Adopted Policy Changes
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2025–26 Academic Year
November 2025
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on November 6, 2025.
- Federal Compliance Requirements (effective September 1, 2026)
Clarified aspects of HLC’s Federal Compliance Requirements, including matters related to recordkeeping for student complaints, public disclosure of certain information, and actions by states and other recognized accreditors. - Separate Audit Requirements (effective immediately)
Revised HLC’s Eligibility Requirements and Assumed Practices to provide flexibility for institutions in how they meet HLC requirements related to providing financial information for the institution that is separate from any related entity. - Revising and Editing Policies (effective immediately)
Clarified the distinction between policy revisions reviewed and adopted by the Board and minor policy edits that HLC staff may make without Board approval or a period of member comment. Minor policy edits by staff may only be made in very limited circumstances.
2024–25 Academic Year
June 2025
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on June 26, 2025. They are effective immediately.
- Administrative Probation
Clarifies the purpose and process for Administrative Probation, as well as other aspects of HLC’s Obligations of Membership. - Seeking Accreditation Reviewers
Changes the name of peer reviewers designated by the Board to conduct certain reviews for institutions seeking accreditation from “Eligibility Reviewers” to “Seeking Accreditation Reviewers.” The changes also clarify other aspects of the Eligibility Process.
February 2025
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on February 27, 2025.
- Open Pathway Evaluative Activities (effective September 1, 2025)
The adopted changes establish an option for eligible institutions on the Open Pathway to choose to complete a Quality Initiative focused on student success during Years 1–4 of the accreditation cycle in lieu of the mid-cycle Assurance Review in Year 4. The changes also clarify certain other practices related to the Standard and Open Pathways. - Student Success Outcomes: Data Collection and Indicator Follow-Up (effective immediately)
The adopted policy changes allow for an expansion of HLC’s risk indicator process to include the evaluation of student success outcome measures, including using data reported to IPEDS. - Teach-Out Arrangements (effective immediately)
The adopted policy changes clarify HLC’s requirements regarding teach-out arrangements. The changes better align HLC’s policies with regulatory requirements, while continuing to be focused on student needs. In conjunction, HLC also published new and updated resources for institutions related to teach-out arrangements. - Special Monitoring (effective immediately)
The adopted policy changes establish special monitoring reports as a possible method for HLC to respond quickly to a developing situation at a member institution. They also clarify HLC’s practices with respect to institutional designations and special monitoring generally.
October 2024
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on October 31, 2024. They are effective immediately.
- Eligibility Requirements
The adopted changes streamline HLC’s Eligibility Requirements and align them with the revised Criteria for Accreditation and Assumed Practices. - Sanctions and Reaffirmation of Accreditation
The adopted changes establish standard time periods for Notice and Probation, as well as the general rule that an institution would have its accreditation reaffirmed when it is removed from Probation or a Show-Cause Order. The changes also clarify the standard for issuing a Show-Cause Order.
2023–24 Academic Year
July 2024
The Higher Learning Commission’s Board of Trustees adopted the following change to the HLC Bylaws through an electronic ballot on July 9, 2024. The bylaw change is effective immediately.
- Adopted Bylaw Change: Composition of Executive Committee
The adopted change expands the membership of the Board’s Executive Committee to include the immediate past chair of the Board. The Executive Committee also consists of the chair, vice chair, treasurer, and the chairs of the standing Board committees.
June 2024
The Higher Learning Commission’s Board of Trustees adopted the following policy on second reading at its meeting on June 27, 2024.
- Criteria for Accreditation and Assumed Practices (changes effective September 1, 2025)
The adopted changes streamline and clarify HLC expectations for institutions. See HLC’s overview document for policy language, implementation timeline, crosswalks between the current and revised Criteria, and definitions of new terms in the revised Criteria. Additional training and support on the revised Criteria will be available for institutions and peer reviewers starting this fall.
February 2024
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on February 29, 2024.
- Multi-campus Visits (changes effective September 1, 2024)
The adopted changes revise when HLC visits a sample of an institution’s branch campuses — a process known as a multi-campus visit — during a comprehensive evaluation. Beginning September 1, 2024, multi-campus visits will take place during comprehensive evaluations for candidacy, initial accreditation or reaffirmation of accreditation. They will no longer occur during other comprehensive evaluations, including Standard Pathway Year 4 comprehensive evaluations that do not involve reaffirmation of accreditation. - Staff Authority (changes effective immediately)
The adopted changes clarify when HLC staff may take certain actions with respect to an institution and when staff may recommend certain actions to an HLC decision-making body. The changes also clarify when institutions have an opportunity to submit a response to a staff member’s recommendation. In connection with the changes made to the Routine Monitoring and Data Collection policy, HLC also updated its Monitoring Recommendations: Considerations for Peer Review document to clarify guidance for peer reviewers.
November 2023
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on November 2, 2023. The policies are effective immediately.
