AOTA RESIDENCY PROGRAM MANUAL American Occupational Therapy Association 4720 Montgomery Lane, Suite 200 Bethesda, Maryland 20814-3449 www.aota.org Copyright (c) 2014, by the American Occupational Therapy Association. All rights reserved. AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 POLICY #1: RESIDENCY SITE CATEGORIES APPLICANT RESIDENCY SITE An applicant residency site has filed a statement of intent and accepted as an applicant. An applicant residency site is preparing the full application for review but has not accepted any residents. CANDIDATE RESIDENCY SITE If a site’s application is determined to have met the requirements for candidacy the site will be recognized as a candidate residency site. Upon official notice of candidate residency site status, the site will be eligible to advertise and accept residents in accordance with the standard timeline. An initial on-site review will be conducted before an approval decision is made. APPROVED AOTA RESIDENCY SITE Recognition as an approved AOTA residency site is granted to a site by action of AOTA prior to completion of the first resident. Continued approval is granted upon review every 5 years by AOTA. The review process confirms that the site is in substantial compliance with the AOTA requirements. APPROVAL WITHHELD A site seeking initial approval may have approval withheld if the review process confirms that the site is not in substantial compliance with the established requirements. The site is expected to assist any residents who have not yet completed their program to find reasonable opportunities to complete their residency experience. The site residency coordinator is provided with a clear statement of each area of noncompliance and is informed that a new application for approval may be made whenever the site is believed to be in substantial compliance with the requirements. A new application must be filed and the initial approval process repeated. Initial fees are reassessed. APPROVAL WITHDRAWN APPROVAL WITHDRAWN—VOLUNTARY (At the request of the residency site.) The site residency coordinator or a designated official of the site may at any time inform AOTA in writing that the site is or will be discontinued by a given date or wishes to have approval withdrawn. If there are any remaining residents participating in the site residency program, this notification must include a plan that ensures equitable treatment of the remaining residents. The plan must specify: the number of residents remaining in the site and their status; a provision for notification to the residents of any additional costs; resources, including staff, for ensuring a quality experience for the remaining residents enrolled in the site program; and how the planned closure will be disclosed to residents in the site as well as to prospective applicants. The official of the site will be informed that the sponsoring institution must apply for approval as a new applicant should it wish to resume sponsorship of an approved site. 2. APPROVAL WITHDRAWN—INVOLUNTARY (For failure to be in substantial compliance with the established requirements or lack of communication or payment.) Approval may be involuntarily withdrawn from a site if a review process confirms that the site is in substantial noncompliance with the established requirements. September, 2012; Revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 The appropriate official is provided with a clear statement of each area of noncompliance and is informed that the residency site may apply for approval as a new applicant whenever the site believes it is in compliance with the established requirements. The site is expected to assist any residents who have not yet completed their residency program to find reasonable opportunities to complete their residency. September, 2012; Revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 POLICY # 2: RESIDENCY PROGRAM INITIAL APPROVAL PROCESS STEP 1: WRITTEN APPLICATION AND REVIEW Applicant Residency Site Status 1. A Statement of Intent will be accepted from interested sites between July 15 and August 15 each year. A Statement of Intent Form may be downloaded from http://www.aota.org/en/Education-Careers/Advance-Career/Residency.aspx. 2. Applications will be accepted based on the date submitted, with a second consideration given for program emphasis (e.g., if 3 applications for Low Vision Residencies are received and 3 already exist, deference may be given to different programs). 3. Accepted Applicant Sites will be notified by September 15. 4. Full payment of the $150 non-refundable application processing fee is due by September 30. If full payment is not received by September 30, the Applicant Site forfeits its position. 5. Once payment is received, the Applicant Site may begin developing its application. The site is required to attend the Residency Program Application Workshop scheduled on the Wednesday (noon-6pm) prior to the AOTA Annual Conference. 6. At the time of the workshop, the site will be provided with a customized timeline for submission of the site’s application and full review. Overview of Residency Site Criteria Addressed in the Application The criteria address five major program components: 1. Curriculum of study: The residency site will include didactic education (e.g., formal learning courses, study groups, case presentations, research, and community service) in an identified area. 2. Mentored service delivery with clients: The residency site will ensure that a minimum of 40% of the residents’ time is spent delivering occupational therapy services in the identified practice area. 3. Involvement in scholarly and/or professional activities: The residency site includes activities in scholarship (e.g., evidence-based studies; advocacy initiatives). 