Conflict of interest guidelines for board and committee members

The board recognizes the need for transparency in the College’s decisions regarding certifications, particularly in cases where Board or Committee members may be in a position to benefit from offering courses approved to satisfy certification requirements. The following guidelines set out

  1. how a conflicted Board or Committee member must disclose a conflict of interest;
  2. the level of participation in discussion and decision ‐ making permitted to a member who has disclosed a conflict; and
  3. how a Board or Committee member must act upon being given the opportunity to benefit financially from a decision in which s/he previously participated.

Some Board members have special knowledge and expertise that make their contributions to discussions of certifications and certification requirements particularly valuable. Those members may also be some of the best‐qualified in the profession to provide instruction in certain treatment modalities. In developing its conflict of interest guidelines, the Board has endeavored to strike a balance that ensures fairness and transparency in its decision‐making, but stops short of interfering with the operations of the College and the continued cultivation of excellence in the profession.

Guideline 1: Declaring a conflict of interest

A Board or Committee member who stands to benefit financially from the approval of a certification or course approved to satisfy a certification requirement must disclose his or her interest and the nature of that interest in the matter from the outset. The conflict should be disclosed to the Registrar upon or before receiving a copy of the agenda for the meeting at which the matter is to be discussed. It must then be reiterated at the outset of discussion of the matter at the meeting, and recorded in the minutes. This guideline applies whether the Board or Committee member is presenting information regarding a certification or course, or merely participating in the meeting at which the certification or course is to be discussed.

Guideline 2: Participation of members who have declared a conflict

The Board’s decision‐making procedure comprises four distinct stages:

  1. presentation of information;
  2. discussion;
  3. deliberation; and
  4. voting.

Stages 1 and 2 of this process involve “information‐gathering” only, while stages 3 and 4 are deliberative in  nature.

Board or Committee members who have declared a conflict must absent themselves from a meeting after the second stage of the decision‐making process. This option will enable the Board to collect the best information available to it from the member, while precluding the member from exerting additional influence or taking on an “advocacy” role during the Board’s deliberations.

Guideline 3: If an apparent conflict arises after a decision is made

From time to time, a Board or Committee member who has recommended, presented on, participated in the discussion of, or voted to approve a certification or certification requirement may later be offered the opportunity to benefit financially from teaching a course that would satisfy certification requirements. Under such circumstances, the member must refrain from benefiting financially from teaching a course satisfying the certification’s requirements for one year after the certification or course requirement is approved – that is, the member must not teach the course for a period of a year after approval, or must offer the course free or “at cost,” unless there is a reasonable alternative course offered in an accessible location and at the same cost by an individual who is not a board member.

The Board reserves the discretion to approve an exception to Guidelines 2 and 3, to be recorded with reasons in the minutes.