For multi-campus systems
Federated accountability
The system publishes one framework. Each campus publishes its own evidence ledger.
A system office may reasonably coordinate a response so that member institutions speak with consistency on shared policy. Two things follow: what the system provides, and what each campus provides.
Coordinate-and-hold, and when it is defensible
Coordinate-and-hold, in which a system pauses public comment during a defined review and prepares a common framework, is a defensible short-term protocol. It limits inconsistent public statements, protects legal review, and recognizes that public-agency communications can become public records. It is defensible on three conditions: the review period is defined, the decision process is named, and the timeline is public.
It becomes a gap only if it substitutes permanently for campus-level evidence. A system can speak to common legal principles and shared statutory responsibilities. It cannot describe the distinct admissions practices, program economics, student borrowing profiles, campus-speech histories, research portfolios, and workforce missions of its institutions in one account. An aggregate can conceal a weak program or a struggling student group at one campus behind a sound average across the rest.
What the system provides, and what each campus provides
The system framework
- Definitions
Shared definitions for every figure: numerator, denominator, time window, and the disaggregation each campus reports.
- Legal review
A common legal review of the letter, the response posture, and the concurrent filings that share the evidence base.
- Commitments
System-level commitments that hold across campuses, each with an owner, resources, and a public reporting date.
- Calendar
One calendar for the system: the October 1, 2026 FVT/GE and STATS submission, the December 31, 2026 target, the January 15, 2027 backfill, and the January 31, 2027 Section 117 report.
- Standard
The evidence codes E0 to E5 and the publication rule, applied identically at every campus.
The campus evidence ledger
- Claims
Each campus's own claim register, coded E0 to E5, with sources, owners, and limitations.
- Contradictions
Each campus's own contradiction ledger. A campus that reports no material contradiction is not ready to publish.
- Domains
The seven-domain entries completed for the campus itself; a system average does not substitute.
- Docket
Campus commitments with campus owners and dates, folded into the system calendar.
- Board
Certification by the campus leadership and, where the structure provides one, the campus council or advisory board, alongside the system board.
How a federated statement is published
The system publishes the framework once. Each campus publishes its own statement and evidence appendix under the framework, on its own site, with the system framework linked. A reader who wants the system position finds it once. A reader who wants a campus's evidence finds it at the campus. The Registry on this site records each campus statement as its own entry, with the system framework noted as context.
Where a system decides that a single collective statement is the right posture, the instrument's condition still applies: the collective statement is accompanied by institution-level evidence appendices, or its strongest claims are not published.