Updated September 16, 2020

WSCUC is seeking comments by September 28 on proposed changes to three important policies — substantive change, credit hour, and teach out plans and agreements. All three have been impacted by changes in federal regulations that took effect on July 1, 2020. Click the links below for more information about each policy. Please send comments to policies [at] wscuc.org by Monday, September 28, 2020. Revised policies reflecting comments will be reviewed and considered for adoption by the Commission in November 2020.

Credit Hour Policy

The Credit Hour Policy was scheduled to be revised in 2018, but work was halted when it became apparent that credit hour would be a topic for federal negotiated rulemaking. The new regulations revise the federal definition of credit hour and require accrediting agencies only to approve an institution’s definition. WSCUC in the past has reviewed an institution’s credit hour policy, processes, and procedures. The Commission decided to continue this practice, while emphasizing measurement of student learning and academic engagement, not “seat time,” and being open to innovative approaches to understanding student work and engagement. The Credit Hour Policy has been revised to reflect the new federal definition of credit hour and to clarify how an institution’s credit hour policy and procedures will be reviewed. 

Staff contact:  Barbara Gross Davis

Teach-Out Plans and Agreements Policy

In February 2019, the Teach-Out Plans and Agreements Policy was revised and the companion Teach-Out Plans and Agreements Guide was created. With the recent changes to federal regulations, the policy and guide have been revised to: 

• Expand the circumstances that require a teach-out plan (e.g., achieving Candidacy; appearing on the Heightened Cash Monitoring list; being placed on probation or show cause);
• Establish the requirements for teach-out plans (e.g., notifying students about Closed School Discharge of Federal Loans; describing the records retention plan)
• Clarify the characteristics that make an institution suitable or unsuitable to serve as a teach-out receiving institution.

In addition to regulatory changes, the Commission added another circumstance that may trigger a teach-out plan if “an institution lacks sufficient resources to operate in accordance with the Commission’s Standards or any time it determines that a teach-out plan is appropriate to safeguard the interests of students.”

The Commission has also added its expectations that institutions submitting teach out plans will:

• Report arrangements they have made to fund expenses that commonly arise at closure (e.g., arranging transcript protection; advising services; communicating to students about their options), and
• Provide students with their academic records even if they have outstanding balances due to the institution. 

The Commission especially welcomes your comments about additional ways to assure student protections and good practices when an institution closes.  

Staff contact:  Barbara Gross Davis

Substantive Change Policy

WSCUC would like your comments on proposed revisions to the Substantive Change Policy and on a possible new category of substantive change.

The Substantive Change Manual, which provides guidance and outlines procedures for institutions navigating the substantive change process, will be updated to reflect the adopted version of the policy. 

Substantive Change Policy

The Substantive Change Policy has been revised to conform to new federal regulations, to increase transparency, and to clarify practices and protocols. 
Changes include:  

• Expanding the circumstances that trigger a substantive change (e.g., launching a direct assessment program; changing the measurement of student progress such as converting from the quarter to the semester system);
• Specifying additional requirements for structural change proposals, including student success and financial health information to be developed by staff and submitted by institutions;
• Identifying conditions that trigger additional types of reviews;
• Providing more details about substantive change procedures for each type of change: new programs and adjustments to existing programs; changes to organizational structure including mission, ownership, legal status or control; and requests for off-campus locations;
• Updating the definitions of off-campus locations.

New Category of Substantive Change

In addition to the draft policy, WSCUC also seeks comment on a possible new category of substantive change that would require Commission review. As business arrangements between institutions and service providers evolve and in some cases expand, the Commission is exploring whether there are levels or types of arrangements (often referred to as “outsourcing”) that should be treated as substantive changes because they may pose challenges to an institution’s ability to meet WSCUC Standards of Accreditation and in particular its independence. One possible framing of a definition for this new substantive change category would be: 

“New or additional outsourcing or business arrangement that would result in a significant proportion of all revenues and/or responsibilities being delegated to any single external entity or affiliated entities.” 

We welcome comments as the Commission explores these concerns and considers a possible policy revision, especially with respect to: 

• What type of outsourcing arrangements might warrant treatment as substantive changes?
• How should “significance” be understood or defined? 
• Should the Commission focus on arrangements that relate to a relationship with a single entity or affiliated entities or the overall scale of outsourcing?
• Should the Commission focus on particular terms or the duration of the outsourcing arrangements?
• And ultimately, how can WSCUC policy appropriately balance the importance of flexibility and innovation for institutions with its core responsibility to assure that standards are met and students protected? 

Staff contacts: Barbara Gross Davis and John Hausaman