MSCHE Accreditation Review and Monitoring Procedures

Accreditation Review Cy cle and Monitoring Procedures Effective Date: July 1, 2025 Contents I. Purpose II. Procedures for Self-Study Evaluation and On -Site Evaluation Visit III. Procedures for Follow-Up Reports and Visits IV. Procedures for Annual Monitoring of Institutions V. Procedures for Out of Cycle Monitoring VI. Procedures for Changes to the Accreditation Review Cycle VII. Procedures for Voluntary Surrender VIII. Definitions I. Purpose The Mid-Atlantic Region Commission on Higher Education (MARCHE), doing business as the Middle States Commission on Higher Education (MSCHE or the Commission), seeks to ensure that institutions are reevaluated and monitored on a regular and consistent basis. The purpose of these procedures is to implement the Commission’s Accreditation Review Cycle and Monitoring Policy and describe the procedures for each component of the accreditation review cycle and monitoring activities. Additional information about the range of accreditation activities conducted by the Commission including reviews or proceedings and any related reports and visits can be found in Accreditation Activities Guidelines. II. Procedures for Self-Study Evaluation and On-Site Evaluation Visit The institution will conduct a Self-Study Evaluation in accordance with the assigned accreditation review cycle. Self-study will require that the institution engage in an in-depth, comprehensive, and reflective assessment process to assess the institution’s educational quality and success in meeting its mission, as well as identify institutional priorities and opportunities for improvement and innovation. Through an inclusive process, the institution must provide evidence and document compli ance with the Commission’s standards for accreditation, requirements of affiliation, policies and procedures, and applicable federal regulatory requirements. A. The institution will begin preparing for self-study evaluation by participating in the Self- Study Institute (SSI), approximately three years prior to the On-Site Evaluation Visit. 1. SSI is a mandatory training on the self-study process. 2. The Commission will send an advance notice (save the date) of the event approximately four months prior to SSI. 3. The Commission will send a formal invitation to the institution at least 8 weeks prior to SSI. 4. The Commission will invoice the institution in accordance with the Dues and Fees Policy and Procedures. B. In accordance with the Commission’s Accreditation Liaison Officer (ALO): Roles and Responsibilities Guideline s and the Communication in the Accreditation Process and Procedures, the institution’s designated ALO is required to update and maintain accurate PROCEDURES

Accreditation Review Cycle and Mo nitoring Procedures Page 2 key contact data in the secure MSCHE portal for each authorized representative of the institution. 1. The Commission will request that the institution report the names of two individuals who will serve as Self-Study Co-Chairs in the secure MSCHE portal. 2. Self-Study Co-Chairs are designated key contacts and will receive key communications about the self-study process. 3. The institution may designate an individual as a Portal Delegate who can access the secure MSCHE portal and upload documents. 4. All designated key contacts have permission to upload documents to the secure MSCHE portal. C. Prior to the Self-Study Preparation Visit (SSPV), the Self-Study Co-Chairs will schedule a virtual meeting with the Commission staff liaison who will provide supplemental training and guidance to the institution. 1. During this virtual meeting, the institution should be prepared to discuss its approach to self-study, the intended outcomes, and the institutional priorities. 2. Also, during this meeting, the timing and logistics of the SSPV will be discussed. D. The institution will draft a Self-Study Design (SSD) using the Self-Study Design Template which is available in the Self-Study Guide available at https://www.msche.org/accreditation/self-study-guide/. 1. The SSD will communicate important information to three audiences: institutional constituencies, the Commission staff liaison, and the Team Chair. 2. The SSD will serve as a guide for the self-study process and assist the Steering Committee and Working Groups with conceptualizing and organizing relevant tasks. 3. The SSD will be reviewed by the Commission staff liaison, who will provide feedback as it is developed and revised until it is accepted. E. The institution will submit a well-developed Self-Study Design draft via email to the Commission staff liaison by 4:30 p.m. ET on the due date, which must be at least two weeks prior to the SSPV. The Commission staff liaison’s email address is available in the secure MSCHE portal. F. The institution will host the Commission staff liaison at the SSPV following SSI, well in advance of the self-study. The purpose of the SSPV is to learn more about the current status of the institution, discuss the institutional priorities identified by the institution, a nd find the most appropriate means of addressing them through the self-study process; acquaint those who will have crucial roles in the self- study with the Commission’s expectations and available resources; discuss and offer feedback on the institution’s draft SSD; and otherwise assist with the institution’s preparations for self-study and peer review. 1. The Commission staff liaison will meet with institutional constituencies including the Chief Executive Officer (CEO)/President, Accreditation Liaison Officer (ALO), Self-Study Co-chairs and steering committee, members of the governing board, faculty, staff, and students. 2. A sample agenda is provided in the

