Statement of Commitment and Conflict of Interest Disclosure Form for Specific Assignments

Higher Learning Commission (HLC) policy indicates that all peer reviewers must “be able to render impartial and objective decisions on behalf of the Commission. Therefore, the Commission will not knowingly allow any person whose past or present activities could affect his or her ability to be impartial and objective to participate in an institutional evaluation…” (HLC Policy PEER.A.10.040: Standards of Conduct).

Likewise, when peer reviewers are serving as members of the Institutional Actions Council (IAC), and for public members of the IAC, HLC “expects that all IAC members will act with objectivity and without conflict of interest when participating in IAC activities. The Commission will not knowingly allow any IAC member to participate in discussions, recommendations, or actions where the IAC member has a conflict of interest that may cause the IAC member to lack objectivity, that may result in the appearance of bias, or that may otherwise call into question the integrity, fairness, or credibility of the IAC processes. ” (HLC Policy INST.D.20.010: Institutional Actions Council).

Information about determining whether a peer reviewer may have a Conflict of Interest is below. For purposes of this information, the term "peer reviewer" is used to include peer reviewers who are serving as members of the Institutional Actions Council (IAC) and public members of the IAC.

Conflict of Interest Definition

A Conflict of Interest is a situation in which a peer reviewer, because of an Education Relationship, Financial Relationship, or other circumstances cannot fulfill their obligations as a peer reviewer in an objective and independent manner or as otherwise required in compliance with applicable laws and regulations. For purpose of this procedure, the term Conflict of Interest also includes:

A potential conflict of interest, in which a peer reviewer, because of an Education Relationship, Financial Relationship, or other circumstances may not be able to fulfill their obligations as a peer reviewer in an objective and independent manner or as otherwise required in compliance with applicable laws and regulations.

An apparent conflict of interest, in which a peer reviewer, because of an Education Relationship, Financial Relationship, or other circumstances may not appear to be able to fulfill their obligations as a peer reviewer in an objective and independent manner or as otherwise required in compliance with applicable laws and regulations.

Peer reviewers will disclose all of their Education Relationships and Financial Relationships at the start of their term on the Peer Corps and/or on the Institutional Actions Council and confirm or update these relationships annually.

At the time peer reviewers or IAC members accept evaluative assignments, they will also affirm none of the following types of conflicts of interest or relationships are present:

Please review the information below carefully prior to providing information or affirming your commitment to these expectations.

Education Relationships

An Institutional Conflict of Interest is a Conflict of Interest with respect to an institution that is accredited by HLC or that is seeking affiliation with HLC.
A Third-Party Conflict of Interest is a Conflict of Interest with respect to an entity or individual with which HLC conducts business or is considering conducting business (“Third Party”). This includes, for example: vendors, consultants, independent contractors, auditors, legal counsel, landlords, banks, etc.
An Education Relationship exists if:
1. The peer reviewer graduated from, attended, attends, has applied to attend, or has accepted an offer of admission to attend the entity in the future.
2. A Related Individual graduated from or attended the entity in the last 10 years, or a Related Individual currently attends, has applied to attend, or has accepted an offer of admission to attend the entity in the future.
A Related Individual is a peer reviewer's:
1. Spouse;
2. Child, grandchild, or great-grandchild (or the spouse of same);
3. Parent or grandparent (or the spouse of same);
4. Sibling (or the spouse of same); or
5. Any other related individual (or the spouse of the same) if living in the same household as the Peer Reviewer.
The term "spouse" in this section includes domestic partners. The terms in sub-sections (ii)-(iv) include "step" relations.

