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Substantive change process for Middle States accreditation

Cornell is required to file a Substantive Change Request with the Middle States Commission, our accrediting body, whenever changes that are substantial in nature are planned.

Substantive changes can occur at any time and are not tied to, nor an integrated part of, the decennial or periodic reports due to Middle States Commission on a regular basis.

Substantive Change Requests

Substantive Change Requests are submitted to the Middle States Commission by the President of Cornell. The Office of Institutional Research & Planning in the Division of Planning & Budget supports the unit or program by handling the interaction with the commission and working to clarify Middle States’ expectations for each specific situation. If you believe that planned changes may trigger the need for a Substantive Change Request, please contact Kristin Walker (, 607-255-2716).

Examples of Substantive Change

Examples that would most likely trigger the need for a Substantive Change Request include, but are not limited to:

  • A program planning to change a degree so that more than 50% of the content would be taught in a manner different from traditional classroom pedagogy
  • A program wanting to use a new location to offer an existing degree
  • A program entering into a contractual agreement with another organization to provide certain aspects of an existing degree

The Commission considers many different types of changes to be substantive and therefore to require commission review and approval prior to implementation of the proposed change.

Substantive change includes, but is not limited to the following:

Change in Content of Method of Delivery

This includes instruction constituting at least 50% of a degree program that represents a significant departure in terms of either the content or method of delivery from those assessed when the institution was most recently evaluated (e.g., distance learning or correspondence courses).

Contractual Agreements

Certain contractual agreements with an institution or organization not accredited by a federally recognized agency to provide any portion of a program(s) on behalf of the accredited institution are subject to commission review. This includes degree completion programs developed by third parties. In addition, certain contractual relationships with entities accredited by a federally recognized agency to provide a credit-bearing program represent substantive changes.

Non-credit Offerings that Affect Mission

Commission review typically covers programs and courses that are offered for academic credit, including credit-bearing non-degree courses and certificate programs offered at either the pre-baccalaureate or the post-baccalaureate levels. Non-credit courses and community services offered in response to constituency needs do not normally fall within the purview of this policy unless they become a major component of the institution’s activities. Nonetheless, the commission expects that established institutional procedures will ensure their quality and integrity and will ensure that these offerings do not affect negatively the institution’s ability to meet its mission.

Additional Locations

An additional location is a location, other than a branch campus, that is geographically apart from the main campus and at which the institution offers at least 50% of an educational program. Additional locations may be domestic or international. This includes corporate sites and locations for limited, rather than ongoing, provision of programs. The commission must determine if the institution has the fiscal and administrative capacity to operate the additional location.

Other Changes

Any significant new academic program or major that requires substantial financial investment or substantial reallocation of financial resources requires review.

Format of Substantive Change Requests

Substantive Change Requests are usually less that 20 pages in length, not including appendices, addressing the following critical factors:

  1. A one-page executive summary of the substantive change proposal
  2. Statement of the nature and purposes of the activities, including relevance to the current institutional mission and evidence of need for the activities
  3. Financial impact of the proposed change
  4. Legal authorization to conduct the program(s) or activity, if required

Additionally, most Substantive Change Requests also include supplemental materials:

  • Basic planning documents including the budget and other information showing adequate financing for the projected activities; provisions for needed resources (faculty, library, facilities, etc.); and analysis of the impact of the proposed change(s) on the rest of the institution
  • Intended constituency
  • Governance and administrative organization
  • Plans for the assessment of student learning outcomes
  • Records of institutional procedures followed in approving the activities
  • Copies of contractual arrangements
  • Publications announcing and/or describing the planned activities, if available