Policies
Policy Title: Accredited Change of Control Status
Number: INST.G.20.040
In accordance with federal regulations, a Change of Control Structure or Organization constituting the acquisition and subsequent merger or consolidation of an institution shall require prior review and approval by HLC following a two-step process described in these policies and HLC’s Change of Control procedures.*
*For more information, see 34 CFR § 600.31(b), 34 CFR § 602.22(a)(1)(ii)(G) and GENERAL-22-70: Updated Guidance and Procedures for Changes in Ownership.
In the event that a member institution seeks to be acquired and subsequently merged or consolidated into the accreditation of another institution, prior review and approval of the acquisition by the HLC Board of Trustees (“the Board”) is required under these policies. Only following HLC Board approval may a member institution consummate an acquisition or other transaction in which it will subsequently be merged or consolidated within the accreditation of another institution. Such transactions are also subject to other requirements set forth in HLC policy.
Placement on Accredited Change of Control Status
As part of its approval of a Change of Control, Structure or Organization described in this policy, the Board shall require that the member institution be placed on Accredited Change of Control status effective upon consummation of the transaction. As part of its placement on this status, the institution will be removed from its accreditation pathway.
Placement on Accredited Change of Control status shall typically be for no more than two years. During this period, the institution will not be required to participate in routine evaluative processes. However, the institution must continue to abide by the Obligations of Membership at all times.
An institution on Accredited Change of Control status may be restricted in its ability to apply for substantive change.
Removal from Accredited Change of Control Status
In most instances, an institution that was placed on Accredited Change of Control status will subsequently voluntarily resign its accreditation with HLC following the completion of the merger or consolidation of the institution into the accreditation of another institution that formed the basis of placement on Accredited Change of Control status.
If an institution was placed on Accredited Change of Control status following its acquisition by another entity with the intent to merge or consolidate the institution within the accreditation of another institution and the merger or consolidation does not proceed, the institution must seek approval for a Change of Control, Structure or Organization as set forth in these policies. If approved by the Board, the Board will set forth the evaluative schedule of the institution in accordance with HLC policy by removing it from Accredited Change of Control status and placing it on the appropriate accreditation status, including the appropriate accreditation pathway.
The Board may also withdraw the institution’s accreditation or take other action as provided in HLC policy following the expiration of the period in which the institution may be on Accredited Change of Control status.
Policy History
Last Revised:
First Adopted: June 2023
Revision History:
Notes:
Policy Title: Accelerated Process for Initial Accreditation
Number: INST.B.20.032
In some instances, institutions that meet the qualifications listed below may be eligible to apply for initial accreditation through an accelerated process.
The accelerated process is distinct from HLC’s other processes for seeking accreditation. An institution participating in an accelerated process does not participate in the Eligibility Process. The institution does not hold candidacy status, and thus does not hold any status with HLC, prior to being granted initial accreditation.
Qualifications to Apply for Initial Accreditation Through the Accelerated Process
An institution must meet the following qualifications in order to apply for initial accreditation through the accelerated process:
- The institution is currently institutionally accredited (a) by an accreditor that is recognized by the U.S. Department of Education and that is historically known as a regional accreditor or (b) by a state entity that is recognized by the U.S. Department of Education as an institutional accreditor of degree-granting institutions of higher education.
- The institution, in its current form, has undergone one reaffirmation of accreditation with its current institutional accreditor. If an institution has not, in its current form, undergone one reaffirmation of accreditation with its current institutional accreditor, the institution must be able to demonstrate other indicia of continuity and stability in its accreditation history.
- The institution has not been placed on a sanction, Show-Cause Order, or other similar negative action with its current institutional accreditor for at least the past five years, and its current institutional accreditor is not currently considering placing the institution on a sanction, Show-Cause Order, or other similar negative action.
Notwithstanding any institution's ability to meet the above qualifications, nothing in HLC policy nor federal regulations requires HLC to consider any non-member institution for initial accreditation, whether through the Accelerated Process or through the Eligibility Process.
Application for Initial Accreditation Through the Accelerated Process
An institution that meets the qualifications above may apply for initial accreditation through the accelerated process. As part of the application process, an institution will be required to demonstrate through a peer review process that it meets the qualifications for participating in the accelerated process, and that it otherwise preliminarily meets HLC’s requirements, including the Eligibility Requirements. Peer reviewers participating in the initial phases of the accelerated process may be Eligibility Reviewers chosen by the Board of Trustees, or other peer reviewers.
As part of the application process, HLC may also require that the institution participate in educational activities designed to familiarize the institution with HLC requirements, policies and procedures.
