Policies and Procedures for Addressing Concerns of Unethical Conduct

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REPORT

The International Psychotherapy Institute
Policies and Procedures for Addressing Concerns of Unethical Conduct
January 13, 2020

These policies and procedures have been designed in conformity with the IPI Ethics Code (2018). In developing these policies and procedures, we have also reviewed a variety of ethics codes, including the American Psychoanalytic Association, American Psychological Association, and the International Psychoanalytical Association.

Initial Consultative Options available to IPI Members and IPI Participants

Any IPI member or IPI participant who is concerned about the personal behavior or professional conduct of an IPI member can bring forward their ethical concern or complaint before the Committees named below, and/or directly to the IPI Executive Director. The IPI member or IPI participant registering such a concern or complaint, will be offered a consultation. The IPI member or IPI participant can choose to bring their concern or complaint initially to the Chair of the Colleague Assistance Committee (CAC), the Chair of the IPI Ethics Committee (EC); or the IPI Executive Director.

The IPI member or IPI participant will be informed about a range of options by which they may initiate their ethical concern or complaint. This preliminary consultation option will not require that the IPI member or IPI participant initiate a formal written ethical complaint. Rather, the IPI member or IPI participant will be offered an informal discussion about the nature of the concern or complaint, and guidance about potential next steps. The options for the initial consultation are outlined below.

Option 1: The IPI Colleague Assistance Committee (CAC) (currently in formation)

The spirit of the Colleague Assistance Committee (CAC) is to serve as a problem-solving resource for the IPI member or IPI participant rather than to investigate or adjudicate the alleged concern. The IPI CAC is tasked with listening to, and exploring any matter relating to behaviors of concern, that do not rise to the level of a possible ethical complaint or violation. Unlike the IPI Ethics Committee, the CAC provides a more informal consultative approach to resolve concerns that may not necessarily involve ethical issues, and therefore would not be expected to lead to any sanctions.

Option 2: The IPI Ethics Committee (EC)

The IPI Ethics Committee is tasked with listening to, and exploring any complaint of reported unethical behavior by an IPI member or IPI participant. The mandate of the IPI Ethics Committee is to investigate the complaint brought by the IPI member or IPI participant. The Ethics Committee may determine that the matter might be preferably handled by the IPI Colleague Assistance Committee (CAC), and may therefore recommend that the issue be referred to the CAC. In the case of a formal complaint, the IPI Ethics Committee serves to make recommendations to the IPI Executive Director and IPI Board of Directors.

Option 3: Notification of the IPI Director

The IPI member or IPI participant may exercise the option to directly notify the IPI Executive Director of the alleged ethical concern or complaint as an initial step, in addition to or as an alternative to one of the aforementioned steps. The IPI Director will assess the nature of the concern or complaint, and may recommend that the IPI member or IPI participant seek further consultation at either the IPI Ethics Committee or the IPI Colleague Assistance Committee.

Initiating an Ethical Concern

Principles of confidentiality pertaining to the discussion of an ethical concern

The identity of the person who is the subject of the concern, and the member concerned, will be held privately, and not disclosed beyond the Colleague Assistance Committee (CAC) and the IPI Executive Director. It is understood that the IPI Executive Director will entrust the process to the CAC. In contrast, if an IPI member or participant would wish to make a formal ethical complaint, then it would be filed with the IPI Ethics Committee.

If a concern were to proceed to the level of a formal complaint, then the concern would be referred to the IPI Ethics Committee.

Principles of confidentiality and procedural issues relating to filing an ethical complaint

In the event that an IPI member of IPI participant files a formal ethical complaint, the identity of the complainant, and the identity of the person who is the subject of the complaint, will not be disclosed beyond the IPI Ethics Committee (EC) and the IPI Executive Director, unless a determination is made, after due process, to file that complaint with the disciplinary body for that practicing clinician. In that context, the IPI Executive Director would use their discretion as to the level of information disclosed to the IPI Board.

Once the IPI member or IPI participant has chosen to register a formal ethical complaint, they will contact the Chair of the IPI Ethics Committee. The Chair of the Ethics Committee will then notify the IPI Executive Director and the Chair of the IPI Board that a formal ethics complaint has been made. Once a member has provided their written complaint, they will be asked to provide permission for the Chair of the Ethics Committee to communicate with the Chair of the Colleague Assistance Committee (CAC) if there is a possibility for that complaint to be handled preferentially by the CAC. The IPI member or IPI participant should be informed that the complaint will be handled with discretion.

The IPI Ethics Committee will utilize the IPI Ethics Code in considering the formal complaint.

Procedure to file a complaint with the IPI Ethics Committee

  1. The person filing the formal written complaint will be provided with a copy of the IPI Ethics Code;
  2. The person filing the formal complaint will be asked to provide a written and signed statement that would include the following pieces of information:
    • a. Name of person alleged to have engaged in unethical conduct;
    • b. Description of the nature of the alleged unethical conduct, including alleged facts and/or circumstances;
    • c. A statement of ethical principles allegedly transgressed with reference to IPI Ethics Code, if possible;
    • d. A statement that confirms the person authorizes the IPI Ethics Committee to utilize IPI’s policies and procedures in handling this ethical complaint.
  3. The Chair of the IPI Ethics Committee will notify the person alleged to have acted unethically, and will provide that person with copies of the formal complaint and other documents submitted by the person registering the complaint, along with the IPI Ethics Committee’s policies and procedures for handling such complaints.
  4. The IPI Ethics Committee will consider whether the complaint rises to a level that would prompt a formal investigation within IPI. Following the formal investigation, the IPI Ethics Committee will determine whether or not the complaint would constitute an ethical breach, and if so, would recommend sanctions to be imposed.
  5. The person alleged to have acted unethically would be notified of their right to be represented by legal counsel, and the right to receive the final decision or recommendation of the IPI Ethics Committee, including a statement of the recommendation to the IPI Executive Director with the rationale by which this recommendation was made.