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Academic Affairs > IBHE Approval & Review > Independent Applications

FREQUENTLY ASKED QUESTIONS:
OPERATING AND DEGREE-GRANTING AUTHORITY
FOR INDEPENDENT COLLEGES AND UNIVERSITIES

Who must seek authorization to operate?

 Any new institution or out-of-state institution coming in to Illinois for the first time, must obtain operating authorityfrom the Illinois Board of Higher Education. In addition, there are several circumstances when a previously approved institution will be required to obtain authorization to operate:

  • All Illinois institutions, including independent institutions otherwise exempt from the statutes are required to obtain authorization to operate and/or grant degrees at new locations. This provision applies to institutions that move to a new location or that plan to offer instruction at a new branch or off-campus location. (Institutions planning to establish a branch or off-campus site should obtain Policies and Procedures for the Approval of Off Campus Units of Instruction from the Board staff)
  • Institutions may need to reapply for operating and degree-granting authority and obtain new authorizations under certain circumstances, such as a change of ownership, merger, or other change in corporate structure. Institutions should consult the Board staff prior to making these changes to determine if new authorization(s) will be required.
  • Institutions that have terminated operations and subsequently wish to resume operations as degree-granting institutions are required to obtain approval prior to resuming activities.

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Who must seek degree-granting authority?

Any institution established after 1961 is required to obtain authorization to grant degrees for each new degree program it plans to offer. An institution must apply for and obtain degree-granting authority for each major and each level in which it plans to award degrees. For example, if an institution planned to offer the Bachelor of Science in Management and the Bachelor of Arts in Political Science, two separate authorizations would be required. Similarly, two separate authorizations would be required to grant the Bachelor of Arts in Political Science and the Master of Arts in Political Science.

In general, Illinois institutions established prior to 1961 are “grandfathered” and are not required to seek authorization from the Board to operate or establish new degree programs on their main campuses. However, all institutions, including those otherwise exempt from the statutes, that wish to operate and/or grant degrees in new locations in Illinois must seek approval from the Board.

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Are religious institutions required to obtain authorizations to operate and grant degrees in Illinois?

All degree-granting institutions, including religious institutions, are required to obtain authorization to operate in Illinois. If a religious institution plans to award an associate, bachelors, masters, advanced certificate, or doctoral degree in any field, it must obtain appropriate authorizations from the Board.

The rules provide a limited exemption for religious institutions that award only a “diploma” or a “certificate” and whose programs are solely devoted to religion and theology. For example, under this exemption, a religious institution could award a Certificate in Bible Studies of a Diploma in Christian Ministry without obtaining authorization.

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Are employers, employee groups, or professional organizations required to obtain authorization to provide training to employees?

 If an employer, employee group, or professional organization plans to award degrees, they are required to obtain authorizations. However, training programs conducted by corporations or other business organizations designed only for their employees are not subject to regulation by the Board. Similarly, neither labor union apprenticeships nor education and improvement programs sponsored by businesses, trade organizations, or professional organizations only for the benefit of their members are required to receive operating authority from the Board.

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Can nontraditional institutions and programs be approved?

 The criteria for approval of both operating and degree-granting authority described above can accommodate nontraditionalinstitutions, programs, and alternative delivery modalities. Institutions will be required to demonstrate that nontraditional programs meet the commonly accepted standards for similar programs by demonstrating equivalent educational outcomes.

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May institutions apply for operating and degree-granting authority at the same time?

All new institutions must obtain operating authority prior to receiving degree-granting authority. Operating authority may be granted on the basis of a well developed plan presented in an application. Before degree-granting authority is approved, however, the institution must show that its plan has been substantially implemented.

The Board may grant operating and degree-granting authority at the same time if an institution has been operating as a postsecondary institution prior to applying for degree-granting authority. In general, the Board may grant operating and degree-granting authority simultaneously under the following circumstances:

  • A previously approved or grandfathered institution plans to offer programs at a new off-campus location;
  • A previously approved or grandfathered institution is required to obtain new authorizations because of change in location, merger, or change in corporate structure;
  • An established out-of-state institution plans to offer programs in Illinois for the first time; and
  • An Illinois institution operating under the Private Business and Vocational Schools Act, as a non-degree institution, applies for authority to offer degree programs for the first time.

