Establishing a Firewall Between an Exam and Its Preparation Materials
By Linda K. Anguish, SPHR
Special thanks to Johnna Gueorguieva, PhD, ICE-CCP, CAE, Director of Assessments, Dental Assisting National Board, Inc. (DANB) and Todd Galati, CAE, Senior Director, Credentialing and Practice Advancement, American Council on Exercise (ACE) for their contributions to this article.
In late 2021, the Institute for Credentialing Excellence (I.C.E.) introduced its first professional certification program, the I.C.E. Certified Credentialing Professional (ICE-CCP). The ICE-CCP is the first program of its type designed by and for individuals who work in the professional credentialing (certification and licensure) field.*
When the I.C.E. Board of Directors approved the creation of the program in February 2020, they requested that it be developed in accordance with the “National Commission for Certifying Agencies (NCCA) Standards for the Accreditation of Certification Programs,” which were the first standards developed by the credentialing industry for professional certification programs in 1977. The NCCA Standards were developed in cooperation with the federal government to help ensure the health, welfare and safety of the public.
The earliest editions of the standards did not provide much guidance in the areas of education and training, simply stating that a certification organization “shall be separate from the education and accreditation functions of the discipline.” In the 2002 edition, commentary had been added that clarified, “In addition to not accrediting programs leading to the initial certification, the certification organization must not require that candidates complete that organization’s program for certification eligibility. If a certification organization provides an educational program (including but not limited to primary education, exam preparation courses, study guides), the organization must not state or imply that: 1) this program is the only available route to certification; or 2) that purchase or completion of this program is required for initial certification.”
The most recent edition, approved by a consensus body in November 2021, consists of 23 standards that cover the essential elements of a high-quality professional certification program. Standard 3, Education, Training and Certification, is one of the most misconstrued, probably due to the brevity of the earliest versions. This standard currently specifies that, “Appropriate separation must exist between certification and any education or training functions to avoid conflicts of interest and to protect the integrity of the certification program.”
The purpose of a professional credentialing program is to recognize those who meet established knowledge, skills or competencies for a particular profession, occupation, role or specialty area. Maintaining a clear separation, often referred to as a “firewall,” between a certification/licensure program and any education or training function designed to prepare candidates for initial certification is critical to avoid any appearance of a conflict of interest. This firewall also protects the integrity of the credential for those who earn it.
Additionally, unlike an assessment-based certificate program, a professional certification program must be impartial regarding how candidates prepare to earn the credential. No two candidates have the exact same background, experience or learning styles. Therefore, as long as the candidate meets eligibility requirements, how they gained the requisite knowledge or skills to earn the credential will vary, as will the degree of preparation needed, if any.
Doing It the Right Way
A surprisingly common misconception is that if a credentialing program wants to become accredited under either the NCCA Standards or the ISO/IEC 17024:2012 Standard, they are prohibited from offering education or training that prepares potential candidates for their assessment instrument. This is not true as long as the credentialing organization is appropriately structured to conduct these activities independently and is fully transparent about its activities. The NCCA Standards specify that accredited programs must:
- Have the appropriate firewalls in place to ensure that staff members, volunteers, subject matter experts (SMEs), contractors, etc., involved in any aspect of test development are not in any way involved in creating or delivering preparation resources.
- Ensure that the appropriate documents regarding confidentiality, conflicts of interest and restrictions from taking the test for a reasonable period are signed and enforced.
- State clearly that the purchase of any preparatory education or training is not required in order to earn the credential, and do not imply that the credentialing organization’s training products are the best way, only way or the guaranteed way to pass.
For more details on these requirements, refer to resources available in the sidebar below.
The ICE-CCP Approach
The steering committee that was appointed by the I.C.E. Board of Directors to oversee the development of the ICE-CCP was careful to address the requirements of Standard 3 directly.
“Since I.C.E.’s mission includes leading through education, we knew that potential candidates would expect that the organization would have resources available to help them prepare for the ICE-CCP examination,” explains William M. Ellis, MS, RPh, ICE-CCP, former chair of both the ICE-CCP Steering Committee and NCCA and current chair of the Certification Services Council.
The committee approved a policy on impartiality related to education and training leading to certification as one of its first orders of business. Excerpts from this policy were included in the ICE-CCP Candidate Handbook:
I.C.E. produces comprehensive education and training materials for all levels of professionals who work in credentialing, including but not limited to the Certificate Program for the Credentialing Specialist. The I.C.E. Academy expects to offer additional resources for examination preparation for those candidates who wish to participate.
