Number: INST.F.20.040

An institution shall have the obligation hereunder to report certain changes, some of which may constitute substantive changes under federal regulation, to HLC as identified in this policy and related policies and to seek and receive HLC approval where appropriate prior to implementing specific changes.

The institution shall use HLC’s change reporting protocol for this purpose. Changes identified as requiring prior HLC approval prior to implementation shall be included in the institution’s accreditation only after HLC has reviewed the change through a process identified in these policies and formally acted to approve the change. HLC’s review and approval process is intended as far as possible to ensure that if implemented the proposed substantive change will not adversely affect the institution’s capacity to continue to meet HLC's requirements. Changes identified as requiring HLC notification are generally included in the institution’s accreditation provided that the institution provides timely notification to HLC through the Institutional Update and other data reporting instruments established by HLC according to a schedule established by HLC. Additionally, institutions that have access to the Notification Program for Additional Locations must notify HLC and receive acknowledgment prior to initiating the Additional Location.

As further detailed below, some of these requirements only apply to institutions that (1) are currently, or in the prior three years have been, on a sanction or under a Show-Cause Order with HLC, or (2) are currently under a provisional certification with the U.S. Department of Education.

Substantive Change Requiring Notification or Approval

1. Changes in actual or apparent mission of the institution or its educational objectives require prior HLC APPROVAL.
2. Significant changes in the character or nature of the student body of the institution, particularly, but not limited to, those changes involved in seeking international students for the first time or acquiring students being taught-out of programs provided by a closing institution require prior HLC APPROVAL.
3. Initiation of new academic program(s) or major(s) other than those listed below, or cancellation or suspension of academic programs requires HLC NOTIFICATION. The following changes require prior HLC APPROVAL:
   1. The addition of academic program(s) at a degree or credential level not previously included in the institution’s accreditation by HLC;
   2. the addition of academic program(s), including Title IV-eligible Certificate programs not related to existing degree programs, that represent a significant departure from programs previously included in the institution’s accreditation;
   3. the addition of a direct assessment program or the addition of competency-based programs wherein the academic program is organized around competencies;¹
   4. the addition of academic programs that require allocation of substantial financial investment or resources, or any programs acquired from another institution;
   5. the addition of academic programs outside stipulations imposed by a previous HLC action limiting such activity without prior approval.
4. A change in one or more of the following requires NOTIFICATION OR APPROVAL:
   1. change from clock to credit hours in one or more institutional programs;
   2. substantial increase or decrease in the number of clock or credit hours required for successful completion of an academic program;
   3. change in term length (e.g. semesters to quarters or semesters to a five-week compressed term) that affects 25% or more of all the institution’s courses or programs;
   4. increase or decrease in the number of credit hours per course in 25% or more of the courses in the institution’s curriculum; and
   5. a change in the manner(s) in which an institution measures student progress, regardless of method.
5. Change in the method of delivery of courses or programs requires prior HLC APPROVAL:
   1. The initial offering of academic programs through distance, correspondence or other alternate delivery wherein 50% or more of the courses or credits in the program are provided through the alternate delivery;
   2. The initial offering of courses through distance, correspondence or other alternate delivery if the institution is not already approved to offer programs through that delivery mechanism; and
   3. Programs offered for the first time by an institution are subject to review and approval, if required, by HLC as a new program (see #3 of this section) prior to being reviewed as distance or correspondence education.
6. The establishment of a campus, including a branch campus, or an additional location requires prior HLC APPROVAL unless the institution has been approved for access to the Notification Program for Additional Locations as outlined in INST.F.20.050.
7. The acquisition of a campus, including a branch campus, or an additional location from another institution, including one established or acquired in order to provide for teach-out of the students from another institution, requires prior HLC APPROVAL unless the institution has been approved for access to the Notification Program for Additional Locations as outlined in INST.F.20.050.
8. Closure or suspension for more than one semester of any of the following requires HLC NOTIFICATION:
   1. an additional location, or
   2. a campus, including a branch campus.
9. The initiation of a contractual or other arrangement wherein an institution outsources some portion of one or more of its educational programs to any of the following parties: an unaccredited institution; an institution that is not accredited by an accreditor recognized by the U.S. Department of Education; or a corporation or other entity:
   1. less than 25% of any educational program outsourced to the other party requires HLC APPROVAL for institutions that are currently on a sanction or under a Show-Cause Order or that have been on a sanction or under a Show-Cause Order in the prior three academic years and requires HLC NOTIFICATION for all other institutions;
   2. 25%-50% of any educational program outsourced to the other party requires prior HLC APPROVAL;
   3. more than 50% of any educational program outsourced to the other party will receive intense scrutiny and will not be approved by HLC except in exceptional circumstances. (Note that federal regulations provides that educational programs provided through contractual arrangements between an accredited institution and an ineligible entity wherein more than 50% of the educational program is being provided by the ineligible entity will not receive Title IV assistance even if approved by the accreditor.)
10. A change in the legal status, form of control, or ownership of the institution shall be subject to the requirements of and procedures associated with HLC’s policies related to Change of Control, Structure or Organization.
11. The following changes require HLC NOTIFICATION within thirty (30) days:
    1. A change in an existing program’s method of delivery.
    2. An aggregate change of 25% or more of the clock hours, credit hours, or content of a program since the agency’s most recent accreditation review.
    3. The development of customized pathways or abbreviated or modified courses or programs to:
       1. Accommodate and recognize a student’s existing knowledge, such as knowledge attained through employment or military service; and
       2. Close competency gaps between demonstrated prior knowledge or competency and the full requirements of a particular course or program.
    4. The initiation of a contractual or other arrangement wherein an institution outsources some portion of one or more of its educational programs to any of the following parties: an unaccredited institution; an institution that is not accredited by an accreditor recognized by the U.S. Department of Education; or a corporation or other entity.
12. Beginning with institutions placed on a sanction or under a Show-Cause Order with HLC after July 1, 2020, or placed under a provisional certification with the U.S. Department of Education as of that same date, the changes detailed above in #9 and #11 require HLC APPROVAL for institutions that (1) are currently, or in the prior three years have been, on a sanction or are under a Show-Cause Order with HLC, or (2) are currently under a provisional certification with the U.S. Department of Education.

¹ For institutions that offered competency-based programs prior to December 1, 2014, HLC will validate the ongoing approval of the programs and their inclusion in the accreditation of the institution.

Policy History

Last Revised: June 2022
First Adopted: June 2010
Revision History: November 2011, November 2012, April 2013, November 2013, February 2014, February 2016, February 2020, June 2020, June 2022
Notes: Policies combined November 2012 – 3.2(a), 3.2(b), 3.2(b)1. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”