HLC has submitted a comment letter to the U.S. Department of Education (ED) regarding the Accreditation, Innovation, and Modernization (AIM) Proposed Rule.

As described in HLC’s last Advocacy Alert, several provisions in the Proposed Rule may require institutions to develop extensive policies, procedures and systems that may not currently exist to maintain accreditation. 

The comment letter notes that requirements for accreditors become requirements for institutions. This burden is likely to actually stifle innovation and is not in the best interest of students. 

Additionally, the comment letter details how aspects of the proposed rule exceed ED’s regulatory authority under the Higher Education Act (HEA) and are not aligned with the HEA’s requirement that an accreditor respect institutional mission. The prescriptive and one-size-fits-all rules for institutions will prohibit an agency from allowing an institution to demonstrate its compliance with agency standards based on its mission. 

HLC’s comment letter affirms our commitment to innovation, respecting the individual mission of each institution, reducing unnecessary burden while maintaining rigorous quality assurance, and partnering with member institutions to foster continuous improvement. 

It is HLC’s hope that the recommendations in its comment letter will better align the final regulations with the intended purpose of the AIM Committee, and will avoid a situation in which accreditation becomes more confusing, more burdensome and more expensive for institutions and the students they serve. 

HLC encourages all members to review both the proposed rule and HLC’s comments and to provide your own comments to ED by the deadline of September 21, 2026.