Revised Federal Compliance Requirements

Review of Federal Compliance Requirements
Policy number: FDCR.A.10.010

HLC member institutions must be in compliance with each of HLC’s Federal Compliance Requirements at all times.

Federal Compliance Requirements apply to an institution regardless of whether the institution is participating in Title IV programs. However, an institution that does not participate in Title IV programs shall be exempted from the Federal Compliance Requirement related to demonstrating that the institution is meeting its Title IV program responsibilities.

An institution shall provide evidence of meeting the Federal Compliance Requirements as part of a comprehensive evaluation for Candidacy, Initial Accreditation, Probation, Show-Cause and Reaffirmation of Accreditation, and as otherwise requested by HLC, for example through the Institutional Update or as part of substantive change processes.

An institution determined not to be in compliance with any Federal Compliance Requirement, even if in compliance with all other HLC requirements, may be subject to routine monitoring, Probation, Show-Cause, or an adverse action, as provided in HLC policy, based on the gravity of the finding as measured by (a) in the case of Probation, the extent to which a substantial remediation period is necessary to address such non-compliance or; (b) in the case of Show-Cause or an adverse action, the extent to which the finding suggests that the institution should not remain accredited.

HLC may require special monitoring related to an institution’s status with regard to the Federal Compliance Requirements and any resulting implications for its compliance with other HLC requirements, as appropriate, when findings by the U.S. Department of Education, a state or another recognized accreditor indicate there may be significant noncompliance with applicable laws or regulations, including the Higher Education Act, as amended, or that the integrity of the institution and its educational programs might be in jeopardy.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 1996, effective September 1996
History:* revised February 1998; edited October 2003; renumbered November 2010 (former policy number 1.7); revised June 2012; renumbered November 2012 (former policy number 4.0); revised June 2019 (effective September 2019); revised June 2020; revised November 2020; edited February 2021; revised February 2022; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Assignment of Credits, Program Length and Tuition
Policy number: FDCR.A.10.020

An institution shall be able to equate its learning experiences with semester or quarter credit hours using practices common to institutions of higher education; to justify the lengths of its programs in comparison to similar programs found in accredited institutions of higher education; and to justify any program-specific tuition in terms of program costs, program length, and program objectives.

Assignment of Credit Hours

An institution’s assignment and award of credit hours shall conform to commonly accepted practices in higher education. An institution seeking, or participating in, Title IV programs, shall demonstrate (1) that it has policies determining the credit hours awarded to courses and programs in keeping with commonly accepted practices in higher education and with any federal definition of the credit hour, as may appear in federal regulations; and (2) that it has procedures that result in an appropriate awarding of institutional credit in conformity with the policies established by the institution.

HLC may sample or use other techniques to review selected institutional programs to ensure the reliability and accuracy of the institution’s assignment of credit.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 1996, effective September 1996
History:* revised November 2011; revised June 2012 (policies combined, see note); renumbered November 2012 (former policy number 4.0(a)); revised June 2019 (effective September 2019); revised November 2020; edited February 2021; revised November 2025 (effective September 2026)
Notes: Policies combined June 2012: 3.10, 3.10(a), 3.10b), and 3.10(c).

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Institutional Records of Student Complaints
Policy number: FDCR.A.10.030

An institution shall keep a record of the student complaints it has received, including its processing of those complaints, and how that processing aligns with the institution’s policies and procedures on the handling of grievances or complaints.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 1998
History:* revised August 1999; revised and renumbered June 2012; renumbered November 2012 (former policy number 4.0(b)); revised June 2019 (effective September 2019); edited February 2021; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Periodic Review and Publication of Transfer Policies
Policy number: FDCR.A.10.040

As aligned with HLC’s Assumed Practices, each institution shall determine its own policies and procedures for accepting transfer credits.

An institution must periodically review its transfer policies and procedures to assess (1) their clarity to those who administer them, to the students who follow them, and to employers and other stakeholders; (2) consistency of their interpretation and application throughout the institution; and (3) their responsiveness to new types of learning opportunities outside institutions of higher education.

