Higher Learning Commission

HLC invites institutions, peer reviewers and other stakeholders to comment on proposed policy changes related to Change of Control, Structure and Organization. HLC’s Board of Trustees approved the proposed changes on first reading in March and will consider them for adoption on second reading at its June 22–23 meeting. 

Proposed Policy Changes 

The proposed policy changes would align HLC policy with recent U.S. Department of Education guidance that now requires accreditors to apply a two-step approval process related to certain types of changes in ownership and control. 

These types generally fall into three categories: 

Scenario A: An HLC member institution (or its component) seeks to (a) be acquired and (b) subsequently merged or consolidated Into the structure of another institution. 

Scenario B: An HLC member institution seeks to (a) acquire and (b) subsequently merge or consolidate another institution (or component) into its structure. 

Scenario C: Those involving both the acquisition of an HLC member institution (or component) and subsequent merger or consolidation into the structure of another HLC member institution. 

Specifically, the proposed revisions to HLC policy would:

• As part of HLC’s Change of Control process, require institutions pursuing one of the scenarios described above to seek separate approval from the HLC Board, as applicable, prior to effectuating each step.  
• Create a new temporary accreditation status for a member institution that is in the process of being merged or consolidated into the structure of another institution, whether that merger or consolidation applies to the member institution or a component thereof. 
• Reinforce that Change of Control, Structure or Organization is a type of substantive change. 
• Clarify certain aspects of the Change of Control process. 

Draft Change of Control Procedure 

To provide additional details on the proposed new two-step process, HLC has also developed a draft Change of Control, Structure or Organization procedure that revises the current procedure and reflects the proposed policy changes. This revised procedure would not go into effect until after the Board takes final action on the policy changes on second reading in June. 

Submit Comments

Please email your feedback to HLC at This email address is being protected from spambots. You need JavaScript enabled to view it.. All comments are due by June 9, 2023. 

Other Pending Proposed Policy Changes 

In addition to the Change of Control proposals, the Board will also consider the following proposed policy changes for adoption on second reading at its June meeting. These proposals were shared with the membership in the March 2023 Leaflet. 

• Arbitration Requirements  
  The policy change would amend the current arbitration provision in HLC’s Obligations of Membership policy to align more closely with federal regulations. The scope of the provision would be limited to disputes arising from adverse actions and would only include an “initial arbitration” requirement. 
• Institutional Actions Council (IAC) Authority 
  HLC policy currently specifies the types of accreditation decisions that may be made by the IAC, and those for which the Board retains authority. The policy changes would clarify that the IAC has the authority to take action on all accreditation decisions for which exclusive authority is not retained by HLC’s Board. 

Questions?

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