Ethical Obligations of Evaluators

Accreditation is based upon a peer review process that requires institutional representatives from all degree levels to review institutions and to make decisions about their accreditation status. In order to maintain the credibility of those decisions, not only must The Commission hold institutions accountable for integrity governing all aspects of their operations, but also must ensure that evaluators responsible for conducting accreditation reviews maintain the highest level of integrity in all matters dealing with the decision-making process of The Commission and in matters dealing with their own institutions. Integrity of the process mandates at least the following ethical obligations and understandings. For additional information regarding The Commission’s philosophy of accreditation, see the Principles of Accreditation. A separate policy, Ethical Obligations of Members of The Commission Board of Trustees, describes the obligations and responsibilities of The Commission Board members.

The process for the determination of an institution’s compliance with accreditation standards requires professional judgment of peers; in this context, professional judgment demands informed review, thoughtful analysis, and reasoned decision making. The collective professional judgment of peers determines the final report of a committee. Evaluators have an obligation to represent all reviews as those of the total committee and not those of particular individuals or groups. When making this collective judgment, it is paramount that evaluators provide for each other an environment that supports a candid exchange of ideas, an opportunity for all opinions to be considered, a respect for individual differences and honest dissent, and a commitment to hold in confidence all such exchanges.

The Commission staff members provide information and advice as is appropriate when assisting evaluators in reviewing an institution. Particularly germane are historical information on similarly situated institutions, and procedural and substantive advice on how the policies and accreditation standards have been interpreted and could be applied to an institution’s case, including possible action and follow up. Their role is an active one, providing advice that may include opinions on institutional patterns, institutional progress, and suggested action.

Although the staff’s role in the process does not supplant the peer review and decision-making process, evaluators should consider information and advice provided by staff to ensure strength and consistency in the process and to prevent decisions that could lead to effective legal action on the part of an institution. Evaluators should support an environment that allows staff to provide relevant and candid advice and to carry out their responsibilities to The Commission and to their assigned institutions, including responsibility for informing an institution of The Commission action and the rationale for such action.

To be eligible to serve as a peer evaluator, service must be scheduled while the individual is serving in an institutional role at a member institution. Exceptions to this requirement may be granted if approved by both the Chief Executive Officer (CEO) of the institution under review and by The Commission President. Clarifications for specific categories of peer evaluators are listed below.

• Evaluators who hold emeriti status at a member institution are eligible to serve up to three years following receipt of emeriti status. Extensions to this limit may be granted if the individual has an ongoing active engagement with the institution as confirmed by the CEO of the institution that awarded the status.
• Evaluators who have retired from a member institution are eligible to serve for up to three years following retirement if approved by the institution’s CEO.
• Evaluators who are separated from the institution and secure employment with another member institution may be eligible for continued service if approved by the CEO of the new institution with which they are affiliated.
• Evaluators who are separated from the institution and are no longer affiliated with a member institution are ineligible to serve. This exclusion includes higher education consultants.
• QEP Lead Evaluators, because they are generally nominated by the institution, are not limited by these eligibility requirements. See the policy, Quality Enhancement Plan, for additional information regarding the nomination and selection of the QEP Lead Evaluator.

Evaluators, including lead QEP evaluators, must maintain complete confidentiality in all accreditation activities and decisions. Confidentiality applies to all documents, correspondence, and discussions relative to all phases of the review. Evaluators are prohibited from saving, copying, uploading, downloading, or distributing these materials through any electronic means that would make them accessible to unauthorized individuals outside the designated review process. Upon conclusion of the review, members must ensure proper disposal of the materials in accordance with established protocols. Evaluators may not retain institutional materials without explicit permission from the institution. Moreover, peer evaluators are expected to maintain confidentiality regarding input from the staff just as they do regarding all other discussions conducted in the review process.

1. information about an institutional case under review, including the analysis of institutional materials; committee discussions before and during the meeting; and the resource material constituting the case
2. information distributed by The Commission staff and oral comments by staff
3. findings and recommendations of the committee
4. former decisions of the Committees on Compliance and Reports or of the Executive Council that may have been shared as part of the record for review
5. rationale for a committee recommendation pertaining to an institution

Without a commitment to confidentiality by all evaluators and in all aspects of the review process, peer evaluators cannot freely execute their responsibility to conduct themselves with professional integrity in accreditation activities and decisions.

The Commission policies provide appropriate safeguards against conflict of interest in arriving at accrediting decisions. Evaluators, including lead QEP evaluators, should not accept appointment to a review committee where conflict of interest, or the appearance of conflict of interest, exists. The Commission relies on the personal and professional integrity of individual committee members, expects them to be sensitive to potential conflicts of interest in the peer review process, and assumes they will act accordingly. If it is discovered that a conflict of interest situation may have significantly affected the evaluation of an institution by a visiting committee, the Chair of The Commission Board of Trustees may ask that a further evaluation of the institution be initiated to determine the validity of the original findings of the visiting committee.

As examples, an evaluator would have a conflict of interest if he or she

1. is employed within a state where the parent campus of the institution is located;
2. has been a consultant at the institution within the last ten years;
3. has been an appointee of the institution within the last ten years (e.g., board member);
4. has been an employee of the institution;
5. has been a candidate for employment at the institution within the last ten years;
6. is a graduate of the institution;
7. has a close personal or familial relationship with persons at the institution or a strong bias regarding the institution;
8. is a stockholder or board member of the institution;
9. has any other relationship that could serve as an impediment to rendering an impartial, objective professional judgment regarding the accreditation of an institution; or
10. is a Board of Trustee member and has been invited to serve as chair or member of an evaluation committee scheduled to review the institution of another Board member.

