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SME Conflict of Interest Policy and Disclosure Form
Please read this page in its entirety then click the link at the bottom of the page to complete and submit the Conflict of Interest Disclosure Form and to indicate that you agree to and comply with the Conflict of Interest Policy. 

Adopted: April 12, 2023 

Policy
The purpose of this conflict of interest policy is to prevent the professional and personal interests of the subject matter expert assessors (“SME”) of the Federation of State Physician Health Programs (the “FSPHP”), from influencing the performance of their duties on behalf of the FSPHP.   

The SMEs of the FSPHP occupy positions of trust and are obligated to discharge their assessment duties in good faith and with undivided loyalty to the FSPHP. They must act in the course of their assessment duties solely in the FSPHP’s best interests without regard to the interests of any other organization with which they are associated or person(s) with whom they are related. They must refrain from taking part in assessment services if they cannot do so with undivided loyalty to the FSPHP. 

This policy requires the disclosure of actual or potential conflicts of interests so that, when a conflict exists, FSPHP may decide, in its sole discretion, whether to temporarily or permanently terminate its authorization of an SME, require that the assessor recuse himself or herself from assessing a particular applicant, or permit the assessor to proceed with an assessment despite the disclosed conflict of interest. 

Definitions
As used in this policy: 

The term “organization” includes without limitation any agency, entity, company, association, firm or other group, whether governmental or nongovernmental, and whether operated on a for-profit or nonprofit basis.

“Interest” refers to both actual and potential interests, including without limitation any position as owner, officer, board member, partner, employee, contractor, consultant or beneficiary, but shall not include the ownership of less than five percent of the outstanding voting securities of a publicly held company.

“Immediate family” means parents, grandparents, siblings, spouse/domestic partner, children and grandchildren whether related biologically, through adoption or through marriage/domestic partnership. 

Conflicts of Interest
A conflict of interest arises when an SME’s personal (financial, reputational, relationship, professional, etc.) interests conflict with the interests of the FSPHP, the relevant FSPHP program, or an applicant entity to which the SME has been assigned to conduct an assessment (i.e., if an SME would benefit by doing something that would harm the FSPHP, the applicable FSPHP program, or an applicant entity to which the assessor has been assigned to conduct an assessment, that is a conflict of interest). 

Examples of Conflicts of Interest
A conflict of interest may exist if the SME, a member of an SME’s immediate family, or an organization for which the SME or the SME’s immediate family member serves as an owner, officer, director, trustee, partner or employee, or a prospective employer of the SME or the SME’s immediate family member:

  • Has a business or financial interest in any third-party dealing with the FSPHP (including an applicant of the applicable FSPHP program) or a prospective grantee of the FSPHP;
  • Holds office, serves on a board, participates in management, or is employed by any third-party dealing with or receiving funding from the FSPHP (including an applicant of the applicable FSPHP program);
  • Derives remuneration or other financial gain from a transaction involving the FSPHP or applicant entity (other than a compensation expressly authorized by the FSPHP);
  • Receives gifts  from any third-party on the basis of his or her position with the FSPHP; or
  • Engages in any outside employment or other activity that will materially encroach on such person’s obligations to the FSPHP; compete with the FSPHP’s activities; involve any use of the FSPHP’s equipment, supplies, or facilities; or imply the FSPHP’s sponsorship or support of the outside employment or activity. 

Use of Information
SMEs shall not use information received from its SME services, whether expressly identified as confidential or not, for personal gain or in a manner that is averse to the FSPHP’s interests. 

Disclosure
At the beginning of an engagement, or whenever an SME believes he or she may have a conflict of interest, the SME shall promptly disclose to the FSPHP any conflicts or potential conflicts of interest.

Please submit the SME Conflict of Interest Disclosure Form and to indicate that you agree to and comply with this Conflict of Interest Policy.