Appeals vs Complaints

Twice this week I've been in discussions about what is the difference between an appeal and complaint.

An appeal is a written request for reconsideration of a determination made by a credentialing body. For example, an applicant may appeal the denying of his eligibility status or a certificant may appeal the determination to revoke her credential.

In contrast, a complaint is a request, other than an appeal, made to a credentialing body, for corrective action relating to the activities of that body or regarding those it credentials.  For example, an individual may file a complaint that a certificant is acting in a manner that violates the profession's code of conduct.  These types of ethics-related complaints typically must follow a formal complaints policy and procedures.  However, also keep in mind that it's important to have a process to consider, resolve and track all complaints.  For example, a candidate may complain that he didn't get his eligibility letter in the published time-frame.    Do you have a system to track and resolve these types of complaints?  I've found many organizations don't!

So, even though the two are often lumped together, as in "you need to have policies and procedures for appeals and complaints" keep in mind that they are, in fact, separate processes.

Going Global?

Going global with certification is a topic of interest to many, but few resources exist to guide efforts.  Here's an article that's not new, but provides timeless advice.  Don't forget to click on the links at the end too - one covers legal issues to consider.  (Caveat:  you may need to be an ASAE & The Center member to view.)

Also important to realize, there is an important distinction between a U.S. association offering a credential to an international audience and one offering global credentialing.  The former occurs much more often.  In this case, a U.S.-based association creates a credentialing program based on U.S. practice and standards and allows individuals in other countries to apply.  In this case, those individuals will be required to know the U.S.-based terminology and standards even if they do not apply to them.  In addition, the program likely won’t cover some terminology and standards important to practice in their country.

In contrast, a truly global credentialing system studies the practice in every country where the certification will be offered, identifies the universal standards that apply to all, and creates the program based on these universal standards.  This, as you can imagine, is usually not an easy task for most professions since terminology, practice standards, and regulations often differ significantly by country.
The differences often lead associations to hybrid approach, including 1) creating the U.S.-based program first and later adopting other versions of it for use in other countries and 2) working with several nations to identify the universal set of standards, but then allowing individual countries to add standards to accommodate their local practice requirements. 

It can be helpful to distinguish the program types using the following terminology:

  • A national program is one that is based on standards that were developed and adopted by one country, yet individuals from other countries are allowed to apply for the credential.
  • An international program is one that is based on standards that were developed and adopted by one country and applied to other countries.
  • A global program is one that is based on universal standards collectively identified by all the countries involved.
  • A multinational program is one that is based on a combination of universal and local standards.  Representatives from different nations collectively define a universal set of standards, but they reserve the right to supplement those standards with ones that reflect their local conditions

National certification programs that allow international applicants are fairly common.  However, how they handle international applicants can vary.  Reciprocity and equivalency are forms to be familiar with:

  • Reciprocity is mutual recognition by two countries of each others standards and/or requirements.
  • Equivalency is the determination that a country’s standards and/or requirements are of equal content and quality of those of another country.

FAQ: Training for Certification

Once again today I received one of the most frequently asked questions from execs considering developing certification: "Can taking our courses or training programs be a requirement for certification?"

The simplistic answer is yes, but only because there are no MANDATES that certifying agencies must follow in program design.  That is, you really are free to develop a credentialing program with whatever requirements you want and you can call it whatever you want (certification, registration, certificate, etc.)  However, just because you can doesn't mean you should.  You should know the implications.

First, mandating specific courses or training programs as a requirement for certification is in violation of the existing voluntary certification industry standards (ANSI and NCCA).   You're likely aware of organizations that require their courses as part of their certification programs.  In some instances, these programs – while called certification – may, in fact, be curriculum-based certificate programs (more on this later)...or they could be a blend between the two types of program.  In other cases, organizations may either not be aware of the industry quality standards or they have chosen not to comply with them.

Second, from the legal perspective, certification-related activities that are anticompetitive, discriminatory, based on subjective standards, or implemented without fair procedures are cause for antitrust concern.  In this case, a legal concern is a tying arrangement – that you are tying the certification product to an educational product (and requiring purchase of both).  Also, there is a fairness concern in requiring everyone to participate in (and pay for) coursework – regardless of whether they may need it.

Looking at the definitions from a purist perspective, if you are developing a program that includes both training and an assessment, that's called a certificate program.  The primary distinction between certification and curriculum-based certificates is in their focus. In certification, the focus is on assessing current experience, knowledge and skills. In a certificate, the focus is on training individuals to achieve a certain knowledge and skill base and then assessing attainment of it.   The programs meet entirely different goals so you need to identify your organization's goals before you determine which program type, if any, you should create.

For more information, check out the articles at this link.

Do you need a hammer?

At the recent ASAE & The Center Great Ideas Conference, an attendee that I had just met asked me an interesting question; he said, "I've read a lot of your writings lately, and I can't tell so I was wondering....are you an advocate of certification or not?"

This shocked me initially because I guess I'd always thought of myself as a certification advocate, I'm a certification consultant for goodness sake.  But then clarity hit and I realized how many organizations have chosen to develop programs other than certification based on my counsel.  My response to him:  If certification is really right for the field, then I'm an advocate.  If it's not, then I'm not.  We proceeded to have a discussion about his certification program and the reasons certification may or may not be right for an organization, and what alternatives there are.  Then I asked him, "If you had NOT developed a certification program, would your field look any different than it does today."  A little sheepishly, he said no, was silent for a minute and then said, "I wish I'd have met you four years ago."  You see, there was a certification consultant who helped him build a  psychometrically sound and legally defensible program - unfortunately it's not really needed by the market.

