Decision-Making Bodies and Related Processes

Following most institutional reviews, peer reviewers or staff make recommendations to an HLC decision-making body, whose members review the case and make a final decision. HLC’s decision-making process is designed to prioritize due process and transparency for institutions and their students.

Decision-Making Bodies

Actions regarding HLC member institutions and institutions applying for membership with HLC are taken by three decision-making bodies comprised of institutional representatives and public members: the Board of Trustees, the Institutional Actions Council, and the Appeals Body. Unless otherwise specified, the decision-making bodies are broadly representative of the colleges and universities accredited by HLC, with attention to institutional type, control, size and geographical distribution. All decision-making bodies abide by HLC’s conflict of interest policies.

Board of Trustees

The Board of Trustees is the governing body of HLC. It typically holds in-person meetings three times a year to take action on institutional cases, to approve and adopt changes to HLC policy, and to conduct other regular business.

Membership

The Board is made up of at least 16 and no more than 21 trustees. Member institutions elect trustees to a four-year term, with an option to extend for subsequent two-year terms, for a total of no more than 12 years of service altogether. At least one of every seven trustees is a representative of the public, and the others are representatives of HLC member institutions or are otherwise involved in higher education.

Board Authority

Cases that require final action by the Board include the following:

• Granting or denying an institution candidacy or initial accreditation.
• Withdrawing status from a candidate or accredited institution.
• Issuing or removing a sanction.
• Issuing or removing a Show-Cause Order.
• Approving or denying a Change of Control, Structure or Organization.

Institutional Actions Council

Membership

The Institutional Actions Council (IAC) is composed of approximately 125 members representing HLC member institutions and the public. The Board of Trustees appoints and authorizes IAC members to serve four-year terms. Those members who represent institutions are also current members of the Peer Corps. Biographical information about IAC members is available upon request.

IAC Authority

The IAC has the authority to take action on accreditation decisions other than those for which the Board of Trustees retains exclusive authority. This includes, but is not limited to, the following:

• Cases of reaffirmation of accreditation, including pathway placement.
• Standard Pathway comprehensive evaluations.
• Open Pathway Assurance Reviews.
• Biennial evaluations during Candidacy.
• Substantive change requests requiring review and approval by a decision-making body, not including applications for Change of Control, Structure or Organization.
• Recommendations for and resulting from interim monitoring.

Some cases heard by the IAC require action by the Board of Trustees. In these instances, the IAC submits a recommendation to the Board for consideration. The Board may either adopt the recommendation of the IAC as its action or may take another action provided by HLC policy.

Appeals Body

The Appeals Body is selected by the Board of Trustees to be available to serve on Appeal Panels. Although many actions by the Board are final actions, an institution may appeal an adverse action of the Board prior to the action becoming final. In these instances, an Appeal Panel hears the case and has the authority to affirm, amend or remand the action of the Board. Meetings of Appeal Panels are held as needed.

Decision-Making Process and Related Processes

Staff Actions

HLC staff may take certain types of institutional actions, as permitted by HLC policy. These actions could include, among others, adjusting the scope of certain previously assigned monitoring or changing the date of an upcoming review.

Actions Taken by Decision-Making Bodies

For evaluations that require action by an HLC decision-making body, the decision-making process begins once the evaluation concludes. A peer review or staff report that includes a recommendation is submitted to an HLC decision-making body. Unless a case is required by policy to go directly to the Board of Trustees for consideration and action, most cases are sent to the IAC for final action or for a secondary review and recommendation prior to action being taken by the Board of Trustees. 

Institutional Response

Institutions are offered an opportunity to respond after each evaluation and at each stage of the decision-making process. Each decision-making body considers the institutional response as part of the full record of the case, along with the recommendation of the peer review team and, where applicable, the recommendations of other decision-making bodies.

Institutional Actions Council

Each year the IAC reviews more than 1,000 cases in two settings:

• IAC Meeting. Meetings are held virtually with a committee of IAC members. Representatives from the institutions are not present at these meetings. The decisions of IAC meeting committees are final unless the Board of Trustees is required by policy to take final action.
• IAC Hearing. HLC policy requires that certain cases go to an IAC hearing rather than a meeting. Representatives from both the institution and peer review team, along with a committee of IAC members, attend these hearings. The IAC hearing committee will typically make a recommendation to the Board of Trustees for final action. See Institutional Actions Council Hearing Process for details about how a hearing is conducted.

A committee of IAC members is selected for each meeting and hearing. The IAC members on the committee are responsible for reading the entire record related to each case. Approximately every six weeks, IAC committees review cases in a meeting format. Hearings are timed to occur in advance of Board meetings. 

An action taken by the IAC is a final action unless the case requires review by the Board of Trustees. If the case requires action by the Board, the IAC includes a recommendation with the report sent on to the Board of Trustees for final action.

Board of Trustees

The Board conducts regular meetings three times per year to take action on institutional cases, to approve and adopt changes to HLC policy, and to conduct other regular business. The Board may also take institutional actions at other times during the year via special meetings or other means, such as electronic ballots, as necessary. 

Board Committee Hearing

HLC will make a Board Committee Hearing available to a member institution in certain situations, including prior to most decisions by the Board to do any of the following:

• Deny initial accreditation to an institution that has candidacy status, except where HLC is denying an application for early initial accreditation prior to the end of the four-year term of candidacy with a possible extension for a fifth year for good cause.
• Withdraw candidacy.
• Withdraw accreditation.
• Conclude a Show-Cause Order process.

The hearing is conducted by a subcommittee of the Board prior to the full Board taking action.

Action Letter

No more than 14 days after a final action by the IAC or action by the Board of Trustees, an Action Letter is sent to the institution. The Action Letter relays the action to the institution.

Appeals

Although many actions by the Board are final actions, an institution may appeal an adverse action of the Board of Trustees prior to the action becoming final by filing a written request to appeal following HLC’s appeals procedures. An Appeal Panel will hear the case and decide to affirm, amend or remand the adverse action to the Board. If the panel affirms or amends the action, the Board will review and act to implement the panel’s decision. If the panel remands the action to the Board for additional consideration, the Board will, after taking into account the panel’s explanation of its reasons for remanding the action, act to affirm, amend, or reverse its original adverse action.

Arbitration of Adverse Actions Following Appeal

A decision by an Appeal Panel concludes the decision-making process. Thereafter, an institution may initiate arbitration with HLC. See Arbitration of Adverse Actions Following Appeal for details regarding possible grounds for arbitration, as well as the process and timeline. The arbitration will be conducted by a single arbitrator who is mutually selected by the parties. The arbitrator may affirm or reverse the decision by the Appeal Panel. Following arbitration, the Board will act to implement the decision of the arbitrator. In accordance with federal requirements, HLC’s arbitration process is an initial process that is non-binding.

Accreditation Actions

HLC posts all institutional actions within 30 days after the action is taken. Actions are published under Accreditation Actions and/or on the institution’s Statement of Accreditation Status in the HLC Directory of Institutions. If HLC’s Board of Trustees denies or withdraws an institution’s candidacy or accreditation, places an institution on sanction, or issues a Show-Cause Order, HLC posts that information in the Directory of Institutions within one day after notifying the institution.