The accountability movement has a way of uncovering things — and the absence of things. In the past year, major scandals having to do with student loans and study-abroad programs have rocked the higher-ed world. Both centered on conflicts of interest. And both uncovered higher ed’s failure to anticipate the inevitable — that when it comes to running the massive, complex institutions that are colleges and universities, conflicts of interest are going to arise as a matter of course. While it was shocking to learn that lenders and study-abroad providers were striking ethically compromised deals with schools, more disturbing still was the realization that many colleges and universities have failed to articulate clear policies and procedures on conflicts of interest.

That was the subject of a session at the recent annual meeting of the National Association of Independent Colleges and Universities (NAICU). Beginning with a show of hands — most of the private college and university presidents in the room could confirm that their institutions have conflict-of-interest policies centered on individuals — the session leaders discovered that most also could not confirm that their schools had framed such policies for institutions themselves. The session leaders went on to urge the creation of such policies, and to block out how institutions might go about it.

Their suggestions were practical and on point. They included writing policies that are clear about how people should report their own and others’ potential conflicts of interest; ensuring that policies give precise, “real-world” examples of such conflicts; soliciting faculty input about how to frame conflict-of-interest policies; and, once the policies are written, publicizing them at all levels of the institution so that everyone is aware of them.

The session leaders also spent time discussing conflicts of interest that involve trustees and non-faculty employees — a pressing topic that ACTA has also dealt with in detail.

You may recall that Dartmouth — in response to recent alumni-trustee elections — has announced plans to restructure its board. Those plans have real problems. And one of the major problems, as ACTA president Anne Neal outlined last summer in a thoughtful series of recommendations, is that there are troubling conflicts of interest inherent in Dartmouth’s governance structure.

ACTA’s document makes strong points that can be applied to institutions generally about how college and university governing bodies can eliminate conflicts that permit CEOs to select and vet the very people who evaluate and compensate them. Citing ways higher ed should incorporate some of the principles embedded in Sarbanes-Oxley, Neal’s memo may be taken as an ethical blueprint for how to identify, report, and cope with conflicts of interest at the higher-ed governance level. It’s also a road map of similar conflicts of interest at private institutions across the country — Princeton, Cornell, Vanderbilt, Hopkins, and others.

If presidents of private colleges and universities want to create policies for conflicts of interest within governance, Neal’s memo is the place to start. Read it here — and circulate it to presidents, trustees, faculty, administrators, and alumni.