Members of review committees must not give advice to or consult with the visited institution, in relation to any issues contained in the follow-up responses or monitoring reports submitted by the institution, until initial action has been taken by The Commission in connection with these issues. A committee member who violates this provision will not be used as an evaluator in the future. An institution is expected to respect the integrity of the accreditation process by not engaging any team member as a consultant, paid or unpaid, or as an employee for this period of time.

A committee member who is recruited or who intends to apply for a position at the visited institution before initial action is taken by The Commission should notify the President of The Commission in advance. A committee member who violates this notification provision will not be used as an evaluator in the future. An institution is expected to respect the integrity of the accreditation process by not engaging any team member as a consultant, paid or unpaid, or as an employee for this period of time. Any evidence of not following this provision of the policy would result in a referral to the Board of Trustees for consideration during the institution’s scheduled review.

Conflict of Interest and Undue Influence. An evaluator is expected to contact The Commission staff when an attempt is made to influence the evaluator’s judgment or to influence an impending review. Examples of undue influence might include:

1. In advance of an off-site review, an evaluator is contacted by representatives of the institution to discuss the upcoming off-site evaluation;
2. A supervisor attempts to influence an evaluator reporting to the supervisor regarding an upcoming institutional review; and
3. In advance of an on-site review, an evaluator is contacted by representatives of the institution to discuss the upcoming on-site evaluation for reasons other than providing requested additional information or clarification.

Evaluators serving on The Commission Review Committees will affirm electronically that they have no conflict of interest with the institution(s) under review as part of the process of accepting a formal invitation to serve.

Institutions accredited by The Commission may be publicly traded corporations or may be owned by publicly traded corporations. The actions that The Commission may take concerning these institutions may affect the stock price of these corporations. This fact necessarily imposes certain obligations on The Commission Volunteers. A copy of this policy will be provided to all The Commission Volunteers upon their appointment or service.

[Publicly Traded Institution]. A Publicly Traded Institution is a corporation that is or that owns an educational institution which is a member of or candidate for accreditation by The Commission, the stock of which is traded on any public stock exchange. [Immediate Family]. An individual’s immediate family includes spouse, children, and parents.

[Direct or Beneficial Ownership.] Direct or beneficial ownership includes ownership in one’s name individually, through a closely held corporation or family partnership, by an individual retirement account or similar retirement vehicle, or by a trust. An individual is not considered a direct or beneficial owner of stock if that individual owns mutual funds that may own stock in a publicly traded institution. An individual is not considered a direct or beneficial owner of stock if that individual’s employer holds stock of a publicly traded institution in its endowment.

[Persons Subject to this Policy]. Persons subject to this policy are The Commission Board Members, Officers, Employees, Volunteers, and their Attorneys.

Obligations concerning publicly traded institutions the stock of which is owned by individuals. No person who is subject to this policy may take any action or serve in any capacity concerning a publicly traded institution the stock of which the individual or the individual’s immediate family owns directly or beneficially. Obligations concerning publicly traded institutions subject to action by The Commission. No person who is subject to this policy may disclose to any person who is not subject to this policy any information concerning any action or proposed action by The Commission concerning a publicly traded institution except through a means that makes the disclosure available to the general public at the same time; provided however, that The Commission may disclose such action or proposed action to representatives of the publicly traded institution in advance of the public disclosure.

Obligations of The Commission staff. The Commission staff shall make available to persons subject to this policy at least annually a list of all publicly traded institutions.

When accepting an appointment to serve, a peer evaluator agrees to the following responsibilities:

1. Meeting Attendance. All evaluators are expected to arrive and depart on the dates and at the times specified by committee chairs or The Commission staff. They are expected to participate in all scheduled meetings and conference calls.
2. Assignments. All evaluators are expected to analyze an institution’s compliance with specific accreditation standards, formulate recommendations or statements of committee findings, and write draft narrative that reflects the consensus of the committee. Fulfilling this responsibility requires completion of reading assignments, communication with other committee members and The Commission staff, and professional conduct in executing the work of The Commission.
3. Collegiality. Evaluators are expected to interact with other evaluators, institutional representatives, and The Commission staff in a collegial and professional manner. This extends to all communications, use of technology, interviews, and committee deliberations. Evaluators should understand that they represent their own institutions and The Commission while engaged in the process of peer review.

All committee members work under the leadership of the committee chair.

1. Evaluators invited to serve on an Off-Site Reaffirmation Committee, or an On-Site Reaffirmation Committee will carefully review The Commission policies on conflict of interest. Evaluators who conclude that they have an apparent conflict of interest with the institution being reviewed will inform The Commission staff and decline the invitation.
2. Evaluators accepting the invitation will affirm via email that they know of no conflict of interest with the institution under review.
3. At the time of the review, members of the Reaffirmation Committee will sign and date a form affirming that they know of no conflict of interest with the institution under review. The final Report of the Reaffirmation Committee will include the signed and dated form for both the Off- and On-Site Reaffirmation Committee members. These forms will remain with the Committee’s Report for archival purposes.

1. Evaluators invited to serve on any other review committee (e.g., Candidacy, Accreditation, Substantive Change, Special) will carefully review The Commission policies on conflict of interest. Evaluators who conclude that they have an apparent conflict of interest with the institution being reviewed will inform The Commission staff and decline the invitation.
2. Evaluators accepting the invitation will affirm via email that they know of no conflict of interest with the institution under review.
3. At the time of the review, members of the evaluation committee will sign and date a form affirming that they know of no conflict of interest with the institution under review. This form will remain with the Committee’s Report, including for archival purposes.

Definitions for identifying and procedures for documenting conflict of interest, the appearance of a conflict of interest, or the absence of a conflict of interest for institutions appearing before the Appeals Committee may be found in The Commission Policy The Appeals Procedures of the College Delegate Assembly.