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FAQ Questions and Answers

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April 5, 2005 "We are about to submit a proposal for an AS in Physical Education Studies with demonstration of transferability using Appendix G. Are we correct that System needs completion of the 'SUNY Transfer Course Equivalency Table' in Appendix G for only articulation between two SUNY units? If we're articulating with two private institutions, we assume we use our long-standing general articulation agreements as evidence of transfer. We assume too that the requirement of a letter from the chief academic officer does not apply to private institutions."
KVA: It is our expectation that proposals for AA and AS degree programs submitted under the Handbook for the Submission of Undergraduate Academic Program Proposals will contain completed course equivalency tables with at least two baccalaureate programs and letters from the respective chief academic officers attesting to the articulation and asserting acceptance of the completed Course Equivalency Table. This includes articulation with SUNY, CUNY and independent baccalaureate institutions.

Our latest guidelines for the submission of undergraduate program proposals, known by users as the 2003 Handbook, include not only proposal section 5.F. (requiring a list of transfer campuses/programs for AA/AS proposals) but also completion of Appendix G (the course equivalency table) for at least two of the baccalaureate programs identified. This emphasis on documentation of transfer is not new. (In fact, it was a focal point in the first State University undergraduate proposal submission guidelines in 1972 and remains in all subsequent versions.)

Background:  The State University of New York has approved several University-wide transfer policies, the most recent being "Reaffirmation and Extension of Transfer and Articulation Policy," which incorporates all previous policy provisions and is outlined in Memorandum to Presidents, Vol. 90 No. 13. This commitment is driven by the statutory mission of the University articulated in Chapter 552, Laws of 1985, excerpted here:

"...the state university shall exercise care to develop and maintain a balance of its human and physical resources that...promotes appropriate program articulation between its state-operated institutions and its community colleges as well as encourages regional networks and cooperative relationships with other educational and cultural institutions..."

Thus our workaday review of undergraduate proposals includes consistency with the mission of the University as reaffirmed in Rethinking SUNY and the mandates of the State University Board of Trustees.

January 24, 2005 "What should we do with a curricular change that is not sufficiently major to require filing a formal revision with System Administration? We don't agree here on what is considered major, especially if the changes involve fewer than 15 credit hours. No one wants to put in the work if unnecessary."
KVA: You are asking when to submit a revision of an existing program to the University for approval and SED for re-registration, and more specifically for an interpretation of "major" in §52.1(h) of the Regulations of the Commissioner of Education:

"New registration shall be required for any existing curriculum in which major changes are made that affect its title, focus, design, requirements for completion, or mode of delivery."

SED provides a list of types of changes and indicates whether they qualify as major and therefore need to be approved (i.e., re-registered) before instituted: see Appendix Q, pages 63-64, of the Handbook for the Submission of Undergraduate Academic Program Proposals.

Of the listed types of changes, the one that most frequently occasions confusion is the first, according to which approval is necessary for "a change of 15 or more required (non-elective) credits in an undergraduate degree program (e.g., adding a track or option)." It may seem that this implies approval is not required for any change of fewer than 15 credits, but such is not the case. It is entirely possible to have a major change of fewer than 15 credit hours. This is particularly (but not exclusively) true of programs leading to professional licensure, which frequently must comply with statutory requirements governing the content even of individual courses. Indeed, minor changes that require information-only reporting to SUNY and SED tend to fall into the category of curriculum updates (e.g., shifting material within or among courses, addition or deletion of courses to stay current with the discipline) so long as the totality of changes apply to fewer than 15 credits of required coursework. Here is what we advise for proposed changes if they are not apparently major (according to the SED list) and involve fewer than 15 credit hours:

1) Check with your Academic Vice President's office on the last time a revision for the particular program was submitted. (This information is available on the hard copy of the SED Inventory of Registered Programs; see the IRP column listing "1st reg/last reg".) If you have made incremental changes to the program since the last registration date that are in their totality major (even if the current change is minor), submit a revision using our Appendix E form. Your cover letter might state that the revision is being submitted to update the registration of the program and that it represents several incremental changes over a period of time.

2) If you have any doubt whether the proposed change is major, submit the revision using our Appendix E.

November 9, 2004 "For our MSW program we need to file a new licensure form now that the legislature has finalized the requirements. SED indicates that a SUNY unit should complete the appropriate form for SUNY in the process of re-licensing the program. We have not found such a form. What should we be using?"
KVA: You are referring to SED's communication of July 2004 to Chief Executive Officers entitled Regulations of the Commissioner of Education Relating to Professional Education and Licensure in Social Work.

While this inquiry relates directly to those State University campuses with graduate social work programs (Albany, Binghamton, UB, Stony Brook, and Brockport with Nazareth), it applies generally to any curricular change necessitated by amended statute and corresponding amended State regulation. In recent years campuses have invested considerable energy in revising curricula to comply with changes in licensure and certification, including for example, CPA accountancy, dental hygiene, licensure-qualifying psychology, classroom teacher preparation, now social work, and in the near future, mental health counseling.

The resulting program "revisions" require the approval (by the University) and the registration (by SED) of "new" programs, usually bearing new titles and requiring special licensure designations on the Inventory of Registered Programs. This is the case with the amended regulations for social work, which eliminate the title "certified social work" and create two new professions: Licensed Master Social Worker (LMSW) and Licensed Clinical Social Worker. SED's instructions to campuses advise public institutions to use the "appropriate SUNY/CUNY proposal submission forms" and submit the proposals through the respective central administrations.

To submit a proposal for the revision of an existing MSW program, the appropriate SUNY form is the Guideline for Revision of Existing Academic Programs found in Appendix E of the 2003 Handbook, in addition to the required SED "Request to Register" form. (Appendix E works for undergraduate as well as graduate program changes.) For a new MSW program the campus should follow the SUNY guidelines for the Submission of Graduate Program Proposals, currently outlined in Memorandum to Presidents, 94-1.

For each MSW program revision we need two copies of the SUNY revision document and two copies of the SED form, including course syllabi as necessary. Where the information in the SUNY revision document duplicates information contained in the SED form, we welcome artful references to specific pages in the SED form. Remember to submit separate requests for each MSW program revision; combined or multiple-award or multiple-award-institution programs (e.g., BA/MSW, MBA/MSW, MSW/JD) require separate submissions. Use the SED Online Inventory of Registered Programs to ensure coverage of all MSW program combinations and permutations.

