Number: INST.F.10.010

Monitoring on Pathways. An institution on the Standard or Open Pathway may be required to file one or more interim reports. An institution on the Standard Pathway may be required to host one or more focused visits. Such monitoring shall be appropriate in circumstances where the team has concluded that HLC should review the institution’s progress in addressing a serious issue at the institution, the resolution of which is relevant to the institution’s future compliance with, or improvement regarding, the Criteria for Accreditation or other HLC requirements.

Other Monitoring. An institution, regardless of its pathway, is always subject to monitoring in the form of interim reports or focused evaluations related to review by HLC of the following: financial and non-financial indicators; a change of control, structure or organization transaction; substantive change; complaints; compliance with other HLC requirements, including the Federal Compliance Requirements and the Assumed Practices; or other HLC investigation or review.

Process for Requiring Monitoring. An evaluation team or staff may recommend that an institution be required to file an interim report or host a focused on-site evaluation on one or more topics. The President may also act to require routine monitoring in a manner consistent with policy on Staff Authority COMM.B.10.020. Following review of routine monitoring, an appropriate decision-making body, or HLC staff where allowed by HLC policy, shall determine whether the monitoring is appropriate for the institution, and, if so, shall act to approve such monitoring.

Interim Reports. An institution shall submit a required interim report according to the due date established in the action calling for the interim report. HLC may designate staff to review and prepare a written analysis of all reports and to act on behalf of HLC to accept the report or require additional reports on the same or related topic or may recommend to HLC’s decision-making bodies that further monitoring, including new interim reports or focused visits, as appropriate to the institution’s pathway assignment, be required on the same topics identified in the action or on other topics.

Focused Visits. An institution that is assigned a focused visit shall host such focused visit according to the date established in the action calling for the focused visit. The institution shall submit a focused report to HLC prior to the evaluation on the topics identified in that action prior to the focused visit. HLC staff may expand the focus of the evaluation where appropriate to review additional topics of concern to HLC. The focused visit shall be conducted by a team of HLC peer reviewers appointed by HLC staff. The length of the focused visit shall be one and one-half days, but HLC may lengthen or shorten the visit or require that team members conduct additional on-site visits to the institution’s facilities to examine specific issues.

The focused visit team will prepare a written report addressing the topics of concern identified in the action calling for the focused visit and any areas of concern raised by HLC staff and identifying deficiencies, if any, at the institution. The focused visit team report shall include a recommendation for HLC action either accepting the institution’s focused report or calling for additional monitoring, sanction, Show-Cause Order or withdrawal of accreditation. The institution shall have the opportunity to file a written response to the focused visit report prior to a decision-making body acting on the report. Focused visit reports will be considered through HLC’s regular review and decision-making processes.

Data Reporting From Member Institutions

All member institutions will complete data reports for HLC; such reporting will occur annually as well as periodically. HLC, with oversight as appropriate from the Board of Trustees, will determine the contents of this reporting to assure that it addresses potential or developing problems with an institution’s compliance with accrediting requirements and institutional stability, as well as solicits updated information on the scope of activities of each member institution. Data required from each institution will include, at minimum, annual financial information, headcount and enrollment, measures related to student achievement, and other indicators. The data reporting will provide HLC with sufficient information to understand and respond to significant shifts in an institution’s capacity and/or scope of educational activities.

Institutional Contact for Data Reporting

To assure that the institution provides accurate and consistent information, each member institution identifies an Accreditation Liaison Officer (ALO) who will bear administrative responsibility for submitting the report in a timely manner. HLC training will be available for those liaisons.

HLC Follow-Up to Institutional Data

In reviewing and analyzing institutional data, HLC will look at relationships among a variety of indicators and other information in any given year or over several years. If those relationships suggest that the institution may be experiencing problems meeting HLC requirements or very rapid change, HLC will ask the institution to submit an explanation of the data. In particular, HLC will ask institutions it identifies through review of information about student achievement to provide information about their strategy for improvement. HLC staff may forward institutional data, and any explanation or other information provided by the institution, to a peer review panel for further review. Such panel may conduct its review in a scheduled meeting or by any means that allows for synchronous or asynchronous communication. If data submitted by an institution, particularly enrollment information, financial indicators based on financial ratios, or any other additional information required by a peer review panel, are indicative of problems meeting HLC requirements, rapid change, significant growth, or otherwise require validation, such peer review panel or HLC staff may call for an on-site evaluation as soon as possible; require that an institution address concerns arising from these data in the next evaluation process; or recommend to the Institutional Actions Council additional institutional monitoring through any process provided for in HLC policy and procedure.

Monitoring of Student Enrollment Growth

HLC will monitor enrollment growth through institutional annual data reporting and will monitor on an ongoing basis growth in enrollment at those institutions that experience significant enrollment growth as defined in HLC procedures or appear to have significant shifts in enrollment based on instructional modalities. HLC will ask institutions that have been identified through the annual data reporting process as having significant enrollment growth to provide information about enrollment growth at the program level. HLC may take follow-up action.

Surveying of Students

HLC may survey students of an institution to gather information about their experience at the institution prior to a comprehensive evaluation at the institution scheduled by HLC. HLC will provide aggregate data resulting from the survey to the institution under review and the evaluation team prior to the comprehensive evaluation. The institution will have an opportunity to provide additional information or other data in response to the student survey data to the evaluation team and HLC prior to the comprehensive evaluation.

Policy History

Last Revised: June 2022
First Adopted: November 1999, February 2003, February 2007
Revision History: February 2001, February 2007, February 2009, February 2010, November 2010, June 2012, November 2012, April 2013, February 2014, June 2014, November 2018, June 2020, November 2020, February 2021, February 2022, June 2022
Notes: Policies combined November 2012 – 3.6, 3.6(a), 1.3, 1.3(a), 1.3(b), 1.3(c). In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”