Standards for public agencies

2020 Edition

Administration and Management (PA-AM) 6: Conflict of Interest

The agency prevents the enrichment of insiders and other abuses through the enforcement of a conflict of interest policy consistent with state laws and regulations.
NA State-administered agency regional office
2020 Edition




 Through sound administration and effective management, the agency achieves its mission and strategic goals; assures appropriate use of public resources for the public good; and remains responsive to the needs of the communities it serves. 
Note: Please see the Conflict of Interest Policy and Procedures Template for additional guidance on this standard.
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.
Self-Study EvidenceOn-Site EvidenceOn-Site Activities
County/Municipality Administered Agency, State Administered Agency (Central Office), or other Public Entity
  • Conflict of interest policy 
  • Policy prohibiting preferential treatment
  • Ethical referral procedures
  • Documentation of policy communication to staff
State Administered Agency (Regional Office)
  • Evaluated at the Central Office only
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 from the previous 12 months
State Administered Agency (Regional Office)
  • Evaluated at Central Office only
County/Municipality Administered Agency, State Administered Agency (Central Office), or other Public Entity
  • Interviews may include:
    1. Agency leadership
    2. Ethics officer/in-house counsel
    3. Oversight Entity/Stakeholder Advisory Panel members
    4. CFO or equivalent
    5. Persons served
    6. Community stakeholders
    7. Personnel
State Administered Agency (Regional Office)
  • Evaluated at Central Office only

Fundamental Practice

PA-AM 6.01

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. ensures that contracts and business arrangements serve the agency’s and service recipients’ best intersts, not private interests;
  5. addresses policy enforcement;
  6. provides a framework for evaluating situations that may constitute a conflict; and
  7. invests management with developing procedures that facilitate disclosure of information to prevent and manage potential and apparent conflicts of interest.
NA The agency is not responsible for developing the conflict of interest policy.

Fundamental Practice

PA-AM 6.02

Advisory group members, personnel, and consultants who 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-AM 6.03

The agency prohibits:
  1. making or accepting payment or other consideration in exchange for referrals; 
  2. preferential treatment of community partners, advisory group members, personnel, or consultants in applying for and receiving the agency's services; and
  3. steering or directing referrals to private practices in which personnel, consultants, or the immediate families of personnel and consultants are engaged. 


It is permissible to include on referral lists personnel and consultants with private practices, or family members of personnel and consultants, but the agency may not actively direct service recipients to the practices of these individuals and must clarify in writing the relationship between the private practitioners and the organization.