Accreditation Review Cycle and Mo nitoring Procedures Page 3 Self-Study Guide available at https://www.msche.org/accreditation/self-study- guides /. 3. The Commission staff liaison will prepare feedback, including final guidance and advice regarding the SSD. 4. If the SSD requires revision, the Commission staff liaison will provide written feedback, request a revised SSD, and establish a due date. G. The institution will submit a final SSD by the established due date, which must be accepted by the Commission staff liaison. 1. The Commission staff liaison will send a letter of acceptance to the CEO/President and copy the ALO and Self-Study Co-Chairs of the institution. 2. The Commission staff liaison will upload the final SSD and the letter of acceptance into the institutional record. H. The institution will engage in activities related to self-study evaluation in accordance with the timeline established in the SSD. I. Designated key contacts from the institution may access the Evidence Inventory in the secure MSCHE portal and begin compiling evidence to document compliance with the Commission’s standards for accreditation, requirements of affiliation, policies and procedures, and applicable federal regulatory requirements. 1. The Evidence Inventory is an organizational tool that allows an institution to collect evidence and document compliance with the Commission’s standards for accreditation, requirements of affiliation, policies and procedures, and applicable federal regulatory requirements. 2. The institution must submit accreditation materials in English. 3. The institution must not use hyperlinks to website or external documents within the written report because the Commission requires the actual documents to accurately preserve them in the review as part of the institutional record. 4. The institution will upload evidence (PDF only) under the appropriate criterion and may cross reference documents. 5. The institution will reference all evidence in the body of the report so that peer evaluators can easily locate the evidence that supports each assertion the institution offers. 6. The institution will use appropriate excerpts or isolate specific pages from existing documents rather than provide lengthy documents as long as the relevance of the evidence is explicit and properly cited in the narrative. J. The institution will compile accreditation materials in a secure and confidential m anner in accordance with applicable laws and regulations i n accordance with the Commission’s Communication in the Accreditation Process Policy and Procedures. 1. The institution will submit only those documents which are required for review or as requested by the Commission. 2. The institution will omit personally identifiable and other sensitive personal information in submissions. 3. If documents are considered pertinent and necessary for the review, the institution will redact personally identifiable information prior to submission. 4. The institution may designate proprietary business information as confidential

Accreditation Review Cycle and Mo nitoring Procedures Page 4 within its submissions that it believes would be exempt from public disclosure under applicable federal and state public records laws and regulations. K. The Commission describes the various measures it takes to safeguard confidentiality in the Communication in the Accreditation Process Policy and Procedures, Section VII Procedures for Confidentiality. L. The Commission staff will assign a team of peer evaluators in accordance with the Peer Evaluators Policy and Procedures. 1. Peer evaluators selected for Self-Study Evaluation have appropriate qualifications, relevant experience or expertise, and training to review the institution’s specific programming and met hods of delivery. 2. The Commission will take into consideration peer institutions and characteristics of peer evaluators identified by the institution in the SSD but the Commission has final discretion in the selection of the team. 3. The Commission will assign a Team Chair who is responsible for leading the team of peer evaluators, communicating with the institution and the Comm ission staff, finalizing and uploading reports to the secure MSCHE portal, and participating in the next level of accreditation decision-making. 4. The Team Chair will work with the institution to schedule the on-site evaluation visit in accordance with the assigned timeframe, approximately three years from the institution’s attendance at SSI. 5. The Commission will assign a Vice-Chair to assist the Chair with coordinating logistics, writing the team report, and mentoring new team members. 6. Each peer evaluator must complete or update an Evaluator Data Form (EDF), disclose any conflicts of interest and verify they have no conflict of interest with the specific assignment, agree to the Statement of Ethical Conduct, and complete the Antitrust Certification of Compliance, in order to serve. 7. Peer evaluators must agree to hold accreditation materials as confidential as part of the Statement of Ethical Conduct. 8. The institution will review the proposed team roster in the secure MSCHE portal to affirm that there is no conflict of interest, as defined in Commission policy and procedures, with any assigned peer evaluator within 10 calendar days. 9. The team roster is considered affirmed upon the 10th day if the institution does not respond. 10. The Commission will reassign a peer evaluator if a conflict of interest is identified in accordance with Commission policy and procedures. The Commission staff will revise the team roster until a team of peer evaluators with no known conflicts of interest is finalized. M. The Team Chair will work with the institution to schedule the on-site evaluation visit in accordance with the assigned timeframe, approximately th ree years after the institution’s attendance at SSI. 1. If there are any disputes about scheduling or the Team Chair and institution are unable to reach an agreement, the Commission staff will make the decision. 2. Once the on-site evaluation visit is scheduled, the Commission will assign the remaining team members.

