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Dear Colleagues,
Last month, we shared that the US Department of Education (USDE) was considering new regulations regarding accreditor independence and that the Commission on Accrediting (COA) and The Association of Theological Schools (ATS) submitted a public comment expressing both support for accreditor independence and concern about certain provisions of the proposed rule. We also indicated that, should the regulations be adopted, COA and ATS would need to evaluate additional structural and operational changes to maintain compliance.
On October 29, 2026, the USDE finalized the regulation. While we continue to review the details and implications, the final rule makes clear that COA and ATS, while already two separate corporations, must further separate operations to comply with the new requirements. Federal implementation timelines require the separation to be completed by July 1, 2027.
COA and ATS began evaluating potential scenarios well before publication of the final rule and are prepared for this transition. We will approach the work with care and transparency during this period of significant change.
While this transition requires substantial work behind the scenes, most member schools should notice little change in their day-to-day relationship with COA or ATS.
Why Structural Separation is Needed
For all member schools, structural separation is necessary to preserve the recognition, credibility, and value of COA accreditation under the new federal requirements. Given our commitment to the ecology of theological education, this is a responsibility we take seriously on behalf of our member schools and the communities they serve. Additionally, more than 60 ATS member schools rely on COA accreditation to participate in federal Title IV student aid programs. Although these regulations are tied to federal student aid programs in the United States, their impact extends beyond US institutions. A small number of Canadian member schools also participate in Title IV programs and therefore have a direct interest in maintaining US federal recognition of COA accreditation.
What Structural Separation Means
Since 2004, COA and ATS have operated as separately incorporated organizations with independent boards, budgets, bylaws, and decision-making structures. Accreditation decisions have long been independent from ATS membership and programmatic activities.
These existing structures already prevent conflicts of interest between COA and ATS and will continue to do so. However, the new federal requirements call for additional operational separation.
Structural separation will require the two organizations to operate more independently in areas where they currently share resources and administrative support. As planning continues, organizational leaders and both boards will evaluate a range of operational changes.
What is Not Changing
COA and ATS are not ending their longstanding shared commitments. COA will maintain federal recognition as an accrediting agency while ATS continues its membership, leadership development, research, and convening work on behalf of theological education.
Member schools can expect continuity in the areas they value most:
- The commitment to quality theological education
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The COA Standards of Accreditation
- Accreditation review processes
- The Board of Commissioners' authority over accreditation decisions
- ATS membership activities and services
- ATS research, initiatives, and leadership development programs
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Planned events and activities for the 26–27 academic year
- Ongoing support for member schools
- The missions of both organizations
Planning and Implementation
Over the coming months, COA and ATS leadership, together with both governing boards, will evaluate and implement the changes necessary to meet the new requirements.
Areas that require review include:
- Executive leadership for each organization
- Administrative and personnel structures
- Financial operations
- Data management and database administration
- Information technology systems and support
- Office space
- Other support services currently shared between organizations
While some administrative functions, systems, and services may need to be restructured or duplicated, our guiding principles remain unchanged. COA will preserve the integrity of accreditation. COA and ATS will each individually maintain excellent support for member schools. It is possible that operational changes required under the newly promulgated federal regulations may result in increased costs in some areas, and we are committed to minimizing unnecessary expenses and disruption. Our goal is to steward organizational resources responsibly and strengthen our collaborative community. We will make decisions carefully and deliberately with these things in mind.
What Member Schools Need to Do Now
At this stage, member schools do not need to take any new action.
For now, institutions should:
- Continue normal accreditation and membership activities
- Monitor communications from COA and ATS
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Share questions and concerns by emailing structural-separation@ats.edu and as other feedback opportunities arise
How to Stay Informed
COA and ATS have established a dedicated webpage, ats.edu/structural-separation, to provide current information about the structural separation process. The page serves as the central source for updates, decisions, milestones, timelines, resources, and FAQs.
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