Private Organization Accreditation

Family Services of Southeast Texas strengthens families through accessible, affordable counseling services and education for issues affecting family life, mental health and employment.  We also provide comprehensive domestic violence shelter and support services.


Advantage Credit Counseling Service

Mary Loftus, VP, Agency Service

Our agency is preparing for reaccreditation under the Eighth Edition Standards. The COA site is well organized and very easy to use. Our team of employees working on the reaccreditation process has found the tools index to be very helpful, particularly some of the templates.
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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.

PA-AG 6: Conflict of Interest

The agency 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 agency as a whole.

Rating Indicators
Full Implementation, Outstanding Performance
A rating of (1) indicates that the agency's practices fully meet the standard and reflect a high level of capacity.  
  • All elements or requirements outlined in the standard are evident in practice, with rare or no exceptions; exceptions do not impact service quality or agency performance. 
Substantial Implementation, Good Performance
A rating of (2) indicates that an agency's infrastructure and practices are basically sound but there is room for improvement. 
  • The majority of the standards requirements have been met and the basic framework required by the standard has been implemented.  
  • Minor inconsistencies and not yet fully developed practices are noted; however, these do not significantly impact service quality or agency performance.  
Partial Implementation, Concerning Performance
A rating of (3) indicates that the agency's observed infrastructure and/or practices require significant improvement.  
  • The agency has not implemented the basic framework of the standard but instead has in place only part of this framework.   
  • Omissions or exceptions to the practices outlined in the standard occur regularly, or practices are implemented in a cursory or haphazard manner. 
  • Service quality or agency functioning may be compromised.   
  • Capacity is at a basic level.
Unsatisfactory Implementation or Performance
A rating of (4) indicates that implementation of the standard is minimal or there is no evidence of implementation at all.  
  • The agency’s observed service delivery infrastructure and practices are weak or non-existent; or show signs of neglect, stagnation, or deterioration.  
Please see Rating Guidance for additional rating examples. 

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
    PA-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 agency 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 agency 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 office of the public guardian falls under the auspices of a larger social service agency that provides direct services to the identified service population, 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. The guardianship agency must develop a clear process for assessing the needs of the individual and identifying the service provider who will most effectively meet those needs.

  • PA-AG 6.02

    When the agency refers the individual to services offered by a government agency with direct oversight of the guardianship program, reasons for the arrangement should be documented in the case record.

  • PA-AG 6.03

    The agency 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 agency acts as both guardian and direct service provider, the court should be notified.

  • FP
    PA-AG 6.04

    The agency 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 agency 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 agency 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. Agencies 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 agency 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 agency 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.

  • PA-AG 6.05

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

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