October 19, 2004 "SUNY has a web page: Academic Programs Information System (APIS) http://www.suny.edu/apis/ that provides enrollment and graduation information for all programs within the SUNY system. I find it a helpful tool in assessing enrollment and graduation trends when considering new program proposals and in assessing program health in my role as advisor to a number of SUNY academic programs. However, the APIS webpage has not been updated in the last few years. Has this useful site been abandoned?"
KVA: Thanks to this inquiry from a now-retired professor, the website has been updated to include Fall 2003 enrollment and 2002-03 degrees awarded and will be maintained routinely for our purposes.

This site is mentioned in the 2003 Handbook for the Submission of Undergraduate Program Proposals under the "Impact" section, where we expect campuses to have researched the effect of a proposed curriculum on similar and related programs in the University System. (You would have done this anyway as a result of on-going academic strategic planning and program assessment practices.)

Here are some suggestions about using the site. If searching using HEGIS numbers, keep in mind that similar and related programs may have different disciplinary code numbers. For example, inherently interdisciplinary programs such as 'environmental' baccalaureate curricula can be found under the Biological Sciences or the Architecture & Environmental Design areas. Programs showing no enrollment may be new or the enrollment may have been reported elsewhere. For instance, enrollment in BS/MS combined offerings is often reported against either the BS or the MS. Finally, APIS is a dynamic resource of hundreds of historic program records. You may find that your programs are not listed with 100 percent  precision; the enrollment and degrees-awarded data, however, represent the figures reported to us by campuses.

If you have questions about using the APIS site or the information listed, you may of course write me.

September 14, 2004 "This is a question about off-campus instruction. What does the SED memo mean by a 'complete program'?"
KVA: You are referring to SED's communication No. 80-16, Memorandum to Chief Executive Officers, Implementation of New Regulations on Off-Campus Instruction, dated September 19, 1980.

This SED policy memorandum describes the process for the implementation of then new Part 54 of the Regulations of the Commissioner of Education. The purpose of these Regulations is to assure quality standards for all "degree-credit instruction in New York" and to integrate off-campus instruction into the Regents' "system of comprehensive, statewide planning for postsecondary education."

The Regulations describe the categories of off-campus instructional activity (e.g., site, center, branch campus). CEO 80-16 summarizes the categories by level of activity, including curricula offered at the extension locations.

For example, an extension center is defined as:

"No complete programs AND more than 15 courses for credit OR more than 350 course registrations for credit in any academic year."

This means no curriculum, leading to a degree or a certificate, can be completed entirely at the remote location. The longstanding SED interpretation of this Regulation requires that for every program toward which courses are offered at the remote location a course or courses will be taken physically at the main campus. Or put another way, SED requires the identification of a course or courses - for each degree or certificate program - that will never be offered at the remote location. Course work offered by distance education from the main campus is judged as available at the extension location and therefore cannot be counted as taken physically at the home campus.

If a complete program - degree or certificate - can be taken at an extension location, it is determined to be a branch campus of the institution, and will require authorization by the Board of Trustees, the Board of Regents and the Governor in the form of a master plan amendment, as well as notification to and review by the Middle States Commission on Higher Education.

We encourage campuses to consult us at an early stage on plans involving off-campus programs. For more on extension activity, please also see the Ask Kate column in the April 23, 2001 Program Review & Planning Update.

August 10, 2004 "We will soon be filing a number of changes to our teacher certification programs. Do we use the Guideline at Appendix E of the Handbook regardless of level? Do we send a copy concurrently to SED? Do you want to see these in draft before we submit formally?"
KVA: Please use Appendix E, Guideline for the Revision of Existing Academic Program, of the 2003 Handbook. While the 2003 Handbook covers undergraduate program submissions, this outline works for the revision of graduate programs as well and will be included in the upcoming guidelines for submitting graduate program proposals.

In addition to the information requested in Appendix E, please also include for each program the following information:

1. The current teaching certificate and level.

2. Description of how the proposed change is consistent with the standards for registering teacher certification programs in §52.21(b) of the Commissioner's Regulations.

3. Description of how the proposed change is consistent with the standards for the accreditation of the program by your chosen national accreditor, NCATE or TEAC.

4. Description of how the proposed change is consistent with SUNY's New Vision in Teacher Education, implementation guidelines contained in Memorandum to Presidents, Vol. 03 No. 2.

There is no need to copy the State Education Department on your proposed teacher education revision. This practice creates confusion and delays as SED will not review a proposal that does not have the University's approval.

No thank you, we do not need to see the document in draft form. We trust you to use Appendix E, supplemented by the information above, for each program and to be forthcoming and succinct.

July 13, 2004 "Will you tell us about the Bachelor of Professional Studies or BPS degree? Is it widely used and recognized? How is it used? Are we authorized to offer it?"
KVA: The Bachelor of Professional Studies (and its counterparts at the master's and doctoral level) was created by the Board of Regents in the early seventies in reaction to a flood of requests for SED to create specialized degrees, such as the Bachelor of Industrial Design and the Bachelor of Planning. It is meant to be a professionally oriented award and thus the liberal arts and sciences requirement is one quarter of the minimum total credits for a bachelor's degree (25% of 120), as is the case with related specialized degrees, e.g., the BBA, BE, or BTech.

You will note in the Rules of the Board of Regents §3.50(a)(2) that the BPS degree is automatically available to institutions authorized to award the BA or BS, which your campus is not at the present time. Authorization to award the BPS for an extant or a new program would require approval by the SUNY Board of Trustees and the Board of Regents as a degree authorization, not as a Master Plan amendment. Degree authorization is a relatively straightforward and apolitical process.

The BPS is offered at 26 institutions statewide, including 4 SUNY and 1 CUNY campuses, for 73 programs. The MPS is offered at 26 institutions statewide including 11 SUNY and 1 CUNY, for 84 programs. The DPS is offered at one independent institution for two programs. These awards appear to be more prevalent downstate.

May 24, 2004 "We are prepared to submit proposals for a Teacher Education Transfer program leading to an AA and an AS. Our courses have now been reviewed in the Template course reconciliation process and we're pleased with the outcome. Our faculty have the revised guidelines and are ready to plug in the courses. Will you give us the inside scoop on the process and how to get it right? (I attended a workshop where you gave helpful hints and cautionary advice. I remember them yet!)"
KVA: There is good news to report on this important project, which has been a challenge for many of us: the University's first Template program has been registered by SED.

