The Pandemic and Reporting Substantive Change

The Pandemic and Reporting Substantive Change

By: Suzette Farmer, PhD, RN

Since March of 2020, nursing faculty across the country have stepped up to ensure that nursing students continue to receive the education they need to safely enter the nursing profession despite the challenges of COVID-19. Now that nursing faculty have begun to implement new ways of teaching to meet student learning needs, they are rightly turning their attention to ACEN Policy #14 Reporting Substantive Changes. The purpose of this brief article is to provide some guidance regarding some of the questions we receive about substantive change submissions.

We will start with a reminder that the following program decisions are not substantive changes per the ACEN:

  • Changes to admission/progression policies (just make sure to keep students and constituents informed!)
  • Revisions to your end-of-program student learning outcomes
  • Resequencing existing nursing courses
  • Delaying admission cycles or temporarily decreasing enrollments

Be sure to review Policy #14 Reporting Substantive Changes to determine if you need to submit a substantive change to the ACEN. Even if your board of nursing requires you to report a change you are making, if it is not listed as a substantive change in the ACEN policy, then it does not need to be reported to the ACEN.

Another important reminder is that the ACEN still expects that all nursing students engage in clinical/practicum learning experiences during their program of study; this includes all nursing students in all programs and all program options. Per the ACEN Glossary, clinical/practicum learning experiences include direct, hands-on, planned learning activities with patients across the lifespan. While each board of nursing and/or professional practice organization (e.g., APRN certification bodies) may allow nursing education programs some flexibility in the number or type of clinical practice hours required during these unprecedented times, clinical practice (direct, hands-on) cannot be completely eliminated and/or replaced in its entirety with simulation (virtual or hands-on). Nursing education programs must ensure that students have sufficient direct clinical/practicum learning experiences throughout the program of study to meet end-of-program student learning outcomes and to prepare the student for practice at the applicable level of education and licensure status.

Now for a quick overview of the most common questions we have received since March 2020. Most of the questions we have received are related to distance education. Many nursing education programs are concerned about the abrupt implementation of distance education and the potential for continuing distance education into the foreseeable future. As you know, under the guidance provided by the U.S. Department of Education (USDE), the ACEN has not required programs to report the temporary implementation of distance education to meet student learning needs during the 2020 Spring and Fall semesters. Although it is possible that the USDE may continue this temporary flexibility into 2021, this is not a certainty, and the ACEN and nursing education programs should plan for a discontinuation of that temporary reporting flexibility. Therefore, we have developed some FAQs about distance education that should assist you in determining whether or not you will need to submit a substantive change for distance education in the future. The FAQs cannot address all possible scenarios, but they should provide enough contextual information for you to determine whether what you are doing is considered distance education by the ACEN and if it needs to be reported. Perhaps the most important FAQ is “How do I know if I need to submit a substantive change for the implementation of distance education?” This FAQ was developed to help you understand how the ACEN calculates the percentage of distance education used in your nursing program of study and whether or not it needs to be reported. The FAQs are available here: You are encouraged to review them prior to contacting the ACEN with additional questions.

One final reminder is that there are two primary purposes for the substantive change policy and process. First, the ACEN is the only nursing accrediting body that is recognized by the USDE for all program levels in nursing, and in order to maintain its status as a USDE-recognized accrediting agency, the ACEN must have and follow a substantive change policy. Second, and perhaps even more importantly, the ACEN is committed to student learning and quality nursing education through accreditation. The substantive change policy and process helps ensure that ACEN-accredited programs remain in compliance with the Accreditation Standards and Criteria. The ACEN is confident that its nursing education programs operate in “good faith” and that accredited programs will continue to report their substantive changes as soon as they identify the need to report, consistent with ACEN Policy #14 Reporting Substantive Changes.