Policy Regarding Investigations and Violations

Reports of Potential Violations and Initiation of Investigations

PAEA may, in its sole discretion, initiate an investigation when it becomes aware of discrepancies in information submitted in CASPA or receives any information that indicates that an individual may have potentially committed fraud in the process of seeking admission to a CASPA-participating PA program or potentially violated any of the terms, conditions, or policies that apply to the use of CASPA. CASPA utilizes systems that detect potential discrepancies in information submitted by applicants and receives notification of potential violations from CASPA stakeholders, including but not limited to representatives of CASPA-participating PA programs.

If a PA program has reason to believe that an applicant may have potentially committed fraud in the process of seeking admission to any CASPA-participating PA program or potentially violated any of the terms, conditions, or policies that apply to the use of CASPA, a designated representative of the program should promptly send a written report of the potential violation to PAEA via email that includes all of the details of the matter to caspa@PAEAonline.org. When submitting the report of any potential violation, PA programs must include all relevant facts, dates, events, information, and documentation that relate to the potential violation. PA programs must report any potential violation to PAEA in writing as required in this policy within thirty (30) days of becoming aware of it.

PAEA reserves the right in its sole discretion not to initiate an investigation for a potential violation where a PA program’s report of the potential violation occurred more than thirty (30) calendar days after it became aware of the potential violation. PAEA also reserves the right in its sole discretion not to investigate any potential violation that occurred more than one calendar year prior to the date of the report made to PAEA, regardless of when a PA program may have become aware of the potential violation.

Investigations of Potential Violations

Once an investigation is initiated, PAEA reviews the potential violation and determines in its sole discretion whether it is more likely than not a violation has occurred, based on information submitted by the subject of the investigation, PAEA current and historical records, information provided by external parties, the terms, conditions, and policies that govern the use of CASPA, and any other available, relevant information.

Communication with the Subject of an Investigation

Once PAEA determines that it is more likely than not that a violation has occurred, PAEA will contact the subject of an investigation in order to:

• Notify the subject that an investigation has been initiated;
• Provide the subject with a summary of the matter being investigated;
• Inform the subject of the terms, conditions, policies, and procedures related to the investigation; and
• Provide the subject with an opportunity to respond.

Based upon the subject’s response, or failure to respond, the PAEA will either develop a draft of the Report to be issued to Legitimately Interested Parties, as defined below, or terminate the investigation in the event that the subject is able to provide evidence that no violation has occurred. If PAEA proceeds with the development of a draft Report, the draft Report will be sent to the subject in order to provide the subject with an opportunity to advise PAEA of any purported inaccuracies contained in the draft Report. If the subject identifies purported inaccuracies in the draft Report, PAEA will endeavor to resolve any disagreements it may have with the subject’s view of the evidence and facts. PAEA may also decide to simply include the subject’s objections to the Report in the final version of the Report if PAEA and the subject are unable to resolve their differences regarding the content of the Report. If the subject does not advise PAEA of any inaccuracies in the draft Report within the prescribed time period, PAEA will modify the Report to indicate that the subject did not raise any objections to the Report after being given an opportunity to do so, and PAEA will then finalize the Report in order to provide it to Legitimately Interested Parties. PAEA has the ultimate sole discretion to determine the findings of fact and content included in a Report in its final form.

PAEA prepares and issues a Report documenting the factual findings of the investigation and may include information provided by the subject of the investigation in accordance with the procedures outlined above. With the issuance of a Report, PAEA makes no judgment as to the culpability of any person with respect to matters reported and does not assess the suitability of an individual to study or practice as a PA. Rather, PAEA strives to communicate complete and accurate information to Legitimately Interested Parties. Evaluation of the accuracy of the information in the Report is the responsibility of the recipient of the Report.

In addition to the issuance of a Report, PAEA reserves the right to take all other lawful action warranted under the circumstances in relation to the subject of an investigation, in PAEA’s sole discretion, if PAEA determines that the subject violated the terms, conditions, and policies that govern the use of CASPA, or any applicable law or regulation.

Legitimately Interested Parties

Legitimately Interested Parties include all PA programs to which an individual has applied or matriculated during the current cycle and PA programs to which the individual applies or matriculates in the future. If, at the time of the investigation, the individual is enrolled in a CASPA-participating PA program, the Report in final form will be forwarded to the current institution of attendance and will be distributed in response to any future application or matriculation activity. The Report in final form will also be issued in response to an application or matriculation at such Legitimately Interested Parties of which PAEA has knowledge. Reports may contain information relevant to academic or disciplinary proceedings, criminal investigations, and decisions relevant to entry into PA programs and professional licensure. Duly constituted licensure and regulatory agencies and health professions educational institutions that make an official request to PAEA for a Report are considered Legitimately Interested Parties.

Arbitration for Disputes

Should an individual conclude that a draft Report unfairly characterizes the evidence and findings of fact related to an investigation or an agreement between parties on the content and language of the Report cannot be reached, the PAEA offers the individual who is the subject of the Report an opportunity to request arbitration. Such arbitration must be requested prior to the issuance of a final Report. Arbitration is conducted by a single arbitrator appointed by the Washington, D.C. office of JAMS. The arbitrator acts solely on the basis of a written record submitted by both parties, and no hearing or oral arguments are held. The sole issue for arbitration shall be whether the PAEA acted reasonably and in good faith in preparing the Report. The arbitrator will have final authority to conclude whether: (1) the Report should be distributed as written; or (2) the Report should be modified in accordance with the arbitrator's directions before distribution; or (3) no Report should be distributed. In addition, the arbitrator determines which party is responsible for JAMS' case management fees and the arbitrator's fee. All other costs associated with arbitration (for example, attorneys' fees) are borne by the party incurring them.