4. Program Evaluation: The residency site has a program evaluation plan that includes competency based evaluation of skills and content knowledge of the resident, as well as effectiveness of the site in meeting objectives. 5. Resources: The human, physical, and fiscal resources needed to achieve the program’s goals are available. Each application is assigned a review team consisting of 2 primary reviewers. The review team completes a thorough review of the submitted materials and prepares a report summarizing: September, 2012, revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 1. Strengths of the proposed residency site; 2. Suggestions for improvement; and 3. Areas of concern where the residency site may potentially not be in compliance. Based on the review team findings, one of the following actions is taken: 1. Site is granted “Candidate Status” and allowed to admit the first resident(s) and proceed with scheduling an onsite visit. 2. Site is denied “Candidate Status” and must reapply. Candidate Residency Site Status 1. Once the application is reviewed and accepted, the full application fee (less the $150 processing fee) is due within 2-6 weeks and the site will be granted “Candidate Residency Site” status. 2. Once granted “CandidateResidency Site” status, the site is eligible to advertise and accept residents. 3. The Candidate Residency Site must accept its first resident within 9 months of being approved. 4. Within 2 weeks of accepting its first resident, the Candidate Residency Site must notify AOTA. A Resident Notification form can be downloaded from: http://www.aota.org/en/Education-Careers/Advance-Career/Residency.aspx. 5. An onsite visit and review will be scheduled prior to when the first resident(s) is scheduled to complete the residency. 6. Once the onsite visit is conducted, a final report will be written and recommendations made to the AOTA Residency Program Review Committee. 7. Within 45 days of a completed site visit and an accepted report, the Residency Program Committee may take one of the following actions on the report: (1) grant recognition; (2) deny recognition; (3) request additional information and/or a second site visit. Approved Residency Site 1. Approval will be granted for a period of 10 years. 2. Approved Residency Sites will be required to complete a brief annual update and submit an annual fee. 3. After 5 years, an interim report is required; however, unless requested by the Residency Program Review Committee, a site visit is not required. 4. After 10 years, a complete application is required; however, unless requested by the Residency Program Review Committee, a site visit is not required. September, 2012, revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 STEP 2: SITE VISIT The site visit is an opportunity for the review team and residency site to identify strengths and potential areas of concern, verify information submitted by the site in the application, and establish fulfillment of criteria for AOTA credentialing. A comprehensive assessment of the site is established through interaction with the clinical environment, clinical staff, and administrators. GENERAL GUIDELINES FOR SITE VISIT 1. Once the residency site has been granted Candidate status, AOTA staff will collaborate with the site to schedule the site visit. The site visit must be completed no later than 30 days prior to the first resident’s completion date. 2. A list of potential reviewers will be provided to the site for identification of potential conflict of interest prior to assignment of the application to reviewers. The site will have ten (10) business days to identify any individuals on the list who may be considered to have a conflict of interest with the umbrella organization or site applying for approval. The identified individuals will not be eligible to participate in the review of the written application, site visit, discussion, or decision of approval for that site. 3. The review team will conduct the site visit to collect data and verify information provided in the application. 4. The site visit will take place over a 1.5-day period and will consist of a series of meetings with administrative officials, clinical staff, and residents. Additional meetings may be requested with affiliated umbrella organizations and/or to verify program facilities. 5. The following items/activities may be components of the review process: A. Observation of actual training (classroom/lab or clinical) B. Review of organizational policies C. Review of facility resources D. Review of faculty CVs or resumes E. Review of curriculum F. Review of performance of residents G. Interviews with clinical faculty H. Interviews with current residents I. Interviews with director/coordinator J. Interviews with administrative officials K. Overview of site visit findings with program administrator(s) 6. The review team will provide a preliminary draft report of findings to the site and AOTA staff at the completion of the site visit. The site will have 14 days to respond to the findings of the review team and provide factual corrections to AOTA staff. However, the site is not able to provide new information that was not available during the time of the site visit. 