Show-Cause (Procedural Order)

Upon recommendation by a peer review team, the Institutional Actions Council, the President, or at its discretion, the Board of Trustees may issue an order requiring an accredited institution to show cause, typically within one (1) year (the Show-Cause period), as to why its accreditation should not be removed. The basis for the issuance of a Show-Cause Order will be the Board’s determination that there is probable cause that the institution does not meet one or more Criteria for Accreditation, and/or is not in compliance with other HLC requirements, which may include the Federal Compliance Requirements, the Assumed Practices, the Eligibility Requirements or the Obligations of Membership. The Board of Trustees may consider shortening the Show-Cause period based on factors including but not limited to the following:  

1. the institution has spent a period of time immediately preceding the issuance of the Show-Cause Order on Probation; 
2. findings of noncompliance pose a serious risk of imminent harm or danger to students.  

The Show-Cause Order is public. The institution remains accredited while it is on Show-Cause. The issuance of a Show-Cause Order is a final action not subject to appeal. 

The Board of Trustees will explain the reasons for its decision and areas of probable non-compliance in the Show-Cause Order and in the letter provided to the institution after the action to impose Show-Cause. The Show-Cause Order will require that an institution (1) submit in a timeframe defined by the Show-Cause order a Provisional Plan comporting with HLC Teach Out requirements for such plans to the Institutional Actions Council for review and approval during the Show-Cause period, (2) present its case for continued accreditation by means of a report, known as a Show-Cause Report, that provides substantive evidence that the institution continues to meet each of the Criteria for Accreditation, all the Assumed Practices, and Federal Compliance Requirements and has resolved the issues that led to the findings of probable non-compliance identified in the Show-Cause Order, and (3) host an on-site evaluation team to validate the report. The President of HLC shall determine whether the institutional liaison or other HLC staff member will accompany the Show-Cause Evaluation Visit. The on-site team will produce a report that includes its findings regarding the institution’s compliance with the Criteria for Accreditation and the Federal Compliance Requirements and conformity with the Assumed Practices for consideration by the Board of Trustees. Only the Board of Trustees may ultimately determine that a Show-Cause Order has been satisfactorily addressed, and that the institution has demonstrated compliance with HLC requirements.  

Process for Imposing or Removing a Show-Cause Order 

The Board of Trustees shall take action at the end of the Show-Cause period. If the institution has demonstrated to the sole satisfaction of the Board that it has ameliorated each finding of probable non-compliance identified by the Board detailed in the Show-Cause Order and that it meets each of the Criteria for Accreditation, all the Assumed Practices and all Federal Compliance Requirements, the Board may remove the Show-Cause Order; the Board may also reaffirm accreditation as required by the institution’s reaffirmation cycle with HLC. The Board may remove the institution from Show-Cause subject to a period of Notice if the institution has demonstrated compliance with HLC requirements, but remains at risk related to those areas of non-compliance or other deficiencies.  

If the institution has not demonstrated to the sole satisfaction of the Board (1) that it has ameliorated each area of non-compliance identified by the Board detailed in the Show-Cause Order and (2) that it meets all HLC requirements, the Board shall withdraw accreditation or take any other action provided for in HLC policy including Probation, as appropriate, subject to the requirements of those policies and provided that the maximum time period of noncompliance as stated in INST.E.60.010 Denial or Withdrawal of Status is not exceeded. 

In all cases, the Board of Trustees will act at the conclusion of a Show-Cause process only if the institution’s chief executive officer has been given opportunity of at least 14 days to place before the Board of Trustees a written response to the Show-Cause Report and any other information arising in the Show-Cause process. 

Board Committee Hearing in Show-Cause 

HLC shall make a Board Committee Hearing available to the institution prior to a decision by the Board concluding the Show-Cause Order process, in keeping with INST.E.70.010 Additional Board Procedures.  

Pathways Assignment 

An institution placed under a Show-Cause Order is removed from any reaffirmation pathway until the Show-Cause Order has been removed. 

