The number of competency-based education (CBE) degree programs has increased rapidly over the past five years, yet there is little research on CBE program development. This study utilized conceptual models of higher education change and a qualitative methodology to analyze the strategies and challenges in implementing CBE business degree programs at three universities. The findings were generally consistent with the constructs in the higher education change models. Important issues not highlighted in the models nor in previous CBE research included the long-run impact of initial institutional structure decisions; the trade-off between cost and quality; the interaction among program flexibility, student characteristics, and faculty interaction; the importance of feedback loops for quality assurance; and variation in alignment with traditional programs. The findings were used to generate a preliminary framework for decision making that educational leaders can use in implementing CBE programs.