Due to the July 1, 2022 change in Florida law (SB 7044), which requires public institutions in Florida, to seek new accrediting agencies, ED added two important Dear Colleague Letters on July 9, 2022.

GEN-22-10) Guidance for Institutions Seeking to Change or Add Accrediting Agencies

GEN-22-10 provides information about the various reasons for changing or adding an accrediting agency for increase of scope or quality of its programs. ED also explains the requirement of ED and the accrediting agency to both determine if the changes requested are voluntary.

“The Department has implemented this statutory requirement via 34 CFR § 600.11(a), which requires an institution to provide all materials related to its prior accreditation or preaccreditation, to provide materials demonstrating reasonable cause for changing its accrediting agency, and to receive the Department’s approval prior to switching accrediting agencies.”

FSA must review the specific circumstances of the institution, which may include the institution’s past history of compliance with the requirements of its accrediting agency, the Department, or other oversight agencies; the institution’s financial stability; and other information about the institution available to FSA. FSA may consider factors such as the following when evaluating a proposed change in accrediting agencies (or an application to have more than one institutional accrediting agency):

  1. The institution’s stated reason for the proposed change or multiple accreditations.
  2. Whether the institution is seeking to change accrediting agencies or multiple accreditations to lessen oversight or rigor, evade inquiries or sanctions, or the risk of inquiries or sanctions by its existing accrediting agency.
  3. Whether the proposed change of agencies or multiple accreditations would strengthen institutional quality.
  4. Whether the institution is seeking to change agencies or seeking multiple accreditations because the new agency and its standards are more closely aligned with the institution’s mission than the current accrediting agency.
  5. Whether the proposed change or addition involves an accrediting agency that has been subject to Department action.
  6. Whether, if ultimately approved by the Department and the accrediting agency, the institution’s membership in the accrediting agency would be voluntary, as required for recognition of the accrediting agency under 34 CFR § 602.14(a).

For several years, institutions have had to notify ED of the intent to change accrediting agencies, and a reason for the request, such as change of scope, but never had to submit supporting materials or wait for preapproval from ED.

 I hate to think how long this approval process from ED may take.

The other DCL –GEN-22-11 supersedes the 2016 requirements and describes steps needed to receive approval of the change from ED.

(GEN-22-11) Procedures for Institutions Seeking Approval of a Request to Change or Add Accrediting Agencies

An institution must take the following steps to change its primary accrediting agency or add a new accrediting agency:

  1. Prior to submitting an application to the new accrediting agency, the 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 related documentation via email to CaseTeams@ed.govwith a subject line that reads “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 agencies, or 600.11(b)(1) through (3), for multiple accrediting agencies, including:
    1. The name of the institution’s current primary accrediting agency;
    2. The status of the institution’s current recognition over the last 24 months;
    3. The new agency from which the institution is seeking accreditation; and
    4. The reason the institution is seeking the change.
  2. Prior to submitting its application to the new accrediting agency, an 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.
  3. 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.