In response to the pandemic, accrediting agencies acted creatively in applying their quality assurance processes in an uncertain and changing world. Today’s guest post provides insights about how one accrediting agency (the Higher Learning Commission) responded to this challenge and their view of the future. We requested this article because we openly wondered when accrediting agencies will expect their institutions to fully meet their standards that may have been relaxed due to COVID-19.

This post originally appeared in the publication Pursuing Regulatory Compliance for Digital Instruction in Response to Covid-19: Policy Playbook, which was published by the Every Learner Everywhere Network and authored by WCET. The publication addressed the reality that when courses move from face-to-face to mostly digital formats (online, emergency remote, blended, hyflex, or whatever permutation you offer), a different set of federal, state, and accreditation rules may apply. The Playbook gives background on several regulations, resources to understand them, and recommendations on how to comply. As we discussed last week, over the next several weeks we will be releasing a deeper look at the Playbook and highlight the appendices on topics such as accreditation, state authorization, financial aid, and accessibility.

To start us off, Karen J. Solomon, Vice President of Accreditation Relations at the Higher Learning Commission (HLC), affords an inside look at the steps that they took and what actions they will take in the future. Speaking of the future, the Department of Education has allowed accrediting agencies to extend waivers past the end of this year. In news from HLC, it appears that they have chosen not to extend any waivers into 2021.

Thank you to Karen for this insightful contribution.

–Russ Poulin, WCET


The spring 2020 COVID-19 pandemic was a catalyst for higher education to embrace online learning, out of both necessity and convenience to serve learners. Institutional accrediting agencies also reacted, making swift and significant changes. The past several months lend insightful foreshadowing into the future of teaching and learning in higher education. Institutional accrediting agencies responded with agility and alignment to federal guidance and waivers of regulations. As with any major shift, there are many moving parts to help stakeholders track the changes taking place. 

Collectively, members of the Council of Regional Accreditation Commissions (C-RAC) worked diligently to continue quality assurance evaluations at the same time. Accreditors worked within the guidance provided by the U.S. Department of Education (the Department) in response to the public health emergency, providing accreditors the opportunity to waive certain requirements for institutions including the opportunity for institutions to transition to distance education and for accrediting agencies to conduct virtual site visits. While institutions provided swift and significant changes, without traditional faculty and student preparation for the shift to teaching in a distance education environment, it is critical for higher education to now focus on a future that relies on online learning.

While institutions provided swift and significant changes, without traditional faculty and student preparation for the shift to teaching in a distance education environment, it is critical for higher education to now focus on a future that relies on online learning.

Karen Solomon

Immediate Response — Spring 2020

Virtual Evaluations

Recognizing the Department’s guidance, the Higher Learning Commission (HLC) Board adopted a temporary emergency policy to empower agency leadership to quickly provide opportunities for institutions to react to the unfolding crisis. The timing of the action was significant; the agency was in the height of its spring evaluation season with more than sixty institutions scheduled to be reviewed by peer reviewer teams traveling to campuses.

HLC determined that to ensure business continuity it needed to implement virtual evaluations. The Department’s guidance required a follow-up visit to occur as soon as possible given travel restrictions or other safety considerations. It was important to maintain the long-term schedule as much as possible in order to have a sufficient number of peer reviewers available throughout the upcoming academic year. Based on the complexities of a few cases, some evaluations were rescheduled to fall 2020.

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HLC worked to ensure consistency and integrity in the evaluations. Training was delivered to all of the peer reviewers assigned to the spring evaluations. Most of the involved institutions had already submitted their required report prior to the announcement of the new visit protocol so information about the transitions typically occurred during interviews between the institution and the team. Institutions were encouraged to use their technology infrastructure as much as possible, so many of the meetings were held synchronously over the internet in secure environments. When this was not possible, conference calls were organized. Reports from institutions and peer reviewers indicated the shift to a virtual evaluation occurred relatively smoothly. 

The question has been raised whether distance education was evaluated during this time. A review of distance education is embedded across the HLC’s Criteria for Accreditation and the focus on quality is expected wherever and however courses and programs are delivered, whether offered 100% online, in hybrid or hyflex formats. All peer reviewers are trained to evaluate distance education. Review of distance education continued throughout the virtual evaluations, depending on the institution’s current approval status to offer courses and/or programs through this modality. 

Notification Process

The agency wanted to know about the changes taking place at all member institutions, not just those scheduled for a spring 2020 visit. All institutions were expected to inform HLC as plans took shape, through a swiftly developed notification process, in order to ensure quality and continuity in instructional activity. The form was used to report on:

  1. adjustments to normal operations, 
  2. changes to the previously reported adjustments to normal operations and, 
  3. determinations that an institution was resuming on-ground operations. 

Because of the fluid situation unfolding, some institutions submitted multiple notification forms over the months regarding adjustments such as the length of academic year, assignment of grades, waiving graduation requirements, and the use of distance education and accelerated formats. Institutions were expected to outline plans for assuring quality, plans for business continuity, and communication plans for their constituents. 

