Substantive Changes Reporting
Certification standards require schools that are approved to operate report certain changes to the MDHEWD either for approval prior to implementation or in order to permit the MDHEWD to fulfill its data reporting requirements. The following is a list of the major categories of change and information regarding the related procedures.
New Programs of Instruction | Revised Programs of Instruction (Substantive) | Revised Programs of Instruction (Non-Substantive)| Continuing Education | Change of Ownership | Change of School Name | Change of Location | Change of Personnel | Branch Campus | Campus Closure | Fee Schedule
Certification standards require that the initiation of all new instructional programs not previously approved by the department, or a current offering delivered in a format not previously approved by the department, must be reported to the MDHEWD at least 90 days prior to the implementation of the new program. In addition, current programs whose components including but not limited to program length, required hours, and/or content have been modified by 50 percent or more are considered new programs and must be submitted for review. Upon receipt of a complete new program proposal, the MDHEWD will provide an acknowledgement to the school that includes the official date of receipt. If the school does not receive a written response to the new program proposal within 90 days of the official date of receipt, the school may choose to offer the program until the department completes the review and identifies a substantive issue or issues that need correction.
NOTE: If the school intends to offer a new concentration in a currently approved program, and the hours of that concentration comprise at least 50% of the total program hours, the concentration is considered to be a new program. Please review the Policy for Review of Program Concentrations for additional information.
Once information is submitted through EDvera, MDHEWD staff will review the material and notify you of the decision or, in some instances, request additional information or clarification.
Certification standards require that the initiation of all substantive program changes must be reported to the MDHEWD at least 60 days prior to the implementation of the change. A substantively changed program is one whose components including, but not limited to, program length, required hours, and/or content have been modified by 20 percent or more. Upon receipt of a complete substantive program change proposal, the MDHEWD will provide an acknowledgement to the school that includes the official date of receipt. If the school does not receive a written response to the new program proposal within 60 days of the official date of receipt, the school may choose to offer the program as changed until the department completes the review and identifies a substantive issue or issues that need correction.
NOTE: If the school intends to offer a new concentration in a currently approved program and the concentration will appear on the diploma presented to the student upon graduation, the concentration is considered to be a substantive program change. Likewise, if the number of hours in the proposed concentration comprise at least 20% of the total program hours, the concentration is considered to be a substantive program change. Please review the Policy for Review of Program Concentrations for additional information.
Once this information is submitted through EDvera, MDHEWD staff will review the material and notify you of the decision or, in some instances, request additional information or clarification.
In order to ensure that we are maintaining accurate and up-to-date information about your school, it is necessary that you provide the MDHEWD with notification of program changes that do not require department approval prior to implementation. Changes in program titles, minor revisions in program length or instructional hours (less than 20 percent), and increases (or decreases) in cost are some examples of these types of revisions. The most expedient way to report this information is to notify MDHEWD. Staff will review the material and make changes within 60 days. In some instances, staff may request additional information or clarification.
NOTE: If the school intends to offer a new concentration in a currently approved program and the number of hours in the proposed concentration comprise less than 20% of the total program hours, the concentration may be considered to be a non-substantive program change. Please review the Policy for Review of Program Concentrations for additional information.
Continuing education is defined as a course, module, or program of instruction no more than twenty-five (25) contact hours in length that is not portrayed or advertised as having a primarily vocational or academic objective but is designed for personal or professional development of a student that typically results in the awarding of a certificate of attendance and may carry continuing education credit.
Certified schools may offer continuing education upon approval by the department and payment of a fee. Branch campuses and extension sites will be approved to offer the same continuing education as the main campus upon request.
In order for a certified school to add Continuing Education programs to their inventory, please complete the new program application in EDvera.
Continuing education offered by certified schools at no cost to the student, including employer-sponsored instruction or training available only to current employees, is not required to be included on the program inventory submitted to the department.
Missouri statutes state:
"A certificate of approval is nontransferable. A change in the sole proprietor of a school, a change in the majority interest of general partners of a partnership owning a school, or a change in majority of stock ownership of a school shall, for the purpose of sections 173.600 to 173.619, be deemed a transfer of ownership. Within thirty days of a transfer of ownership the new owner shall make written application to the board for a new certificate of approval."