Accreditation Review Cycle and Mo nitoring Procedures Page 5 3. The Commission reserves the right to reschedule visits in accordance with its policies and procedures. 4. The Commission staff will consult with the institution to reschedule, adjust, or conduct a virtual visit in the event of any circumstance that would endanger the welfare or safety of peer evaluators or institutional representatives including but not limited to travel advisories, warnings, inclement weather or natural disasters, political or civil unrest in accordance with the Commission’s Travel Policy and Procedures. N. The institution is expected to make appropriate arrangements for Comm ission representatives and communicate this information to them, including but not limited to: 1. hotel reservations; 2. any transportation arrangements; 3. work space, technology, and equipment for use by Commission representatives (both on and off-campus). O. The institution will hos t a Chair’s Preliminary Visit from the Team Chair. The purpose of the visit is to ensure that the institution is ready to host the on-site evaluation visit and to determine if the draft Self-Study Report is adequate to support the work of the team. 1. The Te am Chair will conduct the visit to the institution’s main campus by the established deadline which will be set four to six months prior to the On-Site Evaluation Visit. 2. The Team Chair will schedule this visit with the institution’s CEO/President and manage logistical details with the institution for the agenda and necessary travel arrangements. 3. The Team Chair will notify the Commission staff of the date of the visit. 4. At the conclusion of the visit, the Team Chair will submit a written summary of the feedback they provided to the institution on the draft Self-Study Report and email it to the Commission staff. 5. The Team Chair will submit a Travel and Expense Report in the secure MSCHE portal in accordance with the Commission’s Travel Policy and Procedures. P. At least one year in advance of the scheduled on-site visit, the institution will formally notify all institutional constituencies, including the general public, that the Comm ission makes available the opportunity to submit third-party comments regarding the institution’s compliance with standards for accreditation, requirements of affiliation, policies and procedures, and applicable federal regulatory requirements in accordance with the Commission’s Third-Party Comments for Institutions Under Review Policy and Procedures. Q. The Commission will require self-study site visits to all approved and active branch campuses and a representative number of additional locations in accordance with Commission policy and procedures and federal regulation 34 CFR § 602.22(d). 1. Self-study site visits are required to all designated branch campuses that are approved and active with students enrolled in courses at the branch campus. 2. Self-study site visits are required to one-third or maximum of 10 of designated domestic additional locations that are approved and active with students enrolled in courses at the location.

Accreditation Review Cycle and Mo nitoring Procedures Page 6 a. At least one domestic additional location must be visited. b.At least one prison education program additional location (PEP) must be visited if the institution has any. 3. Self-study site visits are required to one-third or maximum of 10 of designated international additional locations that are approved and active with students enrolled in courses at the location. At least one international additional location must be visited. 4. The Commission does not require self-study site visits to other instructional sites (OIS). 5. The purpose of these visits is to verify information about the locations and ensure ongoing compliance for locations. 6. For this reason, the location must be approved and active with students enrolled in courses at the location. 7. If a location is not active at the time of the review, it does not need to be visited. R. At least 9 months prior to the On-Site Evaluation visit, the institution will review all locations in the secure MSCHE portal to verify the location type, location status, and enrollment at the location. 1. The Commission staff must have the most accurate and up- to -date information to determine which locations are approved and active and will be visited. 2. The institution must submit a substantive change request to close locations and remove them from the institution’s scope of accreditation in accordance with the Substantive Change Policy, Procedures, and Guidelines and federal regulation 34 CFR § 602.22. S. To ensure that a representative sample of required visits take place to meet federal regulation, the Commission staff have final discretion in selecting which additional locations will be visited. 1. The Commission staff will notify the institution, the Team Chair, and the Vice- Chair at least 6 months prior to the On-Sit Evaluation Visit of all of the branch campuses and additional locations that must be visited. 2. The institution must not cancel any of these planned visits if staff have determined that they must be visited. 3. The Commission may, in its sole discretion or based upon changes in federal regulation, determine that a different number of additional locations is representative and appropriate for a particular institution in special circumstances. T. The Team Chair or a designated member of the team will conduct self-study site visits. If the Team Chair needs an additional team member to accompany him or her, due to extraordinary circumstances at the specific location, approval must be sought from the Commission through the Commission staff liaison. U. The institution will upload the Self-Study Report and all supporting evidence to the secure MSCHE portal by 4:30 p.m. ET on the due date. The due date is no later than 10 weeks prior to the On-Site Evaluation Visit. V. Peer evaluators will review the Self-Study Report and all supporting evidence prior to the scheduled On-Site Evaluation Visit.

