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September 29, 2026

Substantive Change: The Accreditation Risk Universities Often Underestimate

Significant program or institutional changes can carry accreditation implications that are easy to overlook. Explore why evaluating substantive change requirements early can help university leaders reduce risk and plan more effectively.

Title slide: 'Substantive Change: The Accreditation Risk Universities Often Underestimate' with the STRElis logo on a blue–pink gradient background.

Universities are constantly evolving. Programs expand, new delivery models emerge, partnerships develop, and institutions respond to changing student and workforce needs.

But some changes that appear operational or strategic may also have accreditation implications.

For health professions education leaders, identifying those implications early is critical. A significant institutional or programmatic change may require notification, review, or approval from an accreditor before implementation.

That is why substantive change should be considered during strategic planning, not after a decision has already been made.

What Is a Substantive Change in Higher Education?

A substantive change is a significant modification or expansion of an institution or program that may fall within an accreditor’s substantive change policies.

What qualifies as a substantive change depends on the institution, accreditor, program, and specific circumstances.

Depending on applicable requirements, changes involving program delivery, instructional locations, curriculum, partnerships, program scope, or expansion may warrant additional accreditation consideration.

The key question should not simply be, “Can we make this change?”

Leaders should also ask, “What accreditation implications should we consider before moving forward?”

Why Can Substantive Change Create Accreditation Risk?

The risk often comes from timing.

An institution may spend months developing an initiative before determining whether the proposed change requires accreditation notification, review, or approval. By then, budgets may be established, timelines announced, faculty assigned, or implementation underway.

If accreditation requirements affect the plan, the institution may need to revisit decisions or adjust timelines.

Evaluating substantive change earlier gives leaders more time to understand applicable requirements and incorporate them into strategic planning.

What Should Universities Consider Before Making a Significant Change?

Before a major program or institutional change moves toward implementation, leaders should consider questions such as:

  • Could this change trigger institutional or programmatic accreditation requirements?
  • Which accrediting bodies may need to be considered?
  • Could notification, review, or prior approval be required?
  • What documentation may be necessary?
  • How could accreditation timelines affect implementation?
  • Who is responsible for managing the process?

The answers will vary depending on the institution, program, accreditor, and proposed change. The important step is making accreditation review part of the planning process early enough to act on what is identified.

Frequently Asked Questions

What does substantive change mean in accreditation?

Substantive change generally refers to a significant modification or expansion of an institution or program that falls within an accreditor’s substantive change policies. Specific definitions and requirements vary by accrediting body.

Does a university need approval before making a substantive change?

It depends on the proposed change and applicable accreditation requirements. Some changes may require notification, while others may require review or approval before implementation.

Can changing a program’s delivery model be considered a substantive change?

Potentially. Changes to how a program is delivered may have accreditation implications. Institutions should evaluate the requirements of their applicable institutional and programmatic accreditors before implementation.

Explore the Full Resource

A strategic decision can quickly become an accreditation issue when substantive change requirements are identified too late.

Substantive Change: The Accreditation Risk Universities Often Underestimate explores why substantive change deserves earlier attention and what university leaders should consider when planning significant program and institutional changes.

[Download: Substantive Change: The Accreditation Risk Universities Often Underestimate]

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