I.C.E. also develops and administers a certification program for credentialing professionals under the governance and oversight of the I.C.E. Certification Services Council (CSC). The CSC’s role in developing and administering certification examinations is to determine if candidates for certification meet the established qualifications and standards. The CSC does not require, provide, approve, accredit, recommend or endorse any specific educational programs, courses, study guides, review materials or other examination preparation products.
The Impartiality Related to Education and Training Leading to Certification Policy further specifies, “I.C.E. staff who develop and produce educational content and programs do not work on the certification program and have no access to certification items, examinations or information about the examination content that is not publicly available. Individuals who develop education and training content and/or deliver examination preparation content and/or related products have access only to publicly available examination information, such as the weighted examination content outline . . . all SMEs and staff involved with the I.C.E. Certification Program shall sign and adhere to conflict of interest and non-disclosure/confidentiality agreements.”
Because delivery of educational resources could not begin until the Examination Content Outline was finalized, the 150+ candidates who signed up for the ICE-CCP beta exam in November 2021 did not have specific certification preparation resources to utilize. A reading list of recommended texts was included in the candidate handbook, and some candidates chose to enroll in or review their material from the Certificate Program for the Credentialing Specialist.
Others relied primarily on their hands-on experience, especially if it spanned all three domains covered on the exam. Norah Duffy, CAE, ICE-CCP explains, “Serving as the director of certification for five multi-level certification programs for the past five years has provided me with important job experiences related to governance, program operations, and assessment development and validation topics. I had previously completed the I.C.E. Certificate Program for the Credentialing Specialists and found that the content aligned closely with the exam and that I needed very little additional preparation.”
But feedback received on the post-exam survey, as well as from potential candidates, indicated that many were looking for more targeted resources to help them prepare. To provide these resources, I.C.E.’s Senior Manager of Education Katie Scott, CAE, worked with four SMEs who were not involved in exam development to create the ICE-CCP Self-Study Guide. The guide was released in time for the fall 2022 testing window and served as material for a pre-conference session at the 2022 I.C.E. Exchange.
The SME team is currently working on a more in-depth program to be delivered virtually in a workshop format, which will be piloted in March 2023, in time for the spring 2023 testing window. As with the self-study guide, all marketing materials will clearly state that the purchase of any preparation materials is an optional decision on the part of the candidate.
“Our candidates are experts in the credentialing field, so we certainly want to uphold the highest standards of integrity in both preparing and testing for the ICE-CCP,” states Ellis.
How Others Handle It
There is more than one way to meet the needs of candidates while complying with the requirements of Standard 3.
The Dental Assisting National Board (DANB) established a separate organization dedicated to education and research, the Dental Advancement through Learning and Education Foundation (the DALE Foundation). The DALE Foundation offers exam preparation resources and other educational materials to help dental professionals prepare for DANB exams and advance their careers.
While it is not necessary to develop education through a separately incorporated entity, it does clearly show that there is a firewall between exam preparation and exams, as they are separately governed. DANB’s Certified Dental Assistant and Certified Orthodontic Assistant certification programs have been NCCA accredited for 25+ years and held ISO 17024 accreditation through International Accreditation Services for six years.
The American Council on Exercise (ACE), which is celebrating 20 years of NCCA accreditation in 2023 and just attained dual accreditation to ISO/IEC 17024, offers optional exam preparatory materials and online courses to candidates for ACE certification exams. ACE maintains its firewall between all ACE certification functions and any preparatory education development and delivery by creating clear separation between the departments responsible for each. The ACE Credentialing Department is responsible for and has autonomy in its oversight and execution of all ACE certification functions, while the ACE Product Development Department is responsible for creating and delivering preparatory education. These departments have different senior leaders, do not share staff and do not contribute to each other’s work. The Product Development Department only has access to the publicly available exam content outlines for ACE certifications to guide their development of preparatory education.
ACE extends its firewall to its SMEs serving on certification committees and contributing to test development as well. To participate on an ACE certification committee, SMEs must have no involvement with ACE or any other organization or institution for the development or delivery of preparatory education for the certification. Before the Product Development Department creates any new exam preparatory education, they ensure that their prospective SMEs are not involved in any certification committee or test development work for the certification program. These steps help maintain a separation between all certification and exam preparation functions and meet the accreditation requirements of both the NCCA and ISO 17024 Standards.
In addition to I.C.E., a number of credentialing organizations have determined that they have an obligation to ensure that there is quality education in the marketplace available for their candidates. As long as this is carefully managed to assure autonomy and impartiality, it need not pose a conflict with accreditation standards.
*See “I.C.E. Launches Certification Program for the Credentialing Professional” for a history of the development of the ICE-CCP program.