Impartiality and Conflict of Interest

The authority of a national standard rests on the impartiality of the institution that develops it. The American Board of First Responder Behavioral Healthcare maintains documented governance structures, institutional controls, and conflict-of-interest requirements directed at a single objective: that the content of the FRBH National Standard is determined by the needs of the workforce it protects, and by nothing else.
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Scope of Impartiality
FRBH develops and maintains a standard. It does not perform conformity assessment, certification, or accreditation of any organization, does not operate such a program, and does not intend to establish one. Conformity with the National Standard is determined by the adopting organization itself.
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The impartiality obligations applicable to FRBH are accordingly those of a standards developer: that requirements are set on their merits, that participation in setting them is open and balanced, and that no party holds a financial interest in their content.
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Independence of the Requirements
The following commitments are established within the published National Standard and cannot be altered without amendment of that document.
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‍The Standard is published without charge. It may be implemented at no cost. Conformity does not depend on any fee, or on the purchase of any service, product, technology, or membership from FRBH or from any other party.
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‍No prescribed provider. The Standard prescribes no workforce protection programs, vendors, clinical services, staffing configurations, software, or organizational structures. Organizations determine the means by which each organizational expectation is satisfied.
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‍No proprietary dependency. The framework underlying the Standard originated as Sustained Functional Resilience (SFR), developed prior to 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 to achieve conformance with it. No requirement of the Standard may be satisfied only by means of a proprietary instrument.
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‍No commercial support relationship. FRBH does not provide readiness, consulting, training, or advisory services to organizations implementing the Standard. Implementation support is limited to general implementation guidance, provided at no charge and on the same terms to every organization, without regard to whether an organization has adopted the Standard.
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Institutional Interests
The National Standard, and the OPHP framework as embodied in it, are owned by FRBH, as are the FRBH name, seal, and marks. FRBH holds unrestricted rights to publish, maintain, revise, and administer the Standard, without continuing royalty, license fee, or payment obligation to any other party. The framework underlying the Standard originated with FRBH's founder before FRBH was formed, under the name Sustained Functional Resilience (SFR). SFR is separately owned, is not part of the Standard, and is not required to conform with it. This position is set out in full in Section D.5 of the National Standard.
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No entity in which a director, officer, chief executive, or founder of FRBH holds an interest, and no entity under common ownership or control with any of them, may perform conformity assessment against the Standard.
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Conflict-of-Interest Requirements
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‍Application. Individuals participating in governance, standards development, or implementation support are subject to documented conflict-of-interest disclosure requirements. This includes directors, officers, National Advisory Council members, and personnel contributing to the development, revision, or publication of the National Standard.
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‍Disclosure. Interests are disclosed on appointment and updated as they arise or change. Interests requiring disclosure include commercial interests in products, services, instruments, technologies, or training that would be affected by the content of the Standard; employment or contractual relationships with organizations that would be subject to it; and financial relationships with FRBH.
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‍Evaluation. Disclosed interests are evaluated in accordance with established governance policy. The test applied is whether an interest could reasonably be seen to influence the exercise of judgment, not solely whether it would.
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‍Mitigation. Where an actual, potential, or perceived conflict is identified, mitigation measures are applied to preserve independence, objectivity, and the integrity of decision-making. Measures include recusal from discussion and decision on the matter concerned, exclusion from access to related material, and where necessary restriction from participation in the function.
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‍Separation of roles. Individuals serving within one institutional function are restricted from participating in another where a conflict could impair independence, objectivity, or impartiality. The chief executive is not a member of the Board of Directors and attends at the Board's invitation.
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Balance of Participation
Impartiality in standards development depends on who takes part, not solely on how decisions are recorded. The National Advisory Council is composed of subject-matter experts drawn from multiple public safety disciplines, serving in a non-voting advisory capacity. Council membership is published.
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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 an annual information return that is publicly available.
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No sponsor, donor, member, adopting organization, or commercial party holds authority over the content of the National Standard. Adoption of the Standard confers no influence over its future revision, and participation in its development may not be purchased.
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Transparency of Process
FRBH publishes the current development status of the National Standard, including process steps that remain outstanding. Substantive revisions are published together with the rationale for each change.
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Comments on the Standard are accepted at any time at info@frbh.org, are logged on receipt, and are considered in every subsequent revision. FRBH publishes its documented response to substantive comments received during formal comment periods, including those it declines to incorporate and the reasons.
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Related Documents
Governance Policy (PDF) · Conflict of Interest Policy (PDF) · Impartiality Policy (PDF) · Board Charter (PDF)