Substantive Change

A substantive change is an institutional change significant enough to alter an institution’s mission, scope, control, or geographical location for instruction. For candidate and accredited institutions, these changes require ABHE review and approval before implementation. Other changes may not require prior approval, but they still require notification to the Commission.

Common examples

• Mission and scope: Substantial changes to institutional mission or intended outcomes; new graduate or doctoral offerings; new credentials or programs that represent a significant departure from current offerings.
• New programs: Graduate or post-graduate additions, doctoral additions, significant-departure programs, adult degree completion programs, and certain competency-based offerings.
• New modalities: First use of a new instructional modality, or reaching the threshold where a credential may be completed primarily through distance education, correspondence, mixed modality, or another newly used delivery method.
• Additional locations and branch campuses: Relocation of the main campus, initiation or relocation of additional locations, and branch campuses. Some of these also require a site visit after implementation.
• Ownership and control: A new or discontinued formal relationship with a denomination or fellowship, change in ownership, merger, acquisition, change in legal status, change in governance, or certain joint ventures.
• Closures and discontinuations: Planned or unplanned institutional closure, closure of a location, or high-impact discontinuation that affects students’ ability to complete a program.
• Innovative or unusual delivery structures: Innovative programs, customized pathways, unusual structures, and other approaches that do not fully align with standard requirements and therefore need review before launch.

Institutions placed on warning, probation, or show cause by the Commission in the last three years, and/or institutions currently on provisional certification for Title IV, HEA programs must treat some additional changes as substantive. In such cases, submission of a substantive change proposal and Commission approval are required before implementation. For more information, see the Policy on Substantive Change and Required Notifications, Substantive Changes 7a-7g.

Not every change is substantive

Some changes are required notifications, not substantive changes. These include examples such as certain delivery-method changes, some curriculum/content changes, extension sites where less than 50% of a credential may be completed, some program additions not treated as change in scope, program closures, nomenclature changes, and institution name changes. Institutions should review both the substantive change list and the required notification list before moving forward.

How to begin

Start with the current Substantive Change forms and instructions. Use the substantive change proposal forms for changes that require prior approval, and note that some program additions that are not treated as a change in scope use a separate form/workflow (see the Required Notifications page). Institutions are also encouraged to contact the Substantive Change Officer for guidance while preparing materials.

When teach-out may also be required

If a change involves institutional closure, site closure, or a location where students may lose the ability to complete a program as promised, a teach-out plan and sometimes one or more teach-out agreements may also be required. For closures or high-impact discontinuations, consult the Teach-Out Arrangements page early in the process.

Before you act

When an institution is uncertain whether a proposed change is substantive, the policy directs institutions to consult the Substantive Change Officer at least six months before the intended implementation.