Understanding the Structural Separation Process
The Commission on Accrediting (COA) and The Association of Theological Schools (ATS) are undertaking a process of structural separation in response to new regulations issued by
the US Department
of Education on October 29, 2026 regarding accreditor independence.
While COA and ATS have operated as separate corporations since 2004, the new federal requirements call for additional separation in certain operational and administrative areas. To maintain
compliance with US federal regulations and preserve recognition of COA accreditation, both organizations must complete this work by July 1, 2027.
This process is being driven by regulatory requirements related to accreditor independence and conflict-of-interest safeguards. It is not the result of concerns about the quality,
effectiveness, integrity, or performance of either organization.
Throughout this transition, COA and ATS remain committed to serving member schools, supporting quality theological education, and ensuring continuity in accreditation and member services.
Commitment to Transparency
COA and ATS are committed to communicating openly throughout this process. As decisions are made, this webpage will be updated with:
- Key decisions and milestones
- Frequently asked questions
- Resources for member schools
We recognize that this transition raises important concerns, and we are committed to providing timely and accurate information. Questions, comments, and feedback are welcome throughout the
structural separation process.
Email: structural-separation@ats.edu
Quick Navigation for Additional Details
Why Structural Separation is Necessary
The US Department of Education has adopted new regulations that require accrediting agencies to operate with greater independence from associated membership organizations
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.
As organizations committed to the flourishing of theological education, COA and ATS are taking the steps necessary to ensure ongoing compliance while continuing to serve member schools
effectively.
What is Changing
To meet the new federal requirements, COA and ATS must evaluate and implement additional operational separation in areas where resources and services are currently shared.
Areas under review include:
- Executive leadership for each organization
- Personnel and administrative support functions
- Financial operations
- Information technology systems and support
- Data management and database administration
- Office space and facilities
- Other shared services and operational arrangements
Some administrative systems and functions may need to be restructured, duplicated, or operated independently. As decisions are made, COA and ATS will seek to minimize unnecessary costs,
disruption, and administrative burden while ensuring compliance with federal requirements.
What is Not Changing
The work of structural separation does not change the fundamental missions of either organization.
Member schools can expect continuity in the areas that matter most:
- The commitment to quality theological education
- 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
-
Planned events and activities for the 26–27 academic year
- Ongoing support for member schools
- The missions of both organizations
The longstanding commitment to educational quality, institutional improvement, and the preparation of religious leaders remains unchanged.
Progress and Timeline
Completed
- COA and ATS reviewed proposed federal regulations and submitted public comments.
- Leadership began evaluating potential structural separation models.
- A joint task force with representation from both ATS and COA boards has been established to support planning and implementation efforts.
Current Phase
- Analysis of regulatory requirements
- Evaluation of operational and administrative structures
- Development of implementation plans
- Review by organizational leadership and governing boards
Upcoming
- Governance review and decision-making
- Operational implementation
- Transition to fully compliant structures
- Completion of structural separation by July 1, 2027
This timeline will be updated as milestones are reached and additional decisions are made.
Structural Separation Communications to Date
Frequently Asked Questions
