Every seven-to-ten years, each U. S. college or university undergoes an institution-wide review and evaluation by its respective regional accreditor (one of six). Maintaining accreditation is a requirement to remain eligible for Federal financial aid assistance and to meet many state-based regulations. These are massive undertakings involving extensive internal institutional research that delve into every aspect of college and university operations. Depending on the peer-reviewed outcomes of the report and ensuing evaluation, interim reports to the accreditor may be required.

Although there are six regional accreditors, the scope of accreditation has common threads and generally follows the paths in which each institution addresses standards that comprise:

• Mission,
• Assessment, planning and evaluation,
• Governance and organizational structure,
• Academics
• Students, student support and engagement,
• Learning, teaching and research,
• Resources,
• Effectiveness, and
• Ethics, integrity, and transparency.

Substantive Change
In the last thirty years, accreditors have focused more efforts and resources to hold colleges and universities accountable when the institutions undertake “substantive change (s).” Although far from uniform, most accreditors have delineated issues of substantive change to include, but not limited to:

• Changes in mission, legal status, and ownership,
• Adding degree programs at a different level than formerly approved,
• Establishing additional campuses,
• Closing programs or branch sites, and
• Acquiring other institutions.

The issue of substantive change will take on a new, and more significant, dimension due to COVID-19. One of the almost unanimous issues that falls under substantive change is the change in programs and courses that represent “significant departure” from the offerings evaluated in the previous accreditation cycle; namely, major changes in content or in delivery methods. Widespread, necessary, and rapid implementation of distance/online learning modalities will come under intense scrutiny as part of substantive change requests or as part of periodic reaccreditation efforts. Indeed, COVID-19 prompted all regional accreditors and the U. S. Department of Education to grant emergency approvals for such modalities, but with terminal dates. In the same context of “significant departure,” the pandemic prompted some colleges and universities to close programs, yet another consequence that will trigger substantive change alerts. The review, evaluation and implementation routes pursued to justify substantive changes in usual circumstances will come under greater scrutiny.

Faculty, Quality and Distance Learning
The institutional research profession has developed intricate measures to benchmark the adequacy of faculty resources needed to ensure institutional and academic quality. While there is ample consideration for university mission and size that encourages heterogeneity, straying too far from accepted benchmarks of full-time faculty employed, or full-time equivalents, will invite more questions and scrutiny. COVID-19 consequences like reductions in full-time faculty, increased use of distance/asynchronous learning platforms and increased utilization of more part-time faculty will force universities to strengthen quality assurance and prompt accreditors to monitor university assertions more intently.

Learning Outcomes and Assessment
Every regional accreditor requires that each college or university undertake research-based planning and evaluation. Learning outcomes are key to academic quality as is the expectation that the university is meeting and exceeding academic goals. The institution must generally demonstrate that academic assessment outcomes are built into the academic improvement cycle. Institutions will be required to demonstrate that academic assessment efforts during the COVID-19 pandemic were not diminished or negatively impacted. An important prerequisite of these learning assessments will be thorough analysis of learning platforms, availability of appropriate technologies and the adequacy of trained staff to support new learning platforms. Of course, if the evidence points otherwise, institutions will likely be asked to address the outcomes.

Adequacy of Financial Resources
Other than the necessity to implement widespread distance/online learning, no other topic has garnered more attention than COVID-19’s impact on higher education’s adequacy and stability of financial resources. Diminished use or total closure of residence halls, reductions in auxiliary revenue, scaled down athletic activities and the resulting loss of related revenue, and the ensuing requisite refunds have caused much angst across all higher education providers. Most of the regional U. S. accreditors have standards that address the impact of fluctuating factors on revenue, enrollment, and budget planning. It is not difficult to draw the line connecting this volatility to financial stability. A consequence one might expect is that accreditors will likely seek confirmation that universities are undertaking comprehensive risk management that ensures short-term economic health and long-term sustainability.

Planning and Contingencies
Finally, COVID-19 has highlighted the precariousness of strategic planning. Universities and colleges proudly shine the light on their objectives, goals, and priorities. In turn, these serve as benchmarks of success, but are mostly contingent on deliberate planning and a high degree of
certainty. At present, it appears that only one of the six regional accreditors in the U. S. requires that the institution demonstrate an ability to respond to “financial emergencies and unforeseen circumstances.” It would seem reasonable that given the COVID-19 experience, higher education institutions may be required to document such an ability, show evidence of greater contingency planning and more scrutiny and evaluation of the related institutional responses. While scenario planning seems to have been used to weigh short-term options, this device may gain new standing as a longer-term tool to assist in reducing uncertainty of outcomes.

In conclusion, COVID-19 has wrought significant personal loss to millions of families and has wrecked havoc on economies, countries, industries, professions and organizations. It will be many years before we understand the true impact of this pandemic. We will gain insight into the impact on higher education from several sources; but, measuring COVID-19’s impact on college and university accreditation will be an important signal as to higher education’s future pathways.