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So, one of the core decisions an association needs to make when launching a new certification program is how the certification program will be organizationally structured and governed. If you make the right structural and governance decisions at the start and maintain effective practices, everything else flows a lot more smoothly.

Some certifying bodies are independent and separately incorporated as nonprofit or corporate entities, such as the American Board of Industrial Hygiene and the Board of Certified Safety Professionals. Others are a committee, business unit, or subsidiary within a larger business entity, like the Certification Governance Council of the Project Management Institute and the Certified Association Executive Commission of ASAE & The Center. Whatever the case, what matters is that authority is established and impartiality is maintained.

Why does an association's certification committee or unit need to establish and maintain appropriate authority and impartiality? According to Jefferson C. Glassie, an attorney specializing in nonprofit organizations and credentialing at the law firm Pillsbury, "the underlying reason is primarily to preserve and protect the integrity of the certification program by ensuring fair and equitable treatment of all persons involved in certification." In my years working in the world of certification, I've seen a few of these conflicts of interest: 

• When members complain that they are frustrated with the "hoops they are required to jump through" for certification or angry after failing the exam, the association's board might attempt to change or lower the standards. Several years ago a certifying body initiated new recertification requirements that brought on significant pushback from the associated professional association's members. The association's board of directors reacted by filing a lawsuit against the certifying body, which was ultimately unsuccessful. The conflict doesn't usually go that far, but that example shows how contentious certification standards can become. Imagine how the scenario might have played out if the certification were housed within the association.
• A business unit that sells training to candidates who fail a certification exam may have a financial interest in increasing the passing score to increase demand for the training.
• A professional association whose members predominantely have a particular academic degree may have an interest in restricting certification to individuals with that specific academic preparation. One association whose certifying body is a separate unit recently changed the eligibility requirements of a certification. The academic accrediting body of the profession (also within the parent association) is upset because completion of a program it accredits is no longer required. The association leadership is now debating which unit is responsible for establishing the profession's certification eligibility criteria.
• A board of directors or a membership department wishes to promote the certification as a benefit of membership and therefore wishes to restrict application to members. Bad idea; it can expose the organization to legal risk.

Setting the Standards

So how does a certification committee or unit ensure appropriate authority and impartiality? The two main certification industry standards provide some guidance. The ANSI/ISO/IEC 17024 General Requirements for Bodies Operating Certification Systems of Personnel standard was developed under the auspices of the International Organization for Standardization (ISO) and was ratified by more than 80 countries, including the United States. The Standards for the Accreditation of Certification Programs were developed by the National Commission for Certifying Agencies (NCCA), the accrediting arm of the National Organization for Competency Assurance.

ANSI addresses the organizational structure and governance of certifying bodies by requiring them to show that

• They are independent, impartial, and ethical in their operations.
• They are responsible for their own decisions relating to the expansion or reduction of the scope of the certification and suspension or withdrawal of the certification.
• Program stakeholders have input on the certification system.
• Interests are balanced and impartiality is assured.
• If training is provided, it does not compromise the integrity of the certification process.

NCCA addresses structure and governance by requiring certifying bodies to show that

• Governance structure, policies, and procedures protect against undue influence and provide for autonomy in decision making related to certifications.
• A system is established to ensure appropriate stakeholder involvement on the governing body, including a public member and certificants.
• Bylaws or policies for selection of governing committee members show that selection prevents inappropriate influence from a parent or outside body.
• The certifying bodies are not also responsible for accreditation of educational or training programs or courses leading to the certification.

According to Roy Swift, Ph.D., ANSI's senior director of personnel credentialing accreditation programs, the primary challenge faced by certifying bodies embedded in a larger legal entity is creating and maintaining the appropriate firewall between certification and other activities, especially the training function. He recommends that organizations just beginning to develop a certification program consider taking the ANSI short course on the ANSI/ISO/IEC 17024 standard to learn about the core requirements of a quality certification program. Then, if individuals responsible for certification development do not have a strong certification background, he recommends they work with a consultant to guide them in the program's development. "The upfront investment will be cost-effective in the long run," Swift says.

Like Swift, NCCA Chair Denise Fandel, CAE, says the primary certification challenges center around establishing proper firewalls. "For example, if a certification governing body is a committee of a larger organization," she says, "the organizational documents such as the bylaws and the policies and procedures must demonstrate that the decision making related to certification polices (such as eligibility, passing point, discipline, et cetera.) are protected from undue influence by any other group." She also points out another challenge: ensuring that the governance committee includes the proper representation. She recommends that organizations start with accreditation in mind as the ultimate goal and suggests using published standards as the guide for development of the program. In addition, researching certification programs that are currently accredited can help establish benchmarks for best practices for the new program.

Key Considerations

As you establish a certification unit, keep in mind a few key considerations for maintaining the appropriate authority and impartiality.