7. After 14 days the report and comments from the site will be forwarded by AOTA staff to the AOTA Residency Program Review Committee. STEP 3: REVIEW BY AOTA RESIDENCY PROGRAM REVIEW COMMITTEE September, 2012, revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 Within 12 weeks of the review team report and comments being submitted they will be reviewed by the AOTA Residency Program Review Committee for final action on the site application. The AOTA Residency Program Review Committee may take one of the following actions on the report: 1. Accept the report of the review team as written and grant approval for 5 years. 2. Accept the report of the review team as amended and grant approval for 5 years. 3. Accept the report of the review team and deny approval. 4. Not accept the report and request additional information and/or a second site visit. The site is notified of the final decision within 45 days of the second on-site visit. The AOTA Residency Program Review Committee may require a second site visit if the first site visit fails to confirm that the site meets the minimum requirements for credentialing. For example, if the site visit team observes a mentoring session where the resident is not being mentored at a residency level, a second site visit may be required. The residency site will have the opportunity to provide written comments as an attachment to the report. In addition, the site will be provided the opportunity to evaluate the site visit team. All documents must be submitted to AOTA within thirty (30) days upon receipt of the report. September, 2012, revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 POLICY # 3: RESIDENCY PROGRAM RE-APPROVAL PROCESS STEP 1: WRITTEN APPLICATION AND REVIEW Approval will be granted for a period of 10 years. 1. Approved Residency Sites will be required to complete a brief annual update and submit an annual fee. 2. After 5 years, an interim report is required; however, unless requested by the Residency Program Review Committee, a site visit is not required. 3. After 10 years, a complete application is required; however, unless requested by the Residency Program Review Committee, a site visit is not required. The written application for re-approval provides documented evidence of the Approved Residency Site’s ongoing ability to meet the established criteria for an approved residency site. OVERVIEW OF RESIDENCY PROGRAM CRITERIA ADDRESSED IN THE APPLICATION The criteria address five major program components: 1. Curriculum of study: The residency site will include didactic education (e.g., formal learning courses, study groups, case presentations, research, and community service) in an identified area. 2. Mentored service delivery with clients: The residency site will ensure that a minimum of 40% of the resident’s time (minimum 560 hours) is spent delivering occupational therapy services in the identified practice area. 3. Involvement in scholarly and/or professional activities: The residency site includes activities in scholarship (e.g., evidence-based studies; advocacy initiatives). 4. Program evaluation: The residency site has a program evaluation plan that includes competency based evaluation of skills and content knowledge of the resident, as well as effectiveness of the site in meeting objectives. 5. Resources: The human, physical, and fiscal resources needed to achieve the program’s goals are available. Each application is assigned a review team consisting of 2 primary reviewers. The review team completes a thorough review of the submitted materials and prepares a report summarizing: 1. Strengths of the proposed residency site; 2. Suggestions for improvement; and 3. Areas of concern where the residency site is potentially not in compliance. September, 2012; Revised April, 2014. AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 STEP 2: SITE VISIT A site visit is only required if the document review identified major areas of concern. The decision for an onsite visit is determined by the AOTA Residency Program Review Committee on review of the report. The procedures for the onsite visit follow the procedures delineated in Policy #2. STEP 3: REVIEW BY RESIDENCY PROGRAM REVIEW COMMITTEE Within 12 weeks of the review team report being submitted, it will be reviewed by the AOTA Residency Program Review Committee for final action on the site application. The AOTA Residency Program Review Committee may take one of the following actions on the report: 1. Accept the report of the review team as written and grant re-approval for 5 years. 2. Accept the report of the review team as amended and grant re-approval for 5 years. 3. Accept the report of the review team and deny or withdraw approval. 