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Conflict of Interest Policy
Effective Date: May 2, 2020
Policy ID: CPS-COI-2020-05
1.0 Purpose and Philosophy
1.1 Purpose
The purpose of this Conflict of Interest Policy is to protect the integrity, impartiality, and credibility of the Council on Pharmacy Standards (CPS) and its certification programs. This policy establishes clear standards and procedures to ensure that all decisions made on behalf of CPS are based solely on the best interests of the organization, its mission, and the public it serves. It is designed to identify, disclose, manage, and mitigate any potential, actual, or perceived conflicts of interest that may arise.
1.2 Philosophy
The value of a CPS credential is built upon a foundation of public trust. It is imperative that all activities related to our certification programs—from exam development and standard setting to governance and disciplinary actions—are, and are perceived to be, completely objective and free from any improper influence or bias. CPS is committed to a culture of transparency and accountability. We recognize that conflicts of interest are common in a specialized profession where experts are interconnected. This policy is not intended to eliminate all relationships but to ensure that such relationships do not compromise the integrity of our processes. The core principle is that the duty of loyalty to the CPS mission must supersede any personal, professional, or financial interests.
2.0 Scope and Applicability
This policy applies to all individuals who have a substantial relationship with CPS and who are in a position to influence its decisions or access confidential information. These individuals, collectively referred to as “Covered Individuals,” include, but are not limited to:
CPS Staff: All full-time, part-time, temporary, and contract employees of CPS.
Volunteers: All non-compensated individuals serving CPS in any capacity, including:
Members of the Certification Commission (CC-CPS).
Members of any committee, subcommittee, or task force (e.g., Appeals Committee, Disciplinary Committee, Standard Setting Panel).
Subject Matter Experts (SMEs) involved in any aspect of the exam lifecycle, such as practice analysis, item writing, item review, and form assembly.
Independent Contractors and Consultants: Any individual or firm contracted to provide key professional services, such as psychometricians, legal counsel, and financial auditors.
Every Covered Individual is required to read, understand, and comply with this policy as a condition of their employment, service, or engagement with CPS.
3.0 Definition of a Conflict of Interest
3.1 General Definition
A Conflict of Interest exists when a Covered Individual has a competing interest or loyalty—whether personal, professional, or financial—that could potentially interfere with their ability to exercise objective and impartial judgment in performing their duties for CPS. A conflict of interest may be actual, potential, or perceived:
Actual Conflict of Interest: A direct conflict exists between a Covered Individual’s personal interests and their duties to CPS, which has already influenced or is actively influencing their actions.
Potential Conflict of Interest: A situation exists that could develop into an actual conflict of interest. The circumstances are such that an individual’s judgment could be swayed in the future.
Perceived Conflict of Interest (or Appearance of Conflict): A situation exists where a reasonable, uninvolved third party could conclude that a conflict exists, even if no actual conflict is present. The appearance of a conflict can be as damaging as an actual one and must be managed with equal seriousness.
3.2 Categories of Conflicts of Interest
Conflicts of interest can arise from various sources. The following is a non-exhaustive list of common categories:
Financial Conflicts: These arise when a Covered Individual, or a close family member, has a direct or indirect financial interest that could be affected by their decisions at CPS. Examples include:
Ownership interest in, or significant compensation from, a company that provides test preparation materials or courses for any CPS certification.
Receiving royalties, honoraria, or consulting fees from the sale of educational materials or services related to CPS certification content.
Holding a significant investment in a company that is a vendor or competitor of CPS.
Accepting gifts, entertainment, or favors of more than a nominal value from any individual or entity that has business before CPS.
Professional Conflicts: These arise from competing professional roles or affiliations that could compromise a Covered Individual’s loyalty to CPS. Examples include:
Serving in a leadership or governance role (e.g., board member, officer) for an organization that offers competing certifications or that develops and endorses specific educational curricula intended to prepare candidates for CPS exams.
Personal involvement in authoring, editing, or instructing for any commercial test preparation program aimed at a CPS credential.
Serving as a faculty member at an institution where curriculum decisions could be influenced by knowledge of confidential CPS exam content.
Personal and Familial Conflicts: These arise from close personal relationships that could impair objective judgment. Examples include:
Participating in any certification-related decision (e.g., eligibility review, exam scoring, disciplinary action) that involves a family member, a close personal friend, or a direct professional associate (e.g., supervisor, subordinate).
Having a direct financial or business relationship with a candidate or certificant.
