Denial or Withdrawal of Status

Withdrawal of Accreditation 

The Board of Trustees shall only take action to withdraw the accreditation of an institution when that institution has been determined to be out of compliance with one or more HLC requirements. The specific grounds for withdrawal of accreditation shall be that the institution does not meet one or more Criteria for Accreditation and/or is not in compliance with other HLC requirements, which may include the Federal Compliance Requirements, the Assumed Practices, the Eligibility Requirements or the Obligations of Membership during the accreditation period.  

This determination may be made by the Board after any of the following: 

1. a focused visit, advisory visit, comprehensive evaluation, or other peer review evaluation; 
2. a period of Notice or Probation; 
3. a Show-Cause process; 
4. upon recommendation of the President, if an on-site visit has occurred within the year preceding the recommendation;  
5. upon recommendation of the President, regardless of whether an on-site visit has occurred within the year preceding the recommendation, if the institution fails to comply with the Obligations of Membership within a reasonable period after receiving notice of noncompliance; 
6. upon recommendation of the President, regardless of whether an on-site visit has occurred within the year preceding the recommendation, if the institution ceases to operate as an institution of higher education; or 
7. upon recommendation of the President, regardless of whether an on-site visit has occurred within the year preceding the recommendation, if the institution fails to maintain authorization to operate as an institution of higher education and grant degrees in HLC’s jurisdiction. 

Other than a team recommendation to withdraw accreditation arising from an advisory visit process, which is referred to the President, any team recommendation to withdraw accreditation will automatically be referred to an Institutional Actions Council Hearing Committee. The Board will consider both the team recommendation and the Institutional Actions Council Hearing Committee recommendations in its deliberations. A recommendation for withdrawal of accreditation by the President is made directly to the Board, and there is no Institutional Actions Council Hearing in this case. HLC shall, in keeping with INST.E.70.010 Additional Board Procedures, make a Board Committee Hearing available to the institution prior to a decision by the Board. 

An institution that is out of compliance with HLC requirements need not have been placed on Probation or Show Cause prior to a withdrawal action. The Board shall immediately act to withdraw the accreditation of any institution it determines has been out of compliance with HLC requirements for more than two years, unless it grants such institution an extension for good cause not exceeding one year based on all of the following factors:  

1. Clear evidence of substantial progress towards meeting HLC requirements, and in particular, the Criteria for Accreditation and Core Components, including evidence of substantial implementation of necessary improvements, in the majority of areas in which the institution has been previously found to be non-compliant; 
2. Verifiable plans to cure the remaining areas of non-compliance or any other areas of non-compliance identified in the action granting the extension by the end of the extension period; 
3. Sufficient capacity and resources in place to cure the identified areas of non-compliance during the extension; and 
4. Likelihood that the institution will be able to demonstrate compliance with HLC requirements by the end of the extension period. 

Withdrawal of accreditation is an adverse action and thus is not a final action and is subject to appeal. 

In no event shall the final effective date of withdrawal be prior to the conclusion of the current academic term inclusive of the institution’s issuance of degrees immediately following such term. The Board in its sole discretion 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. 

Public Disclosure After Withdrawal of Accreditation 

A Public Disclosure Notice for an institution that has had its accreditation withdrawn will be available on HLC’s website shortly after, but not more than one (1) business day after, HLC notifies the institution of the action. Since an institution may appeal this decision by HLC, the public notice shall also include clear reference to the appeal options available to the institution and official comments that the institution provides to be included in the notice. An institution under withdrawal must notify its Board members, administrators, faculty, staff, students, prospective students, and any other constituencies about the action in a timely manner not more than seven (7) business days after receiving the action letter from HLC; the notification must include information on how to contact HLC for further information; the institution must also disclose this status whenever it refers to its HLC status. 

Denial of Accreditation 

The Board of Trustees shall consider denying accreditation to an institution only when that institution has been determined to be out of compliance with the requirements for granting initial accreditation, as detailed in HLC’s policy on Candidacy and Initial Accreditation (INST.B.20.020), or that the institution fails to demonstrate conformity with the Obligations of Membership during its candidacy period. This determination may be made by the Board after a comprehensive evaluation for initial accreditation. 

