The Higher Learning Commission Could Improve Its Evaluation of Competency-Based Education Programs to Help the Department Ensure the Programs Are Properly Classified for Title IV Purposes

We concluded that the Higher Learning Commission did not establish a system of internal control that provided reasonable assurance that schools’ classifications of delivery methods and measurements of student learning for competency-based education programs, including direct assessment programs, were sufficient and appropriate to help the Department ensure that the schools’ programs were properly classified for the purposes of awarding Federal student aid authorized. We further reported that the Higher Learning Commission did not consistently apply its standards for reviewing competency-based education programs because its policies and procedures for substantive change applications needed strengthening. As a result of these weaknesses, the Department might not receive sufficient information about a school’s proposed competency-based education programs to make fully informed decisions about the Title IV eligibility of the programs.