4. Not accept the report and request additional information and/or a second site visit. The site is notified of the final decision within 45 days of the onsite visit . Note: Withdrawal of approval is an adverse action and subject to appeal. September, 2012; Revised April, 2014. AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 POLICY #4: APPEALS PROCEDURES This policy delineates the procedures for Request of Further Consideration and Appeal of Decisions by the Residency Program Review Committee of the American Occupational Therapy Association. GENERAL PRINCIPLES FOR DENIAL OR WITHDRAWAL OF CREDENTIALED RESIDENCY PROGRAM 1. Sponsoring institutions whose residency site has been denied approval or had approval withdrawn by the Residency Program Review Committee may request further consideration of and/or appeal that decision. The first level of appeal is a Request for Further Consideration by the Residency Program Review Committee. If the Residency Program Review Committee sustains its decision, the individual may pursue a second and final level of appeal to the Appeal Panel (see Appeal Panel section) appointed by the American Occupational Therapy Association [AOTA]). 2. Denial or withdrawal of an approved residency site shall not become effective until the decision has become final (i.e., at the conclusion of further consideration and appeal). 3. The decision of the Appeal Panel shall be final. 4. An initial denial of an approved residency site shall not preclude an institution from pursuing a subsequent application for approval. 5. Withdrawal of an approved residency site requires that the formerly approved residency site who desires to obtain re-approval pay a new application fee and present a new application. RULES OF PROCEDURE FOR FURTHER CONSIDERATION 1. Initial Decision of Denial or Withdrawal 1) Notice of denial or withdrawal shall be sent by certified mail, return-receiptrequested, and describe the basis for the denial or withdrawal, specifically addressing the requirements that were not met. 2) If the Residency Program Review Committee does not receive a request for a Further Consideration Review within 30 calendar days of the date the Initial Decision was received (as indicated by the return receipt), the initial decision shall become final and there shall be no further right of further consideration or appeal. 2. Procedures for Further Consideration Review 1) The Further Consideration Review is an opportunity for the site to present written information, documentation, and/or correspondence to demonstrate compliance with those requirements cited as deficient in the Initial Decision. 2) A request for a Further Consideration Review shall be in writing, addressed to the AOTA Residency Program Review Committee, and must be received within 30 calendar days of the date the Initial Decision was received. 3. Notice of Decision After Further Consideration Review April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 1) 2) 3) 4) Sites shall receive written notice of the decision following further review by the Residency Program Review Committee. This notice shall be sent by certified mail, return-receipt-requested, within 30 calendar days of the Committee’s decision. In the event that the Decision Following Further Review is not in the applicant’s favor, the notice shall reference and append this document in order to emphasize the procedure for final appeal. The Decision Following Further Review shall describe the basis for the Residency Program Review Committee’s decision. The site may choose to formally appeal the decision at this point, at which time a request for appeal is filed with AOTA and a copy sent to the Residency Program Review Committee. At this time the petitioning site becomes the Appellant. If AOTA does not receive a request for appeal of an adverse Decision Following Further Review within 15 calendar days after the date that Decision was received, the Decision Following Further Review shall become final and there shall be no further right of appeal. RULES OF PROCEDURE FOR APPEALS 1. General Principles 1) A site subject to an adverse decision taken by the Residency Program Review Committee may appeal that decision if it has reason to believe that the decision was arbitrary, capricious, in substantial disregard of the criteria or procedures of the AOTA Residency Program, or was not supported by substantial evidence in the record upon which the Residency Program Review Committee relied in making the decision. 2) The program has the burden of proof on appeal. 3) The record on appeal shall include, as applicable, the program’s appeal document and supporting materials, reports of on-site evaluation teams, decision letters and other correspondence between the Residency Program Review Committee and the site, and the program’s responses to the Residency Program Review Committee inquiries and actions. Accordingly, the appealing program may not present to the Appeal Panel any data, information, documents, or other evidence that was not part of the record when the Residency Program Review Committee made the decision from which an appeal was taken. The Appeal Panel shall disregard any such material and not utilize it in deciding the appeal. APPEAL PANEL 1. Appeal Panel 1) In the event of a timely and duly filed appeal from a program, AOTA shall select three individuals to serve on an Appeal Panel to consider the appeal. The Appeal Panel will consist of members of the Association in good standing with expertise in the education and/or the practice area identified in the site application. 