Review of Substantive Change

The review process for requests for approving those substantive changes that require HLC APPROVAL as detailed in HLC policies shall primarily be determined in the following two ways: (1) each member institution shall be assigned a designation by HLC according to its experience and maturity in offering new educational programs and new methods of delivery, including offering distance, correspondence education, credit-based competency-based education and direct assessment; (2) HLC shall determine the complexity of the specific proposed changes being requested for approval. 

An institution requesting prior approval of a substantive change shall present appropriate application information seeking approval of the change according to HLC’s change review protocols. Generally, such materials shall be reviewed by HLC according to the provisions of this section; however, certain types of change may require additional review provisions as provided herein. 

As determined by the designation of the institution and the complexity of the change, and unless otherwise stated herein, the change request will be reviewed by one of the following: a Change Panel, a Change Visit or a Desk Review, each of which is described below.  

All change requests will be presented for final review and approval by an HLC decision-making body recognized by the U.S. Department of Education unless approval by HLC staff is otherwise explicitly permitted by HLC policies. Changes will be effective on or after the date of the action of that body. In no case will such approval be retroactive. 

Change of Control, Structure or Organization  

The review process for requests for changes identified as subject to HLC’s Change of Control, Structure or Organization policy will be reviewed in accordance with separate associated procedures found in HLC’s policies regarding Change of Control, Structure or Organization. 

Review of a Campus 

Institutions seeking HLC approval of a main campus or branch campus that houses a full range of instruction as well as administrative and support services shall provide a business plan for the new campus that specifies the following: 

1. the educational programs to be offered at the campus;  
2. the projected revenues, expenditures and cash flow at the campus; and  
3. the operational, management, and physical resources at the campus. 

Within six months of the date the campus matriculates students and offers instruction, HLC will conduct a campus visit.  

Review of Additional Locations 

The review process for additional locations offering 50% or more of an academic program shall be determined in the following two ways: (1) each member institution shall be assigned a designation by HLC according to its experience and maturity in offering new additional locations; (2) HLC shall determine the complexity of the specific proposed changes being requested for approval. Such review shall include consideration of the institution’s fiscal and administrative capacity to operate that location. The only exception shall be for institutions approved for access to the Notification Program for Additional Locations, as defined in this policy.  

Within six months of the date an institution matriculates students and begins instruction at any of its first three new additional locations, HLC will conduct an on-site evaluation visit to that additional location.  

Within six months of the date an institution matriculates students who are incarcerated and begins instruction in a Pell-eligible prison education program at each of its first two additional locations offering the Pell-eligible prison education program, HLC will conduct its first on-site evaluation visit at such additional location(s). 

Institutions remain responsible for ensuring that they have all appropriate approvals for Pell-eligible prison education programs, including approval for any instructional site meeting the federal definition of an additional location prior to initiating a prison education program at that location. 

Notification Program for Additional Locations 

Institutions that have previously received approval from HLC to initiate at least three additional locations may seek access to the Notification Program for Additional Locations. Such access shall reflect HLC’s determination that the institution has a proven record of educational and administrative oversight of such locations and has the capacity to extend that oversight to new additional locations. An institution’s request for initial access to the Notification Program will be granted only after the institution has been reviewed by a Change Visit or other review for other additional locations resulting in a written report that documents the institution’s compliance with appropriate requirements as outlined in this policy.  

Eligibility Criteria for the Notification Program. In order to be eligible to participate in the Notification Program for Additional Locations, an institution must meet the following criteria: 

1. The institution has completed at least one cycle of accreditation. 
2. The institution has demonstrated success in overseeing at least three locations. 
3. The institution is not under a provisional certification with the U.S. Department of Education (having been placed on such status on or after July 1, 2020).  
4. During the previous three years, the institution has not been subject to monitoring for issues related to the quality of instruction at, or to the oversight of, existing additional locations or campuses. 
5. The institution is not currently on Notice with HLC.  
6. During the previous three years, the institution has not been placed on Notice. 
7. The institution is not currently on Probation with HLC or under a Show-Cause Order with HLC. 
8. During the previous three years, the institution has not been placed on Probation or under a Show-Cause Order. 
9. The institution has not had its accreditation withdrawn and the withdrawal action is stayed pending appeal. 
10. There are no other HLC or other legal restrictions on additional locations and/or programs offered off campus. 
11. There are appropriate systems at the institution to ensure quality control of locations that include clearly identified academic controls; regular evaluation by the institution of its locations; a pattern of adequate faculty, facilities, resources, and academic/support systems; financial stability; and long-range planning for future expansion. 

An institution with access to the Notification Program for Additional Locations will be able to open new additional locations after notifying HLC prior to initiating any new additional locations and receiving an acknowledgment that HLC has added the new additional location to its systems.  

