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 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
- 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
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.