In the April column (Program Review Update, vol. 04 no. 12) we made available the Revised Guidelines for the Submission of SUNY Teacher Education Transfer Template Programs. We also reported on the changes to the guidelines negotiated with SED and advised that proposals include course work aligned precisely with that available on the TETT website.

Herkimer County Community College's proposal for Liberal Arts & Sciences: Childhood Education (Teacher Education Transfer) was approved by this office in April and recently registered. That proposal - and all future successful proposals - includes these features:

  • Template curricular requirements: General Education Core (33 credits), Major or Concentration (12-18 credits), and Pedagogical Core (6 credits);
  • the curriculum (and appended semester outline) reflects precisely the course work reconciled and approved in the Template project;
  • the curriculum maximizes the double counting of approved SUNY Gen Ed courses with TETT-vetted content courses to create a lean and efficient course of study with no "wasted" course work;
    (In other words, avoid courses that are not Gen Ed approved, not applicable toward the major/concentration, and will not transfer as professional course work. Try to keep the total credits in the Associate degree as low as possible.)
  • majors/concentrations are directly related to the State's learning standards and are specifically identified (e.g., biology, chemistry) rather than generically described (i.e., science);
  • majors/concentrations should include the necessary cognate courses, that is, chemistry course work for the biology concentration, mathematics course work for the chemistry major; economics and geography course work for the history/social studies major.

(Cognate work may be listed in the major or under "Other Requirements and Electives".)

With the consent of Herkimer County Community College, we are also making available on the web site HCCC's curriculum outlines by major/concentration. These model curricula are for your information and use as illustrative (registered) TETT curricula. Thanks to HCCC.

May 4, 2004 "When do we have to get a proposal to you if we want to admit students this September? (Please don't say we're already too late.)"
KVA: Proposals for the revision of an existing program should allow a minimum 30 days for our review and at least the same for the registration review by the State Education Department. For proposals for a new program please allow a minimum 60 days for the University's review and the same for SED's.

Please note that the 30-day and 60-day time periods are not guarantees for approval. They are targets within which we seek to complete initial review of a proposal. The result of this initial review may either be approval or a request for additional necessary documentation. These targets assume uncomplicated proposals (no master plan amendment or degree authorization is required) and compelling and complete documentation.

In workshops I advise campuses to file program proposals a semester in advance of when they want to advertise the availability of the offering. You are welcome to submit a proposal now for a September 2004 start but we cannot guarantee its registration and you will have no time to market the program.

Recently we have experienced an SED-imposed deadline of May 7, 2004 for the revision of school leadership programs. Ideally we should have had the campus proposals in perfect form by April 7 to assure smooth processing and meeting the SED schedule without unnecessary disruption in our office. In the future, should SED issue other discipline-specific proposal deadlines, we will advise campuses sufficiently in advance of our corresponding deadline.
 
April 14, 2004 "We are preparing a teacher education transfer proposal according to the Template. We are following the guidelines in the August 2003 column. We also have access to the preliminary TETT website for advisement. Do we have to wait for the official launch of the TETT website to develop a final proposal? We see other campuses submitting proposals and are anxious about being able to advertise the availability of the transfer program."
KVA: The "2004 Guidelines for the Submission of SUNY Teacher Education Template Programs" are now available and attached to this week's Program Review Update. This updated version of the Guidelines incorporates amendments recently negotiated with the State Education Department and therefore displace the August 2003 document you mention.

The SUNY Teacher Education Transfer Template website is important not only for advisement but also as guidance for campus academic professionals responsible for developing teacher education transfer AA/AS proposals. You will note that the website includes, by two-year college, a list and course descriptions of all TETT reconciled and approved courses, both pedagogical core and major/concentration courses. We would expect, therefore, that the coursework in a proposal for an AA in Liberal Arts & Sciences: Childhood Education (Teacher Education Transfer) will correspond precisely with that listed on the SUNY TETT website. Proposals that include courses that are not known to transfer to participating SUNY baccalaureate campuses with teacher education will be turned back for modification. This is in the best interest of the transferring student and all campuses. The TETT website is being updated daily. Campuses should feel free to use it as a basis for developing a proposal for a Template Transfer program.

With regard to advertising a Teacher Education Transfer curriculum, campuses are of course aware that the program must be registered by the State Education Department "before the institution may publicize its availability or recruit or enroll students in the curriculum," Commissioner's Regulations 52.1(h). We have developed, with the cooperation of the State Education Department, a description of the SUNY TETT for use by campuses as catalog copy. The text is included in the revised guidelines and recommended for use by campuses as their programs are approved by University and registered by the State Education Department.

March 15, 2004 "We are preparing a proposal for a health technology AAS leading to licensure by the NYS Dept of Health. Are we still able to use Appendix B to submit the proposal, since it states at the top that we should 'Use this application for any new program that does not lead to licensure or preliminary or advanced study in one of the areas licensed by the State Education Department?' We just wanted to make sure that it was licensure with State Ed that was the concern and not another state agency. As a point of curiosity, which form would we use in that case?"
KVA: Please use the Program Proposal Form at Appendix B in the 2003 Handbook. The Guidelines - we've discovered with your careful read - contain a small infelicity here, which we will soon correct.

The Program Proposal Form applies to all proposed undergraduate programs at all levels (certificate, associate, baccalaureate) for all State University campuses (State-operated, community colleges, statutory). Proposals for programs leading to NYS licensure or certification (e.g., accounting by SED; radiologic technology by DOH) must also satisfy pertinent Regulations and use any forms specified by the licensing agency. Program proposals leading to NYS certification as a classroom teacher, for example, must include SED's "Application Form for Registration of a Teacher Education Program" in addition to Appendix B of the 2003 Handbook.

February 23, 2004 "We want to add a concentration to a Ph.D. program. Do we have to get approval from Albany?"
 KVA: Yes. Commissioner's Regulation §52.1(h) applies to all levels of instruction: "New registration shall be required for any existing curriculum in which major changes are made that affect its title, focus, design, requirements for completion, or mode of delivery."

If you want to advertise or admit students to a concentration, we need to seek its registration. For the revision of a doctoral program, follow Appendix E, Guideline for Revision of Existing Academic Program, in the 2003 Handbook.

Please be sure that the concentration represents a focused field or specialization within the parent Ph.D. program rather than a new field or major option that would be better represented as a new Ph.D.

