Number: PEER.A.10.040

HLC expects peer reviewers to behave with the highest level of ethics and integrity while conducting any activity on behalf of HLC. Peer reviewers must abide by appropriate and ethical standards of conduct to assure the public and the higher education community that evaluations have been carried out objectively and with the goal of assuring the public good.

While participating as peer reviewers in any institutional evaluation, hearing or other HLC activity as a peer reviewer, peer reviewers shall agree to abide by the following Standards of Conduct:

Peer reviewers:

1. Conduct themselves with appropriate dignity and professionalism while representing HLC.
2. Treat all institutional representatives, members of the public, fellow peer reviewers and HLC staff with courtesy and respect.
3. Follow HLC’s Policy on Objectivity and Conflict of Interest, as detailed below.
4. Rely on expectations indicated in HLC’s Criteria for Accreditation and other HLC requirements to form professional judgments about institutions under evaluation and refrain from expressing personal opinions based on preconceived notions, biases or predispositions.
5. Act reliably and with competence in all HLC activities. This includes, for example, by reading assigned materials in advance, reviewing HLC requirements, attending required training, collaborating with other team members, meeting team chair expectations and participating in all evaluation activities as outlined by HLC staff.
6. Follow HLC’s Policy on Independent Consulting and guidelines on independent consulting, as detailed below.
7. Decline any offer of gifts, incentives, or other compensation from any institution under review unless those gifts are nominal in nature (less than $50 fair market value per individual gift) or of significance in a particular cultural context and of reasonable value; and notify HLC staff of an offer of such gift that exceeds this threshold. (Note that the institution may provide a meal or social function for an evaluation team or other HLC group provided that the function is conducted simply and at reasonable cost.)
8. Act with appropriate fiscal moderation while conducting an institutional evaluation or other HLC activity. Provide an accurate reporting of all expenses incurred during that activity and otherwise comply with HLC’s financial and reimbursement policies and procedures.
9. During an evaluation visit to an institution and for one year thereafter, refrain from seeking or accepting employment, or exploring any future relationship, with the institution under review.
10. During an evaluation visit to an institution and for a period of one year after HLC action in the evaluation, refrain from soliciting for employment at their home institution any employee of the institution under review.
11. Follow HLC’s Policy on Confidentiality, as detailed below.
12. 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 peer reviewers from engaging in conduct (including activities and communications) that have the intent or effect of limiting competition amongst accreditors, as prohibited by antitrust laws. When peer reviewers have questions regarding particular activities or communications, they will consult with HLC’s Antitrust Compliance Team.
13. Refrain from commenting verbally or in writing on the details of any institutional review in which they have been engaged, whether during the course of any institution’s evaluation or otherwise unless compelled by legal process or otherwise authorized by HLC. This requirement applies even if the institution’s identity is kept confidential.
14. Cooperate in any legal process in which HLC or its Board of Trustees or staff have become engaged, refrain from responding to any inquiries related to legal action made by institutions or their counsel, and direct such inquiries to HLC staff.
15. Destroy any materials related to an evaluation following final decision making related to that evaluation, unless otherwise instructed by HLC staff.

Policy on Objectivity and Conflict of Interest. Peer reviewers must be able to render impartial and objective decisions on behalf of HLC. Therefore, HLC will not knowingly allow any person whose past or present activities could reasonably be expected to affect his or her ability to be impartial and objective to participate in an institutional evaluation. HLC shall establish procedures related to objectivity and conflict of interest. Peer reviewers will disclose any information as required by that policy to HLC staff in advance of accepting any assignment.

When appropriate, HLC staff will notify the institution of potential conflicts of interest and will consult with the peer reviewer and the institution regarding that person’s suitability for the assignment. HLC staff reserves final responsibility for determining whether the peer reviewer will participate in an institutional evaluation, or review.

Policy on Confidentiality. In all HLC accreditation processes, a peer reviewer must agree to keep confidential any information provided by the institution under review and information gained as a result of participating in any part of HLC’s review processes. Confidential information includes, but is not limited to:

1. Information about the institution not made available to the by the institution and not already available as a result of its reporting to the Federal Government’s Integrated Postsecondary Educational Data System (IPEDS);
2. Information provided in institutional reports, and any information made available to the peer review team prior to finalization of the team report;
3. Information shared orally as part of HLC’s review processes.

Keeping information confidential requires that the peer reviewer not discuss or disclose institutional information except as needed to further the purpose of HLC’s evaluation processes. It also requires that the peer reviewer not make use of the information to benefit any person or organization. Maintenance of confidentiality survives the evaluation visit (or assurance review) and continues after the process has concluded.

Independent Consulting

To avoid the appearance of possible conflict of interest in the accreditation process, no peer reviewer who evaluated an institution for HLC may serve as an independent consultant to that institution for a period of three years following the official HLC accrediting action. In addition, no peer reviewer will participate in an HLC evaluation of an institution for which that peer reviewer served as an independent consultant in the previous ten years. (See HLC Policy PEER.A.10.050: Peer Corps Members in HLC Evaluative Activities.)

Peer reviewers will disclose to HLC on an annual basis all consulting activities related to a member institution or related to accreditation and will agree to inform any institution or other entity with which the peer reviewer is developing a consulting relationship that the peer reviewer is acting in a personal capacity and is not representing HLC.

Violations of the Standards of Conduct. HLC staff will review allegations that a peer reviewer has violated the Standards of Conduct or has otherwise failed to meet HLC expectations and may ask the peer reviewer and others involved to provide information. If there is a determination that a peer reviewer has violated a Standard of Conduct or has otherwise failed to meet HLC expectations, authorized HLC staff will address the issue with the peer reviewer. This may include various corrective interventions, including verbal feedback, recommendations for additional training or professional development activities. HLC may also opt to terminate the peer reviewer’s service consistent with these policies.

Policy History

Last Revised: June 2021
First Adopted: January 1983, February 1984, August 1990, February 2001, November 2006
Revision History: October 2003, November 2012, April 2013, June 2018, November 2018, November 2020, June 2021
Notes: Policies combined in November 2012 – 5.1, 5.1(a), 5.2, 5.3, 8.2. In February 2021, references to the Higher Learning Commission as “the Commission” were replaced with the term “HLC.”