We intend that disagreements among students, faculty and administration be worked out by frank and respectful discussion, or by informal mediation via other faculty members. Failing this, student, faculty or administration grievances are heard through the program’s Grievance Mechanism.
A written complaint is required to initiate the Grievance Mechanism. All parties named in the grievance are required to participate in the process of resolution. Once a written complaint has been registered, the parties named in the complaint are notified by the Program Director. The parties exercise a mandatory one-week cooling-off period, during which time they do not work together. This keeps disagreements within the program and upholds client well being. The Grievance Mechanism is enacted at the end of the cooling-off period. Each party may bring an advocate/support person. The Grievance Mechanism is facilitated by two individuals who may be: members of the faculty; members of the administration; members of the Advisory Board, or; outside community members agreed upon by all parties. Neither of these individuals may be directly involved with the grievance issue(s) or participants. The Program Director may reassign a seat on the committee to either another faculty member, student, or staff member to ensure the philosophy and objectives of National Midwifery Institute are represented during the mediation process.
All parties present agree to uphold confidentiality of the proceedings. Parties are reminded that the nature of the Grievance Mechanism is educational and constructive, not punitive. The complaint is read aloud. A history of the grievance is reviewed, including all pertinent communications and attempts to reconcile differences prior to the written complaint. All parties present their statements, and the facilitators ask questions. The facilitators then work with the parties to reach resolution. If resolution cannot be reached, the facilitators will privately discuss the grievance and make a decision. The program’s Philosophy and Purpose Statement, MANA’s Values and Ethics Statement and, in the case of preceptor/student disagreement, their Informed Consent document and the Preceptor Agreement, shall provide the context for all decision making.
Outcomes are limited to the following:
Resolution is reached during the session and parties resume their work together;
Resolution is not reached and the facilitators make one or more of the following recommendations:
The facilitators will speak privately to each party and make another effort at reconciliation;
Professional outside mediation between parties is required;
Parties agree to disagree. In the case of student-faculty grievance, another instructor or precepting site for the student may be sought;
in the case of a seriously offensive incident, NMI may pursue further disciplinary action against any or all parties named in the grievance.
Pursuing disciplinary action is determined with a hearing involving the alleged violator, faculty members and may include the NMI Advisory Board. The outcome of all written complaints and resolutions shall be kept in a separate administration file. Copies of individual complaint records shall be included in the personal files of both parties. The details and outcome of all complaints shall remain confidential. Students will not be discriminated against as a consequence of making a complaint. If a faculty member refuses participation in the Grievance Mechanism, that member may be barred from future program participation.
In case of criminal activity, the student will be advised to file a complaint with the proper authorities. In case of harassment, the student will have the option of utilizing the Grievance Mechanism.
Discrimination Complaints Policy and Procedures
National Midwifery Institute is an equal opportunity employer and educational institution. There shall be no discrimination against any employee, applicant for employment or any student on any basis including actual or perceived sex, gender identity, race, color, marital status, ethnic origin, religion, age, sexual orientation, or disability. This non-discrimination policy applies to all educational policies and programs and to all terms and conditions of employment, which include (but are not limited to): recruitment, hiring, training, compensation, benefits, promotions, disciplinary actions and termination.
If a person (“complainant”) believes that they have been discriminated against, they may take any of the following actions if desired:
A complainant may choose to attempt informal resolution of complaints of discrimination prior to requesting formal assistance with a discrimination complaint, but is not required to do so. If the complainant feels comfortable, they may choose to inform (either verbally or in writing) the person(s) engaging in discriminatory conduct or communication that the behavior is offensive and must stop.
The complainant may request that NMI faculty and/or staff engage in informal actions such as counseling, support, advice, and/or facilitated communication between the complainant and respondent in order to resolve concerns and/or stop the behavior. A complainant or respondent may choose to discontinue efforts at informal resolution and a complainant may make a formal complaint as described below.
The complainant may choose at any time to initiate the program’s formal Grievance Mechanism (see above)
NMI recognizes that the complainant requesting a resolution may or may not wish to be identified. National Midwifery Institute makes every effort to accommodate complainants wishing to remain anonymous.
Formal Complaint Procedure
Any employee, applicant for employment or any student who believes that they have been a victim of discrimination who wishes to make a formal complaint, should submit their complaint immediately in writing by postal mail to: Program Co-Directors, National Midwifery Institute, PO Box 128 Bristol VT 05443. This initiates the program’s formal Grievance Mechanism.
Records of complaints are considered permanent records and are maintained in electronic format indefinitely.
Relationship between Discrimination Complaint Procedures and Disciplinary Actions
Facts gathered and any findings made during the resolution process may be sufficient to obligate the school to take disciplinary action against a faculty member, staff member or student, or for the school to initiate a criminal investigation.
