Substantive Change

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. Moreover, depending on the circumstances, an institution’s substantive change application may be disqualified based on restrictions in federal regulations or based on HLC policies and procedures.  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 each require prior HLC APPROVAL: 
   1. Addition of academic program(s) at a degree or credential level not previously included in the institution’s accreditation by HLC; 
   2. 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. Addition of a direct assessment program or the addition of competency-based programs wherein the academic program is organized around competencies;¹  
   4. Addition of academic programs that require allocation of substantial financial investment or resources; 
   5. Addition of academic programs outside stipulations imposed by a previous HLC action limiting such activity without prior approval. 
4. Each of the following changes requires HLC NOTIFICATION or prior HLC 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. 
   5. Change in the manner(s) in which an institution measures student progress, regardless of method. 
5. Offering courses or educational programs through the modality of distance education requires prior HLC APPROVAL for each of the following: 
   1. The initial offering of courses through distance education. 
   2. Any of the following thresholds: offering 50% or more of an institution’s courses through distance education; enrolling 50% or more of an institution’s students in distance education (with a student being defined as being enrolled in distance education if they take one distance education course); or offering 50% or more of the courses or credits in an educational program through distance education. Once an institution has received prior HLC APPROVAL for one of these thresholds, additional approval for the other thresholds is not required. 
6. Offering courses or educational programs through the modality of correspondence education requires prior HLC APPROVAL for each of the following: 
   1. Initial offering of courses through correspondence education. 
   2. Offering 50% or more of one program through correspondence education. 
   3. Offering 50% or more of multiple programs through correspondence education. 
7. Establishment of a campus, including a branch campus, or an additional location, including for purposes of providing teach out, requires prior HLC APPROVAL unless the institution has been approved for access to the Notification Program for Additional Locations as outlined in INST.G.10.020.  
8. Closure or suspension for more than one semester of an additional location or a campus, including a branch campus, requires HLC NOTIFICATION.  
9. Initiation of a contractual or other arrangement wherein an institution outsources some portion of one or more of its educational programs to certain other 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) requires HLC NOTIFICATION or prior HLC APPROVAL: 
   1. Less than 25% of any educational program outsourced to the other party requires prior 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. Each of the following changes requires HLC NOTIFICATION within thirty (30) days:  
    1. Change in an existing program’s method of delivery.  
    2. 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. 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. 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. 
11. 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, each of the changes detailed above in #9 and #10 require prior 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. 
12. Change of Control, Structure or Organization as defined by these policies requires prior HLC APPROVAL. 
13. Initiation of an institution’s first Pell-eligible prison education program at a first additional location and the initiation of the first Pell-eligible prison education program at a second additional location requires prior HLC APPROVAL. 
14. Initiation of an institution’s subsequent Pell-eligible prison education program at any additional location requires prior HLC NOTIFICATION. 
15. Initiation of a second Pell-eligible prison education program in a modality (or other method of delivery) that differs from the modality or modalities used in any previously approved Pell-eligible prison education program requires prior HLC APPROVAL. 

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: November 2023 
First Adopted: June 2010  
Revision History: November 2011, November 2012, April 2013, November 2013, February 2014, February 2016, February 2020, June 2020, June 2022, June 2023, November 2023 
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.” Policy renumbered in June 2023 (former policy number INST.F.20.040).