Confidential Information Conflicts: These arise when a Covered Individual’s access to confidential CPS information presents an opportunity for personal gain or for the benefit of another person or organization. This includes using knowledge of specific exam questions, passing score studies, or strategic plans for any purpose outside of official CPS duties.
4.0 Disclosure Obligations
Transparency through disclosure is the primary mechanism for managing conflicts of interest.
4.1 Affirmative Duty to Disclose
All Covered Individuals have an affirmative and ongoing duty to promptly and fully disclose any and all interests, relationships, or activities that could constitute a potential, actual, or perceived conflict of interest. The responsibility for disclosure rests with the individual; if there is any doubt as to whether a conflict exists, the individual must err on the side of disclosure.
4.2 Timing and Frequency of Disclosure
Disclosure is required at multiple points:
Initial Disclosure: Prior to accepting any staff position, volunteer appointment, or contract with CPS.
Annual Disclosure: All Covered Individuals must complete and sign a formal Conflict of Interest Disclosure Statement on an annual basis.
Continuous Disclosure: As new situations or relationships arise that could present a conflict, a Covered Individual must submit an updated written disclosure to the Compliance Officer immediately, and in any case before participating in any related CPS activity.
4.3 Disclosure Procedure
All disclosures must be made in writing to the designated CPS Compliance Officer at ethics@pharmacystandards.org. The disclosure must provide a detailed description of the nature of the interest, relationship, or activity, including any relevant parties, dates, and financial considerations.
5.0 Review and Management of Disclosures
5.1 Review and Determination
All submitted disclosure statements will be reviewed by the CPS Compliance Officer. The Officer will determine whether the disclosed matter constitutes a conflict of interest that requires management. This determination will be based on the specific facts of the situation and the principles outlined in this policy.
5.2 Management and Mitigation Strategies
If a potential, actual, or perceived conflict of interest is determined to exist, the Compliance Officer, in consultation with relevant leadership, will determine an appropriate management plan. The goal of the plan is to eliminate or mitigate the conflict to protect the integrity of the certification process. Strategies include, but are not limited to:
Recusal: The most common strategy, requiring the Covered Individual to abstain from participating in any discussion, deliberation, or voting on any matter where the conflict exists. The recusal must be formally documented in meeting minutes or other official records.
Information Firewall: Restricting the Covered Individual’s access to specific categories of confidential information related to the conflict.
Assignment to Non-Conflicting Duties: Modifying the individual’s duties or assignments to remove them from any area where their conflict could influence outcomes.
Divestiture: Requiring the Covered Individual to sell or otherwise dispose of a conflicting financial interest as a condition of their continued service.
Resignation or Termination: In cases where a conflict is so significant that it cannot be effectively managed through other means, the Covered Individual may be asked to resign from their position or have their relationship with CPS terminated.
All management plans will be documented in writing and acknowledged by the Covered Individual.
6.0 Specific Prohibitions for High-Risk Roles
Due to their access to highly sensitive and confidential examination information, individuals serving in exam development roles are subject to additional, specific prohibitions.
6.1 Prohibitions for Exam Development SMEs and Commission Members
Individuals actively involved in any aspect of exam content creation, review, or standard setting are strictly prohibited from:
Participating in any capacity (e.g., author, instructor, editor, consultant) in the development, marketing, or delivery of any commercial or non-commercial test preparation program, course, or publication that is designed to prepare individuals for any CPS certification examination.
Providing private tutoring, coaching, or any form of instruction that is advertised or known to be for the purpose of preparing individuals for a CPS exam.
Sharing, disclosing, or using any confidential examination information for any purpose other than their official duties for CPS.
6.2 Post-Service “Cooling-Off” Period
Upon completion of their service in an exam development or governance capacity, individuals are bound by a three (3) year “cooling-off” period. During this period, they remain prohibited from engaging in any of the test preparation activities described in Section 6.1. This restriction is necessary to protect the security and integrity of the examination content to which they had access.
7.0 Enforcement and Violations
Failure to comply with this policy will be taken seriously and may result in disciplinary action.
Failure to Disclose: An unexcused failure to disclose a conflict of interest is itself a serious violation of this policy.
Investigation: Allegations of a violation will be investigated promptly and confidentially by the Compliance Officer or a designated committee. The subject of the allegation will be given notice and an opportunity to respond.
Sanctions: If a violation is confirmed, sanctions will be imposed based on the severity of the offense. Sanctions may include, but are not limited to, a formal reprimand, removal from a committee or project, termination of the individual’s relationship with CPS, and, where applicable, revocation of any CPS certifications held by the individual.
