Impartiality and Conflict of Interest

The authority of a national standard depends on the integrity and impartiality of the institution that develops it. The American Board of First Responder Behavioral Healthcare (FRBH) maintains documented governance structures, institutional controls, and conflict-of-interest requirements designed to protect the independence, objectivity, and integrity of the FRBH National Standard.
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Scope of Impartiality
FRBH develops and maintains a national standard. It does not perform conformity assessment, certification, or accreditation of organizations and does not operate such a program. Under the current Provisional Field-Test Edition, conformity is determined by the adopting organization through self-assessment.
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FRBH's impartiality obligations therefore center on the standards-development process: requirements must be established on their merits, relevant interests must be disclosed and appropriately managed, participation must support balanced consideration of affected perspectives, and financial or institutional interests must not improperly influence the content of the Standard.
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Independence of the Requirements
The following commitments are established within the published National Standard.
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‍The Standard is published without charge. It may be implemented without payment to FRBH. Conformity does not depend on a fee or on the purchase of any service, product, technology, membership, or proprietary instrument from FRBH or any other party.
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‍No prescribed provider. The Standard does not require a particular workforce protection program, vendor, clinical service, software platform, or organizational structure. Organizations retain flexibility in how they satisfy the requirements of the Standard.
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‍No proprietary dependency. The framework underlying the Standard originated as Sustained Functional Resilience (SFR), developed before the founding of FRBH and separately owned. SFR and its associated instruments, item banks, scoring methodologies, curricula, and software are not part of the National Standard, are not incorporated into it, and are not required for conformity. No requirement of the Standard depends on use of a proprietary instrument.
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‍No organization-specific consulting relationship. FRBH does not provide organization-specific consulting, assess hazards or work environments, recommend exposure controls, or determine organizational conformity. General implementation support is available without charge and on the same terms to organizations through the National Technical Assistance Center.
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Institutional Interests
The National Standard and the OPHP framework embodied within it are owned, maintained, and published by FRBH. FRBH holds the rights necessary to publish, maintain, revise, and administer the Standard without continuing royalty, license fee, or payment obligation to another party.
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The framework underlying the Standard originated with FRBH's founder before FRBH was formed, under the name Sustained Functional Resilience (SFR). SFR and associated instruments and methodologies are separately owned, are not part of the National Standard, and are not required for conformity. This relationship is addressed in Section D.5 of the National Standard.
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No entity in which an FRBH director, officer, chief executive, or founder holds an interest, and no entity under common ownership or control with any such person, may perform conformity assessment against the Standard or hold a financial interest in the outcome of such an assessment.
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Conflict-of-Interest Requirements
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‍Application. Individuals participating in FRBH governance, standards development, advisory functions, or implementation support are subject to documented conflict-of-interest requirements.
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‍Disclosure. Relevant interests are disclosed in accordance with FRBH governance policy and updated when circumstances change. These may include commercial, professional, contractual, employment, or financial interests that could reasonably be perceived as affecting impartial judgment.
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‍Evaluation. Disclosed interests are evaluated under established governance procedures. The relevant consideration is not limited to whether an interest actually influences judgment, but whether it could reasonably be perceived as doing so.
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‍Mitigation. When an actual, potential, or perceived conflict is identified, appropriate measures are applied to preserve independence, objectivity, and the integrity of decision-making. Depending on the circumstances, these measures may include disclosure, recusal, restricted access to relevant materials, or limitation of participation in the affected function.
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‍Separation of roles. FRBH maintains separation among standards development, implementation support, fiduciary governance, executive administration, and advisory functions where necessary to preserve independence and manage conflicts of interest. The chief executive is not a member of the Board of Directors and participates at the Board's invitation.
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Balance of Participation
Impartiality in standards development depends not only on how decisions are made, but also on whose perspectives are considered.
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The National Advisory Council provides multidisciplinary subject-matter expertise from public safety professions and related disciplines and serves in a non-voting advisory capacity. Council membership is publicly disclosed.
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As standards development progresses, FRBH's process provides for broader stakeholder participation, public comment, and the multi-stakeholder consensus procedures required for development of a future Consensus Edition.
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Funding and External Influence
FRBH is a tax-exempt public charity under Section 501(c)(3) of the Internal Revenue Code and files public information returns.
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Financial support does not confer authority over the content of the National Standard. Donors, sponsors, adopting organizations, members, and commercial parties receive no preferential influence over standards requirements, organizational conformity, or FRBH governance as a result of financial support.
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Participation in standards development is governed by the standards-development process and may not be purchased.
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Transparency of Process
FRBH publishes the development status of the National Standard, including significant steps that remain before publication of a Consensus Edition.
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Substantive revisions to the Standard are documented so implementing organizations can identify changes and understand their rationale.
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Comments on the Standard are accepted at info@frbh.org and considered as part of the continuing standards-development process. During formal public-comment periods, FRBH documents the disposition of substantive comments in accordance with its published standards-development procedures.
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Related Documents
Governance Policy (PDF) · Conflict of Interest Policy (PDF) · Impartiality Policy (PDF) · Board Charter (PDF)