Accreditation Review Cycle and Mo nitoring Procedures Page 7 W. If third-party comments were received in accordance with Commission policy and procedures, the Commission will forward them to the team for review in accordance with Third-Party Comments for Institutions Under Review Policy and Procedures. X. Peer evaluators may request additional evidence that is required to clarify information or verify compliance prior to arriving on-site. Y. The institution will host an On-Site Evaluation Visit by peer evaluators. During the visit, peer evaluators will clarify the information provided in the Self-Study Report and verify evidence submitted by the institution by interviewing institutional constituencies (including key administrators, governing board members, faculty, staff, students, and representatives of related entities, if applicable). Z. Peer evaluators may request additional evidence while they are on-site as required to clarify information or verify compliance. AA. The institution will upload all additional evidence that has been requested by peer evaluators to the secure MSCHE portal by 4:30 p.m. ET on the due date. The institution must upload all additional evidence within seven days following the On-Site Evaluation Visit to ensure that all levels of the accreditation decision-making process review the same information. BB. The tea m of peer evaluators will develop a draft Team Report that is concise and summarizes the team’s findings and provides the institution with a detailed written report that clearly identifies any areas of non- compliance with the Comm ission’s standard s for accreditation, requirements of affiliation, policies and procedures, and applicable federal regulatory requirements in accordance with federal regulation 34 CFR § 602.18(b)(5). 1. The team of peer evaluators will use the Team Report Template available on the Commission’s website. 2. If the team is unable to verify compliance or has confirmed non-compliance, the Team Report must identify the specific standards for accreditation, requirem ents of affiliation, policies and procedures, and applicable federal regulatory requirements, and must issue requirements describing actions the institution must take to demonstrate compliance. 3. The Team Report does not include the action that the team will propose to the committee and the Commission. CC. The Team Chair will deliver an oral e xit report conv eying the team’s findings. 1. The institution’s CEO/President will invite all institutional constituencies (including key administrators, governing board members, faculty, staff, students, and representatives of related entities, if applicable) to hear the oral exit report. Media are not considered an institutional constituency. 2. The Team Chair will deliver the oral exit report without taking questions from institutional constituencies. 3. The oral exit report must not differ materially from the draft Team Report and should be equally candid, honest, clear, and forthright. 4. Under no circumstances will the oral exit report be recorded.

Accreditation Review Cycle and Mo nitoring Procedures Page 8 5. Under no circumstances does the Team Chair or any other team member share with the institution the action that the team will propose for consideration by the Committee and the Commission. 6. Similarly, the institution will not publicize the team’s findings o r imply that any particular action will be taken by the Commission. The team’s findings represent only the first step in the multi-level accreditation decision-making process. DD. The Team Chair will share the draft Team Report with the institution’s CEO/Pres ident via email by 4:30 p.m. ET on the due date. EE. The institution will review the draft team report and notify the Team Chair only of any factual errors by 4:30 p.m. ET on the due date. The institution will not use this opportunity to attempt to influence the content of the Team Report or to suggest that the team alter the findings or the tone of the report. FF. The Team Chair will review the institution’s corrections of fact, finalize the Team Report, and upload it to the secure MSCHE portal by 4:30 p.m. ET on the due date. GG. The institution may access the final Team Report in the secure MSCHE portal. HH. The institution will respond to the final Team Report in writing through an Institutional Response. The Institutional Response is in the form of a letter addressed to the President of the Middle States Commission on Higher Education. It is typically between one and five pages in length. 1. The institution will develop an Institutional Response that is brief, thoughtful, and analytical. It is an opportunity for the institution to react to the team’s findings and to acknowledge the team members for their time and expertise. 2. The institution may concur with the team’s findings or honestly and openly present significant differences in perceptions, interpretation, or major findings. 3. The institution will not attempt to influence the content or tone of the Team Report or suggest that the team alter the findings. 4. The institution may include additional evidence or focused documents to support its statement. 5. The institution will upload the Institutional Response directly to the secure MSCHE within established deadlines. 6. The Commission must receive the Institutional Response by 4:30 p.m. ET on the due date. II. The Team Chair will carefully review and consider the Institutional Response and then prepare the Team Chair’s Confidential Brief using the template available on the Commission’s website. 1. The brief will summarize the Team Report and include major findings; it cannot substantively alter the content or tone of the Team Report. 2. The Team Chair will consider the evidence provided in the institutional response which may alter the proposed accreditation action. 3. The brief also will propose an accreditation action in accordance with the Commission’s Accreditation Actions Policy and Procedures. 4. The proposed accreditation action is forwarded for consideration by the

