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Confidentiality and Conflict of Interest

The entire accreditation process is based upon integrity. This includes fair and impartial judgments, protection of confidentiality and the avoidance of any real or perceived conflict of interest. Confidentiality does not end with the site visit.

As a program reviewer, you have had access to a great deal of confidential material. You must not divulge that information to anyone at any time. This discretion is critical to maintaining the integrity of the Commission and its activities as perceived by the programs it accredits. If programs believe they cannot reveal confidential information to the Commission without having it made public, the entire voluntary accreditation process will fail. Only free and open sharing of information allows the process to succeed.

To remind you of the seriousness of the accreditation process and of its commitment to protect confidentiality, the Commission requires all Site Visitors and other external participants to sign an "Agreement of Confidentiality" (Appendix 3.1). By signing the agreement annually, you indicate that you understand the Commissionís policy on confidentiality and agree to abide by it.

Unless otherwise indicated, all meetings and site visit materials, all information obtained on-site, all protected patient health information, and all discussions related to program or institution accreditation are confidential. And, please remember that confidentiality has no expiration date - - it lasts forever!

Perception is also important when considering conflict of interest. Conflict of interest can be real or perceived, and both should be avoided. The institution has the opportunity prior to the site visit to request different Site Visitors if there is some question regarding conflict of interest. They receive a list of the Site Visitors prior to the visit and may request to remove one or more people from the list if they perceive or anticipate a conflict of interest. As a Site Visitor, you also have an obligation to consider whether you have connections with a particular program or institution that make it inappropriate to serve on the evaluation team.

Examples of conflict of interest include:

  • Completing all or a portion of your training at the sponsoring institution or its affiliates;
  • Serving as a program faculty member for the program or institution;
  • Having served as a Site Visitor to the program or institution in the past;
  • Having a personal friend or relative involved with the program or institution;
  • Having been a candidate for a position at the sponsoring institution or its affiliates.

Other conflicts may be less obvious. If youíre not sure whether a conflict exists, call and discuss your concerns with Commission staff. If a conflict of interest is not reported by the site visitor, the Commission might have to discard the results of a site visit and conduct another one, a situation that would be damaging to the integrity of the accreditation process and expensive. The Commission requires that all Site Visitors agree to and sign a Conflict of Interest Statement (Appendix 3.2) to ensure compliance.

Additional information regarding confidentiality and conflict of interest can be found in the Commissionís Evaluation Policies and Procedures (EPP) Manual (Appendix 3.3).

Review and Practice 3.1: Would any of the following conditions be perceived as a conflict of interest? Explain your answer. If you are unsure, what would you do to clarify?

  • You and the program director used to work in the same institution 10 years ago.
  • Your child plans to go to the dental school that you will be visiting next year.
  • You worked closely with several of the institution's faculty on an external committee three years ago.
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