Comprehensive Evaluation for Initial Accreditation Through the Accelerated Process
If peer reviewers determine that the institution is eligible to proceed with the accelerated process, the institution will participate in a comprehensive evaluation for initial accreditation. This process will include the institution completing an Assurance Argument and undergoing an on-site visit by peer reviewers. The institution will be required to demonstrate, as detailed below, that it meets HLC’s Eligibility Requirements, Assumed Practices, Criteria for Accreditation, and Federal Compliance requirements.
Decision Making for Initial Accreditation Through the Accelerated Process
Consistent with HLC policies, only the Board of Trustees may grant initial accreditation, including following an accelerated process. An institution participating in the accelerated process will also participate in an Institutional Actions Council (IAC) hearing prior to Board action. Prior to being granted initial accreditation following the accelerated process, the institution does not hold any status with HLC.
Evaluative Framework for Initial Accreditation Through the Accelerated Process
The requirements for granting initial accreditation following the accelerated process are as follows:
- The institution meets each of the Eligibility Requirements.
- The institution meets each of the Assumed Practices.
- The institution meets or meets with concerns the Criteria for Accreditation.
- The institution meets the Federal Compliance Requirements.
If the Board of Trustees grants initial accreditation following the accelerated process, the Board may, in its discretion, grant such initial accreditation subject to interim monitoring, restrictions on institutional growth or substantive change, or other contingencies.
If the Board of Trustees denies initial accreditation following the accelerated process, the institution may choose to re-apply to participate in the accelerated process. Prior to re-applying, the institution must take steps to remedy the underlying circumstances that led to the denial of initial accreditation. Alternatively, an institution may also choose to proceed with applying for status with HLC through the Eligibility Process. If the Board of Trustees does not grant initial accreditation following the accelerated process, the Board of Trustees will inform the institution as to the earliest date it will consider any new application for initial accreditation through the accelerated process, subject to timeframes in HLC policies.
Denial of initial accreditation following an accelerated initial accreditation policy is an adverse action that is subject to appeal.
Policy History
Last Revised: November 2023
First Adopted: June 2021
Revision History: February 2022, November 2023
Notes:
Policy Title: Responding to Emergencies and Severe Institutional Disruptions
Number: INST.H.10.010
Occasionally, emergencies and circumstances beyond an institution's control severely disrupt institutions of higher education. In response to this, HLC may leverage its existing policies and, if available, any additional flexibilities permitted by the U.S. Department of Education or other entities to allow institutions time to manage the disruption while maintaining a high level of academic quality.
Severe Institutional Disruptions
Severe institutional disruptions are unforeseen circumstances that directly and seriously impact an institution’s ability to operate as it did immediately prior to the disruption. Such circumstances include but are not limited to: natural weather phenomena (hurricanes, tsunamis, tornados, floods, typhoons, wildfires, straight-line winds), geological conditions (earthquakes, volcanic eruptions, mudslides, landslides), public health emergencies (epidemics, pandemics, biological disasters, regardless of origin, water crises), public safety incidents (active shooters, mass shootings or hostage-taking incidents on institutional premises), cybersecurity incidents, or other circumstances beyond the institution’s control that directly and seriously impact the institution’s ability to operate as it did immediately prior to the disruption.
Note that neither an act of nature nor a declaration of a natural disaster or public health emergency by a government official is necessary to establish a severe institutional disruption. At the same time, this policy is not automatically triggered by any such event. Rather, an institution must take the specific steps further explained below in order for HLC to consider applying this policy.
Eligibility for Consideration Under This Policy
All institutions directly affected by a severe institutional disruption are eligible for consideration for accommodations by HLC without regard to their accreditation status or how long they have held any status with HLC.
Process for Consideration
Institutions must inform HLC in writing as soon as possible after being impacted by any circumstance representing a severe institutional disruption and request consideration for this policy to be applied. The institution must:
- clearly identify the disruption;
- describe in detail what aspects of the institution’s operations have been directly affected;
- describe what steps the institution is taking to manage the affected operations; and
- articulate what accommodations are specifically requested.
Accommodating Severe Institutional Disruptions
HLC will make a determination on a case-by-case basis as to what accommodations are available and appropriate under existing policies and taking into account any additional flexibilities afforded by the U.S. Department of Education or other entities, if applicable. The length of the accommodation period will also be tailored to suit the circumstances based on information provided by the institution and the impact of the disruption in question.
Decision-Making Process
The initial decision to allow for accommodations pursuant to this policy shall be approved by HLC’s President or a designee and such accommodations shall be implemented in accordance with HLC policies and procedures. Depending on the accommodations being sought, further action through an appropriate HLC decision-making body may also be taken.
Policy History
Last Revised:
First Adopted: February 2023
Revision History:
Notes: Policy renumbered in June 2023 (former policy number INST.G.10.010).