Higher Learning Commission

Policy Title: Routine Monitoring and Data Collection

Number: INST.F.10.010

Monitoring on Pathways. An institution on the Standard, Open, or AQIP Pathway may be required to file one or more interim reports. An institution on the Standard or AQIP Pathway may be required to host one or more focused visits. Such monitoring shall be appropriate in circumstances where the team has concluded that the Commission should review the institution’s progress in addressing a serious issue at the institution, the resolution of which is relevant to the institution’s future compliance with, or improvement regarding, the Criteria for Accreditation. Commission staff may seek external assistance from peer reviewers or individuals with appropriate expertise who do not participate as peer reviewers in the evaluation process related to monitoring but provide particularized advice and assistance where appropriate to Commission staff or evaluation team members.

Other Monitoring. An institution, regardless of its pathway, is always subject to monitoring in the form of interim reports or focused evaluations related to review by the Commission of the following: financial and non-financial indicators; a change of control, structure or organization transaction; substantive change; complaints; conformity with Assumed Practices; or other Commission investigation or review.

Process for Requiring Monitoring. An evaluation team or staff may recommend that an institution be required to file an interim report or host a focused on-site evaluation on one or more topics. An appropriate decision-making body, or Commission staff where allowed by Commission policy, shall determine whether the monitoring is appropriate for the institution, and, if so, shall act to approve such monitoring.

For an institution that is being considered for initial accreditation, such monitoring shall be appropriate in conjunction with the grant of initial accreditation only when the monitoring is with regard to a discrete issue and does not call into the question the institution’s compliance with the Criteria for Accreditation, in which case the institution will not be granted initial accreditation.

Interim Reports. An institution shall submit a required interim report according to the due date established in the action calling for the interim report. Staff will review and prepare a written analysis of all reports and may act on behalf of the Commission to accept the report or require additional reports on the same or related topic or may recommend to the Commission’s decision-making bodies that further monitoring, including new interim reports or focused visits, as appropriate to the institution’s Pathway assignment, be required on the same topics identified in the action or on other topics.

Focused Visits. An institution on the Standard or AQIP Pathway shall host a focused visit according to the date established in the action calling for the focused visit. The institution shall submit a focused report to the Commission prior to the evaluation on the topics identified in that action prior to the focused visit. Commission staff may expand the focus of the evaluation where appropriate to review additional topics of concern to the Commission. The focused visit shall be conducted by a team of Commission Peer Reviewers appointed by Commission staff. The length of the focused visit shall be one and one-half days, but the Commission may lengthen or shorten the visit or require that team members conduct additional on-site visits to the institution’s facilities to examine specific issues.

The focused visit team will prepare a written report addressing the topics of concern identified in the action calling for the focused visit and any areas of concern raised by Commission staff and identifying deficiencies, if any, at the institution. The focused visit team report shall include a recommendation for Commission action either accepting the institution’s focused report or calling for additional monitoring, sanction or withdrawal of accreditation. The institution shall have the opportunity to file a written response to the focused visit report prior to a decision-making body acting on the report. Focused visit reports will be considered through the Commission’s regular review and decision-making processes.

Data Reporting From Affiliated Institutions

All affiliated institutions will complete data reports for the Commission; such reporting will occur annually as well as periodically. The Commission, with oversight as appropriate from the Board of Trustees, will determine the contents of this reporting to assure that it addresses potential or developing problems with an institution’s compliance with accrediting requirements and institutional stability, as well as solicits updated information on the scope of activities of each affiliated institution. Data required from each institution will include, at minimum, annual financial information, headcount and enrollment, measures related to student achievement, and other indicators. The data reporting will provide the Commission with sufficient information to understand and respond to significant shifts in an institution’s capacity and/or scope of educational activities.

Institutional Contact for Data Reporting

To assure that the organization provides accurate and consistent information, each affiliated organization identifies a liaison who will bear administrative responsibility for submitting the report in a timely manner. Commission training will be available for those liaisons.

Commission Follow-Up to Institutional Data

In reviewing and analyzing institutional data, the Commission will look at relationships among a variety of indicators and other information in any given year or over several years. If those relationships suggest that the organization may be experiencing problems or very rapid change, the Commission will ask the organization to submit an explanation of the data. In particular, the Commission will ask institutions that were identified through review of information about student achievement for more information about student academic achievement at those institutions. The Commission staff may forward data, and any explanation or other information provided by the institution, to a Financial or Non-Financial Panel for further review. If non-financial data, particularly enrollment information, and any other information submitted by the institution, are indicative of problems, rapid change, significant growth, or require validation, the Commission staff may call for an on-site evaluation as soon as possible; require that an institution address concerns arising from these data in the next evaluation process; or recommend to the Institutional Actions Council additional institutional monitoring through any process provided for in Commission policy and procedure.

Monitoring of Student Enrollment Growth

The Commission will monitor enrollment growth through institutional annual data reporting and will monitor on an ongoing basis growth in enrollment and programs at those institutions that have significant enrollment growth as defined in Commission procedures. The Commission will ask institutions that have been identified through the annual data reporting process as having significant enrollment growth to provide information about enrollment growth at the program level. The Commission may take follow-up action.

Surveying of Students

The Commission may survey students of an institution to gather information about their experience at the institution prior to a site visit at the institution scheduled by the Commission. The Commission will provide aggregate data resulting from the survey to the institution under review and the evaluation team prior to the visit. The institution will have an opportunity to provide additional information or other data in response to the student survey data to the evaluation team and the Commission prior to the visit.

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Policy History

Last Revised: June 2014
First Adopted: November 1999, February 2003, February 2007
Revision History: February 2001, February 2007, February 2009, February 2010, November 2010, June 2012, November 2012, April 2013, February 2014, June 2014
Notes: Policies combined November 2012 – 3.6, 3.6(a), 1.3, 1.3(a), 1.3(b), 1.3(c)

Policy Number Key

Section INST: Institutional Policies

Chapter F: Maintenance and Monitoring

Part 10: Routine Monitoring

Related Procedures

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