For violations which involve inappropriate behavior or actions, disciplinary actions may include: an oral warning, written warning, removal from public forums, suspension, dismissal from the program, or termination of employment. Pursuing disciplinary action is determined with a hearing involving the alleged violator, faculty members and may include the NMI Advisory Board.
If a criminal investigation is deemed necessary, a National Midwifery Institute co-director may notify the appropriate authorities. To whatever extent is permissible by law, those conducting a criminal investigation and NMI staff conducting a discrimination investigation on the case will agree to cooperate.
The initiation of a complaint by informal or formal procedure may not cause any reflection on the reporting party nor may it affect their future business dealings with the school, their employment, compensation or work assignments or, in the case of students, academic status, or other matters pertaining to their status as a student with the school.
National Midwifery Institute prohibits retaliation against reporting parties. The school acts vigorously to prevent any retaliation being taken against those initiating informal action or utilizing the program’s formal Grievance Mechanism; retaliation constitutes separate grounds for filing grievance.
Disciplinary actions may include: an oral warning, written warning, removal from public forums, suspension, dismissal from the program, or termination of employment. Pursuing disciplinary action is determined with a hearing involving the alleged violator, faculty members and may include the NMI Advisory Board.
MEAC Grievance Policy
MEAC encourages parties to pursue informal grievance mediation attempts with each other, or with MEAC staff or Board members, to attempt to resolve grievances informally before commencing a formal written complaint process with MEAC. If those attempts fail, MEAC will review complaints received against an institution or program if it is in writing and complies with the guidelines set forth in the Accreditation Handbook, Section G III(P):
Complaints against an Institution/Program
1. MEAC will review in a timely, fair and equitable manner any complaint it receives against an accredited institution or program in accordance with these procedures and will take follow-up action as appropriate based on the results of its review. MEAC encourages parties to pursue informal grievance mediation attempts with each other, or with MEAC staff or Board members, to attempt to resolve grievances informally before commencing a formal written complaint process with MEAC.
2. Contents of a complaint: The complaint shall be submitted in writing and dated by the Complainant and shall include:
a. A statement clearly identifying the submitted materials as a written complaint, and
b. identification of the accredited institution or program against which the complaint is being filed, and
c. a concise statement of the specific activities or conduct that constitute the basis of the complaint, and
d. an explanation of why such activities or conduct violate a specific MEAC standard, benchmark or policy (MEAC standards, benchmarks, and policies can be found at http://meacschools.org/wp-content/uploads/2013/10/2013-Section- B-Institition-Standards-v.2- Accreditation-Handbook.pdf), and
e. a description of the steps already taken to resolve the problem, and
f. a description of what Complainant requests of MEAC to resolve the grievance, and
g. the name and contact information for the person making the complaint or a statement indicating the complaint is being made anonymously. If the complaint is being made anonymously, MEAC still requires a mailing address so that requests for additional information can be made. Every effort will be made to keep the Complainant’s identity and mailing address confidential. If the written complaint does not contain the required information listed above, the MEAC Executive Director will notify the Complainant, and request additional information. The Complainant has 30 business days to respond with additional information; if additional information is not provided within 30 business days the complaint will be considered inactive, and MEAC will take no further action unless the Complainant submits the requested information and a letter requesting that the complaint review re-commence. The Executive Director will review the complaint information, including any additional information requested by MEAC, and determine if the complaint is within the scope of the MEAC standards or policies. If the Executive Director determines that the written complaint does not contain the required information listed above, the complaint is outside the scope of MEAC standards or policies, the MEAC Executive Director will notify the Complainant and the MEAC Board President and enclose a copy of this policy. If the written complaint is found to be within the scope of MEAC standards or policies, the following procedures will commence:
3. Process for handling complaints
a. Within 15 business days of receipt by the MEAC office of a written complaint that includes all of the required components, or submission of additional information by the Complainant as requested by MEAC to complete a complaint, a copy of the complaint and a letter requesting a response to the complaint will be forwarded via certified mail to the institution/program against which the complaint has been filed.
b. The Complainant will receive written notification from MEAC within 15 fifteen business days that the complaint has been received and processed for resolution.
c. The institution/program (the Respondent) will then have a maximum of 30 business days from the date of the letter from MEAC to respond to MEAC in writing to the complaint. MEAC will request the Respondent to provide documentation and/or evidence relevant to the complaint sufficient to permit evaluation of its merits.
d. Whenever a complaint indicates that the school may be in violation of accrediting standards or requirements, the matter may be forwarded to the MEAC Board of Directors for independent consideration or for consideration in conjunction with any other accreditation matter pending before the Board.
e. The MEAC President shall appoint a member of the Board of Directors who shall not have a conflict of interest nor shall have been directly involved in the circumstances giving rise to the complaint to serve as chairperson of an Investigative Committee (the “Investigative Committee”) to investigate the activities or conduct under complaint.
f. Should the MEAC President be named in the complaint, the Investigative Committee Chairperson will be appointed by an uninvolved member of the MEAC Executive Committee.