January 26, 2004 "What policies do we need to keep in mind in developing the academic calendar? I'm relatively new to New York State and have inherited a considerable file of guidance documents, some of which are quite dated and appear to contradict one another."
KVA: This topic differs from the usual matters covered in the Ask Kate column as it is not strictly related to the review of academic program proposals and some of the policies mentioned here apply to the state-operated campuses and are advisory only for the community and statutory colleges.

The foundation of calendar-related policies and regulations is the Carnegie unit, which we covered in the October 22 and November 5, 2002 columns. I recommend you keep the following in mind, listed here from the smallest component regulation to the trumps-all regulation and SED policy:

Note: MP 81-3 allows for a semester of less than 15 weeks of instruction, inclusive of examination periods, which is in violation of - and overruled by - the following Regulation.

  • Educational requirements for awards and loans, Regulations of the Commissioner, §145-2.1: "For State financial aid programs, except for supplemental tuition assistance program (STAP), full-time study, where required by law, shall mean enrollment for at least 12 semester hours for a semester of not less than 15 weeks, inclusive of examination periods;..." (All campuses.)
     
  • SED's CEO policy memorandum 91-07 on Academic and Student Financial Assistance Regulations: "In order to certify students for State awards, an institution must operate on a calendar that conforms to Section 145-2.1(a) of the Commissioner's Regulations...An institution that operates on a calendar in which a semester, inclusive of examination periods, consists of fewer than 15 weeks (or in which a quarter/trimester consist of fewer than 10 weeks) is not in compliance with this regulation. In such cases, a college that certifies students for State financial assistance can be held liable for repayment of the funds which its students received." (All campuses.)
December 9, 2003 "What are you expecting from campuses on the elimination of programs leading to provisional certification? Should we treat them as eliminations and notify you formally? What's the most efficient way to do this? We have over 30 such programs."
KVA: You are asking if you have to file program discontinuances, per State University Memorandum to Presidents Vol. 83 No. 11, for certain teacher education curricula that are scheduled to expire in February 2004.

This question pertains to campuses with classroom teaching programs leading to provisional and provisional/permanent New York State teacher certification. (This includes jointly registered programs or "multiple" programs involving two campuses.) On February 2, 2004, the registration of all classroom teaching programs under the "old" Regulations will expire; SED will no longer issue provisional certificates in elementary and secondary education. (An exception for specified military personnel may be in the making, we understand.) These programs will subsequently be removed from the State Education Department's Inventory of Registered Programs.

For the most part, classroom teaching curricula leading to "prov" and "prov/perm" certificates were replaced and registered beginning in 2000 under the "new" Regulations, §52.21(b), leading to "initial" and "initial/professional" certificates. Technically, therefore, your campus replaced Elementary Education PreK-6 B.S. (leading to provisional certification) with Childhood Education 1-6 B.S. and with Early Childhood Education B-2 B.S. (each leading to initial certification). As you did not eliminate the discipline or the capacity from the College's mission and roster of approved offerings, we will not treat the expiration of programs leading to provisional or provisional/permanent certification as discontinuances. You need not file with us or SED program discontinuances for these curricula.

Please note that programs registered as leading to prov/perm certificates will also expire. If you have prov/perm programs in which you currently have students in a separate "perm" component and they will not complete their programs by February 1, please call or email me. We may need to register separate curricula leading to permanent only to cover your matriculants.

In January you will receive a hardcopy of SED's Inventory of Registered Programs for the State University campuses. This year the routine cover memoranda (SED's and ours) will draw your attention to the imminent expiration of programs under the old Regulations. You may want to review the current IRP for prov and prov/perm classroom teaching programs to be assured that any enrollees will have completed their courses of study this semester. (Hardcopy of the 2002 IRP should be in the office of your chief academic officer; it's also available on-line at: http://www.nysed.gov/heds/irpsl1.html.) The scheduled expirations do not affect programs leading to school administrators, district administrators, or pupil personnel providers.

November 10, 2003 "On page 14 of the new undergraduate guidelines, the 2003 Handbook, one of the conditions for a waiver of the external review for a new baccalaureate program is 'specific degree authorization.' Evidently it is not a Master Plan amendment. What is it?"
KVA: New baccalaureate programs require a review by two external experts. One of the conditions for a waiver of this requirement is affirmation by the campus that it is authorized to award the particular degree award type specified. The item to be checked is:

The campus has specific degree authorization at the baccalaureate level in the program discipline; i.e., approval does not require degree authorization or Master Plan Amendment.

By "specific degree authorization" we mean the authority to offer the particular award type, that is, B.A., B.Arch., B.B.A., B.E., etc., as listed in the Rules of the Board of Regents, §3.50 Registered Degrees, at: http://www.highered.nysed.gov/ocue/rules.htm. For example, you have a registered program in Art leading to a B.A. To award the B.F.A. we would need not only to approve the new (or revised) program but also to seek degree authorization from the SUNY Board of Trustees and the Board of Regents for the campus to award the B.F.A.

This policy is set forth in statute, Education Law §355, Powers and duties of trustees, item 2, which states:

the state university trustees are further authorized and empowered...to grant all degrees diplomas and certificates which heretofore have been granted or have been authorized to be granted upon completion of course of study in any state-operated institution...and also such other degrees as the regents may hereafter specifically authorize them to grant...

Degree authorization is not a Master Plan Amendment, which is functionally a change in mission for the institution. For you to award a B.F.A. in Art would not represent a change in mission as you have the planning authorization in the discipline at the award level, just not the specific degree authorization.

We will be sure that future guidelines are clear on this point. Thank you.

October 21, 2003 "We understand that we need to file with you and the State the revisions to our graduate program. However, we find nothing in the 1994 procedures that addresses changes or revisions to existing graduate programs. We're at a loss on how to proceed. It seems that if we have to file revisions before we implement them the process could be more transparent."
KVA: You are right, of course. The 1994 Procedures for the Submission of Graduate Academic Program Proposals focus on the process for new graduate programs, in particular doctoral programs, and do not contain advice on filing changes to extant graduate offerings.

The procedures for submitting a revision are the same for curricula at all degree levels and can be found in Appendix E of the new undergraduate program guidelines, the 2003 Handbook for the Submission of Undergraduate Academic Program Proposal.

Follow the Appendix E Guideline, state the Guideline item and answer it succinctly but in a forthcoming manner. Remember to use this process for minor revisions to existing programs, not for grand changes (e.g., revising a Ph.D. program to include a new option that amounts essentially to a new Ph.D.). If you have any questions, consult your assigned reviewer here or write me.