(Section 173.606, RSMo)
Initially, the new owner must submit a one page change of ownership notification and, based on the notification, the MDHEWD will issue a 60-day temporary certificate of approval in order to permit the new owners to submit all required documents. As a minimum, the new owner must pay the most recent certification fee, post a security deposit in the minimum required amount, provide a financial statement, and submit a copy of the bill of sale, purchase agreement, or other documentation confirming the nature and provisions of the sale. Although the MDHEWD may require the new owner to submit a new application, this is determined on a case by case basis. Any additional documentation will be referenced in the notification of the issuance of the temporary certificate. There is a $100 fee for processing this change.
Program standards require that the MDHEWD must be notified at least 30 days prior to the effective date of proposed changes in the official name of a school. All changes in a school name must be approved by the MDHEWD prior to implementation. The following information is required to be submitted:
- Written confirmation, by the school, of the new official name under which the school will operate and the date the new name will become effective. This may be provided as part of a notification letter and does not require the submission of particular forms.
- Written documentation of the approval of the name change by its accrediting commission for accredited institutions. If such approval is not required, this should be noted in the notification letter.
- Confirmation of any required approval within the home state if the school is based outside the state of Missouri.
In order to maintain certification, the school must promptly provide verification the required security deposit has been revised to reflect the new school name. This can be accomplished with a rider to the existing deposit or posting of a replacement security deposit.
As guidance, the official name of a school may not be identical to the name of an existing certified school or a public or independent college or university in Missouri. In addition, if the proposed name is deemed by the MDHEWD to cause confusion of identity by members of the public, it will not be approved. There is a $100 fee for processing this change.
Certification program standards require that the MDHEWD be notified at least 30 days prior to the effective date of proposed changes in or additions to the location(s) of a school that is approved to operate. Prior approval by the MDHEWD is required. To obtain approval, the following information must be submitted:
- The school must provide written confirmation of the new official address of the school (or branch) including the effective date for the occupation of the location. Additional information about the change, including telephone and facsimile numbers, is also welcome. This information may be provided as part of a notification letter and does not require the submission of particular forms. There is a $100 fee for processing this change.
- A copy of a brief description of the new location, including a floor plan, must be submitted with the notification letter.
- A copy of revised school publications reflecting the new address and a description of the new facility.
- A new security deposit or a rider to the existing deposit reflecting the new address may be needed for a main campus relocation. This is a requirement for a performance bond. It is not required for an irrevocable letter of credit or a cash bond, as those do not include the school address.
- Written documentation of the approval of such changes by the accrediting association for accredited schools. If such approval is not required, this should be noted in the notification letter.
In order to ensure that communication between the MDHEWD and your school is efficient and effective, it is essential that you keep us informed concerning changes in your primary administrative personnel. As school, campus, and departmental directors change, please let us know using the new administrative personnel form in EDvera. Schools that are not accredited by a recognized accrediting commission should also keep the MDHEWD informed concerning any changes in instructional personnel. By submitting resume and related background information, the MDHEWD can help assure that your new faculty meet the minimum certification requirements and avoid potential problems in this area.
As an additional note for schools offering massage therapy programs leading to state licensure, please provide detailed information concerning any changes that occur relating to instructors or external clinical sites. By providing us with this information promptly we can ensure that all individuals meet the requirements of the MDHEWD and the State Board of Therapeutic Massage.
A branch campus is defined as a geographically separate and permanent instructional facility that is derived from and controlled by its main campus. A branch campus may provide complete and distinct programs and employ unique or shared instructional and administrative personnel. A branch may produce and maintain its own institutional and student records.
To obtain approval to operate a branch campus, the school must submit an initial application in EDvera.
A school that will close a Missouri location must make provisions to fulfill all financial and educational obligations to students enrolled at the time of closure. This may include completing training for all students, refunding tuition, or a combination of these methods. In order to meet certification standards, all such arrangements must be approved by the Missouri Department of Higher Education & Workforce Development (MDHEWD) prior to implementation. Schools must submit a Closing Campus Form and confirm that all students enrolled at the school are able to complete their programs of instruction, including any related examinations or evaluations. If this is not the case, the school must provide an explanation of the arrangements the school is making to comply with this certification requirement.
Upon final school closure, the school is responsible for completing and submitting enrollment and graduation data from the date of the last recertification to the date of the school's closure. Missouri-based schools will complete the MDHEWD 27-P, and schools certified to recruit in Missouri will complete the MDHEWD 04R.
Missouri statutes establish certain obligations for schools that close and failure to comply with these requirements can result in forfeiture of the school’s security deposit and/or legal action to ensure compliance.
The MDHEWD requires payment of a fee in conjunction with administrative requests including program review, changes in school ownership, name, or location, and student record verification. Click here for the Proprietary School Fee Schedule.