Fraud and Abuse

An institution shall not engage in fraud and abuse, as outlined in state and federal law and regulation, or in practices or procedures that are designed to, or have the tendency to, create a falsification, deceive, or deliberately mislead.

Allegations of fraud and abuse may be received by HLC from external sources, including but not limited to, the federal government, a state government, or through the institutional complaints process. If HLC receives an allegation of fraud and abuse, HLC will determine whether the alleged fraud and abuse would constitute a violation of one or more HLC requirements. In reviewing any allegation of fraud and abuse, HLC may consider the nature of the allegation, whether the alleged fraud and abuse appears to meet HLC’s understanding of fraud and abuse as outlined in this policy, other HLC policies, or in federal or state definitions of fraud and abuse, and whether the source of the allegation has provided any evidence of the alleged fraud and abuse.

HLC will review an allegation of fraud and abuse through an appropriate mechanism provided for in HLC policy and procedure based on the source and nature of the allegation. An institution that has been determined, through the appropriate review mechanism, to have engaged in fraud and abuse as outlined in this policy shall be considered to be in violation of HLC requirements, including those related to institutional integrity, and shall be subject to appropriate action, up to and including withdrawal of accreditation.

Evidence of fraud and abuse may also arise from any HLC evaluative activity. In such cases, an institution shall be considered to be in violation of HLC requirements, including those related to institutional integrity, and shall be subject to appropriate action, up to and including withdrawal of accreditation.

HLC shall report incidents of fraud and abuse to the U.S. Department of Education as outlined in its policy on the Relations with the U.S. Government, following the conclusion of HLC’s review of the allegation or evaluative activity. HLC may also refer such allegations to appropriate state and federal agencies.

Policy History

Last Revised or Edited: November 2025, effective September 2026
First Adopted: February 2017
History:* edited February 2021; revised February 2023; revised November 2025 (effective September 2026)
Notes:

* In the history, “revised” indicates that the HLC Board of Trustees adopted changes to the policy, and “edited” indicates that HLC staff made technical amendments or minor editorial revisions that did not require formal Board approval.