2) No individual may be selected to serve on an Appeal Panel if he or she has had any prior involvement with the appealing program/institution or had any involvement with the AOTA Residency Program Review that gave rise to the decision that the institution is appealing. April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 3) 4) No later than 15 days prior to the scheduled appeal hearing date, AOTA shall advise the appealing institution of the names and affiliations of the three individuals selected to serve on the Appeal Panel. If the program has good cause to believe that any member(s) of the Appeal Panel should not hear the institution’s appeal, it must promptly notify AOTA in writing that it objects to the panelist(s) and state with specificity the grounds for the objection. AOTA will consider the objections and decide whether to replace the member(s) of the Appeal Panel with another individual(s). The decision of AOTA with respect to the members of the Appeal Panel is final and may not be appealed. 2. Appeal Procedures 1) Notice of Intent to Appeal. An institution shall commence an appeal by submitting to AOTA a request for appeal of an adverse Decision After Further Review within 15 calendar days after the date that the Decision was received. 2) Grounds for Appeal. Within 30 days after receipt of notice of AOTA’s adverse decision, the institution must submit to AOTA five copies of a written statement of the Grounds for Appeal which specifies the institution’s arguments in support of its contention that the decision was arbitrary, capricious, in disregard of AOTA’s Residency requirements or procedures, or not supported by substantial evidence in the record on which the Residency Program Review Committee predicated its decision. 3) Materials Submitted With Grounds for Appeal. An institution may not submit any documents, data, evidence, or other materials with its Grounds for Appeal unless such materials were in the record at the time the Residency Program Review Committee rendered its adverse decision. 4) Personal Appearance and Representation by Legal Counsel. The program has the right to a hearing before the Appeal Panel and may select a qualified individual(s) to represent the institution at the hearing. The institution also has the right to be represented by legal counsel at the hearing if it so chooses. Within 10 days of the scheduled hearing date, the program shall provide AOTA with the names, titles, and contact information for all representatives who will be participating in the appeal hearing on the institution’s behalf. The program shall also furnish the names and contact information of any legal counsel who will be representing the institution during the appeal proceedings and hearing. 5) Transcript of Hearing. The institution has the right to a written transcript of the appeal hearing and may exercise this right by notice to AOTA at the time of filing the Grounds for Appeal. AOTA will provide the transcription services, but the institution will be responsible for the cost services. An institution may not videotape the appeal hearing. 6) Timing of Appeal Hearing. The appeal hearing will be conducted within 60 days of receipt of the institution’s Notice of Intent to Appeal. AOTA may extend this time for good cause. After consultation with the chief executive officer of the appealing institution, the date, time, and place of the appeal hearing shall be set by AOTA. AOTA shall give written notification to the institution of the date, time, and location of the appeal hearing no later than 10 business days prior to the hearing date. 7) Hearing Format. The following process shall be observed during the appeal hearing: i. The Chairperson of the Appeal Panel shall make an opening statement identifying the participants in the hearing, briefly describing the issues April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 ii. iii. iv. v. vi. on appeal and the standard of review to be used by the Appeal Panel in deciding the appeal, and summarizing the procedures to be followed during the hearing. Following the Chairperson’s opening statement, a representative of AOTA will make a brief statement describing AOTA’s decision and the grounds for that decision. The appealing site will be afforded 30-40 minutes to present arguments as to why its appeal of AOTA’s adverse decision should be granted. The presentation may be made by one or more representatives of the program and/or by the program’s legal counsel. The institution’s presentation shall be limited to issues relevant to the adverse decision of AOTA. After the program has concluded its presentation, members of the Appeal Panel may question the representatives of the institution about its appeal or any of the issues raised by the program during the hearing. Following the question and answer period, the Chairperson of the Appeal Panel shall permit the program to make a brief concluding statement. The appeal hearing shall be concluded and the record closed after the program makes its concluding statement. 3. APPEAL PANEL DECISION 1) 2) 3) 4) Written Decision. After the hearing, the Appeal Panel shall prepare a written decision that details its decision in detail, specifies the reasons for its decision, and describes with particularity the action it is taking—viz. to affirm, remand, or reverse the decision. Transmittal of Decision. Within 30 days of the conclusion of the appeal hearing, the Chairperson of the Appeal Panel shall transmit the written decision of the panel to AOTA. AOTA Action. As promptly as possible after receipt of the Appeal Panel’s written decision, the Residency Program Review Committee shall take action consistent with the appeal decision. Pursuant to these rules, if the decision is to affirm the decision, no further action is required to make the decision effective. Notice of Decision. Upon the decision of the Appeal Panel to affirm the Residency Program Review Committee decision, or upon further action by the Residency Program Review Committee to carry out the Appeal Panel’s decision to remand or reverse the accreditation decision, AOTA shall notify the appealing institution in writing of the final Residency Program Review Committee decision. 