Be assured the new graduate guidelines will include the revision guideline. We hope to issue updated graduate guidelines by in the new year.

September 29, 2003 "We did look to see if we could find guidance in materials from your office, but didn't find any. Are we supposed to notify the Provost's office of the addition of minors? I know they don't require SED approval, but we need to know if your office wishes to be notified about them and/or must approve them. (The minor precipitating this inquiry is an interdisciplinary minor in classical studies that could be combined with any one of several majors on campus.)"
KVA: I am happy to report that minors are a local campus matter. We do not receive, review or approve the introduction or the dissolution of minors, nor does the State Education Department.

Our experience has been that a minor is optional and is based on student interest and faculty expertise. It is an approved (by the campus) course sequence within an area of study providing a degree of specialization within that area, a specialty within a discipline, or a specialty integrating several disciplines. Minors are often recorded on transcripts, consist of 3 to 6 courses with a balance of introductory and advanced course work, most of which is in addition to the major. Minors are not advised in areas leading to New York State licensure or certification, such as, engineering, nursing, medicine, and special education.

In our every day program review work we see successful minors used convincingly as evidence of sustained demand, thus providing the basis for the necessary market documentation for a new major in the (former) minor discipline, in this case Classical Studies.

September 8, 2003 "This is a question about the 'Guidelines for Submission of SUNY Teacher Education Template Programs' that were recently attached to the Ask Kate column. The curriculum we have in mind for transfer to elementary education programs uses existing course work from our Early Childhood AAS program and includes the 6 credit hours required per the Guidelines and two additional professional courses. The Guidelines seem to emphasize 'acceptable course work' so we are wondering if our proposal for 12 credits in the pedagogical core will pass muster. Will it?"
KVA: In a word, no. The proposing campus will be advised to align its proposed teacher education transfer program with the Template requirements and/or to seek a jointly registered program(s) with cooperating institutions.

The Template, as you doubtless know by now, is a prescribed course of study to be universally recognized and accepted across the University to enable transfer to State University classroom teaching programs leading to NYS certification (i.e., birth to grade 2, grades 1-6, grades 7-12). Its design is intended to maximize general education and discipline content, minimize credit loss in transfer, and optimize graduation in just two more years of fulltime study in the baccalaureate certification program. Ideally, use of the Template will eliminate incompatibilities between the Associate transfer degree and the baccalaureate degree leading to initial certification. The ideal Associate degree will be lean and efficient in its design, just as the baccalaureate must be.

Why are we doing this? In the big picture we are honoring the University's statutory mission "...to develop and maintain a balance of its human and physical resources that promotes appropriate program articulation between its state-operated institutions and its community colleges as well as encourages regional networks and cooperative arrangements with other educational and cultural institutions..." (Chapter 552, Laws of 1985)

We are also implementing Chancellor King's 2001 policy, A New Vision in Teacher Education, which commits the University to address the State's need for excellent teachers by developing a model two-year curriculum to be accepted by senior campuses as well as by negotiating jointly registered teacher education programs. In addition, we are implementing the Intra-SUNY Transfer Action Plan which is aimed at improving transfer and articulation between programs particularly to enhance retention and graduation rates.

August 25, 2003 "We have noticed articles advertising 'fast-track' programs being offered by SUNY institutions. What does this mean? Is any special paperwork or notification to System necessary? (We're almost afraid to ask but are more concerned we might be negatively affected by the marketing tactic.) Your advice to the collective would be helpful."
KVA: To your Albany colleagues "fast track" implies a time-shortened or accelerated curriculum in which alternative methods are used for awarding credit, arranging the calendar, or calculating the credit-contact hour relationship. An accelerated format requires separate registration by SED, preceded of course by approval by the University. Often a format change results in a change in the financial aid eligibility for students in the program (e.g., from day to evening, from full-time to part-time). Let me remind you of §52.1(h) of the Regulations of the Commissioner of Education:

New registration shall be required for any existing curriculum in which major changes are made that affect its title, focus, design, requirements for completion, or mode of delivery.

SED defines accelerated format as "The program is offered in an accelerated curricular pattern which provides for early completion."

To advertise or offer a fast-track or accelerated course of study the college would submit a revision of the existing program requesting the addition of or change to a new format. (Use Appendix E in the 2003 Handbook at the Program Review web page cited below.) Provide a description of the difference in the delivery (e.g., from traditional day to accelerated format), including sequencing of courses. This might be illustrated by a semester-by-semester curriculum outline which demonstrates that pre- and co-requisites are met. Identify existing and/or new faculty who will teach in the program. (The issues here are the rank/status and qualifications of faculty in the alternative format.) Provide a description of any issues related to student financial aid. Describe how student services (e.g., advisement, book store, computer services, tutoring, etc.) will be provided.

Revisions of existing programs involving format changes are announced in the Academic Program Developments report attached monthly to this Update. If you are concerned about competition from a neighboring State University campus advertising a fast-track or accelerated program, I suggest you contact its chief academic officer and inquire about the format and delivery of the program, or write me.

For more on the credit/contact hour relationship and the classical Carnegie definition of the semester credit hour, see the October 22, 2002 Ask Kate.

August 12, 2003 "Will you update us on the status of the teacher education templates and guidelines? We would like to have these programs in place for the fall semester. Thank you."
KVA: As one of the associate degree-granting colleges interested in participating in the SUNY Teacher Education Template project, you should have received a July 30th letter from Associate Provosts Gehring and Clarke advising you on the final course correlation taking place for Foundations of Education courses. To summarize this phase, two-year colleges with Foundations courses that proved not to transfer widely within the System have been asked to modify their courses and re-submit them for re-review by the undergraduate teacher education institutions. Two-year colleges with broad acceptance already of submitted Foundations of Education courses and disciplinary sequences (for major/concentrations) should be prepared to submit proposals in accordance with our new guidelines.

Attached here for your use or information are the Guidelines for the Submission of SUNY Teacher Education Template Programs (filename: TETpolicyguidance.rtf). You will note that the process and the required elements represent an abbreviated procedure. It is very important that prior to submitting any proposal, associate degree-granting institutions must have a Foundations of Education course and disciplinary major courses broadly accepted by participating teacher education institutions (see the July 30th Gehring/Clarke letter referenced above).