Accreditation Review Cycle and Mo nitoring Procedures Page 9 committee, the next level of accreditation decision-making. 5. The Team Chair does not share the proposed accreditation action with the institution. 6. The Team Chair will upload the brief directly to the secure MSCHE portal. 7. The brief is not made available to the institution. JJ. The Team Chair will participate in the next level of accreditation decision-making at the committee meeting. The Team Chair will receive m ore information from the Commission staff about this role. KK. The Commission, through its multi-level accreditation decision-making process, will conduct a holistic analysis of all of the accreditation materials and any other appropriate and substantiated information available to it. LL. The Commission will take an accreditation action in accordance with its Accreditation Actions Policy and Procedures. MM. The Commission will provide notification of accreditation actions in accordance with Communication in the Accreditation Process Policy and Procedures and federal regulation 34 CFR § 602.26. III. Procedures for Follow-Up Reports and Visits Based on the outcome of a review or accreditation activity, the Comm ission may direct an institution to submit a follow-up report and may direct a visit in accordance with the Commission’s Accreditation Actions Policy and Procedures. The accreditation action will specify the due date and the standards for accreditation, requirem ents of affiliation, policies and procedures, or applicable federal regulatory requirements that must be addressed. The institution will submit written follow-up report(s) pursuant to the instructions provided in Follow-Up Reports and Visits Procedures and Follow-Up Reports Guidelines. IV. Procedures for Annual Monitoring of Institutions As part of the accreditation review cycle, the Commission conducts annual monitoring to assess institutional strengths and stability or identify any concerns with an institution's ongoing compliance with the standards for accreditation, requirements of affiliation, policies and procedures, and applicable federal regulatory requirements in accordance with federal regulation 34 CFR § 602.19. A. Annual Institutional Update (AIU) The Annual Institutional Update (AIU) is one of the regular and systematic approaches used by the Commission to monitor key data indicators including but not limited to enrollm ent, financial information, and measures of student achievement in accordance with federal regulation 34 CFR § 602.19. The Commission may alter its annual data monitoring process based on changes to federal regulatory requirements. 1. The indicators and metrics are published in the Annual Institutional Update (AIU) Indicators and Metrics posted on the Commission’s website. 2. The Executive Committee of the Commission will review the indicators and metrics on a regular basis to ensure rigor, validity, and reliability.

Accreditation Review Cycle and Mo nitoring Procedures Page 10 3. The Executive Committee of the Commission will identify metrics that indicate whether further review is required. 4. The Commission staff will notify institutions about the timeline and process for the upcoming AIU and provide instructions about how to complete it. 5. The Commission may download data from existing data sources including but not limited to the Integrated Postsecondary Education Data System (IPEDS) for institutions that participate in federal student financial aid programs. 6. The institution is responsible for notifying federal data sources and correcting data if any inaccuracies or discrepancies are identified during this process. 7. The Commission will publish the AIU Dashboard on its website which is publicly available. 8. The Commission may collect supplemental information as necessary. 9. The institution will complete the AIU on an annual basis pursuant to the timeline and instructions provided by staff. 10. The Commission staff may ask the institution to provide additional information based on the analysis of key indicators in accordance with Out of Cycle Monitoring Procedures. 11. The Commission staff will notify institutions about where they fall within the established indicators and metrics. 12. Effective beginning in 2023, Commission representatives will use the AIU indicators and metrics as one source of information that informs decision-making. 13. Institutions should regularly assess their student achievement, annual enrollment, financial health, and federal financial responsibilities against the indicators and metrics. B. Collection and Maintenance of Institutional Data The Commission will regularly collect and maintain data about institutions which are used for monitoring purposes and to convey important information to the public. Institutional data includes directory information displayed on the online Institution Directory. It also includes the institution’s accreditation phase, accreditation status, accreditation history, and scope of accreditation which is published online in the Statement of Accreditation Status (SAS) as defined in Section VIII. 1. The institution must ensure the accuracy of institutional data held by the Commission and notify the Commission of changes that need to be made, within five calendar days of any change. 2. The ALO will regularly re view the institution’s online Institution Directory and any contact or directory information in the secure MSCHE portal and ensure the information is accurate. a. The institution may modify certain (editable) data fields in the secure MSCHE portal including but not limited to key contacts or the student achievement website and will do so within five calendar days of any change. b. However, some data fields, such as the name of the institution, cannot be modified by the institution in the secure MSCHE portal. c. In these situations, the Commission will require that the institution submit an institution change request in the secure MSCHE portal. i. The institution will click the edit tool which will launch online institution change request form in the secure MSCHE porta l. ii. The institution must complete the form, upload a form al change request on institutional letterhead, and upload any additional supporting evidence to