- Faculty Qualifications
Revises the faculty qualifications provision in HLC’s Assumed Practices to emphasize that an institution is responsible for establishing and maintaining reasonable processes for determining that its instructors are qualified. An institution could deem instructors qualified based on a variety of factors, including, but not limited to, academic credentials, progress toward academic credentials, equivalent experience, or some combination thereof. To help clarify the new policy, HLC has developed updated guidelines on faculty qualifications and dual credit. - Pell-Eligible Prison Education Programs
Amends HLC policies related to substantive change to include requirements for Pell-eligible prison education programs and additional locations where Pell-eligible prisons education programs are offered. The requirements align with guidance from the U.S. Department of Education related to the reinstatement of Pell Grant eligibility for students enrolled in such programs. - Accelerated Process for Initial Accreditation
Revises the accreditation history requirements that would potentially qualify an institution to participate in HLC’s Accelerated Process for Initial Accreditation.
The Board of Trustees also adopted the following policy change on single reading on November 2, 2023. The policy is effective immediately.
- Distance Education
Aligns HLC’s substantive change policy with recent guidance from the U.S. Department of Education. It revises the requirements related to when an institution must seek approval from HLC for its distance education offerings. An institution must do so when it initially offers distance education and when it does any one of the following: (1) offers at least 50% of a program through distance education; (2) enrolls at least 50% of its students in at least one distance education course; (3) offers at least 50% of its courses through distance education. Once an institution has received HLC approval for one of these thresholds, additional approval for the other thresholds is not required.
2022–23 Academic Year
June 2023
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on June 22, 2023. The policies are effective immediately.
- Arbitration Requirements
Amends the current arbitration provision in HLC’s Obligations of Membership policy to align more closely with federal regulations. The scope of the provision is now limited to disputes arising from adverse actions and only includes an “initial arbitration” requirement. HLC also published a new procedure regarding arbitration. - Institutional Actions Council (IAC) Authority
Clarifies that the IAC has the authority to take action on all accreditation decisions for which exclusive authority is not retained by HLC’s Board. - Processes for Certain Changes of Control
Aligns HLC policy with recent guidance from the U.S. Department of Education on Change of Control requirements in certain circumstances. HLC has also published an updated Change of Control, Structure or Organization procedure that reflects the policy changes.
February 2023
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on February 23–24, 2023. The policies are effective immediately.
- Overall Revisions to Bylaws
The revisions standardize terminology, streamline and condense language, and clarify procedures and requirements. - Criteria Revision Process
The policy changes allow greater flexibility for staff to design appropriate methods for engaging member institutions and other stakeholders in the process of reviewing and revising the Criteria for Accreditation. - Fraud and Abuse
The policy changes clarify that allegations of fraud and abuse can be submitted to HLC by various external parties and that any allegations will be reviewed using the appropriate mechanism under HLC policy. - Heightened Cash Monitoring
The policy changes clarify that institutions placed on the Reimbursement or Heightened Cash Monitoring 2 (HCM2) payment methods by the Federal Student Aid Office of the U.S. Department of Education are required to submit a Provisional Plan to HLC for approval. The changes also modify the Obligations of Membership to require institutions to notify HLC when they are placed on the HCM2 or Reimbursement payment method. - Recruiting, Admissions and Related Enrollment Practices
The policy changes align HLC’s policy on Recruiting, Admissions and Related Enrollment Practices with new federal regulations on recruitment. The revisions clarify HLC’s expectations and specify that the policy applies to all aspects of an institution’s enrollment process, including financial aid. - Responding to Emergencies and Institutional Disruptions
The new policy establishes that HLC may leverage its existing policies and, if available, flexibilities permitted by the U.S. Department of Education or other entities to allow institutions time to manage an emergency or severe disruption while maintaining a high level of academic quality. Institutions will be required to request accommodations, and HLC will make determinations on a case-by-case basis as to what accommodations are available and appropriate.
November 2022
The Higher Learning Commission’s Board of Trustees adopted the following policy changes on second reading at its meeting on November 3, 2022. The policies are effective immediately.
- Clarification Regarding “Days”
The policy change implements consistent use of the term “days” in HLC policies to signify calendar days. In instances where a different use is required, these instances are stated in the applicable policy as “business days.” - Rules Regarding Prior Peer Reviewer Evaluation and Decision-Making Activity
HLC’s policies include requirements indicating when peer reviewers may be assigned to an evaluation of an institution after having previously participated in an evaluation or HLC Academy activity involving the same institution. The adopted changes set similar requirements for members of the Institutional Actions Council (IAC). The changes also indicate when peer reviewers and IAC members may be assigned to an evaluation or decision-making activity regarding an institution after having previously participated in an IAC decision-making activity involving the same institution. - Special Monitoring
The policy changes provide HLC’s President more flexibility in designing protocols that capitalize on a variety of existing mechanisms to gather information, evaluate evidence and make appropriate decisions that serve the interest of students and the public. Additional changes clarify triggering circumstances, explain Advisory Visits and detail the impact of designations on certain types of substantive-change activity.
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