Autonomy in decision making. Because an association's board of directors is legally responsible for the decisions of the organization, it has the right to decline the recommendations or overturn the decisions of any organizational unit. So, the only way to ensure full autonomy in decision making is to establish a legally independent certifying body. Having said that, it is possible to establish a certifying body that is semi-autonomous and protected from inappropriate or undue influence in decision making related to eligibility criteria, assessment mechanisms, passing scores, and disciplinary actions.

Autonomy of the certification unit should be outlined in official documents (such as the organization's bylaws or policies) that define the certifying body's authority for essential certification decisions and activities, including the provision for acting without approval by another entity. Exclusions to autonomy should be made explicit, such as when the parent association's board approves the certifying agency's proposed budget, for example. The American Culinary Federation, Inc.'s bylaws have a section specifically addressing autonomy of the certification commission, stating that it is "independent and autonomous with respect to all decisions related to the certification program." I've seen many organizations develop a memorandum of agreement between the certifying unit and the parent association, but all this really amounts to is a handshake agreement. The two are the same legal entity, and you can't have a legally binding agreement with yourself.

A separate organizational unit devoted to certification. While industry standards do not dictate how a certifying body within a parent association should be structured, so many potential conflicts of interest exist between certification and other association units that it is usually best to establish an independent unit devoted to certification.

Independence from training. Probably the worst organizational design places the certification function within the education or training department. The primary conflict arises when the association wishes to develop a course of study leading to certification. Five points must be considered here.

1. In accordance with industry standards, coursework designed and offered leading to the certification or as preparatory should not be required.
2. If offering a preparatory course, nothing should be said or implied that certification would be easier or less expensive if the course is taken.
3. If it is desirable to list options for courses meeting eligibility requirements or serving as preparation, then all known courses should be listed.
4. The certification unit should not disclose any information about the exam that is not available to all candidates. For example, when an education department wants to develop a test preparatory course, they do so based on the publicly available test content outline, not based on any insider information (like the test questions!). It's difficult to appear not to have insider information when the staff are one and the same.
5. Individuals involved in the development or review of the certification exam should not be involved in the development or delivery of any exam preparatory coursework.

(Note: ASAE & The Center's Certified Association Executive certification program is housed within ASAE; the CAE immersion study courses are run by The Center for Association Leadership.)

Confidentiality. While most certifying organizations have policies and procedures set up to safeguard confidential information from external audiences, few consider internal issues. Much of the information maintained by a certification unit should not be accessible to personnel from other units. Databases containing candidate and certificant information should be password protected. Relevant offices and file cabinets should be locked. The certifying body should not release any information to other business units that it does not release to candidates or the general public. (For example, the names of certification applicants should not be shared with an education or training department that offers preparatory courses or the marketing department that sends the brochures.)

Inclusivity and balance. The certifying body's structure and processes should enable input from all stakeholders and interested parties without permitting any one interest to predominate. The more inclusive and accommodating the structure, the greater the likelihood that impartiality will be achieved. Associations should identify the stakeholders of the certification program—such as students, certificants, educators, employers, consumers, and regulators—and ensure each stakeholder is represented on the certification governing body. The best way to ensure this representation is to outline the required composition of the certification governing body in the association's bylaws or certification program policies. Sometimes it's not possible to include all stakeholder communities on the governing body due to the number of stakeholders and positions; a rotating schedule of representation is usually a good solution.

Conflicts of interest. Associations should ensure that individuals or entities do not participate in certification decisions or activities when a conflicting interest is present. Some examples include

• A coworker of a certificant filing an appeal with the certifying body would have a conflict in participating on that appeal review team.
• An individual who conducts test-preparation courses would have a conflict in writing questions for the certification exam.
• An individual who is on the board of a competing certifying body would have a potential conflict in participating on a certifying board.

Depending on the situation, such conflicts can be resolved through appropriate organizational firewalls, conflict-of-interest policies, signed conflict-of-interest statements from all individuals involved in certification activities, and reviewing and addressing potential conflicts of interest on an ongoing basis. Having policies and signed statements alone is not enough; you must continually monitor and address conflicts that arise. I often see conflicts being ignored simply because the individuals do not disclose their own conflicts and others are too uncomfortable to bring them up. Pointing out a potential conflict is not an easy task, but it is essential to maintaining certification program integrity.

Establishing and maintaining a certification program that is autonomous in its decision making and impartial in all of its operations isn't easy, but associations that do so will reap many rewards in marketplace value and in respect of the credential. 

Mickie S. Rops, CAE, is president of Mickie Rops Consulting Inc., which helps organizations make credentialing decisions. She is also the vice chair of the ASAE & The Center's Professional Development Council. Elements of this article are excerpted from "Simply Certification: A Primer for Volunteer Leaders and Staff of Personnel Certification Programs," available at www.msrops.com. Email: mickie@msrops.com

More Articles From Associations Now, October 2009

  Associations in a New World

  Organizing a Summit, Step by Step

  Does Your Staff Structure Need an Overhaul?

  Certification Done Right

  Was This Endorsement a Mistake?

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