Sanctions, Show-Cause Orders and Adverse Actions
On This Page
Under certain circumstances, HLC may determine that a member institution is out of compliance, or at risk of being out of compliance, with HLC requirements. As a result, the institution may be placed on a sanction of Notice or Probation, or issued a Show-Cause Order, as applicable under HLC policy. The institution is then required to undergo an additional evaluation to demonstrate that it has addressed the identified concern(s) and is otherwise in compliance with HLC requirements. The institution remains accredited while it is on sanction or under a Show-Cause Order.
If an institution is found to be out of compliance with HLC requirements, HLC may also deny or withdraw the institution’s candidacy or accreditation. An institution’s accreditation may be withdrawn without first placing the institution on sanction. Such denial or withdrawal is an adverse action and is subject to appeal by the institution.
Institutions are obligated to promptly disclose any sanctions, Show-Cause orders and adverse actions to the public. Once the institution has been notified of one of the above actions, the institution’s Statement of Accreditation Status in HLC’s Directory of Institutions and, if applicable, the Mark of Accreditation Status on the institution’s website are updated to reflect the change in status. HLC will also issue a Public Disclosure Notice. See Required Notifications Following Adverse Actions, Sanctions and Related Actions for additional information.
HLC’s Board of Trustees has sole decision-making authority whether to impose or remove a sanction, issue or remove a Show-Cause Order, or take an adverse action.
Note: See HLC’s Dues and Fees Schedule for costs associated with sanctions, Show-Cause Orders and adverse actions.
Sanctions
An institution may be placed on the sanction of Notice or Probation when HLC determines the institution does not meet, or is at risk of not meeting, HLC requirements. An institution on a sanction remains accredited during the period of the sanction. The imposition of a sanction is a final action and not subject to appeal.
Notice
An institution is placed on Notice when it is at risk of not meeting the Criteria for Accreditation. An institution on Notice is placed on the Standard Pathway for the remainder of its accreditation cycle.
An institution is placed on Notice for no more than two years. While on Notice, the institution submits a Notice Report providing evidence that it is no longer at risk of not meeting the Criteria for Accreditation. The institution may also be required to host a Notice Visit to demonstrate that the concern(s) that led to the sanction have been addressed.
At the end of the Notice period, the HLC Board of Trustees may remove the institution from Notice if it is no longer at risk of not meeting the Criteria for Accreditation. If the institution is still at risk of not meeting the Criteria for Accreditation — or if the institution is no longer meeting the Criteria for Accreditation — the Board may take another action in accordance with HLC policies, including extending Notice, placing the institution on Probation, issuing a Show-Cause Order or withdrawing accreditation.
Probation
An institution may be placed on Probation when it no longer meets one or more HLC requirements and the HLC Board of Trustees determines that Probation is warranted as a period for the institution to resolve the areas of concern. An institution on Probation is removed from its Pathway for Reaffirmation of Accreditation.
The initial period for Probation is up to two years. An institution on Probation undergoes a comprehensive evaluation for Probation to provide evidence that the areas of concern have been addressed and to demonstrate that the institution is otherwise in compliance with HLC requirements.
At the end of the Probation period, the Board may remove the institution from Probation if it has addressed the areas of concern and meets all HLC requirements. If the institution still does not meet all HLC requirements, the Board may take another action, including extending Probation, issuing a Show-Cause Order or withdrawing accreditation.
Following removal of Probation, including any extension, and if the Board does not withdraw accreditation or issue a Show-Cause Order, the Board will reaffirm the institution’s accreditation and place the institution on the Standard Pathway. The institution will have a comprehensive evaluation to reaffirm accreditation no longer than four years after the removal of Probation, although the Board may set the reaffirmation date earlier.
Show-Cause Order
An institution is issued a Show-Cause Order when it is not meeting HLC requirements. A Show-Cause Order requires the institution to promptly provide evidence, without a period of remediation, indicating that its accreditation should not be withdrawn. The issuance of a Show-Cause Order is a final action and not subject to appeal. An institution issued a Show-Cause Order is removed from its Pathway for Reaffirmation of Accreditation.
The period for a Show-Cause Order shall not exceed one year. While under a Show-Cause Order, the institution undergoes a comprehensive evaluation for Show-Cause to demonstrate that it meets HLC requirements.
Prior to the HLC Board of Trustees taking action on the comprehensive evaluation for Show-Cause, HLC will make a Board Committee Hearing available to the institution.
At the end of the Show-Cause period, the Board may remove the institution from Show-Cause if the Board determines that the institution should maintain its accreditation. An institution removed from Show-Cause may be subject to sanctions or monitoring. If the institution has not demonstrated that it should maintain its accreditation, the Board may act to withdraw accreditation.
If the Board removes the Show-Cause Order and does not assign a sanction or withdraw accreditation, the Board will reaffirm the institution’s accreditation and place the institution on the Standard Pathway.
Adverse Actions
Adverse actions are actions that:
- Withdraw accreditation.
- Deny accreditation to an institution seeking HLC accreditation, unless the Board denies an early application for accreditation and continues candidacy.
- Withdraw or deny candidacy.
Prior to the HLC Board of Trustees taking an adverse action, HLC will make a Board Committee Hearing available to the institution. Adverse actions are subject to appeal by the institution.
Withdrawal or Denial of Accreditation
An institution’s accreditation may be withdrawn if it does not meet one or more HLC requirements, including if it no longer operates as an educational institution or if it fails to maintain authorization to operate as an institution of higher education and grant degrees in HLC’s jurisdiction. The HLC Board of Trustees may withdraw accreditation without first placing an institution on a sanction or issuing a Show-Cause Order.
When the Board acts to withdraw an institution’s accreditation, the institution remains accredited until the effective date of withdrawal. This effective date will not be before the conclusion of the current academic term at the time of the action, inclusive of the institution’s issuance of degrees immediately following such academic term. The Board may also consider an effective date that takes into account a reasonable period for the institution to conduct a teach out in accordance with other relevant HLC policies and procedures.
An institution seeking accreditation with HLC may be denied accreditation if does not meet one or more HLC requirements.
Withdrawal or Denial of Candidacy
An institution may be denied candidacy, or its candidacy may be withdrawn, if it fails to meet one or more of the Eligibility Requirements, the Assumed Practices or Federal Compliance requirements, or the institution has not provided sufficient evidence that the Criteria for Accreditation can be met within the candidacy period.
Appeals of Adverse Actions
Per HLC policy, institutions may have the opportunity to appeal an adverse action by the Board. The grounds for an appeal are:
- The Board’s decision was arbitrary, capricious, or not supported by substantial evidence in the record on which the Board took action.
- The procedures used to reach the decision were contrary to HLC’s policies and procedures, and the procedural error unreasonably impaired the Board’s consideration.
- The institution has new financial information for consideration. New financial information will only form the basis for an appeal if, as determined in the discretion of the Appeal Panel: (i) the adverse action was based solely on financial grounds; (ii) the financial information was not available at the time the adverse action was made; and (iii) the financial information is significant and bears materially on the financial deficiencies that formed the basis for the adverse action.
