Guidelines from HLC and ODHE for F2F and Online Programs

Higher Learning Commission

The Higher Learning Commission (HLC) follows the “50% rule” when it comes to the proportion of online (distance education) courses in a traditionally face-to-face program. This rule is aligned with U.S. Department of Education guidance and has important implications for institutional accreditation and approval processes.

The 50% Threshold Explained

An institution must seek prior HLC approval if it plans to meet or exceed any of the following thresholds in a given academic year 

1. 50% or more of a program is offered through distance education.
2. 50% or more of students are enrolled in at least one distance education course.
3. 50% or more of all courses are offered through distance education.

This is considered a substantive change and requires a formal application and review process by HLC.

Why It Matters

Crossing the 50% threshold is considered a “significant departure” from traditional delivery methods and is treated as a high-impact, high-risk change. Institutions must demonstrate they have the capacity and quality assurance mechanisms in place to support distance education effectively 

Key ODHE Guidelines on Online Course Proportion

ODHE requires institutions to:

1. Clearly define the delivery modality of each program—whether it is face-to-face, online, hybrid, or HyFlex.
2. Ensure consistency in academic quality across all modalities.
3. Seek approval for new programs or significant changes, including shifts in delivery format (e.g., converting a face-to-face program to online or hybrid).
4. Provide evidence of adequate support services for students in online or hybrid formats.
5. Align with accreditation standards, including those from HLC and other relevant bodies.

When ODHE Approval Is Required

Institutions must submit a change request to ODHE if:

• A program’s primary delivery modality changes (e.g., from face-to-face to online or hybrid).
• A new online or hybrid program is being launched.
• There is a substantive change in how students engage with faculty or instructional content.

These changes are reviewed to ensure compliance with ODHE’s standards for academic quality, student support, and workforce relevance 

Coordination with HLC

ODHE’s review process is designed to complement HLC accreditation. Institutions are expected to maintain alignment with both ODHE and HLC requirements, especially when offering programs that cross the 50% online threshold or involve out-of-state delivery.

Sources

Federal Government, https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2023-05-18/accreditation-and-eligibility-requirements-distance-education

Higher Learing Commission, https://www.hlcommission.org/accreditation/cycles-and-processes/substantive-change/distance-correspondence-education/

Ohio Department of Higher Education, https://highered.ohio.gov/wps/wcm/connect/gov/8caf213a-ff90-4b5f-b2d8-ae8c75b0672f/Academic-Program-Review-Guideines-Procedures_FINAL_Aug2025.pdf?MOD=AJPERES