An institution shall have transfer policies that are publicly disclosed and that include, at a minimum:

1. Any established criteria the institution uses regarding the transfer of credit earned at another institution and any types of institutions or sources from which the institution will not accept credits;
2. A list of institutions with which the institution has established an articulation agreement; and
3. Written criteria used to evaluate and award credit for prior learning experience including, but not limited to, service in the armed forces, paid or unpaid employment, or other demonstrated competency or learning.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: October 1988
History:* revised February 2011; revised February 2009; revised and renumbered June 2012; renumbered November 2012 (former policy number 4.0(c)); revised April 2013; edited February 2021; revised June 2022; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Institutional Practices for Verification of Student Identity and Protection of Student Privacy
Policy number: FDCR.A.10.050

Student Identity Verification

An institution offering distance education or correspondence education, as such terms may be defined in federal regulations, shall have processes through which the institution establishes that the student who registers in the distance education or correspondence education courses or programs is the same student who participates in and completes and receives the academic credit.

In verifying the identity of students who participate in class or coursework the institution may make use of a one or more methods, at the option of the institution, which may include but need not be limited to: (1) secure login credentials; (2) proctored examinations; and (3) technologies and practices that are effective in verifying the identity of students. Institutions must notify students at the time of registration or enrollment of any projected additional student charges associated with the verification of student identity such as separate fees charged by proctoring services, etc.

Student Privacy

All institutions must maintain processes for ensuring the protection of student privacy. Such processes, including any methods related to student identity verification, must also implement reasonable and appropriate safeguards to protect student privacy.

Additional Details Regarding HLC Review

HLC will review an institution’s student identity verification protocols as part of applicable substantive change processes involving distance education and correspondence education.

HLC will review an institution’s processes for ensuring the protection of student privacy during all comprehensive evaluations within the context of the Criteria for Accreditation.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 2009
History:* revised February 2010; revised and renumbered June 2012; renumbered November 2012 (former policy number 4.0(d)); revised June 2019 (effective September 2019); edited February 2021; revised June 2022; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Title IV Program Responsibilities
Policy number: FDCR.A.10.060

As applicable, an institution must comply with Title IV program responsibilities.

Additional Details Regarding HLC Review

In accordance with HLC policy, and as otherwise requested by HLC, institutions will make available for HLC review any documents concerning the institution’s compliance with Title IV program responsibilities, including any results of financial or compliance audits and program reviews, audits reports by the Office of Inspector General of the U.S. Department of Education, and any other information related to its fulfillment of its Title IV program responsibilities.

Default Rates

An institution shall make reasonable efforts to ensure that its students do not take on excessive debt either through federal or private loans. An institution shall also demonstrate that it is appropriately fulfilling its Title IV program responsibilities to manage its student loan program, to minimize student default on such loans, and to provide accurate information to the U.S. Department of Education when required in conjunction with its loan program. Upon request, an institution will make available to HLC information about its participation in federal and private loan programs as well as its three-year Title IV default rates and any default reduction plans provided to the U.S. Department of Education.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 1996, effective September 1996
History:* revised February 1998; edited October 2003; renumbered November 2010; revised and renumbered June 2012; renumbered November 2012 (former policy number 4.0(e)); revised June 2019 (effective September 2019); edited February 2021; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Disclosure of Student Achievement Information
Policy number: FDCR.A.10.070

An institution’s website for students and the public shall include a webpage containing accurate information regarding student achievement. The institution must disclose data that address the broad variety of its student populations and programs, including at the undergraduate and graduate levels as applicable. This information must include, at a minimum, retention, completion, required state licensure exam pass data, and data about the institution’s students after transfer or graduation (such as continuing education, job placement and earnings). The institution must also accurately disclose which student populations are excluded from the data.

The data may also include information appropriate for the mission of the institution and its student populations.

All student achievement information must be presented in plain language with any technical terms defined and the institution’s methodology for compiling the data included.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: August 1990
History:* revised August 1996 (effective September 1996); renumbered February 2010; revised and renumbered June 2012; revised November 2012 (policies combined, see note); revised October 2014; revised June 2019 (effective September 2019); revised November 2020; edited February 2021; revised June 2022; revised November 2025 (effective September 2026)
Notes: Policies combined November 2012: 4.0(f), 4.0(g), 4.0(j).