 

July 25, 2003 "Our 6-year time limit for completion of a master's degree program has been in place for longer than any of us can remember. No one knows the origins or the goals. Can you shed any light on this for us? Is a time limit or a 6 year time limit a SUNY or SED requirement? Would you care to take a stab at the intended objective for having such a rule? Do you know of any SUNY units that have no time-limits or different ones?"
KVA: The statute of limitations or time limit on completion of a graduate degree is a faculty or campus decision. There is no State University or SED requirement on the number of years to degree completion or a requirement that time limits be established.

I consulted colleagues at the State Education Department and at three State University campuses, two doctoral and one comprehensive college with a significant graduate effort. We agreed that the statute of limitations on graduate programs, particularly for the master's, is an academic tradition to ensure that the degree represents a corporate body of knowledge at the time of its receipt. At one doctoral campus the terms are 6 years for a master's, 8 years for a doctorate, and 5 years for a graduate certificate; at the other, the terms are 4 years for the master's, 7 for the doctorate, and none specified for the advanced certificate. At the comprehensive college, the term for a master's degree and advanced certificate is 6 years.

These limits are evidently default criteria as faculty at the surveyed campuses regularly grant extensions provided course work meets contemporary standards and students demonstrate that they are still current with the material. (For example, how current is the required "Introduction to Computing" course taken x years ago?) I am told that this has been a topic of discussion for the last several months on the Council of Graduate Schools Website which perhaps inspired your inquiry or perhaps you might consult.

July 8, 2003 "Greetings from the Pearl of [county], Kate. I hope you are doing well. We are beginning to experience something like summer weather. Spirits are visibly lifted.

"I write with a purpose. A question actually. We have direction from your office to complete an SED form, 'Request to Register a Licensure-Qualifying Program in Public Accountancy'. At the bottom of the form, we are instructed to send it to:

"Professional Education Review Program
State Education Department
Cultural Education Center, Room 3055
Albany, New York 12230

"So, my question: Is the entire program proposal, along with these completed forms, to be sent to SED at the above address? Or do we simply send the completed forms to SED, with full proposal to be sent by System Administration (what happened to 'Central Central') after SUNY review? Or does everything - forms, charts, proposal - get sent to you folks and you haul it to SED?

"I live in fear, Kate, of not knowing the right magic. Help me out."

KVA: You know the answer: Everything goes through this office before going to SED. This applies to all campuses - state-supported, statutory, community colleges - for all programs at all degree levels in all disciplines.

Why? The responsibility of the Provost of the University for all academic programs is delegated to us by the Chancellor based on the powers and duties of the State University Board of Trustees as outlined in New York State Education Law §355 and §6303. The more earthly reason is for us to know fully the courses of study at each campus as the collective makes the State University of New York and therefore the System.

From time to time the State Education Department issues procedures and forgets to add the proviso for CUNY and SUNY campuses to go through their respective central offices. This then makes work for our SED colleagues and us and causes unnecessary delays in processing because SED will not review a program matter that does not have the University's approval.

June 16, 2003 "Last week's Update from your office announced new undergraduate program guidelines, '2003 Handbook for the Submission of Undergraduate Academic Program Proposals.' I arranged the 2001 guidelines in a (hard copy) notebook with tabs to my favorite 'Ask Kate' columns and you've come up with new guidelines! Why new guidelines? Will this make more work for campuses?"
KVA: The Memorandum to Presidents, Vol. 03 No. 4, which covers the 2003 Handbook states the reasons for the new guidelines, "to improve communication and to facilitate campus and System processes." Let me explain.

You know from the periodic distribution of the "Accountability Matrix" in the Program Review Update that we hold ourselves to specific timelines for program submissions. We have done this since the 2001 guidelines were issued. In order to process within the established timelines the volume of the program requests - new curricula, revisions, deactivations, reactivations, discontinuances, extension activity - we need proposals to be succinct, forthcoming "one-read" documents. The 2003 Handbook clarifies definitions and expectations at a number of points. For example, the criteria for expedited review have been clarified; the result of this particular qualification, we believe, will be that only appropriate and selected documents are moved ahead in the review queue.

Just as important, the 2003 Handbook makes explicit the integration of two University initiatives--Assessment and Teacher Education--in the review of program proposals. We have for some time been incorporating, for example, the standards of A New Vision in Teacher Education into our review of new teacher certification programs and curricular revisions. The 2003 Handbook informs campuses up front that this is the case.

How will you be affected by the change in guidelines? First, all program matters begun under the 2001 procedures remain governed by that process. If there is any impact, it may mean our needing additional information on a particular item the previous guidelines neglected to emphasize. Second, you will be better served by forthright information requests and clarity of expectations, e.g., documentation of articulation of associate degree transfer programs. Finally, and with some apology, you may have to assemble a revised hard copy Handbook but we don't recommend it. Why not make the 2003 Handbook at the Program Review Web Site a favorite?

May 27, 2003 "Do you have advice to offer on submitting revisions of teacher education programs en masse? We understand that we must file with SED -through you - any change in a registered program leading to teacher certification."
KVA: You are correct that SED requires that "any change in the courses required for a program as registered" leading to NYS teacher certification requires re-registration of the program (before implementation), and that such changes are filed with us en route to SED. Please note that our review includes compliance with A New Vision in Teacher Education, the SUNY teacher preparation policy. It is possible that a routine revision under the Commissioner's Regulations may not be approvable by the standards articulated in A New Vision.

This advice updates and supersedes previous suggestions offered in this column.

For each program you are revising, provide the following:

1. Registered program title, award, certification title/type, SED program code number.

2. Brief rationale for the change.

3. Description of how the proposed change is consistent with the Commissioner's Regulations, §52.21(b) for classroom teaching.

4. Description of how the proposed change is consistent with the standards of your chosen national accrediting body.

5. Description of how the program change is consistent with the University's New Vision in Teacher Education policy.

6. Effective date of the proposed change.

I suggest that the campus develop a uniform model and method for submitting such changes and that it be used consistently across all departments. The cover letter from the president/provost should mention any time-sensitive issues, including revisions as a result of the implementation of the New Vision policy. Be succinct but forthcoming, not stingy.

It is not helpful to send proposed revisions directly to the State Education Department or to copy our colleagues in the SED Office of College & University Evaluation.

http://www.nysed.gov/heds/irpsl1.html for title, award, certificate, and number.

http://www.highered.nysed.gov/ocue/programregistrationprocedures.htm for registration of programs preparing classroom teachers.

