Substantive Change Policy
The adaptation of existing programs and/or courses and the creation of new programs and/or courses, including changes in the method or location of delivery, provide significant opportunities for Winthrop University’s community of learners. The Board of Trustees and the administration of Winthrop University require internal review and approval of such changes; in addition, regulatory agencies such as the Commission on Colleges of the Southern Association of Colleges and Schools (SACS-COC) and the South Carolina Commission on Higher Education (CHE) require notification and/or approval of such changes before changes can be implemented.
Southern Association of Colleges and Schools
The Commission on Colleges of the Southern Association of Colleges and Schools (SACS-COC) accredits Winthrop University and is required by the federal government to review and approve all major institutional changes. The SACS policy states the following:
The Commission on Colleges of the Southern Association of Colleges and Schools accredits an entire institution and its programs and services, wherever they are located or however they are delivered. It is responsible for reviewing all substantive changes that occur between an institution’s decennial reviews to determine whether or not the change has affected the quality of the total institution and to assure the public that all aspects of the institution continue to meet defined standards.
In addition, the Commission on Colleges is recognized by the U.S. Department of Education as an accrediting agency whose accreditation enables its member institutions to seek eligibility to participate in Title IV programs. To maintain its recognition with the U.S. Department of Education and in accordance with CFR 34, Section 602.22, the Commission on Colleges must include procedures in its policies requiring prior approval of many institutional substantive changes before each change can be included in the agency s previous grant of accreditation to the institution. (http://www.sacscoc.org/pdf/081705/Substantive%20change%20policy.pdf )
Definition of Substantive Change
Substantive change is a federal term and is defined as any “significant modification or expansion of the nature and scope of an accredited institution.” According to federal regulations, substantive change includes
· Any change in the established mission or objectives of the institution;
· Any change in legal status, form of control, or ownership of the institution;
· The addition of courses or programs that represent a significant departure, either in content or method of delivery, from those that were offered when the institution was last evaluated;
· The addition of courses or programs at a degree or credential level above that which is included in the institution’s current accreditation or reaffirmation;
· A change from clock hours to credit hours;
· A substantial increase in the number of clock or credit hours awarded for successful completion of a program;
· The establishment of an additional location geographically apart from the main campus at which the institution offers at least 50 percent of an educational program;
· The establishment of a branch campus. (http://www.sacscoc.org/pdf/081705/Substantive%20change%20policy.pdf )
The University must report substantive changes to SACS. In some cases, the university needs only to notify SACS of a substantive change; however, in most cases, SACS must provide approval prior to the implementation of the change. If Winthrop University fails to adhere to the substantive change policy, the University’s accreditation may be at risk, the institution may lose its Title IV funding, or other sanctions may be imposed. (Read more about the SACS policy statement on the substantive change process.)
The chief executive officer of an institution undergoing substantive change requiring prior approval must provide written notification of the change to the President of the Commission on Colleges of the Southern Association of Colleges and Schools at least six months in advance of implementation of the substantive change. If an institution is unclear as to whether a change is substantive in nature, it should contact SACS-COC staff for consultation. (See page 8 of the Substantive Change Policy.)
Upon notification, the President of the COC will ask the institution to submit a completed prospectus if one has not been submitted. The prospectus must be submitted at least three months in advance of the planned implementation date to allow ample time for review and approval. The completed application prospectus must be submitted in print copy only. (See page 8 of the Substantive Change Policy.)
The SACS substantive change policy statement contains the format required for the Substantive Change Prospectus. (See Appendix.) The department requesting the change prepares information necessary for completion of the prospectus for SACS and forwards the draft prospectus to the college dean. The dean reviews and submits the draft prospectus to the Vice President for Academic Affairs for review. The Office of Academic Affairs then prepares the appropriate cover letter for the President’s review and forwards to the President for approval and signature.
South Carolina Commission on Higher Education
The South Carolina Commission on Higher Education (CHE) must also receive notification and/or provide approval of changes, depending on the nature of the change. (View the Approval Process Timetable for categories.) CHE approves new programs using the following procedures: submission of a Program Planning Summary, optional review by an advisor at CHE offices in Columbia, then submission of a Full Program Proposal. The Planning Summary must be approved by the CHE Advisory Committee on Academic Programs (ACAP). The final proposal must be approved by ACAP, the CHE Committee on Academic Affairs and Licensing (CAAL), and the full commission.
