Substantive Change
Change in higher education is constant and necessary to improve educational quality. Depending on the type of change an institution plans to make—expanding its academic offerings, opening a new location, changing its mission, etc.—it may need to apply for prior HLC approval or notify HLC of the change. This process ensures that institutions continue to meet HLC's standards as they evolve and grow.
Changes Requiring Prior HLC Approval or Notification
HLC cannot approve changes retroactively. If an institution has made a change without obtaining required approval from HLC, it should submit a change application as soon as possible. Depending on the type of change, the lack of approval may result in a delay in Title IV funds being released.
Federal Regulations
HLC has provided guidance on properly declaring program activity to comply with U.S. Department of Education regulations on substantive change that went into effect on July 1, 2020.
Consortial Arrangements
HLC does not review consortial arrangements, but institutions may need to notify HLC or obtain prior approval for substantive changes related to a consortial arrangement, such as offering a new academic program or providing instruction at a new additional location.
New Academic Programs
Offering a new degree or certificate program.
Changes to Existing Programs
Changes involving clock or credit hours, length of term, program content, method of delivery, customized pathways or suspension of a degree or certificate program.
Off-Campus Activities
Opening, closing, relocating or reclassifying a branch campus or additional location. Joining or expanding access to HLC's Notification Program for Additional Locations.
Distance Delivery
Initiating or expanding courses and/or programs offered through distance education or correspondence education.
Contractual Arrangements
Initiating, modifying or renewing contractual arrangements.
Pell-Eligible Prison Education Programs
Offering a new Pell-eligible prison education program (PEP) or changing the modality of an approved PEP.
Competency-Based Education
Offering academic programs through competency-based education (CBE), including direct assessment, hybrid or credit-based CBE.
Mission or Student Body
Changing the institution's mission, educational objectives or the character or nature of its student body.
Control, Structure or Organization
Undergoing a transaction, such as a merger or acquisition, or other change that may affect the institution's corporate control, structure or organization.
Fees and Review Processes
HLC charges institutions a fee for reviewing substantive change applications. The fee varies depending on the type of review an application requires. See HLC's Dues and Fees Schedule for current fees.
Substantive change reviews are conducted by HLC staff or peer reviewers in one of four processes, depending on the type and complexity of the change:
- Desk Review
- Change Panel
- Change Visit
- Change of Control Evaluation
Generally, an institution may withdraw a substantive change application at any time before a Desk Review, Change Panel, or Change Visit occurs. See Substantive Change Review Processes for details about withdrawing an application.
Following the review, an HLC decision-making body will take final action to approve or deny the request. Approved additional locations and branch campuses may also require a follow-up review after approval.
Related Policies
- Substantive Change (INST.G.10.010)
- Review of Substantive Change (INST.G.10.020)
- Monitoring of Substantive Change (INST.G.10.030)
- Change of Control, Structure, or Organization (INST.G.20.010)
- Processes for Seeking Approval of Change of Control, Structure or Organization (INST.G.20.020)
- Monitoring Related to Change of Control, Structure, or Organization (INST.G.20.030)
Questions?
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