STANDARDS | LIBRARY
Standards Review Process Policy
How concerns about a member church are raised, reviewed, and resolved. Includes the required reporting language every member community shares with its congregation, and a plain statement of what the process can and cannot do.
Introduction
The Sacred Plant Alliance (SPA) is a self-regulating professional association of religious communities engaging in ceremonial practices with sacred substances, which are central to the exercise of our religious beliefs. SPA is dedicated to the advancement of ethical and safety-oriented standards for ceremonial use of sacred substances and the legal affirmation of such practices within the United States.
In accordance with this mission, SPA member organizations are reverently committed to the principles of collective responsibility and mutual accountability. Religious community leadership is inseparable from ethical responsibility. Leaders of SPA member organizations may facilitate ceremonies that invite participants into non-ordinary states of consciousness, during which participants may be especially vulnerable. Therefore, when a participant chooses to engage in ceremonial work with the guidance and accompaniment of a SPA member organization, all parties take on a special level of responsibility.
This responsibility is expressed through, but not limited to, the commitments that SPA Members make in accordance with SPA’s collectively developed Member Standards, including the Code of Ethics and Standards of Conduct.
SPA Members further commit to peer review and accountability should any question arise regarding how these commitments are understood or enacted. If anyone has reason to believe that the organization or its leadership were not following SPA Member Standards, and the SPA member organization’s internal efforts cannot remedy that situation, SPA will receive their report and engage a process that supports, to the extent possible, resolution, repair, restoration, and learning. SPA strives to be of service and to protect all participants, communities, plants, and ethical and responsible practices with substances touched by SPA’s work.
This Policy details the process by which member organizations may be reviewed for violations of SPA Member Standards and related SPA Policies, e.g. Membership Agreement and Membership Policy.
Attribution and Responsible Use
SPA encourages organizations and individuals to learn from, adapt, and build upon these standards. Anyone who incorporates, adapts, reproduces, or develops materials based on this document is asked to acknowledge Sacred Plant Alliance as a source. Attribution does not imply SPA’s endorsement, certification, approval, or affiliation unless SPA has expressly provided written authorization.
Explore the Sections
I. Definitions
The following are the definitions of terms used in the Standards Review Process Policy (the “Policy”).
Authorized Representatives: An individual who has been formally designated by a Member’s Leaders to represent the Member in SPA-related matters.
Complainant: A person who makes a Report about a SPA Member, which may include a Leader, and desires to and agrees to participate in an Formal Review.
Determination: The Review Subcommittee’s formal conclusion regarding the issues raised in the Report, which specifies which issues were or were not found to have violated the SPA Standards of Conduct and/or require a Resolution that is within the Scope of Review.
Ethics Committee: The SPA Committee responsible for collaboratively establishing, discussing, and promoting ethical practices and Standards of Conduct amongst SPA Members through policies, education, and peer support.
Formal Action: Official institutional responses taken in response to a Determination, which are delineated further in the Formal Actions section of this document.
Follow Up Process: After the Formal Review has closed, any recommended or required remediation or accountability process for the Respondent which is overseen by the SRC.
Standards Review Process: Process by which the Standards Review Committee evaluates Reports, engages in Formal Reviews, and makes Determinations and Recommendations for remediation of issues within the Scope of Review. The Standards Review Process is further specified in this document.
Initial Review: Upon receipt of a Report, the Standards Review Committee will review the Report, determine if the Report is within the Scope of Review, follow up with the SPA Member if necessary for additional facts, and then decide whether an Formal Review is appropriate.
Formal Review: A formal Formal Review of the facts and circumstances surrounding a Report, leading to a Determination. An Formal Review includes interviews and review of materials, and such Formal Review results in a Determination and potentially Recommendations for remediation to a SPA Member.
Leaders: Individuals associated with a SPA community who, within an organization’s beliefs, practices, and hierarchical structure, may have religious authority and/or facilitate ceremonial work or otherwise lead the community in a corporate or hierarchical sense.
Serious Reportable Issue: A serious issue in connection with the operation of the Church, as fully defined in the SPA Membership Agreement.
SPA Member: The religious organization itself which is granted membership in SPA. The organization may consist of both adherents and Leaders who have been approved for membership and are collectively a SPA Member.
Standards Review Committee: The SPA Committee responsible for receiving reports of adverse events or alleged misconduct and following up with the Standards Review Process as necessary.
Point Person: The member of the Standards Review Committee assigned to the Complainant as their primary point of contact on the Committee.
Recommendations: If deemed appropriate, the Standards Review Committee may issue detailed formal recommendations for remediating issues specified in the Determination. Typically this is part of the Follow Up Process.