Winthrop University Procedures
Winthrop University has adjusted its approval procedures to address appropriate notifications and approvals of academic program changes, including substantive change notifications, and the implementation of the new faculty governance structure.
Note of Caution: Depending on the nature of the program change, it can take 10-12 months to complete the proper approval procedures for substantive change.
Changes in programs or courses or the development of new programs may have an impact beyond the initiating program/department; therefore, program coordinators should review proposed changes and ideas for new programs with the appropriate department chair(s); and chairs should consult with the appropriate dean(s) prior to beginning the internal review process. The dean of the academic unit that houses the existing program or may house the new program will notify the Vice President for Academic Affairs, the CHE Liaison (Assistant Vice President for Academic Affairs), and the SACS Liaison (Associate Vice President for Academic Affairs) that program changes or a new program request will be forthcoming.
At the appropriate point in the process, this group will review the information to ensure that the proposed changes which require notifications, program planning summaries, program proposals, and/or substantive change actions have complete documentation from the beginning of the change process. This group will determine the level of approval needed for the particular change and submit the appropriate notifications in a timely fashion as required by the regulatory agencies.
Internal Control Considerations
Internal Development, Review, and Approval of Program Changes/Modifications and of New Programs
While different changes or modifications require different review and approval processes and timelines, all require appropriate and timely consultation and notification. (See statement above on consultation required before initiating changes.) Please review the timetables for approval of program modifications, new programs, programs offered at off-campus sites, and new programs at already-approved off-campus sites. (View the Approval Process Timetable.)
Because new program proposals are the most time-consuming and extensive changes or modifications, these will be discussed in detail. New programs are offerings that lead to the conferral of a degree or the establishment of any administrative unit such as an institute or research center engaged in research, public service, or instruction. (For full definitions, see CHE Policies and Procedures, pg 3-5.) The CHE publishes timelines with the scheduled meeting dates and deadlines on its website. The current timeline may be found on the CHE website.
New program development requires ongoing consultation among all parties involved. The CHE approval process requires a minimum of one year from the time of submission of a Program Concept Letter until approval of a new program by the Commission.
Program Planning Summary
After appropriate consultation has occurred and agreement has been reached that the new program should be proposed, a Program Planning Summary (PPS) must be developed. The PPS should contain: justification of the proposed program, anticipated program demand and productivity, assessment of possible duplication with other programs, relationship to other Winthrop programs, relationship to other programs at other institutions, information about faculty credentials, cost summaries broken down by new costs vs. redirected costs; and total cost summaries.
Deans should notify the Office of Academic Affairs of the intention to develop a Program Planning Summary well in advance of submitting the information for internal review and approval. The Program Planning Summary, three pages or fewer, is submitted to the CHE at the beginning of the institutional planning process. The purpose of a Program Planning Summary is to inform the Winthrop community and the CHE of the possibility of developing a new academic program. (See CHE Policies and Procedures, pg 14 for required format.)
Once a draft of the Program Planning Summary has been written, the dean of the college where the new program will reside must submit the draft to the VPAA no later than six weeks prior to the deadlines for submission to the CHE. (See CHE Policies and Procedures, page 18.) Final Program Planning Summaries require approval of the department, dean, VPAA, and President before being forwarded to the CHE.
The VPAA may reject a Program Planning Summary. If the PPS is approved by the Vice President for Academic Affairs, a cover letter for the proposal from the President of the University to the Executive Director of the CHE will be prepared by Academic Affairs after review of the planning summary.
The Office of Academic Affairs will submit the cover letter to the President for final review and signature. Submission of a Program Planning Summary to the CHE does not commit Winthrop University to the new program but simply signals the intention of the University to develop a new program within three years. Full administrative and faculty review and approval must take place prior to the implementation of any new academic program (see below).
Please note that the liaisons to CHE and SACS in the Office of Academic Affairs must submit materials to those agencies.
