On Sept. 26, 2022, we updated the numbered list in the third paragraph of this Dear Colleague Letter to provide additional guidance regarding the information an institution needs to submit to the School Participation Division for its initial request to change accrediting agencies before the institution submits an application to the new agency. The School Participation Division may also request additional documents or information to complete its review.
Please note that companion DCL ID GEN-22-10, dated July 19, 2022, describes the policy guidance institutions must follow to change or add an accrediting agency.
In a previous Electronic Announcement published Aug. 5, 2016, the Department reminded institutions of the requirements for seeking FSA approval of a change of primary accrediting agency, including the documentation an institution must submit to FSA in support of a request to change a primary accrediting agency. The Department also specified the procedures for submitting such documentation. This communication updates the procedures for submitting documentation to change or add an accrediting agency by requiring an institution to submit the required documentation to the Department prior to submitting an application to a new accrediting agency. Accordingly, this communication revokes and supersedes the Aug. 5, 2016, announcement. To the extent institutions have begun the process of changing or adding an accrediting agency and relied on the 2016 EA, they must immediately inform the Department consistent with the procedures described below.
Under 34 CFR § 600.11(a) and (b), respectively, the Secretary does “not recognize the accreditation or preaccreditation” of an institution “that is in the process of changing accrediting agencies” or that is accredited or preaccredited “by more than one accrediting agency” unless the institution provides the Department information demonstrating “reasonable cause” for changing or adding accrediting agencies and receives Department approval. Therefore, to ensure that an institution maintains recognition of its accreditation or preaccreditation under 34 CFR § 600.11, an institution must provide the required information and obtain the Department’s approval prior to submitting an application to a new accrediting agency. We believe that these procedures are in better alignment with the requirements of 34 CFR § 600.11, will provide clarity to institutions and afford them earlier information about Department approval, and will help protect institutions from an inadvertent loss of Title IV eligibility.
Accordingly, an institution must take the following steps to change its primary accrediting agency or add a new accrediting agency:
Prior to submitting an application to the new accrediting agency, an institution must notify FSA in writing of its intent to change its primary accrediting agency or add a new accrediting agency. With its notification, the institution must submit to FSA documentation of its current accreditation and materials demonstrating reasonable cause for changing or adding an accrediting agency. Institutions should submit this notification and required documentation via email to CaseTeams@ed.gov with a subject line “Notification Regarding Accreditation.” An institution should include with this notification the materials required by 34 CFR 600.11(a)(1), for a change of primary accrediting agency or 34 CFR 600.11(b)(1) through (3), for multiple accrediting agencies, including a cover letter that includes the following:
The name of the institution’s current primary accrediting agency and the name of the institution’s proposed new agency;
Whether the institution is seeking to change primary accrediting agencies or seeking multiple accreditation;
If the institution is seeking multiple accreditation, whether the institution plans to relinquish accreditation by its current primary accrediting agency and, if so, the timeframe for relinquishment;
The date that the institution’s current accreditation is set to expire;
The reason(s) the institution is seeking the change;
If applicable, an explanation of how the institution believes the new agency would strengthen institutional quality; and
If applicable, how the new agency’s standards are more closely aligned with the institution’s mission.
The institution must also provide supporting materials demonstrating reasonable cause for the change, including documentation to support the institution’s claim that it has reasonable cause to change accrediting agencies (or have multiple accrediting agencies).
The institution must include the following documentation from its current primary accrediting agency:
Most recent determination letter;
Documentation that the institution remains in good standing since the determination letter; and
Any substantive correspondence or other communications with the agency relating to the institution’s accreditation status, requests for information, or inquiries since the most recent determination letter.
Finally, the institution must provide any substantive correspondence or other communications with the new accrediting agency, including any substantive correspondence or other communications with the agency relating to the institution’s planned application. Note that non-substantive communications—such as routine scheduling—do not need to be provided.
Prior to submitting its application to the new accrediting agency, the institution must receive notification from FSA that the institution (a) has provided all the required documentation, (b) has demonstrated reasonable cause for changing its primary accrediting agency or for maintaining accreditation by multiple agencies, and (c) has the Department’s approval under
34 CFR 600.11.
Once the institution has received the notification from FSA described in Step 2 and has secured new accreditation (or, for nonprofit or public institutions, preaccreditation by an agency that is recognized by the Department to grant preaccreditation status), it must formally notify FSA of the new accreditation in the online electronic application (E-App) and update the “primary accreditor” indicator if it is changing. The institution should include documentation of its accreditation or preaccreditation by the new agency as part of the supporting information it provides to FSA through the E-App process. The institution must also submit a copy of the notification that it received from FSA in response to the first step of these procedures. The institution was required to receive this notification before submitting an application to the new accrediting agency.
An institution should not drop its association with its current accrediting agency until after (a) the Department has approved the institution’s request to change its primary accrediting agency or add an accrediting agency, (b) the new agency has granted accreditation to the institution, and (c) the Department has provided written notice that it acknowledges the new accrediting agency as the institution’s primary accrediting agency or the multiple accreditations. Failure to comply with these procedures may result in the institution’s accreditation status not being recognized by the Secretary and could result in a loss of Title IV eligibility.
For more information, please contact the Department at CaseTeams@ed.gov.
Chief Operating Officer
Federal Student Aid