Consistent with the Implementing Regulations (IR) related to “Notification of Changes to Accredited Programs” (C-27 D, C-24 I, C-20 P (PDF, 1MB)) a substantive change [SC] is generally defined as a change that could alter the program's quality and/or impact a program’s adherence to the Standards of Accreditation (SoA). Each IR includes some specific examples relevant to each level. Despite these examples, it is not always clear when a program change raises to the level of a substantive change. The commission understands that programs will evolve and modify training components between periodic reviews, and that not every program modification requires reporting. Ultimately, it is up to individual programs to determine whether a change impacts quality and therefore requires a formal update to CoA.
The purpose of this guidance document is to provide additional information on when a formal substantive change is needed. While some substantive changes are clear (e.g., degree changes, new consortium partners), more minor changes may or may not require reporting. Programs are reminded that all program changes (whether reported to CoA or not) should be reflected in public materials, as appropriate.
Below is a list of common updates with guidance on when a program-level substantive change may (or may not) be needed:
Modifications to evaluation forms [All Levels]
Yes
- If the program has drastically changed the competencies/elements evaluated. This would likely also require updated PWC and DSK (doc only) tables and a detailed narrative.
No
- Minor modifications, such as adding/modifying the elements associated with PWCs and/or changing the minimum levels of achievement (provided they demonstrate appropriate level of practice [i.e., entry-level/advanced]).
Funding Changes [All levels]
Yes
- Loss of funding that may impact ability to meet the SoA and/or training aims.
No
- Loss of funding that does not impact program functioning (e.g., does not lead to loss of faculty/supervisors, student/trainee slots, etc.). This will be reported annually in the ARO.
- Increase in funding. This will be reported annually in the ARO.
Modification to Curriculum/Courses [Doctoral]
Yes
- A major curriculum revision (i.e., shift in required courses/syllabi across multiple PWCs and/or DSK).
No
- Modification to individual course syllabi across time is expected. If coursework continues to cover the same basic content, updated syllabi need not be reported as a substantive change.
Maybe
- New course/methods being used to meet DSK/PWCs. If a program is unsure if a new course/syllabus change will impact the program’s ability to meet the SoA, please contact OPCA for consultation prior to submitting a substantive change.
Rotation/Track Changes [Internship/Postdoc]
Yes
- New emphasis area/track added or removed (Note: if a track is temporarily inactive due lack of trainee placement, etc.—this need not be reported. See below).
- New (never used) rotation site added.
No
- Supervisor changes within existing site/s (unless changes impact ability to meet SoA/aims).
- Modifications to content of existing rotations/tracks that do not impact ability to meet aims/competencies.
- Existing rotation site becomes inactive/active. Often programs may have a rotation that will be active one year and inactive the next (due to intern interest and/or supervisor availability). As long as the site has been previously reviewed by CoA and resources at the site are consistent with that which has been previously reported, a substantive change is not required annually.
If you are unsure whether a program change should be submitted as a substantive change, please feel free to contact the Office of Program Consultation and Accreditation (OPCA) for guidance. Please review the relevant IR (listed above) for additional information on substantive change.
