Doyle, I believe that if your program offered is at the associate-level and is not regulated by the TWC CSC, you would not need to submit a variance for approval. Programs regulated by the TWC CSC (diploma/certificate) would require a variance for instructors who do not meet the requirements. This is true even though you keep the applications on file at the school (not sent in to TWC CSC) for your instructors who do meet the requirements. If you have a specific situation, you can always check with your TWC CSC contact person to be sure of how to proceed. JP Mehlmann