Internal Curriculum Process and CHE Program Proposal
Once the PPS has been submitted to CHE, new programs (as well as program changes) must be submitted through Winthrop’s online Curriculum Application System. (View the Approval Process Timetable.) Winthrop’s internal curriculum process and the preparation of the CHE Program Proposal (a more detailed document than the Program Planning Summary) must be simultaneous processes because of the time required to complete both processes.
Development of the CHE Program Proposal
This document must be developed while the new program is making its way through the University’s Curriculum Action System. It is the responsibility of the department chair and program coordinator in the area where the new program will reside to develop a Program Proposal. The initial draft covers the following elements: cover page, classification, justification, enrollment projections, curriculum, faculty, physical plant, equipment, library resources, accreditation, and estimated costs. The CHE requires a specific format for a Program Proposal which appears in Appendix A of its manual.
Chairs developing proposals should discuss them with their dean prior to beginning the internal review and approval process (below). The dean should also contact the Assistant Vice President for Academic Affairs (CHE liaison) in the Office of Academic Affairs for information on the CHE process and examples of previously submitted proposals from across campus and from other institutions in South Carolina. Whether describing a degree program or an academic unit, the Program Proposal is submitted to the CHE after the internal College review and approval process (including Board of Trustees approval) has been completed. (See CHE Policies and Procedures, Appendix A, for required format.) The CHE liaison will send the proposals to the CHE for informal review. The CHE staff will assure that the proposals are in the appropriate format with all the required elements. Preparation of these materials will require a minimum of four weeks prior to the submission of the documents to CHE.
Internal Curriculum Review and Approval Process
Winthrop’s internal process is as follows:
· Department notifies Assistant Vice President for Academic Affairs that a program will be entered into the Curriculum Application System to ensure appropriate documentation is included in the submission.
· Program/department develops, approves, and submits the proposal in the Curriculum Application System. Please note that each department participating in the proposed program must review and approve the program before it is entered into the system.
· When new programs and program modifications are entered into the system, the system will notify the college dean, the CHE Liaison, and the SACS Liaison.
· Department Chair reviews the proposal. Upon approval, the system forwards to the appropriate College Curriculum Committee.
· The College Curriculum Committee reviews the proposal. Upon approval, the system forwards to the appropriate College Faculty Assembly.
· The College Faculty Assembly reviews the proposal. Upon approval, the system forwards to the Dean of the College offering the program.
· The Dean reviews the proposal. Upon approval, the Dean forwards the proposal to the appropriate University-wide committee.
· If the proposal is for a Teacher Certification program, the proposal is forwarded to the Teacher Education Committee. If the program is for a Bachelor s degree program, it is forwarded to the Committee on University Curriculum (CUC). If the proposal is for a graduate degree program, it is forwarded to the Graduate Council.
· The Teacher Education Committee reviews proposals in light of the State of South Carolina teacher certification regulations. Upon approval, proposals are forwarded to CUC or to Graduate Council appropriately.
· CUC reviews and recommends approval of undergraduate degree programs to the Academic Council. The Academic Council then reviews and, upon approval, submits the proposal to the Faculty Conference.
· The Faculty Conference reviews and approves the program.
· Graduate programs are reviewed and approved by the Graduate Council and then by the Graduate Faculty Assembly.
Required Notifications to/Approvals from Regulatory Agencies
After programs receive the University-wide faculty approvals, the Registrar notifies the SACS Liaison and the CHE Liaison, who forwards the Program Proposal to the Vice President for Academic Affairs for review and approval. The VPAA forwards the program for review and approval by the President; then the proposal is sent to the Board of Trustees for approval.
Once all internal approvals have been secured, the Office of Academic Affairs will submit the proper documents to CHE with a cover letter from the President. In addition to requiring approval of new programs, the CHE expects to review program modifications such as the extension or transfer of a program to another site, the addition of new concentrations within a major, the elimination of majors or concentrations, consolidation of majors, and substantive modifications of majors or concentrations once these modifications have been approved by the Board of Trustees. (See CHE Policies and Procedures, above, Appendix A, for required format.)
Required notifications and requests for approval will be submitted to SACS. Please note that new programs, significant changes to existing programs, and offering programs at off-campus locations require notification to SACS six months prior to the start of the program.