Institutional Actions Council

Composition, Selection, Term, and Activity

The Institutional Actions Council (IAC) shall consist of no fewer than forty (40) members who have been nominated by HLC staff and who have been appointed by the Board of Trustees. IAC members who represent institutions shall be broadly representative of institutions accredited by HLC, with attention to institutional type, control, size, and geographical distribution, and shall be current members of the Peer Review Corps. The IAC shall include representation of individuals who are academics, including faculty members, academic deans or others who have a primary responsibility in the teaching and learning process, and administrators who have a primary responsibility of providing oversight in an institution of higher education.

The IAC shall include a sufficient number of public members. IAC members who are representative of the public shall not be, or have a familial relationship with, current employees, consultants, owners, shareholders, or members of the governing board of any member institution, organization, or applicant thereof, or higher education agency, and shall reside or have a principal place of employment within the area of HLC’s jurisdiction.

The IAC shall make use of committees, known as Institutional Actions Council Meeting Committees and Institutional Actions Council Hearing Committees, in completing its responsibilities for decision-making that may result in final actions or in making recommendations to the Board of Trustees. HLC staff will select individuals from the IAC to compose committees to conduct reviews, as outlined in this policy.

The term of appointment to the IAC shall be renewable four-year terms, to begin at the start of HLC’s fiscal year. HLC may make such term adjustments as it deems necessary consistent with its policies related to peer review.

The IAC shall meet as a body at least one time each year to review the decision process and engage in training.

IAC Authority to Take Action on Accreditation Decisions

The IAC, acting through its committees, is authorized to take action on accreditation decisions other than those for which the Board of Trustees retains exclusive authority, as consistent with HLC policy.

This includes, but is not limited to, taking certain actions regarding:

1. Reaffirmation of accreditation and Pathway placement;
2. Open Pathway Assurance Reviews and Standard Pathway comprehensive evaluations;
3. Biennial visits during candidacy;
4. Applications for substantive change requiring review and decision by a decision-making body, but not including Change of Control, Structure, or Organization; and
5. Recommendations for and resulting from interim monitoring.

For these decisions within its purview, the IAC is authorized to set or modify the next comprehensive evaluation visit date, establish a schedule of required monitoring, and make other changes in the Statement of Accreditation Status.

IAC Authority to Make Recommendations for Accreditation Decisions That Require Board Action

The IAC, acting through its committees, is authorized to review the following recommendations arising from an evaluation process and to forward a recommendation to the Board of Trustees for any accreditation decision for which the Board retains exclusive authority, as consistent with HLC policy.

This includes, but is not limited to, making recommendations regarding whether to:

1. grant or deny status, including candidacy and initial accreditation;
2. issue or remove a sanction, including Notice or Probation;
3. issue or remove a Show-Cause Order; and
4. withdraw status, including candidacy or accreditation.

Conflict of Interest

HLC expects that all IAC members will act with objectivity and without conflict of interest when participating in IAC activities.

HLC 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 IAC processes.

IAC members will periodically be required to confirm their agreement to abide by the conflict of interest and objectivity requirements for IAC members set forth by HLC.

IAC members will also periodically be required to disclose specific circumstances that may result in a conflict of interest. IAC members are expected to promptly update these disclosures, including during an Institutional Actions Council Meeting Committee or Institutional Actions Council Hearing Committee, as needed.

Any conflicts of interest or other recusals will be noted in minutes, as applicable.

Previous HLC Evaluation Activities

An IAC member who participated as a peer reviewer in a comprehensive evaluation of an institution shall not participate in IAC decision-making activity regarding that institution for a period of ten years.

An IAC member who participated in an IAC Hearing regarding an institution shall not participate in IAC decision-making activity regarding that institution for a period of ten years.

With the exception of where deemed appropriate by HLC staff, for example, for continuity purposes, an IAC member who participated as a peer reviewer in an HLC panel or evaluative activity other than a comprehensive evaluation, in IAC decision-making activity, or in an Academy assignment may not participate in IAC decision-making activity regarding that institution for a period of three years.

Confidentiality

An IAC member agrees to keep confidential any information provided by the institution under review and information gained as a result of participating in an action or hearing. Keeping information confidential requires that the IAC member not discuss or disclose institutional information except as needed to further the purpose of HLC’s decision-making processes. It also requires that the IAC member not make use of the information to benefit any person or organization. This obligation to maintain confidentiality continues after the process has concluded. (See PEER.A.10.040, Standards of Conduct, for a list of examples of confidential information available to IAC members.)

Antitrust Compliance

IAC members will be familiar with HLC’s expectations regarding antitrust compliance and conduct themselves in accordance with these expectations when engaging in HLC business or otherwise representing HLC. In general, HLC prohibits IAC members from engaging in conduct (including activities and communications) with the intent or effect of limiting competition amongst accreditors, as prohibited by antitrust laws. When IAC members have questions regarding particular activities or communications, they will consult with HLC’s Antitrust Compliance Team.

Other Standards of Conduct

To the extent applicable and not already stated in this policy, IAC members are expected to adhere to the Standards of Conduct applicable to peer reviewers.

Policy History

Last Revised: June 2023
First Adopted: June 2011
Revision History: April 2013, June 2014, November 2019, June 2020, November 2020, June 2021, June 2022, November 2022, June 2023
Notes: Policies combined November 2012 – 2.2(d)1.2, 2.2(d)1.2a, 2.2(d)1.2b, 2.2(d)1.2b1, 2.2(d)1.2b2. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”