Accreditation Review Cycle and Mo nitoring Procedures Page 11 demonstrate the need for the request. iii. The Commission staff will inform the institution about the process for making a particular kind of change and may request additional supporting evidence. iv. The institution must provide any requested additional supporting evidence according to instructions provided by the Commission staff. 3. The ALO will regularly revi ew the SAS and any data related to the institution’s scope of accreditation in the secure MSCHE portal and ensure that information is accurate. a. The institution may update certain data fields in the portal which are editable at any time, including adding other instructional sites (OIS) or updating OIS name, address, or headcount data in the secure MSCHE portal and will do so within five calendar days of any change. b. The ALO will regularly review data related to all locations (branch campus, additional location, OIS) in the secure MSCHE portal and ensure the address information is accurate. c. The Commission requires review and approval prior to implementation for some changes because they substantively change the institution’s scope of accreditation in accordance with Substantive Change Policy, Procedures, and Guidelines, Complex Substantive Change Procedures, and federal regulation 34 CFR § 602.22. d. The institution must submit the appropriate substantive change request form in accordance with Commission policy and procedures. 4. On a quarterly basis, the Commission will send reminders to institutions to review information in the secure MSCHE Portal and ensure it is accurate. 5. On an annual basis, the Commission will require institutions to upload required documents including but not limited to annual audited financial statements, m anagement letters, bond rating letters, and Single Audits. a. The documents are used in the accreditation decision-making process and in the analysis of the AIU. b. The documents are stored in the institutional record. c. The institution must submit draft audited financial statements if the final documents are not ready at the time of collection. d. The institution must submit the most recent fiscal year audited financial statements within six months o f the end of the institution’s fiscal year at the latest. e. The Commission will request that the institution submit any outstanding documents through formal or informal requests for information. V. Procedures for Out of Cycle Monitoring The Commission will conduct monitoring activities outside of regularly scheduled accreditation activities when it obtains information that raises concerns about a member institution’s ongoing compliance with the Commission’s standards for accreditation, requirements of affiliat ion, policies and procedures, and applicable federal regulatory requirements. The procedures for out of cycle monitoring reviews can be found in Out of Cycle Monitoring Procedures. VI. Procedures for Changes to the Accreditation Review Cycle

Accreditation Review Cycle and Mo nitoring Procedures Page 12 The accreditation review cycle is continuous and does not expire until accreditation ceases. The institution’s assigned cycle cannot be altered except under extraordinary circumstances, following non-compliance, to comply with federal regulation, or in accordance with Commission policy and procedures. Only the Commission may alter the accreditation review cycle. A. When impacted by extraordinary circumstances, the institution may request a delay in the due date of a required accreditation activity within th e institution’s accreditation review cycle. 1. Extraordinary circumstances include but are not limited to situations beyond the institution’s control or any situation which may put Commission representatives at risk (natural disaster or other catastrophic event, civil or political unrest in the institution’s geographic location). 2. The institution will email the designated Commission staff liaison to request a delay and must demonstrate that extraordinary circumstances exist. 3. The Commission staff, at their discretion, will decide if extraordinary circumstances exist. 4. The Commission staff will take an action in accordance with the Commission’s Accreditation Actions Policy and Procedures, to grant or reject the request for a delay. The action will be noted in the institution’s accreditation action history. 5. If a delay is granted, the Commission staff will specify the revised due date not to exceed one year from the original date. 6. If it is still not possible to conduct an appropriate review at the conclusion of the one-year delay, the Commission staff may grant another one-year delay, at their discretion. 7. Any delay in the due date will not alter the institution’s accreditation review cycle and the institution must continue to adhere to the schedule set for the assigned cohort. B. For all complex substantive changes, the Commission will, at the time of the substantive change action, direct the institution to conduct a new comprehensive evaluation in accordance with and the Complex Substantive Change Procedures and federal regulation 34 CFR § 602.22(h). The Commission will reassign the institution to a new accreditation cycle and will indicate the year of the next evaluation in the accreditation action. C. The Commission will not move an accredited institution from accredited to candidate for accreditation status (pre-accreditation) unless, following the withdrawal of accreditation, the institution applies for and is awarded candidate for accreditation status under the new application in accordance with federal regulation 34 CFR § 602.23(f)(1)(iv). Institutions that participated in the Title IV, HEA programs before the withdrawal of accreditation are subject to the requirements of 34 CFR § 600.11(c). VII. Procedures for Volunta ry Surrender The institution may voluntarily surrender its candidate for accreditation status (pre-accreditation) or accreditation status at any time in accordance with the Commission’s Voluntary Surrender Procedures. VIII. Definitions The following definitions are used and/or inferred in this policy and/or procedures:

