Routine Monitoring and Data Collection

Monitoring shall be appropriate in circumstances where HLC has concluded that it should review the institution’s progress in addressing a serious issue at the institution, the resolution of which is relevant to the institution’s compliance with, or improvement regarding, HLC requirements.

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.Other than a focused visit following an approved Change of Control, Structure or Organization, an institution on the Open Pathway that is assigned a focused visit will be moved to the Standard Pathway.

Process for Requiring Monitoring. An evaluation team or HLC staff may recommend that an institution be assigned monitoring in the form of filing one or more interim reports or hosting one or morefocused visits related to one or more HLC requirements. Following review of the recommendation, and any institutional response, if applicable, 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 assign such monitoring.

The HLC president may also otherwise act to require monitoring as consistent with HLC policies.

Interim Reports. An institution shall submit any required interim report(s) according to the due date(s) established in the action calling for the interim report(s). Prior to the institution submitting the interim report(s), HLC staff may act to expand the focus of the report(s) to review additional related topics or HLC staff may recommend to a decision-making body that the focus of the interim report(s) be expanded to add new topics.

HLC may designate staff to review and prepare a written analysis of interim reports. Upon review of an interim report, HLC staff may either (1) accept the report or require one or more additional interim report(s) on the same or related topic; or (2) recommend that an HLC decision-making body require further monitoring, including one or more additional interim reports on different topics, or one or more focused visits on the same, related or new 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 on the topics identified in that action prior to the focused visit. Prior to the focused visit, HLC staff may, with reasonable notice to the institution, act to expand the focus of the focused visit to review additional related topics or new topics.

The focused visit shall be conducted by a team of HLC peer reviewers. The length of the focused visit shall typically be one and a half days. HLC may adjust the length of 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 identified in the actions calling for the focused visit, any additional related topics or new topics raised by HLC staff, or other topics identified by the team. 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.

Data Reporting From Member Institutions

All member institutions will complete data reports for HLC. Such reporting will occur annually, and may also occur periodically, as otherwise required by HLC. HLC will determine the contents of this reporting to assure (1) that it addresses potential or developing concerns with an institution’s stability and compliance with HLC requirements and (2) that it adequately 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 information, and information related to student success outcomes, including student achievement. The data reporting will provide HLC with sufficient information to understand and respond to significant shifts in an institution’s capacity or scope of educational activities.

HLC Follow-Up to Institutional Data

HLC will establish and maintain procedures to follow-up with institutions regarding institutional data as necessary. This institutional data includes data that the institution provides to HLC or other data that HLC has regarding the institution, including data regarding the institution that is otherwise available from public sources.

In reviewing and analyzing institutional data, HLC will look at relationships among a variety of established risk indicators in the institutional data, and other information, in any given year or over several years. If those relationships suggest concerns with the institution’s stability, such as experiencing very rapid change, or concerns with the institution’s compliance with HLC requirements, HLC will ask the institution to submit an explanation of the data, including, as appropriate, the institution’s strategies for improvement. HLC staff may require that this explanation and any other information provided by the institution be forwarded to peer reviewers or HLC staff for further review.

Upon review, the peer reviewers or HLC staff may accept the explanation provided.

If institutional data indicate concerns with the institution’s compliance with HLC requirements, or otherwise require further validation, the peer reviewers or HLC staff may recommend monitoring on specific HLC requirements, as related to the institutional data, to an HLC decision-making body or the HLC president may otherwise assign monitoring as consistent with HLC policy.

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: February 2025
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, February 2024, February 2025 
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.”