g. Within 30 business days, the Chairperson of the Investigative Committee shall appoint at least one additional member of the Investigative Committee who is a current or former member of the MEAC Board of Directors or a current or former Accreditation Review Committee Member, excluding any current or former members with conflicts of interest or who may have participated directly or indirectly in the complaint under review. A public member must participate in either the Investigative Committee or the Executive Committee, the body that will render the complaint review decision. Within ten business days of appointing the Investigative Committee members, the Chairperson of the Committee shall notify the Respondent of the names of the members of the Investigative Committee.
h. The Chairperson of the Investigative Committee shall notify the Complainant in writing that the Respondent has been advised of the nature of the complaint and that an investigation of the charge is pending in accordance with these procedures. The notification will include the address to which any additional information in support of the complaint may be sent and the deadline for the submission of any such additional material.
i. The Investigative Committee will review the documentation provided by the Complainant and the Respondent and create a report analyzing this documentation, including how each area of the complaint reflects compliance or non-compliance with MEAC standards, benchmarks, or policies by the Respondent. The report will also identify areas where the Respondent complied with MEAC standards, benchmarks, or policies. Where areas of inadequacy or weakness in policy, action or response by the Respondent occurred that require feedback and/or remediation, the Committee may make a recommendation for resolution of the complaint. This resolution may include:
i. a follow-up complaint report submitted by the Respondent addressing changes to inadequate areas or weaknesses identified in the investigation, or
ii. action regarding the accreditation or pre-accreditation status of the institution or program, including interim report(s), show cause action, or revocation of pre-accreditation or accreditation status.
j. The Investigative Committee shall complete the investigation within 90 business days after its formation or such other time as determined by the MEAC President. The MEAC President and the Investigative Committee Chairperson shall determine whether and for how long an extension of the 90 business-day timeline should be granted if the Respondent requests an extension of the deadline.
k. The Chairperson of the Investigative Committee shall send the Investigative Committee’s report and recommendations to the Executive Committee in advance of the Executive Committee’s next available scheduled meeting and present the Committee’s findings at that meeting.
l. The Executive Committee will consider the Investigative Committee’s recommendations and determine whether the Executive Committee requires any additional information to render a decision. If no further information is required, the Executive Committee will determine whether the complaint is valid, and if so, what actions are needed to achieve resolution. MEAC may request that the Respondent submit a follow-up report describing how Respondent will address inadequacies and weaknesses, or MEAC may take actions regarding the accreditation or pre-accreditation status of the institution or program, ranging from requiring Interim Report(s) to initiating a Show Cause Action to revoking pre- accreditation or accreditation status.
m. If more than half the Executive Committee has conflicts of interests with the complaint under review, then the consideration of the complaint will be considered by the full MEAC Board, excluding those with conflicts of interest.
4. Resolution of the complaint:
a. If the Executive Committee decides to require the Respondent to prepare a follow-up report addressing weaknesses or areas of inadequacy, the Respondent’s response will be considered by the Investigative Committee. The Investigative Committee will provide an analysis of the Respondent’s response and either make recommendations for further action or recommend that the complaint be declared resolved. The Executive Committee will consider the Investigative Committee’s analysis and recommendations and make the final decision on whether further action is required by the Respondent or if resolution of the complaint has been achieved.
b. If the Executive Committee decides to require an Interim Report(s) or initiate a Show Cause action in response to the complaint review, then these will be referred to an Accreditation Review Committee and will follow MEAC’s policies and procedures for Interim Reports and Show Cause Actions.
c. If the Executive Committee’s complaint review decision includes a mix of weaknesses or inadequacies and items requiring Interim Reports or a Show Cause Action, then all items will be referred to an Accreditation Review Committee and will follow MEAC’s policies and procedures for Interim Reports and Show Cause Actions.
d. The President or Executive Director will notify in writing the Complainant and Respondent of the findings of the complaint review and any decisions by the MEAC Executive Committee or Board regarding actions to be taken by the Respondent.
e. The Respondent may request an appeal hearing to dispute the findings or MEAC’s decision regarding actions to resolve the complaint. If the Respondent does not request a hearing within 30 business days from the date of the Complaint Findings letter, MEAC will consider the complaint review closed.
f. The Complainant may also request a hearing if the resolution has failed to satisfy the Complainant or if the Complainant wishes to pursue the matter further. If the Complainant does not communicate in writing to within 30 business days from the date of the Complaint Findings letter, MEAC will consider the complaint review closed.
g. If the Complainant and Respondent accept that the complaint review has been resolved, the MEAC Board President will provide written confirmation of closure to both parties.
h. A hearing in accordance with MEAC’s due process procedures will be arranged if further recourse is required and/or if the situation warrants such action.
i. The MEAC President shall present a synopsis of the processing and outcome of complaints and investigations to the MEAC Board at the next regularly scheduled Board meeting following final resolution.