Plenary III - Institutional Changes Northwest Commission on Colleges and Universities Accreditation Liaison Workshop March 13, 2013

Topics for Institutional Changes Substantive and Minor Changes (Policy A-2) Distance Delivery of Courses, Certificates and Degree Programs Termination/Suspension of an Educational Program (Standard 2.D.4) with or without Teach-Out Plans and Teach-Out Agreements New Instructional Sites Contractual Relationships with Other Institutions/Organizations Curriculum Revisions

The Commission recognizes that institutions of higher learning are in a constant state of change. Not all changes coincide with regularly scheduled evaluation reports and visits. Therefore, changes are not automatically included under the current accreditation status of the institution. Some mechanism is needed to keep the Commission apprised of substantive changes that occur outside of scheduled evaluation years. Institutional Changes: Operating Assumptions

Policy A-2 provides a mechanism for institutions to keep the Commission apprised of changes that do not fall within regular review cycles. Policy A-2 Substantive Change: Institutional Perspective

The Commission has a responsibility to the Department of Education to monitor substantive changes to ensure that they are in compliance with the Commission’s Accreditation Criteria. Those criteria are: 1. Eligibility Requirements 2. Standards 3.Policies Policy A-2 Substantive Change: Commission Perspective

Commission nomenclature identifies two categories of Substantive Change. SUBSTANTIVE and MINOR Classifications of Changes

Examples of Substantive Changes Mission and Core Themes Legal status, sponsorship, merger, or control Offering courses/program(s) for academic credit outside of the NWCCU region Adding degree programs at a new degree level (higher or lower) than currently listed for the institution in the NWCCU Directory

Establishing new degree programs not closely related to other fields of study at the institutions Offering academic programs through contractual relationships (collaboratives, partnerships, agreements) with non-regionally accredited organizations Offering a program or degree-completion opportunity by distance delivery, or, significantly altering a delivery modality already in place Examples (continued)

Establishment of a branch campus Offering program(s) for academic credit within NWCCU region not previously reported or evaluated Change in clock hours to credit hours, or, substantial increase or decrease in the length of a program Establishment of an additional location where 50% or more of an educational program is delivered

Total Substantive and Minor Changes 2010 and 2011

A LASKA S UBSTANTIVE AND M INOR CHANGES

I DAHO S UBSTANTIVE AND M INOR CHANGES

M ONTANA S UBSTANTIVE AND M INOR CHANGES

N EVADA S UBSTANTIVE AND M INOR CHANGES

O REGON S UBSTANTIVE AND M INOR CHANGES

U TAH S UBSTANTIVE AND M INOR CHANGES

W ASHINGTON S UBSTANTIVE AND M INOR CHANGES

Substantive Change Proposal The purpose of the proposal for substantive change is to enable an institution to set forth the activities constituting the change and demonstrate the impact of the change on the institution as a whole. The proposal for substantive change should address: a. Mission and Goals: 1. Clear statement of the nature and purposes of the change in the context of institutional mission and goals

b. Authorization: 1. Evidence of formal approval by the governing board and/or by the appropriate governmental agency to offer the proposed existing and/or new program(s) at the proposed site(s) c. Educational Offerings: 1. Descriptive information of the educational offering(s) 2. Evidence of approval by the appropriate academic policy body of the institution

d. Planning: 1. Plans and descriptive materials indicating evidence of need for the change and the student clientele to be served 2. Procedures used in arriving at the decision to seek the change 3. Organizational arrangements that are required within the institution to accommodate the change 4. Timetable for implementation

e. Budget: 1. Projections (revenue and expenditures) for each of the first three years of operation 2. Revenue and expenditures associated with the change itself 3. Institutional financial support to be reallocated to accommodate the change 4. Budgetary and financial implications of the change for the entire institution

f. Student Services: 1. Provision for student services to accommodate the change 2. Implications of the change for services to the rest of the student body g. Physical Facilities: 1. Provision for physical facilities and equipment h. Library and Information Resources: 1. Adequacy and availability of library and information resources

i. Faculty: 1. Analysis of the faculty and staff needed 2. Educational and professional experience qualifications of the faculty members relative to their individual teaching assignments 3. Anticipated sources of plans to secure qualified faculty and staff

The Commission requires that documentation associated with substantive change be made available to the Commission or its representatives upon request. You will be contacted if there is information requested. Missing Information?

Best Practices and Reminders 1. All proposals for substantive change should be submitted prior to the implementation of the change. 2. Please allow the Commission Office about 90 days to analyze a proposal – excluding institutional time needed for requests for additional information; minor changes generally require less time.

3. If unusual time constraints are associated with the proposal (legislative action, contractual agreement termination in process), please let us know when you submit the prospectus. 4. If in doubt as to whether or not the anticipated change is a substantive change, or a minor change, please call the Commission Office prior to submission. Best Practices and Reminders (con’t)

5. When writing a proposal for substantive change, please address all the elements of Commission Policy A-2, specifically sections a through i of Policy A-2 and include a copy of the institution’s latest IPEDS Finance Report. Omitting elements from the proposal will delay its review. Best Practices and Reminders (con’t)

6. Implementing substantive changes without Commission approval may trigger a show cause order. 7. When in doubt, call us. We are glad to help. Best Practices and Reminders (con’t)

New Programs and Curricular Revisions Is it a Substantive Change or a Minor Change? How much of the content is new to campus? What proportion of program outcomes change? Is a related program in existence at main campus or repackaged offerings? What additional resources are needed to support delivery of the program (human, material, financial)? Is another institution/organization involved?