Report: An account of any potential or alleged violations of the SPA Standards of Conduct, made to SPA’s Standards Review Committee through its Reporting Mechanisms.
Reporting Form: The form made available to all community members of SPA Members, by which they can make a Report to the Standards Review Committee.
Reporting Mechanisms: A manner to communicate a Report to the Standards Review Committee, including the Reporting Form or to a Standards Review Committee member via phone or email.
Resolution: Forms of repair or other processes required as a result of a Determination or Recommendations.
Respondent: The SPA Member that is the subject of a Report or Formal Review
Standards Review Committee (SRC): The SPA Committee responsible for receiving, responding to, and investigating reports. The Standards Review Committee works in cooperation with the Ethics Committee and with the authority of the SPA Board of Directors. Members are appointed by the Chair of the Ethics Committee, who is appointed by the Board to a 2-year term.
Standards Review Process (SRP): The process by which the Standards Review Committee responds to Reports; this includes the Initial Review, as well as any Formal Review, Determination, and Follow-Up Process deemed appropriate by the Standards Review Committee.
Scope of Review: Any concerns, issues, or violations of the SPA Policies that are intended and able to be addressed by the Standards Review Committee.
SPA Policies: SPA Membership Policy, SPA Standards of Conduct, and this SPA Standards Review Process Policy, as well as any other SPA policies or standards, each being standards by which SPA Members have agreed to abide by with respect to their community practices, including relationships within the community and ceremonies.
SRC Materials: Any written materials related to or resulting from a Standards Review Process.
II. Process Overview
This section offers framing for the Standards Review Process and information about its scope. A summary of the steps in the process and its timeline may be found in the appendices.
A. Standards Review Process Purpose
● The Standards Review Process (SRP) is the structure whereby SPA receives, investigates, and responds to reports about SPA Members from concerned parties about Standards of Conduct.
● The SRP has two functions:
To provide a mechanism for members of SPA Member communities to be heard in cases of harm by a SPA Member
To support the SPA Member in repair, establishing appropriate internal policies and procedures to reduce the likelihood of similar situations in the future, and making improvements for the safety and well-being of all congregants.
● The SRP is executed by the Standards Review Committee (SRC).
● The SPA Standards Review Process Policy is not intended to create a duty of care or make SPA in any way responsible for ensuring the safety of participants in ceremonies facilitated or other aspects of operation by SPA Members and Leaders. SPA recommends that any complainant consider all legal options available to them for redressing the incident and any related statute of limitations by speaking to an attorney.
● The SRP is not a legal proceeding aimed at determining innocence or guilt, or civil liability or equitable relief; but rather, a method for supporting SPA Members in making improvements to better serve their communities. It also serves to assess a SPA Member’s eligibility to continue their SPA Membership in cases of severe violations of SPA Standards of Conduct.
B. Scope of Review
● It is within the scope of the SRC to evaluate and address:
Breaches of SPA’s Member Standards, including Code of Ethics and Standards of Conduct, where there has been serious harm, or it can be reasonably anticipated that serious harm may occur.
“Serious harm” means that it causes an individual severe, ongoing, and/or persistent pain or impairment.
Other alleged breaches of SPA Membership Policy or Membership Agreement
● Scope of Review does not include a Member’s day-to-day operations that are not specified in the Member Standards(e.g., employment disputes, interpersonal conflict, organizational structures) or issues that arise between community members of a SPA Member.
● Scope of Review does not include any issues related to organizations or leaders that are not SPA Members.
If the SRC receives a report about an organization or individual who is not a SPA Member or Leader, they should refer complainants to other associations if the SRC has reason to believe that they belong to another association. Otherwise, the SRC will determine whether and what type of response is warranted, on a case-by-case basis.
Complaints about non-SPA organizations will be tracked for the purposes of Membership and community safety. These prior Reports will be reviewed by the SPA Membership Committee as part of the process for reviewing new applicants to SPA.
● The Scope of Review is not limited to ethical issues that happen in a ceremony. SPA Members are expected to uphold the Standards of Conduct in all areas of their operations.
● The Scope of Review is not limited to issues brought forth in a Report. The SRC may initiate an Investigation based on information learned through the peer review process, informal communication, or any other means, or at its discretion even in the absence of cause for concern. For example, the SRC is empowered to initiate routine Reviews for the purposes of complaint prevention or quality assurance.
● In its oversight of the SRC, the Board reserves the right on a case-by-case basis to address issues beyond those specifically enumerated in SPA Member Standards, Membership Agreement, or Membership Policy, and which may indicate that church practices or a Leader may pose a danger to their community (e.g., if a Leader was convicted of murder, but murder is not explicitly named as a SPA violation).
