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Student Healthcare Provider Conflict of Interest and Faculty/Program Leadership Healthcare Provision Policy Policy Title: Student Healthcare Provider Conflict of Interest and Faculty/Program Leadership Healthcare Provision Policy Program: Master of Science in Physician Assistant Studies
Effective Date: November 1, 2026 Last Reviewed: November 1, 2026 Review Cycle: Annually Responsible Office: PA Program Director Related ARC-PA Standard: A3.06
Related NLU Policies: Student Guidebook, Student Code of Conduct, Conflict of Interest policies, Student Health/Wellness policies, and applicable University privacy policies
1. Purpose
The National Louis University (NLU) Physician Assistant (PA) Program is committed to maintaining appropriate professional boundaries, avoiding conflicts of interest, protecting student privacy, and ensuring that students have access to healthcare providers who are independent of their academic evaluation and progression within the PA Program. The purpose of this policy is to ensure that the Program Director, Medical Director, and Principal Faculty do not participate as healthcare providers for students enrolled in the NLU PA Program , except when immediate emergency medical care is necessary.
This policy establishes a clear separation between:
• The educational and evaluative responsibilities of program leadership and faculty; and • The personal healthcare needs of PA students.
This separation protects students from actual or perceived conflicts of interest and supports confidential, objective, and professional relationships between students and program personnel.
The policy is established to meet ARC-PA Standard A3.06 . ARC-PA explicitly requires programs to prohibit the program director, medical director, and principal faculty from participating as healthcare providers for students, except in emergency situations.
2. Policy Statement
The NLU PA Program prohibits the Program Director, Medical Director, and Principal Faculty from serving as healthcare providers for students enrolled in the PA Program , except in an emergency situation where immediate care is necessary and no appropriate alternative provider is immediately available.
Program leadership and principal faculty may not:
• Establish an ongoing provider-patient relationship with an enrolled PA student; • Serve as the student's primary care provider; • Provide routine medical care to an enrolled student; • Provide behavioral health or mental health treatment to an enrolled student; • Prescribe medications for an enrolled student except as necessary during an emergency; • Provide routine medical evaluations or clearance for an enrolled student; • Serve as the student's treating healthcare provider; • Provide ongoing follow-up care to an enrolled student; • Provide confidential healthcare services to an enrolled student that could create a conflict with the individual's educational or evaluative role; or • Use their faculty or program leadership position to influence a student's selection of a healthcare provider.
This prohibition applies regardless of whether the healthcare service is provided:
On campus;
• • • • • • •
At an NLU facility; At a clinical affiliate; In a private practice;
During an SCPE;
During a program-sponsored activity; or
At another healthcare location.
3. Individuals Covered by This Policy
This policy applies specifically to:
A. Program Director
The NLU PA Program Director may not provide healthcare services to an enrolled PA student except in an emergency.
B. Medical Director
The NLU PA Medical Director may not provide healthcare services to an enrolled PA student except in an emergency.
C. Principal Faculty
All NLU PA Program Principal Faculty are prohibited from serving as healthcare providers for enrolled PA students except in an emergency.
D. Associate Medical Director
The Associate Medical Director is also expected to maintain appropriate professional boundaries and shall not serve as a student's healthcare provider when functioning in a program leadership or faculty role , except in an emergency. This requirement is intentionally broader than the minimum A3.06 requirement and supports the program's commitment to avoiding conflicts of interest involving individuals who participate in student education, assessment, clinical education, or program governance.
4. Separation of Educational and Healthcare Roles
The NLU PA Program recognizes that program leadership and faculty members may maintain clinical practices outside the University.
However, when a faculty member, Medical Director, Associate Medical Director, or Program Director encounters an NLU PA student who is also a patient, the individual's healthcare provider role must remain separate from their educational or program role .
Faculty and program leadership must not use information obtained through a healthcare relationship to influence:
Academic evaluation; Clinical evaluation;
• • • • • • • •
Professionalism assessment;
Promotion or progression decisions;
Remediation decisions; Academic standing; Graduation decisions; or
Other program-related decisions.
Likewise, information obtained through the educational relationship must not be used to provide or influence personal healthcare except when necessary to respond to an emergency.
5. Routine Healthcare Needs
Students requiring routine healthcare should obtain care from an appropriately qualified healthcare provider who is independent of the NLU PA Program's educational and evaluative structure . Students may access healthcare through appropriate University resources, community healthcare providers, health systems, primary care providers, behavioral health providers, specialists, urgent care centers, emergency departments, or other qualified healthcare professionals.
The Program will not require a student to obtain healthcare from a Program faculty member, Program Director, Medical Director, or Associate Medical Director.
6. Emergency Exception
The prohibition does not prevent a Program Director, Medical Director, Associate Medical Director, or Principal Faculty member from providing necessary emergency assistance when an immediate medical situation occurs and intervention is required to protect the student's health or safety.
Examples may include:
Cardiac arrest;
• • • • • • •
Severe allergic reaction;
Major trauma;
Syncope with injury;
Severe bleeding;
Acute respiratory distress;
Seizure;
• Other immediately life-threatening conditions.
In an emergency, the faculty member or program leader may provide appropriate emergency assistance within the individual's training and scope of practice until the student can be transferred to an appropriate independent healthcare provider or emergency medical service.
The emergency exception does not establish an ongoing provider-patient relationship .
Once the immediate emergency has been addressed, the student must be referred to an appropriate independent healthcare provider or emergency medical service for continuing care.