A team recommendation to deny accreditation will automatically be referred to an Institutional Actions Council Hearing Committee. The Board will consider both the team recommendation and the Institutional Actions Council Hearing Committee recommendations in its deliberations. HLC shall make a Board Committee Hearing available to the institution prior to a decision by the Board, in keeping with INST.E.70.010 Additional Board Procedures. 

Denial of accreditation is an adverse action and thus is not a final action and is subject to appeal except in cases where the Board, in taking such action, denies an institution’s early application for accreditation prior to the end of the institution’s candidacy period and thereby continues the institution’s candidacy status or extends that status to a fifth year, as provided for in HLC policy.  

In no event shall the effective date of the denial of accreditation be prior to the conclusion of the current academic term inclusive of the institution’s issuance of degrees immediately following such term. The Board in its sole discretion may also consider an effective date that takes into account a reasonable period not exceeding 120 days (unless HLC grants a good cause extension) for the institution to conduct a Teach Out in accordance with federal regulations and other relevant HLC policies and procedures.  

Denial or Withdrawal of Candidacy Status 

The Board of Trustees shall only take action to deny or withdraw the candidacy status of an institution that fails to meet the requirements for achieving and maintaining Candidacy, as detailed in HLC’s policy on Candidacy and Initial Accreditation (INST.B.20.020). 

This determination may be made by the Board after any of the following: 

1. a focused visit, advisory visit, comprehensive evaluation or other peer review evaluation; 
2. upon recommendation of the President, if an on-site visit has occurred within the year preceding the recommendation;  
3. upon recommendation of the President, regardless of whether an on-site visit has occurred within the year preceding the recommendation, if the institution fails to comply with the Obligations of Membership within a reasonable period after receiving notice of noncompliance; 
4. upon recommendation of the President, regardless of whether an on-site visit has occurred within the year preceding the recommendation, if the institution ceases to operate as an institution of higher education; or  
5. upon recommendation of the President, regardless of whether an on-site visit has occurred within the year preceding the recommendation, if the institution fails to maintain authorization to operate as an institution of higher education and grant degrees in HLC’s jurisdiction. 

Other than a team recommendation to deny or withdraw candidacy arising from an advisory visit process, which is referred to the President, any team recommendation to deny or withdraw candidacy will automatically be referred to an Institutional Actions Council Hearing Committee. The Board will consider both the team recommendation and the Institutional Actions Council Hearing Committee recommendations in its deliberations. A recommendation for denial or withdrawal of candidacy by the President is made directly to the Board, and there is no Institutional Actions Council Hearing in this case. In cases involving a recommendation to withdraw candidacy, HLC shall, in keeping with INST.E.70.010 Additional Board Procedures, make a Board Committee Hearing available to the institution prior to a decision by the Board,. 

Denial or withdrawal of candidacy status is an adverse action and thus is not a final action and is subject to appeal.  

In no event shall the final effective date of withdrawal of candidacy status be prior to the conclusion of the current academic term inclusive of the institution’s issuance of degrees immediately following such term. The Board in its sole discretion 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. 

Public Disclosure After Denial of Accreditation or Denial or Withdrawal of Candidacy Status 

A Public Disclosure Notice for an institution that has had accreditation denied or candidacy withdrawn, or had candidacy denied, will be available on HLC’s website shortly after, but not more than one (1) business day after, HLC notifies the institution of the action. Since an institution may appeal this decision by HLC (except in cases where HLC has extended an existing candidacy), the public notice shall also include clear reference to the appeal options available to the institution and official comments that the institution provides to be included in the notice. An institution under withdrawal or denial must notify its Board members, administrators, faculty, staff, students, prospective students, and any other constituencies about the action in a timely manner not more than seven (7) business days after receiving the action letter from HLC; the notification must include information on how to contact HLC for further information; the institution must also disclose this status whenever it refers to its HLC status. 

Policy History

Last Revised: June 2022 
First Adopted: January 1983 
Revision History: revised November 1994, May 2002, June 2006, February 2011, February 2012, February 2014, June 2020, November 2020, June 2021, November 2021, February 2022, June 2022 
Notes: Policies combined November 2012 – 2.5(f), 2.5(f)1, 2.5(f)2, 2.5(f)3, 2.5(f)4. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”