However, an institution must seek prior HLC approval for the first two additional locations where it offers its first Pell-eligible prison education program even if it is otherwise eligible for, or participates in, the Notification Program for Additional Locations.  

An institution that remains eligible for the Notification Program for Additional Locations and is otherwise eligible to offer Pell-eligible prison education programs under HLC policy may utilize the Notification Program for Additional Locations program to notify HLC of additional locations where it offers a second or subsequent Pell-eligible prison education program. 

Continued institutional eligibility for access to the Notification Program for Additional Locations will be reviewed at least every five years, typically in conjunction with a multi-location visit. 

Removal or Suspension From the Notification Program. HLC may act to suspend or remove an institution from the Notification Program if it does not meet the criteria above.  

An institution will be suspended from the Notification Program if: 

1. The institution is under a provisional certification with the U.S. Department of Education. 
2. During the previous three years, the institution has been subject to monitoring for issues related to the quality of instruction at, or to the oversight of, existing additional locations or campuses. 
3. The institution is, or during the previous three years has been, on Notice with HLC. 

An institution that is suspended from the Notification Program will be eligible to participate in the Notification Program once the issue that resulted in the suspension is resolved, provided that the institution continues to meet all of the other criteria for eligibility to the Notification Program. 

An institution will be removed from the Notification Program if: 

1. The institution does not have at least three additional locations. 
2. During the previous three years, the institution has been placed on Notice for issues related to the quality of the institution’s off-campus instruction or related issues. 
3. The institution is, or during the previous three years has been, on Probation with HLC or under a Show-Cause Order with HLC. 
4. The institution has had its accreditation withdrawn and the withdrawal action is stayed pending appeal. 
5. There are HLC or other legal restrictions on additional locations and/or programs offered off campus. 
6. There are not appropriate systems at the institution to ensure quality control of locations that include clearly identified academic controls; regular evaluation by the institution of its locations; a pattern of adequate faculty, facilities, resources, and academic/support systems; financial stability; and long-range planning for future expansion. 

An institution that is removed from the Notification Program must re-apply to participate in the Notification Program. 

HLC may also suspend or remove an institution that undergoes a Change of Control, Structure or Organization as defined in HLC policy from the Notification Program, for example, based on concerns related to its additional locations.  

Substantive Change Review Process Structure  

Change Panel. A Change Panel shall consist of two or more peer reviewers who shall review applications for approval of substantive change submitted by institutions.  

The Change Panel may seek additional information from the institution if such information is being sought to explain or clarify the materials provided by the institution in its application for change. 

The Change Panel may recommend that the change be denied or that it be approved with or without additional monitoring as appropriate. Such recommendation will then be forwarded to an appropriate HLC decision-making body. The institution shall be given an opportunity to review the recommendation and provide an institutional response prior to consideration by the decision-making body.  

Alternatively, the Change Panel may recommend that the change be further evaluated by an on-site evaluation team, either by a Change Visit or by a previously scheduled focused or comprehensive evaluation.  

Change Visit. A Change Visit shall consist of a team of two or more peer reviewers designated by HLC who shall review applications for approval of substantive change submitted by institutions.  

The Change Visit team may recommend that the change be denied or that it be approved, with or without additional monitoring as appropriate. Such a recommendation will then be forwarded to an appropriate HLC decision-making body. The institution shall be given an opportunity to review the recommendation and provide an institutional response prior to consideration by the decision-making body. 

Desk Review. A Desk Review shall consist of a review of a proposed institutional change conducted by HLC staff. The staff member may recommend that the change be denied or that it be approved, with or without additional monitoring as appropriate. Unless approval by HLC staff is otherwise explicitly permitted by these policies, the Desk Review will result in a recommendation to an appropriate HLC decision-making body. The institution shall be given an opportunity to review any recommendation for denial and to provide an institutional response prior to consideration by the decision-making body. 

Policy History

Last Revised: November 2023 
First Adopted: November 1999, June 2010  
Revision History: November 1999, June 2009, June 2011, June 2012, November 2012, February 2014, June 2020, November 2020, June 2021, June 2022, November 2023 
Notes: Policies combined November 2012 – 3.2(b)1.1, 3.2(b)1.2, 3.2(b)1.3, 3.2(b)1.4, 3.2(b)1.4a, 3.2(b)1.4b, 3.2(b)1.4c, 3.2(b)1.4d, 3.2(b)1.4e, 3.2(b)1.5, 3.2(b)2, 3.2(b)2.1, 3.2(b)2.2, 3.2(b)2.3. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.” Policy renumbered in June 2023 (former policy number INST.F.20.050).