Standard Procedures for Program Integrity Matters
NCCCO’s Program Integrity Team is responsible for ensuring that matters involving program integrity and ethics & discipline are addressed and managed in a timely, efficient, and systematic fashion.
In general, NCCCO’s Program Integrity Team (PIT) procedures shall be applied so as to treat all parties fairly and equitably, and to ensure that all applicable matters are handled in a constructive, impartial and timely manner.
The following provides a summary of the standard procedures applicable to all Program Integrity matters.
Procedures for New Matters
(A) New Complaints / Matters
(1) Potential violations/complaints brought to the attention of NCCCO Staff are forwarded to the PIT for review.
(2) To promote the timely reporting of complaints and increase the likelihood that investigations are conducted with reference to necessary and/or appropriate information and to maximize the availability of relevant evidence, potential violations/complaints should be submitted as early as possible. In certain cases, complaints made after 90 days from the date of the incident may be closed with no action, at the discretion of the PIT.
(1) If a matter involving program integrity or ethics & discipline is brought to the attention of NCCCO by a person or persons other than NCCCO Staff, whenever possible, NCCCO shall promptly acknowledge receipt of the complaint.
(2) To the extent possible, NCCCO shall also provide the complainant with progress reports and notice of the conclusion and outcome of the process by which the complaint was handled. As reasonably necessary or appropriate, NCCCO may also provide such progress reports or notices to other interested parties, such as employers.
(C) Preliminary Evaluation
(1) New Matters are to be discussed at the next scheduled PIT meeting and, in any event, within 30 days of being added as a New Matter. In exigent situations, New Matters should be discussed as soon as possible.
(2) In appropriate situations, a matter may be closed upon initial review without further action.
(3) If a matter is determined by the PIT to require further action, then a new Case is formally “opened”.
Procedures for the Investigation and Disposition of Cases
(A) Investigation of Cases
(1) The PIT shall be responsible for investigating each Case and for gathering and verifying any and all necessary information to validate each complaint.
(2) In Cases where the PIT concludes that an incident is to be investigated, in general, the subject of the investigation shall be sent a letter notifying them of the investigation. Any such letter must be sent within 10 days of the PIT meeting at which the case is opened.
(3) An investigation report is prepared by the staff lead assigned to the Case with the assistance of PIT staff. These reports are reviewed at subsequent PIT meetings and may be revised or supplemented thereafter. Investigation reports may be utilized to determine further recommendations and/or action. Except in extenuating circumstances, where additional time is necessary, investigation reports shall be completed within 60 days of a New Matter being added.
(4) In each Case involving a Practical Examiner, Test Site Coordinator, or Auditor, the PIT shall determine whether or not the program participant’s actions were “willful.”
- A willful violation is defined as “an act done voluntarily with either an intentional disregard of, or plain indifference to, the requirements of NCCCO policies or relevant industry safety or other standards.”
- In the event of a willful violation, in addition to any other sanctions, an individual suspended or sanctioned in any one capacity shall be automatically suspended or sanctioned in every other capacity in the program; provided, however, that the individual’s certification(s) may or may not be suspended or sanctioned, at the discretion of the PIT.
- In cases involving Practical Examiners, where an examiner’s actions are found to be willful, he or she shall be required to request permission from the Practical Exam Management Committee (PEMC) for re-entry into the Practical Examiner Program after expiration of any revocation period.In addition, the examiner will be required to appear, either in person or by telephone, at the PEMC meeting at which the foregoing request is heard.
(B) Referral of Matters/Cases
(1) As necessary or appropriate, and consistent with NCCCO’s Decisions and Appeals Matrix, the PIT may refer matters and/or cases to another appropriate entity for further investigation and/or handling, including:
a. The Ethics & Discipline Committee
b. The Practical Exam Audit Committee
c. The Practical Exam Management Committee
d. The Test Site Incident review/response team
(2) A matter or case may be referred to another entity in whole or in part, for exclusive or concurrent action, and before or after investigation and review by the PIT, depending on the entity to which the matter or case is referred.
(C) Disposition of Cases
(1) In the case of matters not otherwise referred, decisions regarding the disposition of a Case, including a Case opened in response to a complaint, shall be made and approved by the PIT. As necessary or appropriate, and as warranted under the circumstances, any member of the PIT previously and personally involved in the underlying subject matter of the Case should recuse himself or herself from the final decision regarding disposition.
(2) Upon conclusion of an investigation by the PIT, if a program participant or other person is recommended for revocation or other disciplinary action, under the authority granted to NCCCO Staff, the PIT shall send an appropriate letter reflecting the action taken and advising the participant or person of the action taken and any applicable rights of appeal. Any such letter must be sent within 10 days of the PIT meeting at which the action was taken.
(3) If a program participant is revoked, the participant’s record(s) will be updated accordingly. In addition, the participant will be removed from the Verify CCO Online (VCO) database.
(4) Except in extenuating circumstances, where additional time is necessary, investigations shall be completed, decisions shall be reached by the PIT, and/or matters referred to another appropriate entity, and the participant or person shall be advised of any action taken and any applicable rights of appeal, within 90 days of a New Matter being added. To the extent possible, Cases involving suspensions shall be expedited for resolution as promptly as practicable.
As appropriate, the foregoing procedures shall be subject to considerations of confidentiality relating to the complainant and the subjects of any complaint.
Additional Program Integrity procedures:
Administrative Holds during Investigations
- Suspensions Pending Investigation
- Matters Involving Practical Examiners
- Incidents Involving Safety Issues
- Matters Involving Complaints against Training Providers