4. Appeal Expenses 1) 2) April, 2014 Expenses of Appealing Institution. An appealing institution is fully responsible for all of its expenses in prosecuting its appeal. Expenses of the Appeal Panel. The appealing institution shall also be exclusively responsible for all of the reasonable costs associated with the appeal hearing including the hearing room, transcription services, travel, meals, and lodging for members of the panel. AOTA RESIDENCY PROGRAM POLICIES MANUAL 2014 POLICY #5: FEE PAYMENTS Programs will be invoiced by AOTA as per the following schedule: 2015 2016 2017 2018 2019 Application Fee $1,800 $1,850 $1,900 $1,960 $2,020 On-site Visit Costs $2,600 $2,680 $2,760 $2,840 $2,920 $900 $930 $960 $980 $1,010 $1,800 $1,850 $1,900 $1,960 $2,020 Annual Fee: Re-Approval Fee *Annual fees begin the year after approval is granted. *No Annual Fee in Re-Approval Year. Re-Approval fee does not include the cost of the onsite visit. September, 2012, Revised April 2014 AOTA RESIDENCY PROGRAM POLICIES MANUAL 2014 POLICY #6: AOTA RESIDENCY PROGRAM REVIEW COMMITTEE Committee Purpose: The Residency Program Review Committee will: 1. Review all applications for initial AOTA Residency Program approval and re-approval; 2. Assure the educational community, the general public, and other agencies or organizations that the site has both clearly defined and appropriate objectives, maintains conditions under which these objectives can reasonably be expected to be achieved, appears to be accomplishing them substantially and can be expected to continue to do so; 3. Grant AOTA approval status to residency sites when the site has demonstrated substantial compliance with the requirements or deny/withdraw credentialing status should the program fail to demonstrate substantial compliance with the requirements. Membership: Residency Program Review Committee will comprise of: 1. Five members representing diverse practice areas; 2. Non-voting members. Designated AOTA staff liaison(s), who shall serve as member (s) without voting privileges. Appointment: 1. Members: The Voluntary Leadership Development Committee (VLDC), in consultation with the staff liaison, and appropriate others, shall recruit and identify qualified persons from the COOL database in accordance with the requirements for balanced composition. To provide for continuity, no more than one-third of the membership may rotate off in a single year. If three or more members are scheduled to rotate off in a given year, the chairperson shall select one (or more if necessary) member(s) to stay for an additional year to preserve the balanced composition. Terms: 1. Serve a maximum of two consecutive full 3-year terms unless the second term is extended by the chairperson. Qualifications: 1. Members who are occupational therapists shall maintain any regulatory requirements necessary to identify themselves as an occupational therapy practitioner throughout their term of office. 2. Association member in good standing. September, 2012; April 2014 AOTA RESIDENCY PROGRAM POLICIES MANUAL 2014 3. Computer access via high-speed Internet connection is recommended for communication and conduct of business throughout the Association. Council members must be comfortable working in an email environment including opening, saving, editing, and sending attachments as needed. September, 2012; April 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 POLICY #7: CONFLICT OF INTEREST & CONFIDENTIALITY AOTA STAFF, REVIEW TEAM MEMBERS, AND RESIDENCY PROGRAM REVIEW COMMITTEE MEMBERS 1. Shall abide by AOTA’s Code of Ethics. 2. Shall act in ways to preserve the confidentiality of the personnel, residents, programs, and residency sites that are evaluated. 3. Shall expeditiously handle all matters pertaining to the residency approval. 4. Shall not provide any service, whether paid or unpaid, to any institution or residency sites in litigation with or having an appeal of any Residency Program Review Committee action under active consideration. 5. Shall not disclose to any person, institution, or program any information related to the Residency Program Review Committee actions that are not publicly available. CONFLICT OF INTEREST WITH INDIVIDUAL RESIDENCY PROGRAMS Responsibility for identifying a conflict of interest with any given residency site lies with the individual staff and volunteer member. AOTA has the final authority to determine when a conflict of interest exists. In making a decision regarding conflict of interest, a staff member or volunteer must consider the possibility of perceived conflict of interest as well as actual conflicts of interest as defined as follows: 1. A close personal, professional, educational, or financial interest, or other special relationship (including those of a negative nature), in any institution in question within the past 5 years. 