Financial Relationships With Institutions

An Institutional Conflict of Interest is a Conflict of Interest with respect to an institution that is accredited by HLC or that is seeking affiliation with HLC.
A Financial Relationship exists if:
1. A peer reviewer is currently, or has been, an employee of the institution.
2. The peer reviewer is currently, or in the last 10 years has:
  1. Been an officer, board member, director, partner, trustee, or in another similar relationship with an institution;
  2. Had more than a nominal ownership interest or investment in an institution; or
  3. Received, or anticipates receiving, more than nominal compensation or other benefits from the institution, including gifts.
3. A Related Individual currently, or in the last 10 years has:
  1. Been an employee, officer, board member, director, partner, trustee, or in another similar relationship with an institution;
  2. Had more than a nominal ownership interest or investment in an institution; or
  3. Received, or anticipates receiving, more than nominal compensation or other benefits from the institution, including gifts.
A Related Individual is a peer reviewer’s:
1. Spouse;
2. Child, grandchild, or great-grandchild (or the spouse of same);
3. Parent or grandparent (or the spouse of same);
4. Sibling (or the spouse of same); or
5. Any other related individual (or the spouse of the same) if living in the same household as the peer reviewer.
The term “spouse” in this section includes domestic partners. The terms in sub-sections (ii)-(iv) include “step” relations.
Determining what amount is nominal will vary based on the circumstances of a situation. For example, the dollar value for a nominal gift is different than the dollar value for nominal compensation as an independent contractor. In general, an amount is “more than nominal” if it could reasonably be perceived as significant enough to influence an individual’s objectivity.

Financial Relationships With Third Parties

A Third-Party Conflict of Interest is a Conflict of Interest with respect to an entity or individual with which HLC conducts business or is considering conducting business (“Third Party”). This includes, for example: vendors, consultants, independent contractors, auditors, legal counsel, landlords, banks, etc.
A Financial Relationship exists if a peer reviewer or a Related Individual:
1. Currently is an employee, officer, board member, director, partner, trustee, or in another similar relationship with the Third Party;
2. Currently has a more than nominal ownership interest or investment interest in the Third Party; or
3. In the past year, has received, or anticipates receiving, more than nominal compensation or other benefits from the Third Party, including gifts.
A Related Individual is a peer reviewer’s:
1. Spouse;
2. Child, grandchild, or great-grandchild (or the spouse of same);
3. Parent or grandparent (or the spouse of same);
4. Sibling (or the spouse of same); or
5. Any other related individual (or the spouse of the same) if living in the same household as the peer reviewer.
The term “spouse” in this section includes domestic partners. The terms in sub-sections (ii)-(iv) include “step” relations.
Determining what amount is nominal will vary based on the circumstances of a situation. For example, the dollar value for a nominal gift is different than the dollar value for nominal compensation as an independent contractor. In general, an amount is “more than nominal” if it could reasonably be perceived as significant enough to influence an individual's objectivity.

Other Circumstances

An Institutional Conflict of Interest is a Conflict of Interest with respect to an institution that is accredited by HLC or that is seeking affiliation with HLC.
A Third-Party Conflict of Interest is a Conflict of Interest with respect to an entity or individual with which HLC conducts business or is considering conducting business (“Third Party”). This includes, for example: vendors, consultants, independent contractors, auditors, legal counsel, landlords, banks, etc.
Previously undisclosed circumstances that could require disclosure include, but are not limited to:
1. A peer reviewer’s or Related Individual's close professional or personal relationship with key representatives of a Third Party or institution
2. A peer reviewer’s previous other dealings with a Third Party or institution, such as the peer reviewer’s or a Related Individual’s recent application for employment, or the peer reviewer’s or a Related Individual’s recent receipt of awards or honorary degrees
3. A peer reviewer’s review of an institution through an accreditor other than HLC in the past 10 years
4. A peer reviewer’s cooperative or competitive relationship with a Third-Party or institution
5. Any other circumstances that might create a Conflict of Interest

Questions?

Contact HLC at accreditation@hlcommission.org.

Statement of Commitment

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I have reviewed the Objectivity and Conflict of Interest Information for Peer Reviewers and Institutional Actions Council Members. I am familiar with, and agree to abide by, the expectations and procedures stated there and in HLC policy. I do not have any Conflicts of Interest, as defined in the Objectivity and Conflict of Interest Information for Peer Reviewers and Institutional Actions Council Members and HLC policy, that would preclude my participation in the review of the following institution(s). I will promptly update these disclosures as required.

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