June 2018—Violations of a certification body’s policies, including its code of ethics and substance abuse policy, can threaten the trustworthiness of a certification program and erode its integrity. NCCCO has always taken such matters very seriously and, in line with its policy of continuing improvement, has announced two major enhancements to its program integrity tools.
New Program Integrity Hotline
The first is the establishment of a Program Integrity Hotline. The Hotline, which can be reached via a toll-free phone number (1-833-30-NCCCO) or a dedicated email address (email@example.com), has been designed to facilitate the receipt of reports of unethical behavior and potential misconduct so that they may be fairly and reasonably investigated. NCCCO receives reports of inappropriate conduct from a wide range of sources, including employers, examiners, state agencies, co-workers, and even certificants themselves. The new Hotline is expected to be as successful in capturing information about potential misbehavior of certificants as the VCO system has been in identifying cases of fraud and misrepresentation of credentials.
New Online Verification to Include Practical Examiners
The second enhancement to NCCCO’s program integrity tools is an expansion of NCCCO’s highly popular Verify CCO Online candidate verification system to include practical examiners. By using the expanded verification system, program participants will be able to verify practical examiner credentials online, just as they have been able to verify certification credentials for certificants.
New Program Integrity Team
In addition to adding these new tools, NCCCO continues to enhance the process by which program integrity matters are handled. All program integrity matters are now directed to the recently formed Program Integrity Team (PIT) for consideration and investigation. The PIT is a five-person team authorized to act on certain matters directly, in which case any decisions are made by a consensus of the entire team. Other matters are referred by the PIT to the appropriate committee (such as the Ethics & Discipline Committee), together with an investigation report prepared by the team.
The PIT ensures that matters involving program integrity, ethics, and discipline are addressed and managed in a timely, efficient, and systematic fashion, that all parties are treated fairly and equitably, and that the appropriate checks and balances are provided to underpin a strong certification program.
Communication with Complainants
Under NCCCO’s new PIT procedures, if a matter involving program integrity or ethics and discipline is brought to the attention of NCCCO by someone other than NCCCO staff, whenever possible, NCCCO will promptly acknowledge receipt of the complaint.
NCCCO will also aim to provide the complainant with progress reports and notice of the conclusion and outcome of the process by which the complaint was handled. As reasonably necessary or appropriate, NCCCO may also provide such progress reports or notices to other interested parties, such as employers.
Intake of New Matters
New incidents are reviewed by the PIT within 30 days; sooner if possible. After preliminary review and discussion are completed by the PIT, initial recommendations are made regarding how to proceed with each case. In appropriate situations a matter may be closed upon initial review without further action. If a matter is determined by the PIT to require further action, then a new case is formally opened for further investigation and action. If a program participant is recommended for suspension while an investigation is ongoing, the PIT may send a suspension letter to that person.
Investigation of Program Integrity Matters
The PIT subsequently investigates each case, as appropriate, gathering and verifying any and all necessary information to validate each complaint. In each case, the PIT will determine whether or not a program participant’s actions were “willful.” In the event of a willful violation, in addition to any other sanctions, an individual suspended or sanctioned in any one capacity will be automatically suspended or sanctioned in every other capacity in the program.
Disposition of Program Integrity Matters
Upon the conclusion of an investigation by the PIT, if a program participant or other person is recommended for revocation or other disciplinary action, the PIT then sends an appropriate letter reflecting the action taken and advising the participant or person of the action taken, in addition to the applicable rights of appeal.
Except in certain extenuating circumstances, where additional time is necessary, investigations will be completed, decisions will be reached by the PIT, and the participant or person will be advised of the action taken and applicable rights of appeal within a 90-day time period.