New Programs Usually a substantive change if … New discipline of study to campus Another institution or organization is involved Significant resources are needed to support delivery of the program (human, material, financial) A new degree level of educational offering, higher or lower

Program Minors, Options and Endorsements Usually a Minor Change …. Some Exceptions: Another institution/organization is involved A new instructional site is utilized It is being eliminated or suspended Significant new expenditures are needed Online Delivery for the first time

Addition of a New Instructional Site Usually a Substantive Change …. Geographically apart from main campus? Is the street address new to your institution? Are more than 50% of program requirements delivered? What additional resources are needed to support delivery of the program (human, material, financial)? What if a portion of the curriculum is delivered online? Where is the 50% breakpoint?

An Existing Instructional Site with Curricular Additions Minor Change possibly? Some Factors Considered: Site already NWCCU approved and in use Delivery of less than 50% of program requirements Minimal new resources needed Appropriate Student Services Pilot program or limited time, i.e., summer session

Distance Delivery: Instructor and Student are not in the Same Physical Space Substantive Change or Minor Change? Some Factors Considered: Instructional site already NWCCU approved and in use Delivery of less than 50% of program requirements Institution has a history of distance or online delivery, five successful years with appropriate infrastructure

New Program – New Degree Level Always a Substantive Change Diligence is needed to substantiate projected enrollment and financial budgets For lower degree levels, i.e., graduate to baccalaureate: student services, general education, authorization For higher degree levels, i.e., baccalaureate to graduate or doctoral: library collection, faculty credentials, professional versus research-oriented, scholarship Candidacy stage until next evaluation report

Termination/Suspension of an Educational Program Standard 2.D.4 In the event of program elimination or significant change in requirements, the institution makes appropriate arrangements to ensure that students enrolled in the program have an opportunity to complete their program in a timely manner with a minimum of disruption.

Does a Teach-out Plan or Teach-out Agreement Exist? Submit to NWCCU for approval prior to implementation when engaging a teach-out agreement involving another institution The teach-out agreement must meet standards and policies of accreditation, and, “teach-out” institution must provide equitable treatment of students

Related -- Closure of a site Common reasons - Mergers or acquisitions between institutions Consolidation of state or institutional resources Permanent – not a suspensio n

Teach-Out Plan or Agreement: Areas for Consideration Students – arrangements to complete degree programs including negotiation of the transfer of grants and scholarships Academic and Financial Records – preservation with state agencies or other institutions and including copies of records forwarded to students when possible Faculty and Staff – those necessary to continue until closing date; no guarantees but good-faith efforts to assist in relocation and reassignments

Teach-Out (continued): Resources – extended through last term, including faculty and staffing, counseling, and other essential support services Disposition of Assets – arrangements for facilities, equipment, library collections, endowments, etc. Communication – reasonable notice is given to all employees and students

Contractual Relationships with other Institutions/Organizations In effect, “lending” accreditation status to other institution or organization Must adhere to criteria for accreditation Memorandum of Understanding (MOU) between the institutions/organizations is strongly advised

Expectations for Contractual Agreements Primary purpose – education Mission – consistency Academic credit awarded – follows established procedures; consistency Curriculum – under control and oversight of “lead” institution to include consistency with institution’s recruitment of students, admissions, instruction and faculty credentials, evaluation of student progress (learning outcomes), records, tuition and fee charges, library resources

Requirements for Contractual Agreements Executed by institutional authorities Period of agreement and conditions of renewal Provisions for review and approval of performance by contracted party Clearly established responsibilities between your institution and the contracted party

Contractual Agreements (continued): Scrutiny of Enrollment Agreement Tuition – policies and rates, refunds, collection practices Student Recruitment – advertising and promotional literature; duties and responsibilities of admissions’ representatives and organizations (“field agents”) Written/translated into English language

Complaints Against Member and Candidate Institutions Sometimes a result of institutional changes…… Must be documented in writing with an original signature sent via postal mail to the NWCCU office No responsibility for isolated individual grievances, but may investigate individual complaints to determine if they reflect educational quality or general welfare

Complaints (continued): Initial Review Criteria: 1. Adequate Documentation 2. Institutional Appeals or Grievance Procedures have been utilized within the appropriate time period (2 years from initiative of procedures) 3. Conditions appear to jeopardize educational quality or general welfare of the institution

Complaints (continued): If initial review criteria are met: 1. President or Chief Executive Officer of the institution is notified and a response is requested 2. President of the Commission makes a determination of compliance with criteria for accreditation

Complaints (continued): If the President of the Commission judges the institution to be out of compliance with criteria for accreditation: 1. Complaint is referred to the Commission 2. Institution and complainant are notified 3. Commission takes action

Complaints (continued): If the Commission judges the complaint to be related to criteria for accreditation: The complaint will be made available to the chair of the evaluation committee, or single evaluator, for the next regularly scheduled institutional evaluation “Third party” complaints are processed by evaluation teams

Review Relevant Commission Policies: Most ALO time is spent with: 1. Substantive Change 2. Credit Hour Policy (new for a year or two) 3. Distance Delivery 4. Contractual Agreements 5. Teach-out plans 6. Accreditation Liaison Officer Responsibilities

Questions?