Substantive Change FAQs

Frequently Asked Questions about Substantive Change

The substantive change policy was revised in June 2024. Is the prospectus I'm planning to submit by the July 1, 2024, deadline expected to conform to the June 2024 policy? (Added June 2024)

Yes.  As a rule, policies are effective the date they are approved by the SACSCOC Board of Trustees. Carefully review, using the redline version of the policy changes, any new or different requirements for the substantive change type you’re submitting and ensure your submission addresses the current policy requirements.

Wait -- what? Where are the FAQs I've seen here before? (Added 04/26/2024)

We’re refreshing the FAQ page content. Some of the prior questions were, well, infrequently asked now so we’re starting over and adding more timely FAQs received from institutions. Let us know what questions you’d like to see here and we’ll do our best to answer them.

Are all substantive changes now submitted through the Institutional Portal? (Added 04/26/2024)

Yes.  Submit your substantive change through the portal only; don’t mail, ship, or email.  For guidance, refer to the Documents Submitted for SACSCOC Review policy, viz., Appendix A (Electronic Submission of Documents).  An Institutional Portal User Guide is available in the portal.

I’m preparing a prospectus that requires the institution’s two most recent financial statement audits. In our state, public universities do not have annual independent financial audits; we are considered part of the system’s consolidated financial report. Can I provide the unaudited financial statements submitted to the system that are aggregated into the system’s consolidated financial report? (Added 08/02/2022, affirmed 04/26/2024)

No.  An audited/reviewed financial statement is required; unaudited is insufficient.  If your institutional financial statements are included as supplemental schedules to the opinioned system audit, that may be submitted as audit evidence.  The schedules must be a published part of the audit to be considered.  Additional institutional finance guidance, including audits, is available on the SACSCOC website; this guidance is in the context of compliance certifications and monitoring reports, but the core audit guidance applies to substantive change submissions, too.