Memo to Presidents, Vol. 03 No. 2, Policy Guidelines for the Implementation of A New Vision in Teacher Education.

May 13, 2003 "I'm putting together a 'flow chart' for the program approval process to help our faculty. Once SUNY approves the program, it then forwards it to SED for registration. Is this step 'pro forma' or might there be a request for revisions by SED that sends the proposal back to the department? When can the department advertise the program, after SUNY or SED approval?"
KVA: SED does often ask questions on compliance with the Rules of the Board of Regents and Regulations of the Commissioner of Education. These questions back to campus - with a copy to System Administration - tend toward technical matters such as program format, financial aid, and licensure issues. The campus responds directly to SED, with a copy to us. Keep in mind that our review involves State University policies and priorities and SED's review emphasizes regulatory compliance. Part 52.1(g) of the Regulations are clear on advertising: "Each curriculum for which registration is required shall be registered before the institution may publicize its availability or recruit or enroll students in the curriculum."

Attached for your information is a flow chart of the process that we use in program proposal workshops.

April 29, 2003 "This is a follow-up question to the earlier advice regarding Teaching Assistant Associate degree programs. You advised that the content of the program would resemble the 'template' transfer program that System is developing. This is in fact what we have done and we're now seeking articulation agreements to complete the final proposal. Guess what! The two senior colleges to which our students transfer do not agree on the curriculum we have designed for Teaching Assistant AS. Each wants different adjustments to the 'pedagogical' part of the curriculum. Now what?"
KVA: The April 15 column addressed Teaching Assistant programs and the new State and Federal regulations. We suggested that an associate degree program for Teaching Assistant/Paraprofessional would probably be very similar to the model curriculum under development for the University's teacher education transfer "template," that is, a liberal arts and sciences curriculum with a minimum of introductory professional education course work.

Staff working on the teacher education "template" project are very encouraged by the degree of compatibility of courses across the system, particularly considering the dynamic: most of the 35 two-year colleges and most of the 11 teacher preparation campuses have signed on to be a part of the inaugural effort covering multiple majors/concentrations at two certification levels. It is an enormous articulation agreement in the making.

It does not surprise me, however, that in negotiating a specific articulation agreement with your favorite senior or teacher preparation college that you would discover individual campus preferences on the fine points of a one-on-one agreement. We would suggest that if at all possible you ride the wake of the template negotiations and the course-to-course articulation information that will follow. It's very possible that the campus individuals with whom you are discussing a specific articulation agreement are not the individuals working with us on system-wide model.

April 15, 2003 "We want to submit a certificate and/or an associate degree program called Teaching Assistant as so many campuses are doing. The Program Announcements we've seen contain a glimpse of the curriculum and vary widely. Is there a 'preferred' content for the program for SUNY and SED? Or, will you tell us what you will be reviewing them for?"
KVA: There is considerable interest in new Teaching Assistant certificate and degree programs driven in part by changes to the New York State Regulations and by the federal No Child Left Behind (NCLB) Act and Title I funding. We sought the advice of SED's Office of College and University Evaluation and the Office of Teaching to prepare this column.

Our advice emphasizes the review and registration of Teaching Assistant programs and the relationship to baccalaureate programs, particularly those leading to NYS teacher certification. (This should be of interest, therefore, to the two-year colleges as well as senior campuses, especially those with teacher certification programs.)

If you are interested in developing a Teaching Assistant program, here's our best advice:

1) Familiarize yourselves with the Part 80 of the Commissioner's Regulations, specifically § 80-5.6 on supplementary school personnel at http://www.highered.nysed.gov/tcert/part80.htm. Note the change in requirements for candidates who apply on or after February 2004. It is critical to the success of your proposal that the certificate program be designed to give students an educational path to a baccalaureate degree.
 
2) Your Program Announcement and the eventual proposal should specify the Teaching Assistant level (I, II, III, pre-professional) the program seeks to cover.
 
3) At the proposal stage, the SUNY review will look for evidence of need for the program. (This is the market documentation critical to the University's focused review on "mission, market, quality.") Here we would wish to see evidence of the college's work with specific local school districts to identify their quantitative and qualitative needs. Identify the school districts and describe their needs.
 
4) The program proposal for a Teaching Assistant certificate must demonstrate that all certificate course work is "acceptable toward meeting the requirements for a baccalaureate degree." There are several ways of demonstrating this. The certificate might consist entirely of liberal arts courses that are part of your Liberal Arts and Sciences AA/AS, and/or it might consist entirely of general education requirements that transfer to a number of baccalaureates. Or, the certificate might consist entirely of course work offered in a jointly-registered associate/baccalaureate degree program.

If the Teaching Assistant certificate contains non-liberal arts course work (e.g., pedagogy) and is not subsumed under a jointly registered program, the proposal should contain a letter from an appropriate academic officer at a senior campus stating that all the courses in the Teaching Assistant Level II or III program would be accepted toward meeting the requirements of a baccalaureate degree at that campus. (It is not sufficient to state that the courses in the certificate can be applied toward an associate degree program at the proposing campus.) For a pre-professional Teaching Assistant certificate, the entire 18 credit hours must be transferable to at least one baccalaureate teacher preparation program at a specifically identified senior campus.

 

5) An associate degree program for Teaching Assistant/Paraprofessional will probably resemble closely the first two years in a jointly-registered teacher education program, that is, a liberal arts and sciences curriculum with a minimum of introductory work in professional education. In fact, the teacher education transfer "template" curriculum (about to be finalized) is the ideal curriculum for the NYS teaching assistant certificates and the NCLB paraprofessional.
 

If you have proposed a Teaching Assistant Certificate or associate degree, our review may require us to seek assurance or information on one or more of the above points.

March 24, 2003 "We have a letter from the Office of College and University Evaluation of SED advising us that we have to register separately the programs which we offer using distance learning. What is the SED policy? What are the procedures? Do we have to go through SUNY? (We looked through the FAQs. It doesn't appear you've addressed this.)"
 KVA: Several campuses have received similar letters from OCUE/SED about programs that are apparently being marketed as available via distance learning. Technically, there is not a promulgated SED policy on the registration of distance education programs; there is, however, an SED practice based on an interpretation of a particular Regulation.

The Regulations of the Commissioner of Education §52.1(h) state: "New registration shall be required for any existing curriculum in which major changes are made that affect its title, focus, design, requirements for completion, or mode of delivery." (Emphasis added.) You will recognize this as the Regulation we use in advising on the necessity of a program revision.

