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Substantive Change

The substantive change process is designed to ensure the consistency of quality across all institutional operations, on- and off-campus and through distance education, and to ensure that institutions undergoing major changes continue to meet the WASC Standards of Accreditation. The concern for quality has grown as off-campus programs have crossed regional and international boundaries, technology-mediated learning has flourished, more institutions are beginning to offer both professional and research doctorates, and more institutions are merging or affiliating with other institutions.

Under both WASC Commission policy and the federal Department of Education, certain substantive changes are required to have prior approval.

Categories of Substantive Change

WASC categorizes substantive changes by the level of review necessary to obtain approval. These categories respond directly to federal as well as Commission requirements. There are two levels of review:

Committee Review

Addition of new degree programs or changes involving alterations to delivery methods of existing degree programs, such as online and off-campus programs, including:

  • New degree program at a degree level for which the institution does not have General or Specified degree-granting approval.
  • New modality—distance education or correspondence education
  • New off-campus site (more than 25 miles from the main campus or an approved regional center)
  • New regional center
  • Change in length of a degree program
  • New degree program in which 25% or more of the program will be delivered by an institution or organization not certified to participate in Title IV, HEA programs.

Committee and Commission Review (Also Referred to as Structural Change)

Complex changes that reach beyond a particular program and affect the institution as a whole, including:

  • First degree at a degree level at which no programs have been offered
  • Joint degree
  • Change in mission
  • Change in legal status
  • Change in ownership or control, including mergers and acquisition


Institutions are encouraged to submit the Substantive Change application and fee at least six months prior to the planned implementation date of the change to ensure a spot on the review calendar and to provide adequate time for review and approval by the Commission. Structural changes typically take approximately two months longer to complete. Institutions should plan accordingly because programs cannot be started without WASC approval.

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