C. SPA Member Commitments
● SPA Members and their Leaders are committed to cooperate with a Standards Review Process in the spirit of openness and mutuality and in a way that is consistent with their position as mature community leaders.
● SPA Members acknowledge that the Review Process may require difficult conversations, such as potentially being confronted with accusations, and not all parties may be able to operate amicably.
● SPA Members and Leaders should extend to each other the benefit of the doubt that each is acting in good faith throughout the process.
III. Committee Structure
A. Ethics and Standards Review Committee Structures
● The Ethics Committee (EC) is responsible for:
Promoting accountability and ethical standards amongst SPA Membership, for example, through developing trainings or other resources
Administering the annual peer review process
Occasional revisions of the Standards of Conduct and Standards Review Process Policy. These revisions must be approved by SPA Membership and the Board.
Defining term limits, procedures for SRC membership changes, and other procedural matters for the EC. Changes to existing procedures will be formalized by the SPA Board.
● The SRC is responsible for:
Receiving, responding to, and investigating reports according to the process defined in the Standards Review Process Policy.
Reporting to the SPA Board of Directors regarding current reports and Formal Reviews
Summarizing reporting statistics and any actions taken during the year for the EC and SPA Membership at large, as appropriate
● The EC Chair will be appointed by the SPA Board of Directors to a 2-year term. There are no term limits.
● Any Leader of a SPA Member may request to join the EC. When someone joins the EC, the EC Chair should check that there are no outstanding reports about them. A Leader may not serve on the EC until any and all outstanding Reports about them have been investigated and resolved.
● The SRC will be led by the EC Chair. The EC Chair will appoint the other members of the SRC.
● The SRC will be created with a total of at least three seats.
A majority of seats must be filled by Leaders or Authorized Representatives. The others may be SPA staff or Board members.
Among SRC members, there must be representatives of, at minimum, two different communities and more than one gender.
There are no term limits or limits on the number of Committee members.
● Before assuming their responsibilities, EC and SRC members should be advised that ethics work can be emotionally difficult and time-consuming. They should also be clear on all the confidentiality requirements they will be required to follow.
● Individuals serving on the EC and the SRC may be volunteers or paid, as arranged by the EC Chair (with consultation of the SPA Board of Directors, as needed).
● In the case of a conflict of interest, where a report has been made about a SPA Member that an SRC member is or has been part of or has a familial relationship with Leaders of such SPA Member, the EC Chair shall select a member of the Board of Directors, SPA Staff, or Leader to replace the conflicted party for the subsequent SRP. Where the EC Chair is the conflicted member, the Board of Directors will select such person. A conflicted member of SRC will immediately identify such conflict and recuse themselves from the SRP, including communications and any decision required, and will be removed from the SRC email group and SRC documents for the duration of the SRP.
IV. Confidentiality and Recordkeeping Guidelines
A. Confidentiality
● The SRC should keep all details of the SRP confidential except where authorized by this Policy or otherwise allowable by law. This includes, without limitation, disclosures necessary to comply with external reporting obligations, responding to lawful subpoenas or court orders, cooperating with governmental or regulatory investigations, obtaining legal counsel, or address credible threats to health or safety.This includes but is not limited to reports, witness accounts, and any other information received in the course of their service to the SRC.
When speaking to anyone outside the SRC, SRC Members may choose to change identifying details of a case to keep the identity of a Complainant, survivor or others involved, confidential. This will only be done when, in the SRC’s estimation, it is necessary to prevent serious harm from occurring or to protect the privacy rights of the various individuals involved.
● A Respondent is asked to keep the Report and identifying details of the Complainant confidential during the Formal Review, except from other Church Leaders, legal counsel, and parties involved in supporting them in the review process, e.g. their mentors.
● A Complainant is asked to either refrain from speaking publicly about the pending case or sign a Waiver of Confidentiality that lifts the burden of confidentiality from the Respondent.
In the case where there may be multiple Complainants or Witnesses coordinating with each other, the SRC does not expect them to keep information confidential from each other. However the SRC should keep separate communication streams with each Complainant or Witness.
B. Limits of Confidentiality
a. General Limits of Confidentiality
● The SRC should clearly communicate with Complainants and Respondents around the limits of confidentiality.
● Despite best efforts and adherence to the Policy’s protocols for confidentiality, the SRC and SPA cannot guarantee confidentiality of any information they receive.
● The SRC may make exceptions to Confidentiality in the following cases:
Any information shared may be disclosed to the Respondent for purposes of resolution and improvement, although the SRC will attempt to limit this information to the minimum necessary amount. The Respondent may be permitted to share information with others in Church leadership for the purposes of resolution and improvement.