If, at the conclusion of the Show-Cause period, the Board of Trustees removes the institution from Show-Cause and does not withdraw accreditation or place the institution on Probation or take other action related to a finding of non-compliance, the Board shall assign the institution to the Standard Pathway. The institution will have an evaluation to reaffirm accreditation no later than four (4) years after the Board acts to remove Show-Cause and depending on the previous date of reaffirmation although the Board may set the reaffirmation date earlier, and the institution will be set in the Standard Pathway accordingly. The Board may also require interim monitoring as a part of its action. The institution will remain on the Standard Pathway until it completes a full ten (10) year cycle and is then reaffirmed without further sanction at which time it may be considered for another pathway.  

Substantive Change During the Show-Cause Period 

HLC will not consider for approval any substantive change during the Show-Cause period other than a Provisional Plan as required under this policy and any accompanying Teach-Out Agreements, unless the institution can demonstrate that the change is required by law or by the requirements of a specialized accreditor or is essential for the institution to demonstrate compliance with the Criteria for Accreditation or Federal Compliance Requirements or to remain fiscally viable. Even if HLC accepts the application after this showing of necessity, the application will be subject to strict scrutiny by HLC and may be denied or deferred by staff or by the Institutional Actions Council Committee for consideration by HLC after the Board has removed Show-Cause. Under the federal regulations, additional requirements for prior approval for certain substantive changes apply specifically to institutions placed under a Show-Cause Order after July 1, 2020, as well as for three academic years following removal of such Show-Cause Order, and may be found in HLC’s policies on substantive change (see INST.G.10.010 Substantive Change). An approval of a substantive change for an institution on Show-Cause is not indicative of a determination by HLC that an institution has corrected identified areas of probable non-compliance. 

An institution on Show-Cause is not eligible for the Notification Program for Additional Locations and shall be removed from that program by staff after being placed on Show-Cause and for a period of three years thereafter. Additional information may be found in HLC’s policies on substantive change (see INST.G.10.020 Review of Substantive Change).  

Public Disclosure of Show-Cause 

A Public Disclosure Notice for an institution on Show-Cause will be available on HLC’s website after, but not more than one (1) business day after, HLC notifies the institution of the action issuing the Show-Cause Order. An institution on Show-Cause must notify its Board members, administrators, faculty, staff, students, prospective students, and any other constituencies about the action in a timely manner not more than seven (7) business days after receiving the action letter from HLC; the notification must include information on how to contact HLC for further information; the institution must also disclose this status whenever it refers to its HLC accreditation.   

Show-Cause Evaluation Visit 

An institution under a Show-Cause Order shall undergo a Show-Cause Evaluation Visit by HLC according to a schedule set by HLC’s Board of Trustees in placing the institution on Show-Cause. The evaluation will review the institution’s compliance with all the Criteria for Accreditation and Federal Compliance Requirements and conformity with the Assumed Practices. The visit will be narrowly tailored at HLC’s discretion to make this key determination. 

A team of peer reviewers appointed by HLC staff in accordance with HLC procedures shall conduct a visit to the institution’s main campus and other institutional locations as determined by HLC based on its policies and procedures; for institutions that offer only distance or correspondence education, the team shall conduct its on-site visit to the institution’s administrative offices but may include other institutional locations. 

HLC shall retain discretion to determine the length of the on-site visit or to require that team members conduct additional on-site visits to the institution’s facilities to examine specific issues. 

The President of HLC shall determine whether the institutional liaison or other HLC staff member will accompany evaluation visits related to Show-Cause.  

Institutional Responses to the Show-Cause Evaluation Visit Report  

An institution shall have the opportunity to provide a written response to the written report of a Show-Cause evaluation following HLC policies for the provision of institutional responses. An institution shall have at least 14 days to prepare and submit an institutional response to the team report prior to review and action through HLC’s decision-making processes. 

Policy History

Last Revised: June 2023 
First Adopted: June 2000 
Revision History: June 2006, November 2012, February 2014, February 2015, November 2018, June 2020, November 2020, November 2021, February 2022, June 2022, November 2022, June 2023 
Notes: Policies combined November 2012 – 2.5(c), 2.5(c)1, 2.5(c)2, 2.5(c)3. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”