Adopted Policy Changes
2024–25 Academic Year
October 2024
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on October 31, 2024. They are effective immediately.
- Eligibility Requirements
The adopted changes streamline HLC’s Eligibility Requirements and align them with the revised Criteria for Accreditation and Assumed Practices. - Sanctions and Reaffirmation of Accreditation
The adopted changes establish standard time periods for Notice and Probation, as well as the general rule that an institution would have its accreditation reaffirmed when it is removed from Probation or a Show-Cause Order. The changes also clarify the standard for issuing a Show-Cause Order.
2023–24 Academic Year
July 2024
The Higher Learning Commission’s Board of Trustees adopted the following change to the HLC Bylaws through an electronic ballot on July 9, 2024. The bylaw change is effective immediately.
- Adopted Bylaw Change: Composition of Executive Committee
The adopted change expands the membership of the Board’s Executive Committee to include the immediate past chair of the Board. The Executive Committee also consists of the chair, vice chair, treasurer, and the chairs of the standing Board committees.
June 2024
The Higher Learning Commission’s Board of Trustees adopted the following policy on second reading at its meeting on June 27, 2024.
- Criteria for Accreditation and Assumed Practices (changes effective September 1, 2025)
The adopted changes streamline and clarify HLC expectations for institutions. See HLC’s overview document for policy language, implementation timeline, crosswalks between the current and revised Criteria, and definitions of new terms in the revised Criteria. Additional training and support on the revised Criteria will be available for institutions and peer reviewers starting this fall.
February 2024
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on February 29, 2024.
- Multi-campus Visits (changes effective September 1, 2024)
The adopted changes revise when HLC visits a sample of an institution’s branch campuses — a process known as a multi-campus visit — during a comprehensive evaluation. Beginning September 1, 2024, multi-campus visits will take place during comprehensive evaluations for candidacy, initial accreditation or reaffirmation of accreditation. They will no longer occur during other comprehensive evaluations, including Standard Pathway Year 4 comprehensive evaluations that do not involve reaffirmation of accreditation. - Staff Authority (changes effective immediately)
The adopted changes clarify when HLC staff may take certain actions with respect to an institution and when staff may recommend certain actions to an HLC decision-making body. The changes also clarify when institutions have an opportunity to submit a response to a staff member’s recommendation. In connection with the changes made to the Routine Monitoring and Data Collection policy, HLC also updated its Monitoring Recommendations: Considerations for Peer Review document to clarify guidance for peer reviewers.
November 2023
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on November 2, 2023. The policies are effective immediately.
- Faculty Qualifications
Revises the faculty qualifications provision in HLC’s Assumed Practices to emphasize that an institution is responsible for establishing and maintaining reasonable processes for determining that its instructors are qualified. An institution could deem instructors qualified based on a variety of factors, including, but not limited to, academic credentials, progress toward academic credentials, equivalent experience, or some combination thereof. To help clarify the new policy, HLC has developed updated guidelines on faculty qualifications and dual credit. - Pell-Eligible Prison Education Programs
Amends HLC policies related to substantive change to include requirements for Pell-eligible prison education programs and additional locations where Pell-eligible prisons education programs are offered. The requirements align with guidance from the U.S. Department of Education related to the reinstatement of Pell Grant eligibility for students enrolled in such programs. - Accelerated Process for Initial Accreditation
Revises the accreditation history requirements that would potentially qualify an institution to participate in HLC’s Accelerated Process for Initial Accreditation.
The Board of Trustees also adopted the following policy change on single reading on November 2, 2023. The policy is effective immediately.
- Distance Education
Aligns HLC’s substantive change policy with recent guidance from the U.S. Department of Education. It revises the requirements related to when an institution must seek approval from HLC for its distance education offerings. An institution must do so when it initially offers distance education and when it does any one of the following: (1) offers at least 50% of a program through distance education; (2) enrolls at least 50% of its students in at least one distance education course; (3) offers at least 50% of its courses through distance education. Once an institution has received HLC approval for one of these thresholds, additional approval for the other thresholds is not required.
2022–23 Academic Year
June 2023
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on June 22, 2023. The policies are effective immediately.