2. An employee or consultant to an entity, other than the institution under review or other consideration, that provides all or a significant portion of the institution’s funding (e.g., a state department of education or a federal or private agency providing significant grants or research funding) within the past 5 years. 3. A current or former student or graduate, or parent of a current or former student or graduate of the institution in question within the past 5 years. 4. A current or former candidate for a paid position within the past 5 years with the entity in question. 5. A position, whether paid or voluntary, current or within the past 5 years, to or for the institution in question. This includes positions as a consultant, advisor, or faculty member (including clinical or adjunct). 6. A residence and/or place of employment in close proximity to the institution in question within the past 5 years. Close proximity is determined by geographic, educational, and economic spheres (communities of interest) of influence rather than strict political boundaries. September 2012; Revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 7. A position, whether paid or voluntary, current or within the past 5 years, in an institution that is generally viewed by peers and occupational therapy students as a major competitor to the institution in question. This includes positions as a consultant, advisor, or faculty member (including clinical or adjunct). ABSENTING ONESELF FROM DELIBERATIONS Members of the Residency Program Review Committee, with the exception of paid staff, shall absent themselves from deliberation on the institution in question if a conflict exists. The individual should declare the conflict, receive acknowledgment from the Chairperson, and remove him or herself from the meeting. When discussion of the program in question is completed, a staff member will call that individual and instruct him or her to rejoin the meeting. WITHDRAWING ONESELF FROM PARTICIPATION IN DISCUSSION Members of the Residency Program Review Committee and paid staff must withdraw from any formal or informal discussion of any institution when the potential exists for another party to reasonably perceive that they have a conflict of interest. Withdrawal means that the individual conveys no information, either verbal or nonverbal, that could be construed as influencing the course of the discussion or action. DISCLOSURE Members of the Residency Program Review Committee must complete a Disclosure Statement upon joining the Committee and on an annual basis while serving on the Committee (see Addendum). September 2012; Revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 Addendum: Disclosure Statement CONFLICT OF INTEREST LIST NAME: Please indicate all programs with which you have a conflict of interest by entering the applicable conflict code(s), and return this completed form to AOTA. Conflict Reason Codes: 1 Special Relationship with Institution 2 Consultant/Funding Source 3 Former/Current Student of Institution 4 Candidate for Paid Position Within Past 5 Years State 5 6 7 Paid or Voluntary Position Within Past 5 Years Close Proximity/Communities of Interest Work or Provide Service to Competitor Institution RESIDENCY SITE CODE Signed: Date: CONFLICT OF INTEREST WITH RESIDENCY PROGRAMS Responsibility for identifying a conflict of interest with any given RESIDENCY PROGRAM lies with the individual staff member, Appeal Panel member, or Review Committee member. AOTA has the final authority to determine when a conflict of interest exists. In making a decision regarding conflict of interest, a staff member or evaluator must consider the possibility of perceived conflict of interest as well as actual conflicts of interest as defined as follows: 1. A close personal, professional, educational, or financial interest, or other special relationship (including those of a negative nature), in any institution in question. September 2012; Revised April, 2014 AOTA RESIDENCY PROGRAM POLICY MANUAL 2014 2. An employee or consultant to an entity, other than the institution under review or other consideration, that provides all or a significant portion of the institution's funding (e.g., a state department of education or a federal or private agency providing significant grants or research funding) within the past 5 years. 3. A current or former student or graduate, or parent of a current or former student or graduate of the institution in question within the past 5 years. 4. A current or former candidate for a paid position within the past 5 years with the entity in question. 5. A position, whether paid or voluntary, current or within the past 5 years, to or for the institution in question. This includes positions as a consultant, advisor, or faculty member (including clinical or adjunct). 6. A residence and/or place of employment in close proximity to the institution in question within the past 5 years. Close proximity is determined by geographic, educational, and economic spheres (communities of interest) of influence rather than strict political boundaries. 7. A position, whether paid or voluntary, current or within the past 5 years, in an institution that is generally viewed by peers and occupational therapy students as a major competitor to the institution in question. This includes positions as a consultant, advisor, or faculty member (including clinical or adjunct). September 2012; Revised April, 2014
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