7. Emergency Incident Reporting
When the emergency exception is invoked, the incident should be documented through the University's established incident reporting process.
The NLU Incident Report Form is available at:
NLU Incident Report Form
Students or personnel needing assistance with completion of the form may contact the NLU Office of Student Affairs/appropriate University office identified on the reporting form.
The incident report should document the occurrence and actions taken without unnecessarily documenting confidential medical information beyond what is necessary for institutional safety, risk management, or required reporting.
8. Student Privacy and Confidentiality
The NLU PA Program recognizes that healthcare information is private and must be protected in accordance with applicable law and University policy.
Program personnel must not request or access a student's confidential medical information unless there is a legitimate educational, legal, safety, or administrative need to know.
A student's decision to seek healthcare outside the Program must not negatively affect:
Admission;
• • • • • • • •
Academic standing; Clinical placement;
Evaluation; Progression; Promotion; Graduation; or
Participation in the PA Program.
9. Disclosure of Potential Conflicts
If a Program Director, Medical Director, Associate Medical Director, or Principal Faculty member becomes aware that they are providing or have been asked to provide healthcare to an enrolled PA student, the individual should promptly disclose the potential conflict to the appropriate supervisor or University authority, while maintaining the student's privacy.
The faculty member or program leader should:
1. Decline or discontinue the non-emergency provider relationship; 2. Provide appropriate referral to an independent healthcare provider; 3. Avoid involvement in academic decisions that could reasonably create a conflict; 4. Maintain appropriate confidentiality; and 5. Document the conflict through the appropriate institutional process when required.
10. Clinical Practice by Program Faculty
The NLU PA Program recognizes that faculty members and program leadership may maintain clinical practice as part of their professional responsibilities.
Clinical practice does not create an exception to this policy.
A faculty member who encounters an NLU PA student in a clinical practice setting should not voluntarily assume responsibility for the student's routine healthcare solely because the individual is a PA Program faculty member or program leader.
When feasible, the student should be referred to another qualified healthcare provider.
If emergency circumstances require immediate intervention, the faculty member may provide emergency care consistent with the emergency exception described in this policy.
11. Student Responsibility
Students are encouraged to seek healthcare from providers who are independent of the NLU PA Program's educational and evaluative structure.
Students are not required to disclose personal healthcare information to the Program Director, Medical Director, Associate Medical Director, or Principal Faculty unless disclosure is required
by a separate University or Program policy, law, safety requirement, or clinical participation requirement.
Students who believe that this policy has been violated may report the concern through established NLU reporting and grievance mechanisms.
12. Reporting a Concern
A student who believes that a Program Director, Medical Director, Associate Medical Director, or Principal Faculty member has participated in providing healthcare outside an emergency situation may report the concern through the University's established reporting process.
The NLU Incident Report Form is available at:
NLU Incident Report Form
The form directs students to use the appropriate NLU process for concerns, including the Issues Resolution Form for complaints and the Academic Appeals Form for academic-related concerns.
Reports will be reviewed in accordance with applicable NLU policies and procedures.
13. Consistent Application
The policy applies consistently to all enrolled NLU PA students and to all individuals serving as:
Program Director; Medical Director;
• • • •
Associate Medical Director; or
Principal Faculty.
The prohibition is not dependent upon:
Student academic standing;
• • • • • •
Faculty rank;
Length of faculty service;
Student year in the curriculum;
Location of the healthcare encounter;
Clinical specialty;
• Whether the provider relationship is paid or unpaid; or • Whether the faculty member and student have an existing personal relationship.
The only exception is the provision of necessary emergency assistance as described in this policy.
14. Monitoring and Compliance
The PA Program will monitor compliance through:
Faculty orientation;
• • • • • • • • • •
Faculty policy acknowledgment; Program leadership orientation;
Student orientation;
Faculty handbook/policy dissemination;
Clinical education orientation;
Incident reporting;
Student concerns and complaints;
Annual policy review; and Program CQI processes.
Any identified violation will be reviewed by the appropriate University and/or Program authority and addressed according to applicable NLU policies.
15. Annual Review
This policy will be reviewed at least annually by the PA Program Faculty Organization and/or appropriate program governance body.
The annual review will consider:
Reported incidents; Student concerns; Faculty feedback;
• • • • • •
Program leadership feedback; Changes in ARC-PA Standards;
Changes in NLU policies;
• Applicable legal or regulatory requirements; and • Opportunities for improvement.
Approved revisions will be published through the NLU PA Program's established policy- distribution mechanisms.
16. ARC-PA Standard A3.06 Crosswalk ARC-PA A3.06 Requirement
NLU PA Program Policy Mechanism
Policy is included in the NLU PA Program's published policy resources Students and faculty can access the policy through program policy resources and student/faculty materials Applies to all enrolled PA students and covered program personnel
Program publishes policy
Policy is readily available
Consistently applied
Program Director prohibited from providing healthcare Medical Director prohibited from providing healthcare Principal Faculty prohibited from providing healthcare
Explicit prohibition except emergency
Explicit prohibition except emergency
Explicit prohibition except emergency
Emergency care permitted when necessary to protect student health/safety
Emergency exception
Requires separation between healthcare and educational/evaluative roles
Conflict-of-interest protection
NLU Incident Report Form and applicable NLU complaint/issue- resolution mechanisms
Reporting mechanism
Ongoing monitoring
Annual review, incident reporting, student concerns, and CQI
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