Private Organization Accreditation

As one of the largest family services agencies in the country, Child & Family Services has dedicated its resources to meet the needs of the community since 1873.


Barry Gourley

Volunteer Roles: Endorser; Peer Reviewer

It is an honor to be a COA volunteer. I’ve had a great opportunity to work with fabulous COA volunteers, I’ve grown professionally in the COA accreditation process and I’ve met some wonderful people across this nation who are working hard to help and support children and families.
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The agency earns and sustains the public trust through honest, truthful, and responsible transactions, partnerships, and relationships with individuals, communities, providers, businesses, donors, and government entities.

PA-ETH 2: Conflict of Interest

The agency prevents the enrichment of insiders and other abuses through the adoption and enforcement of a conflict of interest policy consistent with state laws and regulations.

Interpretation: COA does not define “conflict of interest,” and expects an agency’s policy to do so.

The Panel on the Nonprofit Sector, Interim Report, Section 4, Conflict of Interest Policy Disclosure contains a useful description of the Conflict of Interest issue. References to the Internal Revenue Code note that the Code defines a conflict of interest and that: “All states mandate that directors and officers owe a duty of loyalty to the organization, and improperly benefiting from a transaction involving a conflict of interest more than likely involves a violation of the duty of loyalty. Some state statutes specifically penalize participation in transactions involving conflicts of interests unless the organization follows certain prescribed procedures.”

Note: Please see Conflict of Interest Policy and Procedure Template - Private, Public, Canadian, Network for additional assistance with this standard.

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 administration and management 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
    County/Municipality Administered Agency, State Administered Agency (Central Office), or other Public Entity
    • Conflict of interest policy and procedures
    • Network Management Manual
    • Network utilization data to review referral and utilization patterns
    State Administered Agency (Regional Office)
    • Documentation of policy communication to staff
    County/Municipality Administered Agency, State Administered Agency (Central Office), or other Public Entity
    • Management meeting minutes documenting discussions of potential and apparent conflicts of interest
    • Financial statements/audits
    • Network client files to review reasons for referrals to particular providers
    State Administered Agency (Regional Office)
    • No On-site Evidence
    County/Municipality Administered Agency, State Administered Agency (Central Office), or other Public Entity
    • Interview:
      1. Agency head
      2. Ethics officer/in-house counsel
      3. Oversight Entity/Stakeholder Advisory Panel members
      4. CFO or equivalent
      5. Persons served/community stakeholders
      6. Personnel
    • Network interview:
      1. Network Advisory Body
      2. Directors of agencies that contract with the managing entity
      3. Network personnel involved in assessments and referral
    State Administered Agency (Regional Office)
    • Interview:
      1. Agency leadership
      2. Persons served/community stakeholders
      3. Personnel

  • PA-ETH 2.01

    A conflict of interest policy is tailored to the agency’s specific needs and characteristics, and:

    1. defines conflict of interest;
    2. identifies groups of individuals within the organization covered by the policy;
    3. addresses transactions between oversight entities and the agency;
    4. addresses policy enforcement;
    5. provides a framework for evaluating situations that may constitute a conflict; and
    6. invests management with developing procedures that facilitate disclosure of information to prevent and manage potential and apparent conflicts of interest.

    Interpretation: If an agency has a conflict of interest policy requiring signature of the designated authority, these signed forms should be available with the policy. The conflict of interest policy should ensure, among other things, that advisory members recuse themselves on matters where their objectivity could be compromised.

  • PA-ETH 2.02

    Conflict of interest policies and procedures ensure that contracts and business arrangements serve the agency’s and service recipients’ best interests, not private interests.

  • PA-ETH 2.03

    Advisory group members, personnel, and consultants who in any way have a financial interest in the agency’s assets, business transactions, leases, or professional services:

    1. disclose this information; and
    2. do not participate in any discussion or vote taken with respect to such interests.

  • PA-ETH 2.04

    The network has a process for ensuring that its activities are carried out in an even-handed, principled manner and in the interests of service recipients.

    Interpretation: It is essential that the network guard against any real or perceived conflict of interest in the manner in which it conducts its business, especially with regard to assessment, referral, and utilization management practices.

    NA The agency is not a network management entity.

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