- Arbitration Requirements
Amends the current arbitration provision in HLC’s Obligations of Membership policy to align more closely with federal regulations. The scope of the provision is now limited to disputes arising from adverse actions and only includes an “initial arbitration” requirement. HLC also published a new procedure regarding arbitration. - Institutional Actions Council (IAC) Authority
Clarifies that the IAC has the authority to take action on all accreditation decisions for which exclusive authority is not retained by HLC’s Board. - Processes for Certain Changes of Control
Aligns HLC policy with recent guidance from the U.S. Department of Education on Change of Control requirements in certain circumstances. HLC has also published an updated Change of Control, Structure or Organization procedure that reflects the policy changes.
February 2023
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on February 23–24, 2023. The policies are effective immediately.
- Overall Revisions to Bylaws
The revisions standardize terminology, streamline and condense language, and clarify procedures and requirements. - Criteria Revision Process
The policy changes allow greater flexibility for staff to design appropriate methods for engaging member institutions and other stakeholders in the process of reviewing and revising the Criteria for Accreditation. - Fraud and Abuse
The policy changes clarify that allegations of fraud and abuse can be submitted to HLC by various external parties and that any allegations will be reviewed using the appropriate mechanism under HLC policy. - Heightened Cash Monitoring
The policy changes clarify that institutions placed on the Reimbursement or Heightened Cash Monitoring 2 (HCM2) payment methods by the Federal Student Aid Office of the U.S. Department of Education are required to submit a Provisional Plan to HLC for approval. The changes also modify the Obligations of Membership to require institutions to notify HLC when they are placed on the HCM2 or Reimbursement payment method. - Recruiting, Admissions and Related Enrollment Practices
The policy changes align HLC’s policy on Recruiting, Admissions and Related Enrollment Practices with new federal regulations on recruitment. The revisions clarify HLC’s expectations and specify that the policy applies to all aspects of an institution’s enrollment process, including financial aid. - Responding to Emergencies and Institutional Disruptions
The new policy establishes that HLC may leverage its existing policies and, if available, flexibilities permitted by the U.S. Department of Education or other entities to allow institutions time to manage an emergency or severe disruption while maintaining a high level of academic quality. Institutions will be required to request accommodations, and HLC will make determinations on a case-by-case basis as to what accommodations are available and appropriate.
November 2022
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on November 3, 2022. The policies are effective immediately.
- Clarification Regarding “Days”
The policy change implements consistent use of the term “days” in HLC policies to signify calendar days. In instances where a different use is required, these instances are stated in the applicable policy as “business days.” - Rules Regarding Prior Peer Reviewer Evaluation and Decision-Making Activity
HLC’s policies include requirements indicating when peer reviewers may be assigned to an evaluation of an institution after having previously participated in an evaluation or HLC Academy activity involving the same institution. The adopted changes set similar requirements for members of the Institutional Actions Council (IAC). The changes also indicate when peer reviewers and IAC members may be assigned to an evaluation or decision-making activity regarding an institution after having previously participated in an IAC decision-making activity involving the same institution. - Special Monitoring
The policy changes provide HLC’s President more flexibility in designing protocols that capitalize on a variety of existing mechanisms to gather information, evaluate evidence and make appropriate decisions that serve the interest of students and the public. Additional changes clarify triggering circumstances, explain Advisory Visits and detail the impact of designations on certain types of substantive-change activity.
2021–22 Academic Year
June 2022
The Higher Learning Commission’s Board of Trustees adopted the following policy and bylaw changes on second reading at its meeting on June 23, 2022. The policies and bylaws are effective immediately.