Accreditation Review Cycle and Mo nitoring Procedures Page 13 A. Accreditation activities. All activities (including but not limited to reviews, reports, visits) conducted by Commission representatives related to the institution’s accreditation phase, accreditation status, or scope of accreditation occurring throughout the accreditation review cycle and during monitoring activities for a member (accredited or candidate) or applicant institution. B. Accreditation materials. All documentation related to accreditation activities including but not limited to the institution’s written reports to the Commission, subm itted evidence, team reports, institutional responses, confidential briefs, complaints or third-party comments, action notifications, substantive change requests, transcripts of proceedings, team rosters, and any correspondence of record. Accreditation materials are treated as confidential by Commission representatives, become part of the institutional record, and are retained in accordance with the Commission’s Maintenance and Retention of Commission Records Policy and Procedures. C. Additional location. A domestic or international physical facility or location that is geographically separate from the main campus and within the same ownership structure of the institution, at which the institution offers at least 50 percent of the requirements of an educational program. An additional location participates in Title IV program s only through the certification of the main campus. A Federal, State, or local penitentiary, prison, jail, reformatory, work farm, juvenile justice facility, or other similar correctional institution is considered to be an additional location even if a student receives instruction primarily through distance education or correspondence courses at that location. The Commission utilizes the federal definition of additional location in 34 CFR § 600.2 and will conform its designation to match the Secretary of Education’s if it learns its designations diverge in accordance with federal regulation 34 CFR § 602.24(f)(1-3). D. Annual Institutional Update (AIU). One of the approaches used by the Commission to regularly and systematically monitor key data indicators including but not limited to enrollment, financial information, and measures of student achievement in accordance with federal regulation 34 CFR § 602.19. E. Branch campus. A domestic or international physical facility or location of an institution that is geographically apart from the main campus of the institution, and within the sam e ownership structure of the institution, and that is also (1) approved by the Secretary as a branch campus, and (2) independent from the main campus. The branch campus is considered independent of the main campus if it is permanent in nature; offers credit bearing and/or Title IV eligible courses in educational programs leading to a degree, certificate, or other recognized educational credential; has its own faculty and administrative or supervisory organization; and has its own budgetary and hiring authority. The Commission utilizes the federal definition of branch campus in 34 CFR § 600.2 and will conform its designation to match the Secretary of Education’s if it learns its designations diverge in accordance with federal regulation 34 CFR § 602.24(f)(1-3). F. Location status. A status assigned to each additional location and branch campus by the Commission for substantive change, billing purposes, and to determine which locations will be visited during the self-study evaluation (self-study site visits).