The SED working guideline is that if half or more of the credits toward the degree or certificate can be earned though distance education, it is considered a distance education program and requires separate registration. The OCUE division will advise you of two options to achieve registration of a distance education program: an individual proposal for review and approval of the distance education aspects of the specific program or application for an "institutional" review called the Institutional Capability Review. (More on this alternative process at a later date.)

We hold that the addition of a new mode of delivery (e.g., evening, weekend, distance education format) for an existing program is easily accomplished by the submission of a curriculum revision, with the campus providing minimal information. The result is an annotation to SED's Inventory of Registered Programs for that curriculum. This approach has worked for years for the general-purposes programs (including teacher education) under the OCUE's purview as well as for NYS professional licensure programs (e.g., engineering, nursing, accounting) under the purview of SED's Office of the Professions.

Absent an SED policy on the individual program review process for distance education, which would both detail the documentation to be provided and apply to all courses of study under both SED offices, we are developing a single guidance for our campuses. Until we can consult more widely and issue a SUNY guideline, please consult your assigned reviewer in this office.

Note: If you are offering programs via telecommunications, it is also important that you consult the Middle States Commission on Higher Education on filing for a Substantive Change. The Commission requires that an institution receive prior approval through the substantive change procedures before offering 50 percent or more of a degree program through distance learning.

March 10, 2003 "Is there a process for the approval of "undeclared major"? Do you have any advice to offer on its use?"
KVA: The practice of permitting entering students to defer declaration of a major until a later time in their course of study is known as "undeclared major." This practice allows matriculation for student financial assistance eligibility.

The State policy that pertains here is CEO 84-7 of the State Education Department, Guidelines Concerning "Matriculation" and "Approved Program" for Purposes of State Student Financial Aid. The pertinent excerpt follows:

"Academic practices at certain institutions permit entering students to defer declaring a major until a later time in their course of study. In such instances, students usually take courses in a variety of disciplines that are common to a number of degree programs. Matriculated students who defer declaration of a specific major may be considered to be enrolled in one or more of an institution's approved (registered) programs. For financial aid purposes, a student must declare a major not later than the beginning of a sophomore year in a 2-year program or the beginning of the junior year of a baccalaureate program so that the student is able to complete the degree in the normal time frame. In each case, the academic record for the student must designate the student's enrollment in a program that has been registered by the State Education Department and appears on the Inventory of Registered Programs as a program eligible for State student aid. While a declaration must be made at specified points as noted above, students are, of course, free to change their choice of a major."

There is not a related State University policy on the matter. It has been our practice to receive and approve requests to institute the use of the undeclared major. As it is not a formal academic program (credit bearing and leading to an award), it does not require the approval of the State Education Department to be instituted. Our approval will remind the proposing campus that it is very important to design and implement the campus system in such a way that every student declare a major not later than the beginning of the sophomore year in a two-year program and/or the beginning of the junior year in baccalaureate program. We advise too that the campus procedure and policy be clearly delineated and that each student's declaration form bears the date the major was selected. These items would be of interest in the event of a management audit.

We further advise campuses against the use of registered programs, such as general studies, liberal arts, and individual studies, as routine "holding" areas for undecided students. These curricula, while flexible, are structured with course distribution requirements that would be subject to review for satisfactory academic progress in a financial aid audit. The undeclared major allows the undecided student to explore different program options in a system of advisement and student services in order that s/he is successfully admitted to the major of choice and completes the program on time.

Contact Kate to Request a copy of CEO 84-7.

February 24, 2003 "We have been working with our nearby four-year college on a jointly registered program for over a year. Now we see that other community colleges are submitting proposals for the teacher education transfer 'template' associate degree and they appear to be getting registered. What do you advise at this point?"
KVA: You are correct that proposals for teacher education transfer programs have been submitted. However, we do not at this time have the final recommendations from the Working Group on Teacher Education for the associate degree curriculum content, and therefore we are unable to review the proposed programs for consistency with what will become the University's template. This office expects to issue an implementation protocol-involving an abbreviated proposal and streamlined process-for this initiative by April 1.

I recommend that you continue your discussions with your neighboring college for a jointly registered program (particularly in the high need areas of math and science) and that you participate fully in the universal transfer template project.

February 3, 2003 "We have a letter from your Enrollment Marketing office in which they are trying to clean up the curriculum charts in the SUNY Application Viewbook. We were listed in the Viewbook for several programs that are not really SED approved. Of the five being removed we want to add one and change titles for others. Do you know about this project? Can we get these programs approved in time - by June 1- to be listed in next year's Viewbook?"
 

KVA:We have been working closely with the Office of Enrollment Management to have the program list in the SUNY Application Viewbook reflect approved and registered curricula at our campuses. Let me remind you of a couple Regulations of the Commissioner of Education (emphasis added):

Part 52 Registration of Curricul: §52.1(g): Each curriculum for which registration is required shall be registered before the institution may publicize its availability or recruit or enroll students in the curriculum.

Part 53 Information for Students and Prospective Student: §53.3(d)(1): The instructional programs of the institution shall be accurately described. A list of degree, certificate and diploma programs shall be provided. The list shall be consistent with the inventory of registered degree and certificate programs maintained by the Education Department. The list shall contain at least the official approved program title, degree, and HEGIS code number and shall be preceded by a statement that enrollment in other than registered or otherwise approved programs may jeopardize a student's eligibility for certain student aid awards.

We discovered that over time the Viewbook - 700,000 copies of which are printed and distributed each year - had accumulated numerous unauthorized curricula. Evidently, the need to market offerings had driven permutations in program listings and cross-listings, with the eventual result that the accuracy of the Viewbook had been compromised. The practice now is to list only registered programs, as verified by the SED program code number. Of the 51 campuses that use the SUNY Application Processing Center, 44 received notification of "inconsistencies" with SED's IRP, generating work for the campuses and for this office.

As your assigned program reviewer (each campus contemplating a similar request should consult its assigned reviewer), I'd like to discuss by telephone the curriculum you wish to add (register). Since it is a "spin-off" of an existing registered major, perhaps we can do with an abbreviated proposal. You should post the Program Announcement immediately to solicit comments from other campuses. For title changes, please use the process listed on the Program Review Website as Revision of Existing Program. To do this by June 1 we will need succinct but forthcoming one-read documentation. It's do-able.

 


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