- Board of Trustees Nominations Process
The bylaw changes modify the process for nominating trustees to serve on HLC’s Board of Trustees. Under the previous process, a Nominating Committee comprised of individuals from member institutions provided a pool of nominees to a committee of Board members, who developed a slate of nominees to stand for election. The adopted changes simplify the process such that the Board committee serves as the nominating committee. - Corporate Formalities
The bylaw changes formalize the role of Treasurer as a corporate officer, provide that HLC’s President may appoint other employees to serve as a corporate officer, and clarify language related to election, resignation and removal of officers. - Grounds for Certain Adverse Actions
The policy changes standardize the grounds for denial or withdrawal of candidacy and withdrawal of accreditation. The changes also establish that certain additional Board procedures are not applicable in situations where the Board withdraws candidacy or withdraws accreditation because an institution has ceased to operate as an institution of higher education or has lost its legal authorization to operate as an institution of higher education and grant degrees in HLC’s jurisdiction. - Institutional Practices for Verification of Student Identity and Protection of Student Privacy
The policy change clarifies that institutions’ obligations to use processes that protect student privacy go beyond student identity verification in distance and correspondence education offerings. The change aligns HLC policy more closely with federal regulations. - Public Member Representation on the Institutional Actions Council
The policy changes clarify that, per federal regulations, every HLC decision-making body, including individual committees of the Institutional Actions Council (IAC), must have one public member for every seven committee members. - Publication of Policies on Transfer of Credit
Federal regulations provide that an institution’s policies related to transfer of credit must disclose certain information. Further, an institution is required to make these policies publicly available. The adopted policy change ensures that HLC explicitly articulates the minimum requirements imposed by federal regulation are required to be included in an institution’s policies related to transfer of credit. - Student Achievement and Other Data Reporting
The policy changes identify what data must be disclosed by all institutions; take into account the relevance of mission-specific data in the context of student achievement; conform language in policy with instructions appearing in HLC’s Federal Compliance and Institutional Update materials; and reinforce HLC’s expectations that underperforming institutions will develop effective strategies to continuously improve. - Substantive Change Policy and Review Processes
The policy changes articulate the purpose of HLC’s substantive change review and approval process and clarify procedures related to desk reviews and approval of substantive change requests by HLC staff. The changes also specify substantive change requirements for institutions under a provisional certification with the U.S. Department of Education, and add a requirement in the Obligations of Membership regarding institutions notifying HLC when they are placed under or removed from a provisional certification status.
February 2022
The Higher Learning Commission’s Board of Trustees adopted the following policy and bylaw changes on second reading at its meeting February 25, 2022. They are effective immediately.
- Accelerated Process for Initial Accreditation
So long as an institution meets all other qualifications articulated in the policy, the adopted changes permit an institution that, in its current form, is institutionally accredited by a state entity that is recognized by the U.S. Department of Education as an institutional accreditor of degree-granting institutions of higher education to be considered for accelerated initial accreditation. Additionally, the changes clarify that nothing in HLC policy nor federal regulations requires HLC to consider any non-member institution for initial accreditation. - Board of Trustees Term Length
The adopted bylaw change extends the total possible term length for trustees from eight years to up to 12 years. The change also simplifies the criteria and process for when a trustee may serve additional terms beyond their initial four-year term. - Decision-Making Options Related to the Assumed Practices and Federal Compliance Requirements
The adopted changes clarify the decision-making options available when an institution is out of compliance with any Assumed Practice or Federal Compliance Requirement but otherwise in compliance with the Criteria for Accreditation. - External Consultation
The adopted changes consolidate existing policies that allow HLC to exercise its discretion in seeking assistance from external experts where appropriate to advance the work of its staff members, peer reviewers and members of HLC decision-making bodies without such external experts participating in any evaluative process. - Processes for Reaffirmation of Accreditation
The adopted changes reorganize, consolidate and clarify policies related to processes for Reaffirmation of Accreditation and the Standard and Open Pathways. The changes also revise the meaning of Reaffirmation of Accreditation and extend the maximum timeframe for reaffirmation. - Recognized Accreditors
The adopted changes standardize the use of the phrase “recognized accreditor” to refer to those accreditors “recognized by either the U.S. Department of Education or the Council for Higher Education Accreditation.”
November 2021
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting November 4–5, 2021. They are effective immediately.
- Evaluating the Criteria for Accreditation
The adopted change adds a statement that elaborates on HLC’s increasing commitment to consideration of varying institutional missions, models and approaches within higher education when evaluating the Criteria for Accreditation. The change also clarifies that peer reviewers are expected to exercise their judgment as to whether an institution meets the Criteria at the level of each Core Component and Criterion, rather than at the level of the subcomponents, and to prepare their team reports accordingly. - Additional Board procedures
The policy change clarifies when certain procedures related to due process, including a Board Committee Hearing, are available to an institution prior to the Board taking action.
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