Accreditation Review Cycle and Mo nitoring Procedures Page 14 G. Main campus. The primary physical facility at which the institution offers eligible programs, within the same ownership structure of the institution, and certified as the main campus by the Department and the Comm ission. The institution’s primary administration, classroom buildings, residence halls, library, and other buildings are housed within the same reasonably contiguous geographic area or parcel of land of the main campus. For an institution that only offers distance education programs, the main campus is where its administrative offices are located. H. Other instructional site (OIS).Any off-campus site where the institution is operating and where it offers one or more credit-bearing or Title IV eligible courses when 49 percent or less of an educational program can be completed there. An institution must report any location as OIS in the secure MSCHE portal whenever the location does not meet the definition of a main campus, branch campus, or additional location. This would include but is not limited to dual enrollment courses at high schools, schools where students complete practica or other structured, institution-supervised learning experiences for teacher preparation, or clinical sites or hospitals so long as 49 percent or less of an educational program can be completed at the site. OIS is not defined in federal regulation and does not require approval through substantive change prior to implementation. I. Peer evaluator. An individual who is selected and assigned to an accreditation activity by the Commission staff. This individual is part of the multi-level accreditation decision- making process and will participate in the proposal of an accreditation action. Peer evaluator is not intended to include a Commissioner serving in an official Comm issioner capacity on a committee or the Commission. Peer evaluator is not intended to include an assistant or any other observer of an accreditation activity. J. Planned institutional closure. An institutional closure that is submitted to the Commission through the substantive change process more than six months prior to the date of closure allowing enough time to implement an orderly closure and a comprehensive teach-out plan and applicable teach-out agreements. The date of closure is defined as the point in time at which the institution has ceased academic/instructional operations and has no students actively enrolled in its degree programs (Requirement of Affiliation 2). The institution can choose to dissolve their corporate legal entity under applicable state law at a later date, but the Commission’s focus is o n ensuring the institution winds down academic/instructional operations in an orderly manner and implements a comprehensive teach-out plan (and teach-out agreements if applicable) making arrangements for students to transfer to another institution or complete their education. See also the definition for unplanned institutional closure. I. Scope of accreditation. The institution’s accreditation status covers a defined scope of educational offerings, including but not limited to credential levels, delivery methods, and locations (additional locations, branch campuses, and other instructional sites) which have been reviewed by the Commission during accreditation activities. A ny changes proposed by a member institution that are considered substantive must be reviewed through the substantive change review process prior to implementation in order to be included within the institution’s scope of accreditation by the Comm ission.

Accreditation Review Cycle and Mo nitoring Procedures Page 15 J. Statement of Accreditation Status (SAS). The Commission’s official public statement ab out each institution’s current accreditation status. The SAS is a downloadable, printable statement with information about the institution, including but not limited to the institution’s accreditation phase, accreditation status, scope of accreditation, an d a history of the accreditation actions taken by Commission. K. Teach-out. A process during which an institution or institutional location that provides 100 percent of at least one program engages in an orderly closure or when, following the closure of an institution or location, another institution provides an opportunity for the students of the closed institution to complete their program, regardless of their academic progress at the time of closure. (federal definition in 34 CFR § 600.2, slightly modified to remove the word “program”). L. Teach-out agreement. A written agreement between two or more institutions that provides for the equitable treatment of students and a reasonable opportunity for students to complete their program of study if an institution, or an institutional location that provides one hundred percent of at least one program offered, ceases to operate before all enrolled students have completed their program of study. (federal definition in 34 CFR §600.3) M. Teach-out plan. A written plan developed by the institution that provides for the equitable treatment of students if an institution, or an institutional location, ceases to operate before all students have completed their program of study, and may include, if required by th e institution’s accrediting agency, a teach -out agreement between institutions. (federal definition in 34 CFR §600.3) N. Unplanned institutional closur e. The Commission deems any institutional closure that is submitted six months or less from the date of closure to be unplanned and disorderly because there is insufficient time to implement a comprehensive teach-out plan and applicable teach-out agreements. Unplanned institutional closures are not permitted to be processed through the substantive change review process. The date of closure is the point in time at which the institution has ceased academic/instructional operations and has no students actively enrolled in its degree programs (Requirement of Affiliation 2). See also the definition for planned institutional closure. Number: P2.1 Version: 2025- 07 -01 (substantive revisio n), 2025- 10 -27 (editorial change). Effective Date: July 1, 2025 Previously Issued: N/A Approved: Approved by Cabinet, June 13, 202 5 Initial Approval Date: July 31, 2018 (Approved by Cabinet) Revisions: October 1, 2020 (technical amendment); Oct ober 1, 2022 (technical amendment); July 1, 2023 (remove MPPR); Septe m be r 1, 2024 (remove Recommendations Responses); July 1, 20 25 (substantive revision), October 27, 2025 (maximum visits to additional locations). Federal Regulations: §602.18 (e) Ensuring consisten cy in decision-making; §602.19 Monitoring and reevaluation; §6 02.22 Substantive change; 602.23(g) Operating procedures all agen cies must have; Related Documents: Accreditation Actions Policy and Procedures; Accreditation Activities Guidelines; Comm unication in the Accreditation Process Policy and Procedures; Comp lex Substantive Change Procedures; Dues and Fees Policy and Procedu res; Follow-Up Reports Guidelines; Follow-Up Reports an d Visits Procedures; Out of Cycle Monitoring Procedures; Peer Evaluators Policy an d Procedures; Substantive Change Policy, Procedures, and Guidelines; Teach-Out Plans and Agreements P olicy and Procedures; Travel Policy and Procedures; Voluntary Surren der Procedures;