This policy establishes guidelines to identify, disclose, and manage conflicts of interest in the ITEFLOCA accreditation process. It is designed to ensure that all accreditation decisions are made objectively, impartially, and in accordance with established standards.
SECTION 1: SCOPE AND PURPOSE
This policy applies to all individuals involved in the ITEFLOCA accreditation process, including but not limited to:
- ITEFLOCA Director and management team
- Staff reviewers and evaluators
- Contract reviewers and volunteers
- Administrative personnel with access to provider information
- Advisory board members
The purpose of this policy is to:
- Identify potential conflicts of interest in the accreditation process
- Establish procedures for disclosure and management of conflicts
- Ensure the integrity and credibility of ITEFLOCA accreditation decisions
- Maintain compliance with ethical standards for accreditation bodies
SECTION 2: DEFINITION OF CONFLICTS OF INTEREST
A conflict of interest exists when an individual’s personal, financial, professional, or other interests could reasonably be perceived to:
- Compromise their ability to make fair and impartial decisions
- Influence the outcome of an accreditation review
- Result in preferential or prejudicial treatment of a provider
- Create an unfair advantage or disadvantage for any provider
2.1 Types of Conflicts
Financial Conflicts:
- Current or recent employment by a provider seeking accreditation
- Ownership interest or investment in a provider or competing organization
- Receipt of consulting fees, royalties, or other compensation from a provider
- Significant business relationship with a provider
Personal Conflicts:
- Family relationship with provider owners, directors, or key staff
- Close personal friendship with provider representatives
- Previous disputes or negative interactions with a provider
- Any relationship that could reasonably influence objectivity
Professional Conflicts:
- Current or recent affiliation with a provider
- Competitive relationship with a provider
- Prior involvement in developing courses being reviewed
- Public positions taken on specific providers or methodologies
SECTION 3: DISCLOSURE REQUIREMENTS
3.1 Initial Disclosure
All ITEFLOCA personnel and reviewers must complete a Conflict of Interest Disclosure Form:
- Upon joining ITEFLOCA
- Annually thereafter
- When circumstances change that create new potential conflicts
3.2 Case-Specific Disclosure
Prior to each accreditation review, assigned reviewers must:
- Review the provider and course information
- Disclose any potential conflicts specific to that provider
- Affirm their ability to conduct an impartial review or request reassignment
3.3 Ongoing Obligation
All ITEFLOCA personnel have an ongoing obligation to disclose conflicts of interest that arise during the accreditation process, even if not identified in initial disclosure forms.
SECTION 4: MANAGEMENT OF CONFLICTS
When conflicts of interest are identified, ITEFLOCA will implement appropriate management strategies:
4.1 Recusal
Individuals with significant conflicts must recuse themselves from:
- Reviewing specific providers where conflicts exist
- Participating in accreditation decisions for those providers
- Accessing confidential information related to those providers
- Discussions regarding those providers’ accreditation status
Where the director has conflicts of interest, they must recuse themselves from having any role in the accreditation process and relinquish all processing authority to the lead advisor, who will act as director for all matters related to the accreditation of that/those specific course(s).
4.2 Reassignment
When a reviewer discloses a conflict:
- The review will be reassigned to another qualified reviewer
- The reviewer with the conflict will have no access to the review process
- All reassignments will be documented in the accreditation file
4.3 Additional Oversight
In cases of minor conflicts where recusal is not warranted:
- Additional oversight may be implemented
- Secondary review by unconflicted personnel
- Documentation of the conflict and management approach
4.4 Disclosure to Providers
In certain situations, conflicts may be disclosed to providers:
- When a conflict cannot be fully mitigated through recusal
- When a provider raises concerns about potential bias
- When transparency is deemed necessary for maintaining trust
SECTION 5: PROHIBITED ACTIVITIES
The following activities are explicitly prohibited for all ITEFLOCA personnel:
- Accepting gifts, entertainment, or other benefits from providers seeking accreditation
- Using confidential information obtained through the accreditation process for personal gain
- Providing consulting services to a provider to help them achieve accreditation while involved in their review
- Making public statements about providers that could compromise impartiality
- Participating in accreditation decisions when significant conflicts exist
SECTION 6: TRAINING AND AWARENESS
To ensure understanding and compliance with this policy:
- All ITEFLOCA personnel will receive initial training on conflict of interest identification and management
- Annual refresher training will be provided
- This policy will be included in the Reviewer Training Manual
- Regular reminders about disclosure obligations will be communicated
SECTION 7: DOCUMENTATION AND RECORD KEEPING
ITEFLOCA will maintain records of:
- All conflict of interest disclosure forms
- Specific conflicts identified during the accreditation process
- Actions taken to manage disclosed conflicts
- Decisions regarding reviewer assignments and reassignments
- Any provider complaints related to potential conflicts
These records will be retained in accordance with ITEFLOCA’s document retention policy and applicable laws.
SECTION 8: VIOLATIONS AND CONSEQUENCES
Violations of this policy may result in:
- Removal from specific accreditation reviews
- Termination of employment or contractor relationship
- Revocation of volunteer status
- Re-evaluation of accreditation decisions if compromised
- Other appropriate disciplinary or corrective actions
SECTION 9: POLICY REVIEW
This Conflict of Interest Policy will be reviewed annually to ensure it remains effective and aligned with best practices in accreditation.
SECTION 10: CONTACT INFORMATION
Questions about this policy or to report potential conflicts of interest should be directed to:
Email: accreditor@itefloca.com
Website: www.itefloca.com