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Standing With States and Other Accreditors
Policy number: FDCR.A.10.080

An institution shall fairly represent to HLC and to the public its history and status with other recognized accreditors and with each state in which it is authorized or licensed. This obligation includes accurately disclosing when an action affecting its accreditation status has been taken by any state in which it is authorized or licenses or by any other recognized accreditor.

An institution shall disclose to HLC any pending or final state actions that affect the institution’s legal status or authority to grant degrees or offer programs. An institution shall disclose to HLC any pending or final adverse actions by a recognized accreditor or an action to impose a sanction, Show-Cause or other negative action.

Additional Details Regarding HLC Review

If another recognized accreditor or a state has taken any of these actions regarding an institution that is seeking accreditation with HLC, HLC, through its decision-making processes and subject to the Eligibility Requirements, will carefully weigh these matters in reaching its own decision to grant candidacy or initial accreditation.

If another recognized accreditor or if a state has taken any of these actions regarding a member institution, HLC will undertake a prompt review of the institution and the related action to determine whether additional review or HLC action, including sanction or withdrawal of accreditation, is appropriate.

HLC will make required notifications related to such actions to the U.S. Department of Education as outlined in COMM.C.10.030, Relations With the U.S. Government, State Higher Education Agencies, and Other State Offices.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: January 1983
History:* revised, and renumbered June 2012 (policies combined, see note); renumbered November 2012 (former policy number 4.0(i)); revised June 2019 (effective September 2019); edited February 2021; revised June 2021; revised February 2022; renumbered February 2025 (former policy number FDCR.A.10.090); revised November 2025 (effective September 2026)
Notes: Policies combined June 2012: 9.1, 9.2, 9.3, 9.4.

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Fraud and Abuse
Policy number: FDCR.A.20.010

An institution shall not engage in fraud and abuse, as outlined in state and federal law and regulation, or in practices or procedures that are designed to, or have the tendency to, create a falsification, deceive, or deliberately mislead.

Additional Details Regarding HLC Review

Allegations of fraud and abuse may be received by HLC from external sources, including but not limited to, the federal government, a state government, or through the institutional complaints process. If HLC receives an allegation of fraud and abuse, HLC will determine whether the alleged fraud and abuse would constitute a violation of one or more HLC requirements. In reviewing any allegation of fraud and abuse, HLC may consider the nature of the allegation, whether the alleged fraud and abuse appears to meet HLC’s understanding of fraud and abuse as outlined in this policy, other HLC policies, or in federal or state definitions of fraud and abuse, and whether the source of the allegation has provided any evidence of the alleged fraud and abuse.

HLC will review an allegation of fraud and abuse through an appropriate mechanism provided for in HLC policy and procedure based on the source and nature of the allegation. An institution that has been determined, through the appropriate review mechanism, to have engaged in fraud and abuse as outlined in this policy shall be out of compliance with HLC requirements as applicable, including those related to institutional integrity, and shall be subject to appropriate action, up to and including withdrawal of accreditation.

Evidence of fraud and abuse may also arise from any HLC evaluative activity. In such cases, an institution shall be out of compliance with HLC requirements as applicable, including those related to institutional integrity, and shall be subject to appropriate action, up to and including withdrawal of accreditation.

HLC shall report incidents of fraud and abuse to the U.S. Department of Education as outlined in COMM.C.10.030, Relations with the U.S. Government, State Higher Education Agencies, and Other State Offices, following the conclusion of HLC’s review of the allegation or evaluative activity. HLC may also refer such allegations to appropriate state and federal agencies.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 2017
History:* edited February 2021; revised February 2023; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.

Recruiting, Admissions and Related Enrollment Practices
Policy Number: FDCR.A.20.020

An institution is expected to act with fundamental fairness and transparency in all aspects of the enrollment process. For purposes of this policy this includes lead generation, recruiting activities, admissions processing through matriculation, and related practices such as financial aid determinations and administration. This expectation applies comprehensively to prospective students and, to the extent applicable, current students (referred to collectively in this policy as students).

