2015-2016SUBSTANTIVE CHANGE

COMPLIANCE WORKSHOP

Presented by

Jodi Pettazzoni, Ph.D.

Director of Assessment and Accreditation

and SACSCOC Liaison

October 06, 2015

Purpose of this Workshop

• Increase awareness of SACSCOC, UNC General Administration (UNC-GA), and UNCG policies

• Define and identify substantive changes• Clarify areas of confusion • Share lessons learned• Discuss ways to improve our processes

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SACSCOC and UNCG Policies on Substantive Change

“Member institutions are required to have a policy and procedure to ensure that all substantive changes are reported to the Commission in a timely fashion.”

The Office of Assessment and Accreditation will offer periodic training for liaisons on substantive change policy and other academic program compliance issues.

SACSCOC and UNCG policies on Substantive Change:http://www.sacscoc.org/pdf/081705/Substantive%20change%20policy.pdf

http://policy.uncg.edu/substantive_change_compliance/

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Definition of Substantive Change

“A significant modification or expansion of the nature and

scope of an accredited institution.”

US Department of Education Defines (in most cases)

and SACSCOC Enforces

Substantive Change for Accredited Institutions - Policy Statement -

http://www.sacscoc.org/pdf/081705/Substantive%20change%20policy.pdf

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Examples of UNCG’s RecentSubstantive Changes

• Establishing new off-campus sites• Substantial increase in credit hours >25%• Dual degree with international institution• Program discontinuations• Initiating programs or courses offered

through contractual agreement or consortium

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Other Examples of Substantive Changes

• New levels of degrees (e.g. AA or AS)• Competency-based educational programs• Academic programs that are substantively

different than our current programs• Accelerated Degree Programs (?)• Any of these could indicate a mission

change, which SACSCOC needs to know about

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CS 3.12.1– Substantive Change

From The Principles of Accreditation: Foundations for Quality Enhancement

“The institution notifies the Commission of changes in accordance with the Commission’s substantive change policy and, when required, seeks approval prior to the initiation of changes.”

http://www.sacscoc.org/pdf/2012PrinciplesOfAcreditation.pdf

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Consequences of Substantive Change Non-compliance

“If an institution fails to follow SACSCOC substantive change policy and procedures, it may lose its Title IV funding or be required by the U.S. Department of Education to reimburse it for money received by the institution for programs related to the unreported substantive change. In addition, the institution’s case may be referred to SACSCOC Board of Trustees for the imposition of a sanction or for removal from membership.”

Substantive Change for Accredited Institutions - Policy Statement -http://www.sacscoc.org/pdf/081705/Substantive%20change%20policy.pdf

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The Four Steps to Substantive Change Compliance

1. Understand when a change is substantive

2. Follow UNCG and UNC GA procedures

3. Allow adequate time

4. If a substantive change requires approval prior to implementation always wait for the approval letter from SACSCOC before implementing.

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Step 1: Identifying Substantive Changes

Suspect it is a substantive change if it:– Is something new or different (significant

departure)– Involves another institution (academic credits)– Is a discontinuation of program or site– Involves an off-campus location– Is a change in length of program (+/- 25%)– Involves a signed contract or agreement

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Is the New Program aSignificant Departure?

• Are there programs closely related?

Example: The new BA in Arts Administration which draws from what UNCG currently is approved to offer (i.e. arts, non-profit administration, business administration) vs. something new to UNCG, such as an engineering program.

• Will the program require new or additional:– Courses,– Faculty, – Equipment,– Facilities,– Financial resources,– Library or learning resources?

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Step 2: Follow UNCG and UNC-GA Procedures

• UNC-GA and SACSCOC policies and procedures are in process of changing (more on this later)

• Detailed procedures are found in the Curriculum Guide (pdf version) http://curriculumguide.uncg.edu/

• The Curriculum Guide is reviewed annually, but it is a live document and will be updated when relevant changes are made

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Step 3: TimingBe aware of the time that may be needed for:

1. UNCG internal process

2. Other institutions for collaborative agreements

3. UNC-GA / Board of Governors

4. SACSCOC

5. US ED Participation Agreement for financial aid (off-campus and certificate programs)

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Step 4: SACSCOC ApprovalSome substantive changes require an approval letter from SACSCOC prior to implementing the change. Wait for this one!

Some substantive changes involve notifying SACSCOC prior to the implementation, which they accept.

Accept ≠ Approval

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Unreported Substantive Change

What to do?1) Contact SACSCOC Accreditation Liaison

(Jodi Pettazzoni) immediately

2) Jodi notifies President of Commission

(Date of original implementation)

3) If the change required prior notification, it will be addressed by the President of the Commission

4) If the change required prior approval, it will be forwarded to the Commission for action at its next meeting

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UNCG’s Substantive Change Compliance Policy

Metrics are kept and reported annually regarding timely reporting of substantive change activity.

Following all established procedures for processing initiatives, all initiatives requiring external authorization were reported in a timely manner.

Working together towards compliance works!

UNC GA Submissions29

Timely Submissions100%

SACSCOC Submissions17

Timely Submissions100%

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DifferencesSACSCOC & UNC-GA

– Educational Program• SACSCOC: A coherent course of study leading to the

awarding of a credential.• UNC-GA: Degree programs (majors) approved by Board

of Governors.

– Certificate: A formal award certifying the satisfactory completion of a postsecondary education program.

• SACSCOC: Certificates are treated the same as degrees• UNC-GA: Certificates are not approved by the BOG, but

are included in the Academic Program Inventory (API)

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DifferencesSACSCOC & UNC-GA

– Distance Education (off-campus)• SACSCOC: Approves the off-campus site.

