Comprehensive Evaluation

Federal Compliance

The Higher Learning Commission (HLC) is responsible for ensuring that all member institutions comply with applicable federal regulations established by the U.S. Department of Education. Some of these regulations correspond directly with HLC’s criteria for accreditation and assumed practices.

As part of its accreditation responsibilities, Navajo Technical University (NTU) may be subject to federal compliance reviews at any time. In addition, HLC peer reviewers conduct a federal compliance review during the university’s comprehensive evaluation. This review confirms that NTU adheres to federal requirements governing higher education institutions and remains eligible to participate in federal student financial aid programs.

HLC Requirements Related to Federal Regulation

The HLC has established a set of requirements to ensure that both the Commission and its accredited institutions comply with federal regulations. As part of the federal compliance review process, NTU provides documentation and evidence demonstrating its adherence to these requirements and its commitment to maintaining institutional integrity, accountability, and transparency.

The HLC evaluates institutional compliance with the following federal requirements:

1. Assignment of Credits, Program Length, and Tuition

Institutions should make sure that they have a policy or set of policies and procedures for assigning credit hours for all types of courses, disciplines, programs, credential levels, formats, regardless of modality.

Institutions should be able to articulate the processes and structures in place to demonstrate how they adhere to the policy(ies) for assigning credit hours (e.g., by reference to course approval guidelines and processes, course proposal forms, curriculum committee reviews, program review, registrar’s class scheduling procedures etc.).

Institutions that provide instruction through online, alternative, compressed or other formats should also have policies that address how learning is determined, organized and evaluated, and how the institution determines instructional equivalencies.

In addition, the institution should be able to justify tuition variations for a particular program or programs based on costs for offering that degree, the length of the program, or the objectives of the program.

HLC’s intent is (i) to review an institution’s policies regarding the award of credit in relation to the types of courses, disciplines, programs, credential levels and formats offered, regardless of modality; (ii) to determine how the institution ensures it is adhering to those policies; and (iii) to review the institution’s process for verifying length of academic period and compliance with credit hour requirements through course scheduling.

2. Institutional Records Regarding Student Complaints

The institution is expected to demonstrate that it utilizes a systematic complaint- tracking process that best fits its needs. This process should contemplate any formal complaint the institution receives, regardless of the subject matter. Whatever approach the institution takes, the institution should demonstrate that its process effectively allows student complaints to be received, tracked and handled in a timely manner.

While under certain circumstances the institution and team may receive copies (or other notification) of student complaints filed directly with HLC prior to the evaluation visit, institutions are not required to supply any student complaints as part of demonstrating compliance with this requirement.

3. Publication of Transfer Policies

The institution must disclose its transfer policies to students and to the public. At a minimum, these disclosures must include:

Any established criteria the institution uses regarding the transfer of credit earned at another institution and any types of institutions or sources from which the institution will not accept credits;

Written criteria used to evaluate and award credit for prior learning experience including, but not limited to, service in the armed forces, paid or unpaid employment, or other demonstrated competency or learning; and

A list of institutions with which the institution has established an articulation agreement, as well as information about each articulation agreement. The information the institution provides should include any program-specific articulation agreements in place. Also, the information the institution provides should list the specific credits that articulate through the agreement (e.g., general education only, pre-professional nursing courses only, etc.) and include whether the articulation agreement anticipates that the institution under HLC review does the following:

Accepts credits for courses offered by the other institution(s) through the articulation agreement.
Offers courses for which credits are accepted by the other institution(s) through the articulation agreement.
Both offers courses and accepts credits with the other institution(s) in the articulation agreement.

4. Institutional Practices for Verification of Student Identity

Institutions must verify the identity of students who participate in courses or programs provided through distance or correspondence education. The institution must use some number of approaches to verify student identity—which may include, but need not be limited to, for example, a secure login and pass code, proctored examinations, or other technologies and practices—as long as the institution can demonstrate the effectiveness of its approach(es). Additionally, if the method by which the institution verifies student identity will incur a cost to the student (such as a fee for a proctored exam), the institution must disclose that cost to the student at the time of registration or enrollment. The institution must also demonstrate that it is making reasonable efforts to protect student privacy in verifying student identity.

5. Protection of Student Privacy

All institutions must develop and maintain procedures to ensure student privacy is protected in compliance with relevant federal law. Institutions must also ensure the privacy and security of student data (including without limitation, student educational records). In addition, institutions must provide training to ensure adherence to established procedures by employees (and any third-party contractors acting on the institution’s behalf). The institution must also be transparent with students about how any personal data is collected and used.

6. Publication of Student Achievement Data

The institution must disclose student outcome data in a manner that is easily accessible to the public. These data should be available on the institution’s website and should be clearly labeled. Any technical terms in the data should be defined, and any necessary information on the method used to
compile the data should be included. Data may be provided at the institutional or departmental level or both, but the institution must disclose student outcome data that address the broad variety of its programs. Additionally, if an institution uses student placement rates in any marketing or recruitment content, it must also disclose these data.

7. Standing with States and Other Accreditors

An institution must disclose to HLC any change in the status of its relationship with any other specialized, professional or institutional accreditor and with all governing or coordinating bodies in states in which the institution may have a presence. The expectation is that the disclosure will fairly and
accurately represent the institution’s relationship and will proactively inform HLC of any negative action that significantly qualifies that status (e.g., sanction or adverse action). An institution is not required to disclose routine monitoring imposed by other accrediting agencies to satisfy this requirement.

8. Recruiting, Admissions, and Related Enrollment Practices

All institutions must provide a code of conduct (or the equivalent) related to recruiting, admissions and enrollment management, as well as training materials for any recruiters, admissions counselors, marketing or advertising staff, financial aid advisors, and any other personnel engaged in direct communications with prospective students prior to their matriculation. Institutions are also responsible for exercising appropriate oversight over any third-party contractor(s) involved in providing such services to prospective students. Institutions are expected to otherwise be in continuous compliance with HLC policy on Recruiting, Admissions and Related Institutional Practices (FDCR.A.20.020).