Managing and mitigating conflicts of interest is a critical part of the delivery of EPA. It must be covered in applications to the Register of End-point Assessment Organisations (RoEpAO), and forms a central part of the conditions of acceptance for EpAOs. It will also be checked during external quality assurance visits.
End-point Assessment must be independent, and that independence must be at an organisation and assessor level from design through to delivery. Conflict of interest policies should therefore cover, as a minimum:
- experts who are involved in the design of end-point assessment tools
- employees of the EpAO
- end-point assessors (and invigilators, where applicable)
- those involved in panels associated with policies such as, appeals, malpractice, complaints, and sanctions.
Conflicts of interest can be potential, actual or perceived and can be wide ranging but here are a few examples:
- organisational – where an organisation is on the RoATP and on the RoEpAO
- Financial – where an individual organisation may gain financially from their involvement, for example though shareholdings in competitor companies
- Intellectual property – where an individual or organisation may gain an advantage from their involvement, for example, a self-employed sector expert being involved in the design of end-point assessment materials when they also work with training providers delivering the apprenticeship they are involved in designing the EPA tools for
- Personal – where an assessor may be related to, be close friends with an apprentice, or where an assessor may be working for multiple EpAOs, or where an assessor has managed the apprentice, or has been involved in an element of their training.
- Viewpoints - EPA must be objective as well as independent. If a person involved in EPA expresses view that may be prejudicial this may be considered to be a conflict of interest
If an organisation is on the RoATP and the RoEpAO they must have clear and total separation, including financial separation, between training delivery and assessment. Those on the RoATP and RoEpAO are not permitted to train and assess the same apprentices (register pre-application guidance page 15 and Conditions page 11).
As an EpAO you will therefore need to be able to demonstrate though your conflict of interest policy how you will:
- raise awareness and understanding of conflicts of interest
- identify and record conflicts of interest
- mitigate conflicts of interest
- manage conflicts of interest
- review conflicts of interest
From experience of delivery end-point assessment, our end-point assessment expert Jacqui Molkenthin, would recommend the following:
- codes of practice for all those involved, this may mean one for assessors, one for experts involved in tool design, one for staff and so on
- conflict of interest training to be integrated into all manuals and training sessions
- a nominated senior responsible officer for conflicts of interest, and the associated conflict of interest records and management
- a regular review process for conflicts of interest, this could be, for example, per cohort for assessors, each time a new employer selects the EpAO, the addition of new RoEpAO approvals for your organisation, and so on
- a clear conflict of interest declaration template covering the areas of expertise listed above
Some may choose to have a process for the declaration of conflict of interests (don’t forget it covers potential and perceived conflicts of interest, for management and mitigation, as well as actual conflict of interest). It may be worth producing a template to declare no conflict of interest as well as (potential/perceived/actual) conflict of interest. This is because, if the person only declared if they did have a conflict of interest then, potentially, the onus would then be on the EpAO to prove that those who have not filled in a template fully understood conflicts of interests and did not have a conflict of interest.
Please be aware that these are hints and tips from our end-point assessment expert Jacqui Molkenthin, a former service delivery manager of a successful end-point assessment organisation.
If you would like support or further information, please do not hesitate to contact Jacqui.
This article was written by Jacqui Molkenthin; check out her profile on our experts page.