Approval is needed for any site that is not the main campus, where students can earn 50% or more credits toward an educational program. Approval is needed for financial aid (UNCG’s Title IV Participation Agreement) and Homeland Security. Please note that electronic delivery to a group of students at a specific location would be an off-campus site.

• UNC-GA: Approves each program at each site.Authorization needed for a site away from the institution’s campus offering 50% or more of a program. Program is listed on Academic Program Inventory.

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Off-Campus

SACSCOC Substantive Change Policy

Initiating Off-Campus Sites  

Procedure 1Requires prior approval of a prospectus

Student can obtain 50% or more credits toward program

Procedure 2Letter of notification prior to implementation

Student can obtain 25-49% of credit

NA Student can obtain 24% or less(UNCG keeps track of these.)

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Lesson LearnedOff Campus

When SACSCOC policy says 50% of a program, this includes certificates.

Example: A department is planning on offering three courses (9 hours) of a 30 hour master’s program at an off-campus location (less than 50%). The three courses offered at the off-campus site can also can be used to complete a 15 hour certificate program (more than 50%).

50% of an 15 hour certificate program = 7.5 hours

Notification before second course offered (25%=3.75 hours)

Approval before third course is offered (7.5 hours)

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Lesson Learned

When UNC-General Administration policy says 50% or more of a program, it could even be less.

Example: RN to BSN degree completion program offers its required courses at community colleges. Since the students can complete the requirements without coming to campus, UNC-GA wants it included on their Academic Program Inventory for distance education programs.

25 credit hours / 122 total hours = 20% (SACSCOC)

25 credit hours / 60 degree completion = 41% (GA)

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DifferencesSACSCOC & UNC-GA

– Distance Education (online)• SACSCOC: UNCG is approved to offer all of its

established programs online. UNCG reports all online programs on the Institutional Summary.

• UNC-GA: Authorization required for every program offering 50% or more online.

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Distance EducationApproval at 50% or more

UNC Policy Manual 400.1.1[R]Regulations for Academic Program Planning and Evaluation

(Amended 08/26/13)

“Alternative, online, and distance delivery of BOG-approved degree programs require approval by General Administration and an assurance to General Administration that all reporting to and necessary approvals from regional or specialized accreditation agencies will have occurred prior to the program beginning. If a program will be delivered out of state, the institution must assure GA that all required licensing or other authorization is secured before the program is offered out of state.

Approval by GA is required if fifty percent or more of the degree program will be offered in an alternative, online, or distance delivery mode, or a combination of these modes.” 

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Latest from UNC General Administration

A big THANK YOU to last year’s workshop attendees for making the “50% distance education” a follow-up action item.

1) UNC-GA is now fully aware of the problem

2) They are making incremental changes

3) We should not expect a solution overnight

4) We still have to follow the current policy

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Lessons Learned-Contracts

Example 1: Financial Aid was not involved in the initial review

process which resulted in having to change the initial agreement.

Example 2: Changes made subsequent to the initial review but not

communicated back to the reviewers prior to obtaining signatures

resulted in agreements having to be changed and re-signed.

Delayed start of each program.

Policy on Contract Review and Approval and Signature Authority:

http://policy.uncg.edu/university-policies/contract_approval/

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Collaborative Certificates

A word of caution regarding “certificate” with another entity’s logo on the certificate.

– This signifies it could be a joint award, requiring approval by SACSCOC and perhaps GA.

– This could instead be a certificate of completion with no academic credits or transcript involved.

– If there is an agreement, it needs SACSCOC approval

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Message from General Counsel

“Pursuant to the policy, all contracts (agreements of any

type, regardless of whether they are called MOU, contract,

agreement, etc.) of any type, not just academic contracts,

need to be reviewed and approved either by our office or

by the Purchasing Office (which handles routine

purchasing/services related types of agreements. The only

exception is for contracts for which there is an approved

template, or amendments to previously approved

agreements that do not contain substantive changes.

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Message from General Counsel

As to consequences of signing a contract that has not been approved,

it would depend on a several factors I think.  In any situation it would

be a breach of university policy; in the case of someone who had

authority to sign the agreement (which is a very clearly specified list of

individuals referenced in the policy), if the contract contained language

the university is prohibited by law from accepting, there is a significant

risk to the employee that the contract would be determined to be a

personal contract between the person who signed it personally and the

other party.  In the case of someone who lacked signature authority,

the contract would be a personal contract. ”

Email from Michael Jung, Associate General Counsel 9/30/2015

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Titles

The UNC Board of Governors approves a title for each degree major. That title is the official title and is to be used on all websites and marketing materials.

Please check your websites and make sure that you are using your authorized title.

If you want a different title, please request one. Form L: Request for Program Title or CIP Code Change.

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Curriculum Guide

Task Force’s recommendations are being incorporated into the Curriculum Guide.

• Form A: New or Amended Course Proposal no longer requires a syllabus

• Departments and Units are to provide UCC/GSC with a summary statement of their review

• Form D: Routine Course Change Request utilizes “Essential Course Information” for mode of delivery in lieu of a syllabus

The Office of Assessment and Accreditation now maintains the Curriculum Guide. If there are any user issues, please let us know.

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Heads Up

• UNC-GA: In process of changing academic policies and forms

(Target: December)• SACSCOC: Will be reviewing and revising

their accreditation principals• UNCG: Course type code project reduces

number of course types and aligns them with UNC General Administration

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Contact Information

Jodi Pettazzoni, PhD

Director of Assessment and Accreditation

SACSCOC Accreditation Liaison

jepettaz@uncg.edu

334-5535

Barbara Tookey, MS, MBA

Academic Programs Specialist

bstookey@uncg.edu

334-5975