1.2.14 Conflict of Interest Policy for Volunteers
In order to ensure that programs receive an equitable and impartial review from the Commission on Accreditation (COA), free from any ethical conflicts or inappropriate influences that could either corrupt the integrity of the accreditation process or could result in any appearance of impropriety, the following conflict of interest policies and procedures shall be in place. The same rules apply for all volunteers interacting with programs on behalf of CSWE-COA (whether commissioners or site visitors).
Ethical Guidelines/Direct Conflicts
A variety of situations exist where the potential for ethical dilemmas in the form of a conflict of interest (hereinafter “COI”) can arise, when volunteers serve in the capacity of a site visitor or a commissioner. Some of these potential ethical conflicts are easily discernable and others more nuanced. The questions of whether the visitor can act in an impartial manner free from any bias, or the potential for the program to believe that any such lack of impartiality exists, should be paramount to determining the existence of a potential ethical COI.
A. Situations Where Recusal is Necessary
In the event that any of the situations (below) occur, the volunteer MUST recuse themself from any involvement in the visitation or review of a program, and decision-making about a program:
a. The volunteer lives or works in the geographical location of the institution or social work program’s main campus (i.e., within the same state or metropolitan area); if the volunteer is affiliated with the same educational system (e.g., SUNY, CSU, etc.); or where the appearance of a conflict of interest might be present. If a program is online-only, this applies to a volunteer who lives or works in the same state or metropolitan area of the institution's main campus.
i. An exception to this rule is that volunteers may conduct visits when there is a necessity for a Spanish-speaking volunteer regardless of geographical location, as long as that volunteer does not fall under any other situations where recusal is necessary.
b. The volunteer visited the program for the last accreditation review.
i. An exception to this rule is Commissioners may be readers of program documents for programs they have read for previously.
ii. An exception to this rule is Commissioners may be readers of program documents for Spanish-speaking programs they have visited in a prior candidacy benchmark due to the necessity for review by Spanish-speaking Commissioners.
c. The volunteer has any existing or prior relationship with the institution or the social work program, as an employee, faculty member (full or part-time), staff member, student, alumnus, intern, donor, board member, member of educational or research collaborative, previous or current applicant (student or employment), party to any litigation, and/or consultant.
d. The volunteer has any pecuniary or personal interest in the program or its parent institution. This may include but is not limited to, any monetary or personal interest in the outcome of an accreditation decision; any close personal or professional relationships with individuals at the institution or social work program (including, but not limited to, any family members attending); or nonpublic or privileged information.
e. The volunteer believes that any other circumstances not aforementioned, could result in an impairment of judgement, create any appearance of impropriety, or cast any reasonable doubt as to the integrity of the accreditation process.
f. Any exceptions to the above must be approved by DOSWA staff or the COA Executive Committee.
Confidentiality of Accreditation Process and Materials
Program materials provided to volunteers are strictly to be used in furtherance of the accreditation process for the specific program that developed those materials. These materials are confidential, as is the review process. The volunteer is not to use any of that program’s materials for any other purpose and must dispose of, delete, and/or destroy any program-related materials following the site visit or review. Any volunteer who is found to have used program materials for personal gain, consultant work, internal use by their own program, or discusses confidential program material or findings with any external source outside of Department of Social Work Accreditation (hereinafter “DOSWA”) staff, will be removed from service.
Responsibility to Notify of Alleged COI
A. Programs: If a program is aware of any potential COI issue related to commission/site visitor assignments, they are responsible for immediately notifying DOSWA staff (the Site Visit Coordinator) of such potential COI, so that alternative arrangements can be made. Should it later be determined that a program knew or should have known of a potential COI and did not disclose this, it could have a potential adverse impact on their accreditation status per section 1.1.15 Integrity Policy in the EPAS Policy Handbook.
B. Volunteers: Should a volunteer become aware of any potential COI, it is also their responsibility to immediately notify DOSWA staff (the program’s Accreditation Specialist and the Site Visit Coordinator) of such potential COI, so that alternative review or visit arrangements can be made. Should it be later determined that a volunteer knew or should have known of a potential COI and did not disclose this, they will be referred to the COA Executive Committee for remediation and potentially removed from future service.
Accepting Gifts/Personal Time
The primary function of a commission/site visit is program analysis in furtherance of the accreditation process. Social engagements, gratuities, or gifts may interfere with this function or create an appearance of impropriety or bias. Therefore, in furtherance of a need to keep the accreditation process impartial, site visitors and commissioner visitors should not accept non-visit related social invitations or gifts from institutions, programs, individual faculty/staff, students, or any other stakeholder group, and should politely decline any such overtures in relation to the commission/site visit. Additionally, while conducting a visit, a volunteer may be in close proximity to family, friends, colleagues, etc. Volunteers should exercise prudence and refrain from visiting with any of these personal contacts during the time in which they are scheduled to attend to matters associated with the site visit. Volunteers should not make any plans that may interfere with their work of the site visit, given that the travel and lodging the site visitor is receiving is at the expense of the program and is with the understanding that they first perform the duties associated with the visit, free from any distractions. Upon the conclusion of the visit, the volunteer exercises care and discretion in the use of their personal time, ensuring that any personal activities do not incur additional cost or undue burden on the host institution and program (i.e., extending the visit an additional day or night).