Distance Education Waivers

Because of the Department’s guidance regarding waivers related to the transition to distance education (and HLC’s recent temporary policy), institutions could request a temporary waiver of normal HLC processes for approving distance education. This was embedded in the notification process. HLC recognized the shift in spring 2020 to distance education for almost all programs, was a rapid and unplanned response to an exploding crisis. Institutions that lacked the capacity to initiate or expand their distance education offerings were counseled to consider developing arrangements with other institutions that had capacity and expertise offering programming in this manner. 

HLC received a relatively small number of waiver requests. Out of a membership of approximately 970 institutions, 16% requested and were granted waivers and an additional 5% indicated that they did not plan to go outside of their current level of approval for distance education and would not be requesting a waiver. Most of the institutions that were granted waivers were small institutions that offered a highly specialized residential experience, were located in rural areas where connectivity could have been a challenge, or were single-purpose institutions offering highly experiential training or development. 

Next Steps

Institutional Evaluations 

Given the current state of the pandemic, HLC is working to identify peer reviewers that are willing to utilize alternative travel options (as described below) to keep our work going. Each institution that completed a virtual evaluation in spring 2020 will participate in a verification visit. All previously scheduled comprehensive evaluations for fall 2020 will be conducted with the majority of the team working virtually. It is expected that one member will travel to the campus simultaneously while the team is working. If it is impossible to have a reviewer on campus, then HLC will resume the verification visit protocol and the visit will be rescheduled to spring 2021. HLC recognizes that some institutions will need to reschedule if students are not on-campus during the term when the peer reviewer is scheduled to visit. 

The question remains whether peer reviewers will be allowed or want to travel during this time. Many peer reviewers may work for institutions that are not allowing employees to travel during the pandemic while others may prefer to defer visiting campuses until it is deemed safe to travel. HLC conducted a survey in early summer to identify peer reviewers that expressed interest in being involved in the visit process. At the time of writing this overview, the results of the survey had not yet been tabulated and should be available in mid-July 2020 so assignments can be made for visits beginning in September 2020.

Notification Process 2.0

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In late June 2020, all institutions were informed that they should continue to notify HLC of adjustments being made to protect the health and safety of their campus communities.

As HLC staff communicate with institutions, it has become apparent there are challenges to developing definitive plans due to the uncertain nature of how the pandemic will continue to impact their communities, students, and personnel.

This second wave of notification informs HLC of the steps taken to ensure quality and continuity in its instructional activity for the upcoming academic year. 

Extension of Distance Education Waivers 2.0

In summer 2020, HLC allowed institutions to request a waiver that will extend to December 31, 2020 due to additional guidance released by the Department. In order to be granted this extension, institutions must demonstrate a commitment and plans related to hallmarks of quality in distance education as published on HLC’s website. The request for the extension required the submission of detailed information regarding its efforts to ensure the integrity of academic offerings through curriculum changes, reconsideration of assessment of student learning, faculty development and support, and services to support student learners in an online environment.

Institutions have been informed they must submit a complete distance education application for review if they anticipate they will need to offer distance education options into 2021 (including Spring 2021). 

Future Focus

In recent months, HLC’s President, Barbara Gellman-Danley, has documented many of the trends that have occurred (and are continuing to occur) during the health crisis. During its June 2020 meeting, HLC’s Board of Trustees took time to discuss the challenges facing higher education in the midst of significant changes to enrollment and resources, the training needed for faculty (and also for students) to thrive in distance education environments, and the challenge of the credit hour as institutions rethink what a semester of learning could look like. They raised questions about the projected ‘new normal’ and how the process of quality assurance will need to evolve. 

HLC will review its hallmarks for distance education, updated in 2009, to support institutions exploring and expanding distance education on a greater scale in the coming year.

Karen Solomon

HLC will review its hallmarks for distance education, updated in 2009, to support institutions exploring and expanding distance education on a greater scale in the coming year. Many of the institutions receiving waivers may have minimal knowledge and resources to develop distance education offerings that follow the hallmarks of quality. HLC is working to provide member education opportunities throughout the 2020-2021 year to enhance awareness and develop good practices at institutions.

The ability to maintain business continuity will support ongoing, regularly scheduled reviews of institutions to enable HLC to continue to ensure quality during the time when the landscape of higher education is undergoing significant disruption and change. Institutions will be expected to evaluate their efforts to provide a sound academic experience to ensure student success and equity in education.

HLC plans to study the information provided through the notification process to learn about the innovative strategies institutions proposed, modified and launched in response to the need to embrace online learning, out of both necessity and convenience in serving learners. With an eye toward nimble response to crises, the Higher Learning Commission is committed to outcomes measurements and quality assurance for all students.

Suggested Resources and References

Karen J. Solomon

Vice President of Accreditation Relations, Higher Learning Commission (HLC)


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