In addition to requirements set forth in other HLC policies, an institution is expected to comply with the following obligations:

1. The institution treats students ethically, respectfully and professionally in the marketing, recruiting, admissions and financial aid process so that students can make informed enrollment decisions about matters such as enrollment and financial aid without being subjected to high-pressure tactics from the institution or a related contractor, including but not limited to:
   1. Falsely claiming that enrollment spots are limited or taking advantage of students’ lack of understanding to pressure students to enroll;
   2. Pressuring students to make an immediate financial aid decision;
   3. Engaging in repeated unsolicited contact with the student after clear communications from the student that further contact is unwelcome.
2. All institutional recruiting, admissions and financial aid personnel have appropriate education, job titles, and skills for their role and are overseen by the institution, which enforces a formal code of conduct for all such personnel; the institution also oversees any third-party contractors who provide recruiting, admissions and financial aid services and assures that any personnel who work with their students have similar education, skills and experience as personnel employed by the institution. The institution ensures consistent, accurate information and a high quality of service is provided. As applicable, the institution exercises oversight that ensures adherence to any regulations or other requirements governing recruiting activities in particular areas, such as, for example, athletics.
3. The institution ensures that its recruiting, admissions and financial aid personnel accurately describe the nature of their role.
4. All information that the institution provides to students during any aspect of the enrollment process is accurate, complete and up to date.
   1. If an institution uses student job placement data in any marketing or recruitment contet, it must also publicly disclose these data on its website along with information necessary to substantiate the truthfulness of its marketing and recruitment materials.
   2. If an institution chooses to reference its accreditation status in advertising and recruiting materials or other document or location, such as its website, that disclosure will accurately explain its status with HLC and the academic programs, locations and other institutional activities included in its accreditation. This obligation includes accurately disclosing when an action affecting its accreditation status has been taken by any other institutional or programmatic accrediting body.

Such information is provided without any requirement that students provide their contact information.

5. The institution promptly honors any request from a student to remove that student’s name from phone, email or other contact lists. Student information collected through any aspect of the institution’s enrollment processes is maintained and protected as outlined in the institution’s data privacy policy, which must be prominently posted on the institution’s website.
6. Institutional recruiters, admissions officers, financial aid officers or appropriate third parties engaged in similar roles on the institution’s behalf may answer questions about the student application process for admissions and financial aid, but in no case will such personnel complete applications for students without student permission or apply the signature of a student to an application.
7. If an institution requires a student to sign an enrollment agreement, the enrollment agreement is limited to basic information about course of study, tuition and fees, and other related information. Any enrollment agreement shall not include language limiting a student’s ability to: (1) file a complaint with an accreditor or state agency; (2) take legal action in the event that any dispute resolution processes agreed to by the institution and the student are unsuccessful in resolving the dispute to the satisfaction of the parties; or (3) seek to discharge a student loan through remedies available to borrowers under state or federal law. Students are provided sufficient time, as determined by the situation and any mandates in state law, to review any enrollment agreement and to consult with others as a part of that review process before being required to sign the document or lose an offer of admission and related financial assistance.
8. Students have the right and responsibility to register for each academic term in which they are eligible to enroll. The institution does not automatically register any student in the next term without that student’s affirmative consent to such registration or the opportunity for the student to cancel that registration before the student is assessed tuition or fees for that term.
9. Prior to enrolling a student in a program or major, the institution ensures that the student has had sufficient time to review the institution’s policies and procedures; to understand the amount of federal, state and institutional financial aid the student is eligible to receive; to learn how many credits previously earned, if any, will transfer and whether those transferred credits will be applied to requirements of the major or general education or the process; and to understand the timeline for evaluation of those credits.
10. The institution shall not induce or pressure a student to enroll by a specific deadline outside of the regular process of scholarship monies, institutional discounting, fee waivers, financial aid, other assistance or institution-branded gifts of nominal value.
11. The institution does not otherwise engage in aggressive or deceptive recruitment tactics or conduct, such as may be defined and prohibited by federal regulations. This prohibition includes, but is not limited to, the following institutional acts or omissions:
    1. Obtaining students’ contact information through websites that falsely claim to provide assistance with finding employment or obtaining government benefits;
    2. Discouraging students from consulting with parties unrelated to the institution prior to finalizing their decisions or commitments;
    3. Failing to timely respond to students’ requests for additional substantive information related to enrollment or loan obligations.
12. The institution shall not use threatening, abusive, or manipulative language to influence a student’s decision.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: November 2017, effective September 2019
History:* edited February 2021; revised February 2022; revised and renumbered February 2023 (former policy number CRRT.C.10.010); revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.