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What must an institution do to maintain operating and degree-granting authorization?

The Board grants authorization to operate and authorization to grant degrees on the condition that the institution maintains the standards and conditions that were presented in its application and that served as the basis for granting the authorization.

Periodically, the staff will review materials provided by each institution, including the institution’s most recent catalog, annual reports on enrollments and degrees granted, reports on faculty salaries, student financial aid and default rates. In some cases, if the staff determines that more information is needed, the institution may be asked to respond to program review questions. If the responses do not establish that the institution is in compliance with the conditions of approval, the institution may be allowed to provide a plan by which it will achieve compliance or revocation proceedings may be initiated.

In addition, the Board of Higher Education is required to investigate verified written complaints about any authorized institution.

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Can operating and degree-granting authority be revoked?

The Board has the authority to revoke the authorizations of institutions. The most common grounds for initiating the revocation process is violation of the conditions of approval, that is, failure on the part of the institution to maintain the standards and conditions that were presented in its application and that served as the basis for granting the authorization.

Other grounds for revocation include: 1) failure to comply with any of the rules adopted by the Board; 2) fraudulent conduct on the part of any person associated with the institution that results in injury or financial loss to students; and 3) failure to permit inspection of premises or records by an authorized representative of the Board.

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Are there reporting requirements for authorized institutions?

Once an institution has received approval to operate and grant degrees, it is expected to respond to annual requests from the Board for information. Institutions authorized by the Board (as well as all public institutions and “grandfathered” private colleges and universities) are expected to respond to the Board’s requests, including the following:

  • Current copy of catalog (annual submission at the beginning of the fall term)
  • Illinois Board of Higher Education Student Financial Aid (annual survey). 
  • Illinois Board of Higher Education Fall Enrollment Survey Parts 1 and 2 (annual survey)  
  • Illinois Board of Higher Education Student and Staff Race and Ethnicity Data (annual survey)
  • Integrated Postsecondary Education Data System (IPEDS, Title IV Schools) (submitted online)
  • Non-Title IV Schools must complete IPEDS completions and fall staff or the IBHE equivalent (annually)

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Does Board of Higher Education approval to operate mean the institution is accredited?

After approval by the Illinois Board of Higher Education, an institution may state that it is approved or authorized to operate and/or grant degrees in Illinois. However, an institution cannot state that it is “accredited” on the basis of these authorizations. Accreditation is granted by private, non­governmental organizations, usually comprised of “peer” educational institutions. Approval by the Board does not ensure accreditation, although criteria employed in the award of operating and degree-granting authority are very similar to those of some accrediting bodies. Most accrediting bodies require that the institution be authorized to operate by the state in which it intends to offer instruction.

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Does approval by the Board make the institution eligible for the various federal and state aid programs for higher education?

 No. Each of those programs has its own requirements for eligibility, including the Board of Higher Education. Almost without exception, however, approval by the Board of Higher Education for operating and degree-granting authority is a pre-condition for eligibility for those programs.

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Do new concentrations within a previously approved program require additional approval?

Institutions should consult with Board staff prior to adding a new concentration, option, or minor to determine whether there has been a substantial modification in the conditions of approval. If the degree title conferred upon a student does not change, additional approval generally is not required but a program change request should be submitted to allow IBHE staff to review the proposed change. The change request is reviewed to determine if the changes do not alter the original conditions of the approval granted by the Board. This allows institutions to revise approved programs to accommodate changes in the discipline or occupational requirements.

For example, if an institution offers a B.A. in Political Science and wishes to add coursework concentrating on international relations, it need not seek separate authorization for this concentration. However, the institution would be required to obtain approval to offer a B.A. in International Relations. 

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If an institution is given degree-granting authority, how long must it wait before it can begin awarding degrees?

Unless an institution was authorized to operate in Illinois or was in operation before 1961, it cannot award any earned degree until one year after it has received the authorization and approval to grant degrees from the Board.

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