Private Organization Accreditation

HeartShare assist individuals with developmental disabilities through education, day, residential and recreation programs, case management, and health services, and provides foster care/adoption services, counseling, after school and energy assistance programs, and programs for people with HIV/AIDS.


The Village for Families & Children, Inc.

Galo A. Rodriguez, M.P.H., President & CEO

COA Peer Reviewers demonstrated their expertise through their knowledge of COA standards as well as experience in the behavioral health field. In addition, COA’s seminars and tools were very helpful in guiding us through the accreditation process.
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Individuals who receive guardianship services maintain a level of independence and self-determination appropriate to their functional capacity, and are at minimized risk of abuse, neglect, or exploitation.

AG 6: Conflict of Interest

The organization establishes the well-being of individuals as its primary responsibility and eliminates the risk, or appearance, of a conflict of interest.

Interpretation: A conflict of interest exists when an action made on behalf of the individual may be seen as self-serving to the guardianship worker or the organization as a whole, such as when the organization arranges for the individual to live in one of its residential facilities for which it will collect rent or some other form of payment.

Rating Indicators
All elements or requirements outlined in the standard are evident in practice, as indicated by full implementation of the practices outlined in the Practice standards.
Practices are basically sound but there is room for improvement, as noted in the ratings for the Practice standards; e.g.,
  • Minor inconsistencies and not yet fully developed practices are noted, however, these do not significantly impact service quality; or
  • Procedures need strengthening; or
  • With few exceptions procedures are understood by staff and are being used; or
  • For the most part, established timeframes are met; or
  • Proper documentation is the norm and any issues with individual staff members are being addressed through performance evaluations (HR 6.02) and training (TS 2.03); or
  • Active client participation occurs to a considerable extent.
Practice requires significant improvement, as noted in the ratings for the Practice standards. Service quality or program functioning may be compromised; e.g.,
  • Procedures and/or case record documentation need significant strengthening; or
  • Procedures are not well-understood or used appropriately; or
  • Timeframes are often missed; or
  • A number of client records are missing important information  or
  • Client participation is inconsistent; or
  • One of the Fundamental Practice Standards received a rating of 3 or 4.
Implementation of the standard is minimal or there is no evidence of implementation at all, as noted in the ratings for the Practice standards; e.g.,
  • No written procedures, or procedures are clearly inadequate or not being used; or
  • Documentation is routinely incomplete and/or missing; or  
  • Two or more Fundamental Practice Standards received a rating of 3 or 4.

Table of Evidence

Self-Study Evidence On-Site Evidence On-Site Activities
    • Adult Guardianship conflict of interest policy
    • Procedures for assessing service needs and identifying appropriate service providers
    • Procedures for submitting court petitions
No On-Site Evidence
    • Interview:
      1. Program director
      2. Relevant personnel
    • Review case records

  • FP
    AG 6.01

    Whenever possible, the guardianship program:

    1. operates as an independent entity; and
    2. refers individuals to services offered by outside providers.

    Interpretation: When the guardianship program is part of a larger organization or entity, it should have the authority to make independent decisions in order to avoid conflicts due to the potentially competing interests of the larger organization or entity. Exceptions to element (b) should be made only: (1) when an appropriate outside service provider is unavailable, and (2) when the exception is in the best interest of the individual served.

    Research Note: When the population receiving social services from the organization is the same population for whom the organization is acting as guardian, a conflict of interest can arise. In such situations, guardianship workers may not have the autonomy required to advocate on the individual’s behalf or assess the quality and appropriateness of the service being provided. A clear process for assessing the needs of the individual, and identifying the service provider who will most effectively meet those needs should be established.

  • AG 6.02

    When the organization acts as both guardian and direct service provider, reasons for the arrangement should be documented in the case record.

  • AG 6.03

    The organization discloses any potential conflict of interest to all involved parties including the court, the individual, and his or her family as appropriate.

    Interpretation: For example, if the organization acts as both guardian and direct service provider, the court should be notified.

  • FP
    AG 6.04

    The organization only petitions the court for its own appointment as guardian when no other entity is available.

    Research Note: The literature strongly suggests that there is an inherent conflict of interest when the organization acts as both petitioner and guardian. The guardian’s first responsibility is to protect the rights and assets of the individual, and acting as petitioner could be seen as self-serving. When acting as petitioner, an organization has the power to pick only those cases that would be profitable or require minimal staff time and avoid cases involving destitute individuals or individuals with significant behavioral issues.

    However, it is also important to point out that barriers to finding a petitioner such as a lack of community relationships or an inability to cover court and filing fees could result in individuals going without needed services. Organizations should collaborate with other stakeholders such as nursing homes, police departments, community mental health agencies, family members, adult protective services, hospitals, attorneys, and assisted living facilities to identify potential petitioners within the community. The organization should also be aware of fee waivers in their state that may make petitioning the court more financially viable for community members and service providers.

    When the organization must act as petitioner, it should do so based upon a referral from a neutral third party and provide evidence that steps were taken to protect the individual’s right to due process including access to quality legal representation.

  • AG 6.05

    All guardianship fees are reported to and approved by the court.

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