Special Monitoring

Special monitoring allows HLC to respond quickly to a developing situation at a member institution. The HLC president may assign special monitoring based on information received from a variety of sources indicating that special monitoring may be appropriate. Special monitoring processes shall be tailored as appropriate under the circumstances and include a special monitoring report, an advisory team visit or an institutional designation.

Circumstances That May Give Rise to Special Monitoring

Circumstances that may result in special monitoring include, but are not limited to:

1. Significant situations involving the institution’s governing board, administration, faculty or student body.
2. Material reduction in educational program offerings, faculty or enrollment.
3. Information regarding potential serious misrepresentation to students or the public.
4. Any of the conditions related to the assignment of institutional designations, as detailed below.

Special Monitoring Reports

A special monitoring report is a report prepared by the institution and submitted to HLC to gather further information about situations that give rise to concerns about the institution’s compliance with HLC requirements.

Staff or assigned peer reviewers shall review the special monitoring report and make factual determinations related to the institution’s compliance with HLC requirements without articulating any recommendation for action. Such determinations shall be used to assist the HLC president in determining an appropriate action or recommendation for action.

Advisory Visits

An advisory visit is an on-site evaluation conducted by a team of peer reviewers of appropriate size and expertise to gather further information about situations that give rise to concerns about the institution’s compliance with HLC requirements.

The institution will be required to provide information about its compliance with the applicable HLC requirements identified by the HLC president in advance of the advisory visit. HLC may also make other information in the institution’s record available to the team in advance of an advisory visit.

An advisory visit can be of any reasonable duration calculated to maximize the team’s ability to conduct an effective evaluation, including interacting with appropriate constituencies of the institution, such as students, faculty, administration and the institution’s board. The timing and format of an advisory visit is in the sole discretion of the HLC president.

An advisory visit team shall make factual determinations related to the institution’s compliance with HLC requirements without articulating any recommendation for action. Such determinations shall be used to assist the HLC president in determining an appropriate action or recommendation for action.

Institutional Designations

Institutional designations inform the public that the institution is experiencing a significant financial issue or is being investigated by a governmental agency. Institutional designations shall be assigned as soon as possible after HLC has confirmed that a factual basis for the institutional designation exists. HLC does not undertake any independent evaluation of the underlying circumstances giving rise to the institutional designation, as related to HLC requirements, in advance of assigning an institutional designation.

Information about the assignment of an institutional designation will be published in a Public Disclosure Notice on the institution’s Statement of Accreditation Status on HLC’s website.

While an institutional designation is in place, HLC may require that the institution undergo routine monitoring or special monitoring, as determined appropriate by the HLC president.

Financial Issue Designation. Conditions that may contribute to the assignment of a Financial Issue designation include, but are not limited to:

1. The U.S. Department of Education places the institution on the Reimbursement payment method or Heightened Cash Monitoring 2 (HCM2).
2. The institution files for bankruptcy.
3. The institution declares financial exigency or other financial emergency.
4. The institution’s independent auditors express doubt regarding the institution’s ability to operate as a going concern, indicate an adverse opinion, or otherwise make a finding of material weakness related to the institution’s financial stability.
5. HLC identifies a source raising serious concerns about the institution’s financial viability or financial management practices, such as Security Exchange Commission filings, state auditor reports or other similar sources.
6. HLC identifies other similar financial situations affecting the institution’s financial capacity.

Governmental Investigation Designation. Conditions that may contribute to the assignment of a Governmental Investigation designation include, but are not limited to:

1. Significant investigation of an institution by a governmental entity related to the institution’s operations or activities.
2. Notice of intended limitation, suspension or termination action by the U.S. Department of Education.
3. Significant litigation or enforcement action involving an institution that is by or joined by a governmental entity related to the institution’s operations or activities.

Process for Assigning or Removing an Institutional Designation. The HLC president will notify the institution of the intent to assign an institutional designation and will provide the institution a minimum of 14 days to respond before acting to assign the institutional designation.

The HLC president will take into account the institution’s response in making the decision whether to assign the institutional designation. Upon review of the institution’s response, the HLC president, after consultation with the Board of Trustees, shall have the authority to assign the institutional designation.

The HLC president shall periodically reevaluate the institutional designation while in place.

The HLC president will remove the institutional designation when HLC has taken appropriate action following review of the institution’s ongoing compliance with HLC requirements in light of the circumstances than contributed to the institutional designation. Any decision of the HLC president related to assigning or removing an institutional designation is final.

Presidential Action or Recommendation Following Special Monitoring

Following special monitoring, an institution will be provided with the report or analysis of the peer review team or HLC staff and with information regarding any action recommended or required by the HLC president.

After considering both the information in the report or analysis and HLC policies, the HLC president shall have the authority, subject to HLC policies and procedures, (1) to act to accept the report or analysis with or without further routine monitoring; or (2) to take a recommendation to the appropriate HLC decision-making body to assign a sanction, issue a Show-Cause Order, or take an adverse action with respect to the institution.

For any action taken by the HLC president following special monitoring, the institution shall be notified of such action.

For any action the HLC president intends to recommend to a decision-making body, the institution shall be notified of such recommendation at least 30 days prior to the intended date of deliberation and decision by that decision-making body.

The institution shall have at least 14 days to respond in writing to any action or recommendation of the HLC president.

Policy History

Last Revised: February 2025 
First Adopted: November 1999  
Revision History: February 2001, February 2007, June 2012, November 2012, August 2016, June 2020, February 2022, November 2022, February 2025 
Notes: Former policy number 3.6(b), 3.6(c). In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”