In 2009, the Office of the Inspector General of the U.S. Department of Education (OIG-ED) criticized the Higher Learning Commission's oversight of for-profit colleges and recommended that the agency consider "limiting, suspending, or terminating the organization's status.

[12] The guidelines identified ten core principles—Focus, Involvement, Leadership, Learning, People, Collaboration, Agility, Foresight, Information, and Integrity—that high performing organizations use to guide their operations, and required institutions to develop their own projects to apply those principles tho their own activity and measure their success.

The program took a collaborative approach with "Strategy Forums" where groups of institutions shared their insights about the "Action Projects" they undertook to address various challenges.

At the end of the review cycle institutions were responsible for preparing a "Systems Portfolio" that required them to answer specific question about processes, results, and improvements for each of the 9 AQIP categories.

[14] In order to elect participation in AQIP,[15] institutions were required to be accredited for ten years and to have demonstrated established foundations in "expected practice" under traditional pathways.