So, here's my plea.  If you are considering developing a certification program, do NOT send out an RFP to certification consultants and/or testing agencies asking them to help you build it.  Why?  Because they just might help you build a really expensive program that has no impact!   Invest the time and resources to determine if certification would make the impact you  desire.  You might be surprised to find certification isn't the answer (or maybe it is).  There's a big toolbox out there -- certification, certificates, accreditation, awards, member classification systems, professional development, among many others.  Figure out what you're trying to build BEFORE you invest in one tool.  And if advisors are only selling one tool (usually certification), take great pause before signing that contract.    I don't believe anyone would intentionally try to sell you a program you don't need.  It's just that, if all you're selling is a hammer, everything tends to look like a nail.

Note:  many of the writings my colleague was referring to are included in the book and blog of the same name: We Have Always Done It That Way:  101 Things About Associations We Must Change.

501c3 or c6 for Certification: Does it matter?

In theory, both 501(c)(6) and (c)(3) organizations can offer certification; however, which type an organization is DOES MATTER, especially to the IRS.  In short, most certifications are viewed by the IRS as primarily serving the profession rather than the public - thus a (c)(6) is appropriate and the certification revenue would be exempt from UBIT.  However, a (c)(3) with substantial income from certification may be putting its status at risk.  A (c)(3) with insubstantial income from certification does not put its status at risk; however, the certification income will likely be subject to UBIT. 

That's an oversimplified explanation, so read the details in this article by lawyers at Venable LLC or this one by Pillsbury Winthrop Shaw Pittman lawyers (neither are new articles but the information is still current). 

Next Generation Credentialing

In case you didn't see it, Shannon Carter and I published an article on Next Generation Credentialing in the June Associations Now magazine.  Also, I'll be taking a concept touched on in the article - purpose-driven certification products and services - to the next level at a presentation at the 2007 NOCA conference:  Exploring New Frontiers in Credentialing, November 14 - 17, 2007 in San Antonio, TX.  There's no conference web page yet, but I'll post it when available.  Hope to see you there!

New Standards for Technology-delivered Assessments

ISO/IEC has released a new international standard: ISO/IEC 23988:2007 Information technology - A code of practice for the use of information technology (IT) in the delivery of assessments.

The aims of the standard are to provide a means of:

  • showing that the delivery and scoring of the assessment are fair and do not disadvantage some groups of candidates, for example those who are not IT literate;
  • showing that a summative assessment has been conducted under secure conditions and is the authentic work of the candidate;
  • showing that the validity of the assessment is not compromised by IT delivery;
  • providing evidence of the security of the assessment, which can be presented to regulatory and funding organizations (including regulatory bodies in education and training, in industry or in financial services);
  • establishing a consistent approach to the regulations for delivery, which should be of benefit to assessment centers who deal with more than one assessment distributer;
  • giving an assurance of quality to purchasers of "off-the-shelf" assessment software.

The 39 page in-depth standard can be purchased and downloaded from the ANSI store.  All associations considering or offering computer- or internet-based testing (and all associated service providers/vendors) would benefit from a review of this informative standard which, by the way, applies to both low and high-stakes assessments.

How Secure are Your Tests?

Do you deploy proactive strategies to see if your test questions are being pirated?  Do you monitor your test statistics for evidence of cheating or item exposure?   You should!  Test security is something all certifying agencies need to be concerned with.  Caveon, a company well known for its expertise and services in test security, has a plethora of quality downloadable resources addressing test security on their website.  Check them out.

Requiring Training for Certification

I was asked today if an organization could require candidates for their certification program to purchase their training materials.  This is becoming a popular question.   As always, there's not a clear-cut answer.

If your organization has or is trying to create a professional certification program for the field, then it is not desirable to require purchase of training materials your organization has created.  Doing so would not be in compliance with the certification industry standards promulgated by the National Commission for Certifying Agencies or the American National Standards Institute for their accreditation programs for certifying bodies.   The problem is not with offering the training, it's with REQUIRING it.

If, on the other hand, your organization's program is a curriculum-based certificate program, then the training is an integral component of the program so it can and should be required. 

There's a final IF.  If your program is really a blend between certification and curriculum-based certificate, then the answer gets even greyer.  The answer then depends upon how the program really functions in the market as to whether or not it's a good idea to require study materials.  Generally, it's not.

Click here to learn more about the distinctions between professional certification and curriculum-based certificates.

Retired Status for Certification: Good Idea or Not?

The question of whether or not to create a retired class of certification comes up frequently on various electronic lists. Is it a good idea?  I'm a consultant, right, so you know my answer: IT DEPENDS. :-)

It's understandable for those retired to want to maintain their credential as a sort of badge of honor, even when they are no longer practicing. However, giving in to these demands can diminish the value of the credential.

In considering this issue, you and your Board need to consider the real purpose of the credential. Is it public protection or is it more recognition-focused? If your certification has a public protection purpose, then it's likely contradictory to waive the continuing competency requirements for any class of certificants. Bottom line, if your focus is on public protection, then you want to do your best to ensure your certificants are competent. Telling some of them they don't need to learn anymore while still holding up the same designation as others isn't consistent with the public protection focus. Many of the retired classes of certification I've seen are based on age alone. BAD idea. If you go down the path of adding a retired class, consider requiring a signature attestation that the individuals are, in fact, retired from the field that you are certifying.

Or, rather than adding a separate retired category, consider ways to make the requirements more user-friendly to this cohort. Make sure they are not unnecessarily restrictive or cumbersome. For example, do you require only traditional CE activities - such as conference attendance - which can have financial, mobility and geographic limitations? Consider what other activities you can allow that are accessible and affordable to everyone. For example, reading peer-reviewed journal articles is one activity to consider adding because it has few barriers. Or, could you offer them a discount?

On the other hand, if the purpose of the certification is really about recognition within your profession, then a retirement class has fewer implications.  Not best practice, in my opinion, but it can be done.