

In accreditation—as in life—timing is everything. Waiting for approval may feel frustrating, but it’s a necessary guardrail that protects institutions and students alike.

The key is understanding which lane you’re in: notification or approval. Move too early in the wrong lane, and you risk crossing the line.

At SACSCOC, our goal isn’t to slow progress but to ensure that every substantive change strengthens, not strains, institutional quality. Yes, we are looking at reducing our total categories, streamlining processes, and improving support structures, but there are some things that we are held accountable for too. My hope is that we will be able to cull down the total numbers of SubChange so that our focus can be on reducing turnaround time and improving supports and communications.

So the next time someone says, “We can go ahead, it’s already been submitted,” take a breath and ask one simple question:

Is that law—or lore?