Show-Cause (Procedural Order)

Show-Cause is a public procedural order that attaches to an institution’s accreditation status. A Show-Cause Order is not a sanction.

A Show-Cause Order shifts the burden to the institution to promptly provide evidence, without a period of remediation, indicating that its accreditation should not be withdrawn. The basis for the issuance of a Show-Cause Order will be the determination by the Board of Trustees 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. A Show-Cause Order is appropriate where review of an institution’s compliance with HLC requirements through a comprehensive evaluation for Show-Cause, rather than a remediation period on Probation, or withdrawal of accreditation, is warranted.

The institution remains accredited while it is on Show-Cause. The issuance of a Show-Cause Order is a final action and is not subject to appeal.

Process for Imposing Show-Cause

Only the Board shall take action to place an institution on Show-Cause.

A recommendation by a team of HLC peer reviewers to place an institution on Show-Cause, other than one arising from an advisory visit process, 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.

The HLC president makes a recommendation for Show-Cause resulting from an advisory visit process directly to the Board.

In all cases, the Board will act on a recommendation to impose Show-Cause only if the institution has been given at least 14 days to submit a written response to the recommendation.

The Board is not required to have placed an institution on Probation prior to issuing a Show-Cause Order.

Length of Show-Cause

The period for a Show-Cause Order shall not exceed one year. The Board may shorten the Show-Cause period to less than one year based on factors including, but not limited to, the following:

1. The institution has spent a period of time immediately preceding the issuance of the Show-Cause Order on Probation;
2. Findings of noncompliance pose a serious risk of imminent harm or danger to students.

Review Processes While on Show-Cause

In placing an institution on Show-Cause, the Board will notify the institution of the specific areas of noncompliance that led to the action to impose Show-Cause and the next steps as part of the Show-Cause process.

The Board’s action will require that an institution placed on Show-Cause:

1. Submit in a timeframe defined by the Board a Provisional Plan comporting with HLC’s Teach Out requirements, as articulated in applicable policies.
2. Submit an Assurance Filing that provides evidence that the institution continues to meet the Criteria for Accreditation, the Assumed Practices, and the Federal Compliance Requirements and has resolved the issues that led to the findings of noncompliance identified in the Show-Cause Order.
3. Host an on-site evaluation team to validate the report.

The comprehensive evaluation for Show-Cause generally will be conducted in accordance with established HLC procedures for comprehensive evaluations.

The HLC president shall determine whether the institutional liaison or other HLC staff member will accompany the team conducting a comprehensive evaluation visit for Show Cause.

HLC shall retain discretion to determine the length of the comprehensive evaluation visit for Show-Cause or to require that team members conduct additional on-site visits to the institution’s facilities to examine specific issues.

The team shall recommend whether to remove Show-Cause, specifying any routine monitoring that should be attached to the removal; whether to recommend Notice, if the institution is at risk of noncompliance; or, in the event of ongoing noncompliance, whether to assign Probation, subject to the maximum timeframe for noncompliance articulated in INST.E.60.010 Denial or Withdrawal of Status, or withdraw accreditation.

An institution shall have the opportunity to provide a written response to the written report of a comprehensive evaluation for Show-Cause following HLC policies for the provision of institutional responses. An institution shall have at least 14 days to prepare and submit an institutional response to the team report prior to review and action through HLC’s decision-making processes.

Board Committee Hearing in Show-Cause

HLC shall make a Board Committee Hearing available to the institution prior to a decision by the Board concluding the Show-Cause Order process, in keeping with INST.E.70.010 Additional Board Procedures.

Process for Removal of a Show-Cause

Only the Board may take action to remove a Show-Cause Order.

At the end of the Show-Cause period, the Board will review the recommendation of the team, as well as any response filed by the institution.

If the Board finds that the institution has ameliorated the findings of noncompliance identified by the Board detailed in the Show-Cause Order and that it otherwise meets the Criteria for Accreditation, the Assumed Practices and the Federal Compliance Requirements, the Board may remove the Show-Cause Order.

The Board may remove the institution from Show-Cause subject to a period of Notice if the institution has demonstrated compliance with HLC requirements but remains at risk of noncompliance with the Criteria for Accreditation.

If the institution has not demonstrated (1) that it has ameliorated each area of noncompliance identified by the Board detailed in the Show-Cause Order and (2) that it meets all HLC requirements, the Board may withdraw accreditation or impose Probation, subject to the maximum time period of noncompliance as stated in INST.E.60.010 Denial or Withdrawal of Status is not exceeded.

Pathways Assignment

An institution placed on a Show-Cause Order is removed from any reaffirmation Pathway until the Show-Cause Order has been removed.

If the Board removes the institution from Show-Cause and does not withdraw accreditation or place the institution on Probation, the Board shall reaffirm the institution’s accreditation and shall assign the institution to the Standard Pathway. The institution will have a comprehensive evaluation to reaffirm accreditation no later than four years after the Board acts to remove Show-Cause. The Board may also require routine monitoring as a part of its action. The institution will remain on the Standard Pathway until it completes a full 10-year cycle. If at that time the institution’s accreditation is reaffirmed without further sanction, the institution may be recommended as eligible to choose the Open Pathway if otherwise eligible.

Substantive Change While on Show-Cause

In general, HLC will not consider for approval any substantive change applications during the Show-Cause period, other than a Provisional Plan as required under this policy and any accompanying Teach-Out Agreements, unless the institution can demonstrate that the change is required by law or by the requirements of another recognized accreditor or is essential for the institution to demonstrate compliance with HLC requirements.

Any application may be denied or deferred by staff or by the Institutional Actions Council Committee until after the Board has removed Show-Cause for any reason as provided in HLC policy, including if the institution has not demonstrated that the change is required by law or by the requirements of another recognized accreditor or is essential for the institution to demonstrate compliance with HLC requirements.

An approval of a substantive change for an institution on Show-Cause is not indicative of a determination by HLC that an institution has corrected identified areas of noncompliance related to the Show-Cause Order.

Under the federal regulations, additional requirements for prior approval for certain substantive changes apply specifically to institutions placed under a Show-Cause Order after July 1, 2020, as well as for three academic years following removal of such Show-Cause Order, and may be found in HLC’s policies on substantive change (see INST.G.10.010 Substantive Change).

An institution on Show-Cause is not eligible for the Notification Program for Additional Locations and shall be removed from that program by staff after being placed on Show-Cause and for a period of three years thereafter. Additional information may be found in HLC’s policies on substantive change (see INST.G.10.020 Review of Substantive Change).

Public Disclosure of Show-Cause

A Public Disclosure Notice for an institution on Show-Cause will be available on HLC’s website after, but not more than one business day after, HLC notifies the institution of the action issuing the Show-Cause Order. An institution on Show-Cause 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 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 accreditation.  

Policy History

Last Revised: October 2024 
First Adopted: June 2000 
Revision History: June 2006, November 2012, February 2014, February 2015, November 2018, June 2020, November 2020, November 2021, February 2022, June 2022, November 2022, June 2023, October 2024 
Notes: Policies combined November 2012 – 2.5(c), 2.5(c)1, 2.5(c)2, 2.5(c)3. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”