Prior HLC approval or notification may be required for substantive changes related to the initiation, modification or renewal of contractual arrangements. A contractual arrangement is an arrangement in which the institution outsources some portion of its academic programs—that is, degrees or certificates offered for academic credit—to:

1. An unaccredited institution.
2. An institution that is not accredited by an accreditor recognized by the U.S. Department of Education.
3. A corporation or other entity.

The services provided by the contractual party may include instruction, oversight of the curriculum, assurance of the consistency in the level and quality of instruction and in expectations of student performance, and/or the establishment of the academic qualifications for instructional personnel.

Arrangements That Do Not Require HLC Approval or Notification

HLC approval or notification is not required for arrangements between an institution and a third party in which any of the following conditions apply:

• The contract is solely for goods and services, such as food services and parking lot management, that are unrelated to the provision of academic programs.
• The institution offers the goods or services to another party. (Note that if the other party is an accredited or candidate for accreditation with HLC, that party may need to seek approval for the arrangement.)
• The contractual partner provides an internship that does not include a formal instructional component.
• The contractual partner provides only books or supplies supporting the academic program or only equipment or a platform for internet-based instruction.
• The contract between the contractual partner and the institution provides only for the articulation or transfer of courses that are transcribed as transfer credit on the students’ transcripts and not the outsourcing of courses carrying academic credit from the institution.

In addition, the following arrangements do not fall under the definition of a contractual arrangement and do not require HLC approval or notification:

• Consortial Arrangement: An arrangement in which all of the contractual partners providing goods or services related to academic programs are institutions accredited by agencies recognized by the U.S. Department of Education. As of February 2020, institutions are no longer required to notify HLC of or request prior approval for consortial arrangements.
• Credit Transfer: Based on its transfer policy, an institution independently determines whether credits already earned by a student from another institution are acceptable in transfer. These determinations may be based on credit, course and curriculum equivalencies, often without reference to partial fulfillment of a specific credential. Each institution teaches its own curriculum and courses; there is no outsourcing involved.
  
  An institution may decide whether to accept credits from other institutions regardless of their accredited status. HLC requires member institutions to clearly communicate their transfer policies to the public.
  
  
• Articulation Agreement: An arrangement between institutions that agree in advance, via Memorandum of Understanding or other agreement, to accept each other’s credits in transfer, often in partial fulfillment of one or more specific credentials. In these cases, students may be simultaneously enrolled in multiple institutions. Each institution teaches its own curriculum and courses; there is no outsourcing involved.
  
  Institutions may decide whether to enter into articulation arrangements with other institutions regardless of the other institution’s accredited status. However, HLC member institutions should make the public aware of all such arrangements (e.g. by listing such arrangements on the website, providing more details in program catalogs and ensuring clarity in the transcript produced as a result of such arrangements).

Screening Form for Contractual Arrangements

Institutions engaging in any arrangement that meets the definition above should complete HLC’s screening form for contractual arrangements.

Note: Institutions that are currently on or recently removed from HLC sanction or Show-Cause Order, or that are under provisional certification, are subject to additional requirements and should complete this alternative screening form.

Types of Requests

The following information is provided for general guidance. Institutions planning a change related to a contractual agreement should contact their HLC staff liaison to confirm that prior HLC approval or notification is required.

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