Obligations of Membership

While seeking and holding membership with HLC, an institution voluntarily agrees to meet obligations set forth by HLC as follows:

1. The institution participates in periodic evaluation through the structures and mechanisms set forth in HLC policies, submission of reports as requested by HLC, filing of the Institutional Update, and any other requirements set forth in its policies.
2. The institution regularly reviews current HLC policies and procedures. It adheres to such policies and procedures in good faith.
3. The institution designates an Accreditation Liaison Officer in accordance with HLC requirements.
4. The institution is candid, transparent, and forthcoming in its dealings with HLC, including cooperating with all requests for information from HLC.
5. The institution notifies HLC of any condition or situation that has the potential to affect the institution’s status with HLC, such as a significant reduction in program offerings, potential institutional closure or serious legal investigation (including, but not limited to, conditions or situations included in HLC’s policy on special monitoring).
6. As further defined and explained in HLC policy, the institution informs HLC of its relationship with any related entity wherein institutional decision-making is controlled by that entity and of any changes in that relationship that may affect the institution’s compliance with HLC accreditation requirements.
7. The institution describes itself in identical terms to HLC and to any other recognized accreditor or regulatory body with which it holds or seeks membership with regard to purpose, operating authority, governance, programs, locations, degrees, diplomas, certificates, personnel, finances, and constituents.
8. The institution notifies HLC when it receives a pending or final adverse action from or has been placed on sanction by any other recognized accreditor; if a state has issued a pending or final action that affects the institution’s legal status or authority to grant degrees; if it is placed on, or removed from, a provisional certification for participation in Title IV by the U.S. Department of Education; or if it is placed on, or removed from, the Reimbursement payment method or the Heightened Cash Monitoring 2 payment method by the U.S. Department of Education.
9. The institution notifies its constituents when it receives a pending or final adverse action from or has been placed on sanction by any other recognized accreditor or if a state has issued a pending or final action that affects the institution’s legal status or authority to grant degrees.
10. The institution notifies applicable constituents whenever HLC has required it to submit a Provisional Plan for approval, and provides an accurate explanation as to the rationale for that Provisional Plan.
11. The institution accepts that HLC will, in the interest of transparency to the public, publish outcomes from its accreditation process in accordance with HLC policy.
12. The institution portrays its accreditation status with HLC clearly to the public, including the status of its branch campuses and related entities. The institution posts the electronic version of HLC’s Mark of Accreditation Status in at least one place on its website, linking users directly to the institution’s status on HLC’s website.
13. The institution provides its constituents and applicants with any Public Disclosure Notice or Public Statement it receives from HLC and accurately communicates the significance of, and underlying reasons for, such Public Disclosure Notice or Public Statement as required by HLC.
14. The institution maintains prominently on its website a telephone number that includes an option for both current students and the public to speak with a representative of the institution.
15. The institution ensures that any information submitted to HLC generally will not include unredacted personally identifiable information (PII). If the institution submits information with unredacted PII because it is necessary for evaluative purposes or otherwise, it will clearly identify the information as such, if applicable.
16. The institution submits timely payment of dues and fees in accordance with the published Dues and Fees Schedule and accepts the fact of surcharges for late payment.
17. Prior to taking legal action against HLC, the institution agrees to submit to initial arbitration any dispute it may raise regarding an adverse action as such term is defined in HLC policy and that it is not able to resolve through HLC’s processes.
18. The institution agrees that in the event it, or any third party, takes legal action against HLC related to any accreditation action or makes any legal inquiries of HLC related to the institution, the institution shall, to the extent allowed by law, be responsible for all expenses, including but not limited to attorneys’ fees, expert witness, and related fees, incurred by HLC in responding to such legal inquiries and/or defending the action.

Meeting Obligations of Membership

Institutions must remain in compliance with the Obligations of Membership at all times. The HLC President shall make a final determination as to whether an institution is in violation of the Obligations of Membership such that Administrative Probation should be imposed. HLC may make use of any reasonable means to determine whether the institution has violated an Obligation of Membership including, but not limited to, seeking written information from the institution or scheduling one or more peer reviewers or staff members to meet with one or more institutional representatives either on-campus or through other appropriate method.

Administrative Probation

HLC staff or peer reviewer(s) may recommend an institution for Administrative Probation. Such recommendation shall be made to the President in writing and information about such recommendation shall be provided to the institution for an institutional response. The institution shall have a minimum of 14 days to respond in writing to the recommendation. The HLC President shall then review the recommendation and the institution’s response and make the decision whether to impose Administrative Probation. If the institution’s response is unsatisfactory, the HLC President shall place the institution on Administrative Probation for a period not to exceed ninety days. The HLC President will notify the institution of the imposition of the Administrative Probation and the conditions for its removal in writing. During the ninety-day time period, the institution will be expected to remedy the situation that led to the imposition of Administrative Probation. At the end of the ninety-day period, the institution shall provide evidence that it has remedied the conditions leading to Administrative Probation to the President. Such evidence may be reviewed directly by HLC Staff, or peer reviewers as necessary to confirm the institution’s compliance. Upon such validation, the President shall remove Administrative Probation.

If an institution fails to remedy the situation that led to Administrative Probation by the end of the ninety-day period, the HLC President shall take a recommendation concerning the institution to a decision-making body. Depending on the nature and the severity of the circumstances, such recommendation may involve a change in the institution’s Pathway for Reaffirmation of Accreditation at the time of its next comprehensive evaluation, removal from the Notification Program for Additional Locations, interim monitoring on the underlying issue that led to Administrative Probation, the application of a sanction, the issuance of a Show-Cause Order or the withdrawal of accreditation, in accordance with HLC policies and procedures.

Disclosure of Administrative Probation

Administrative probation is noted on an institution’s Statement of Accreditation Status along with the reason for the Administrative Probation until its removal.

Policy History

Last Revised: June 2023
First Adopted: January 1983
Revision History: Renumbered February 2010, February 2012, June 2013, February 2017, June 2019 (effective September 2020), June 2020, November 2020, February 2022, June 2022, November 2022, February 2023, June 2023
Notes: Policies combined November 2012 – 1.6, 2013 – 1.6(a), 1.6(b), 1.6(b)1. 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.B.30.020).