All information received by a member of the SRC may and should be shared with all other members of the SRC. Future members of the SRC may also receive information about cases according to the Recordkeeping Policy detailed below.
The SRC may share detailed information about the case with the SPA Board.
The SRC may share broad information about Reports received with SPA Membership (e.g. existence of the report, types of violations, number of reports received, etc.) for education or for the purpose of evaluating SPA systems.
The SRC may report occasionally to the wider community about the situations it has encountered. Such discussion is for the purpose of ethics education and will not include names or other identifying details about Complainants when feasible.
The SRC should make reports to government agencies as required by law. Additionally they may make reports to authorities in cases where there is egregious and seriously harmful activity or imminent threat. See section (b) on External Reporting for more information.
The SRC may release information about a case publicly in a Public Notice, if it is deemed necessary for public safety. In this case they will often choose to anonymize details but cannot guarantee it. See Section VII(B)9 for additional information.
The SRC may be required to release information in the event of legal processes like subpoenas.
● Additionally, Complainants should be aware that SPA may not consider all Determinations to be confidential documents and cannot control whether and with whom these documents are shared. Determinations will be written in a way that takes into account possible harms if they were made public. Determinations should include a request that all parties exercise discretion when choosing where to share them, and a note that they are intended for internal use of the church.
b. External Reporting
● The SRC should make external reports to government agencies according to the same standards as other professionals governed by mandatory reporting laws for the applicable jurisdiction.
● In particular, written and verbal reports of physical, sexual, mental or emotional abuse of a minor, elderly person, or dependent adult, including only suspicions, should be reported immediately to external parties, like enforcement agencies.
● Reporting is also required if there is a serious threat to harm an identifiable potential victim, including oneself or another, or when required by a court order.
● External reporting should be done through the chair of the EC.
C. Recordkeeping
● SRC Materials must be securely maintained and solely accessible by the SRC.
● The SRC will maintain a database of SRC Materials. This database’s version history should be regularly audited for security and tampering (at least annually).
● The SRC should keep careful records related to every Report, Initial Review, and Formal Review.
Keep a master “Timeline Doc” that logs every phone call and email before, during, and after a Review, including anonymous ones.
Include all known details about contact history, dates of potential violation, how to reach Complainant(s), and the nature of the alleged violation.
Note: Even if a Complainant does not submit a written Report, the information they provided may become relevant later, for example, if another Report is brought against the same practitioner.
● If cases are discussed via email, the SRC should not use names of the Complainant or Respondent in the email. Instead, they should use terms like “Practitioner X” or “Respondent 1.”
● SPA records may be subpoenaed if there is a court order. If this occurs, please engage SPA legal counsel, who will give guidance on how and whether to share documents outside of the SRC.
● The SRC will retain SRC Materials as follows:
The SRC will retain records of Final Determinations and Recommendations indefinitely. These materials will be accessible to future members of the SRC.
The SRC will delete all other records related to a closed case at the end of their term.
For open cases, detailed case materials will be retained through an SRC term change to ensure continuity in the Investigation.
Reports that are not about SPA Members are kept indefinitely for the purposes of member screening.
V. No Retaliation Policy
Retaliation is prohibited by the SPA Standards of Conduct. SPA maintains a No Retaliation policy towards all complainants, regardless of the outcome of their Report. Retaliation is in general defined as any kind of negative action that takes the form of punishment as a result of their Report. Any SPA Member or Leader who is found to have committed retaliation on a Complainant will be further subject to the formal SPA Ethics process.
VI. Standards Review Process
A. Allowance for Necessary Procedural Adjustments
● During the SRP, SRC members should make best-effort attempts at availability, balancing needs of a swift but deliberate process, which is summarized in Appendix B.
● The SRC or SPA Board may adjust the timelines of the process at their discretion, particularly to allow for the potentially circuitous nature of an ethical review process. If they receive additional information at any stage, which may substantially alter the outcome, they may adjust the process to allow for additional information gathering.
● In scheduling meetings, the SRC should respond quickly to logistics emails and offer several options for meeting times in a given period, balancing accommodation with their other commitments. If there is a delay that impacts third-parties, they must be notified.
● The SRC is authorized to make minor alterations to this procedure as they deem necessary for the immediate wellbeing or safety of anyone party to a Report. However, they are expected to notify the Board as soon as possible of any significant deviations. Major changes to the SRP are expected to go through the normal approvals process.
B. Reporting Mechanisms; Receiving a Report
1. Creation of Reports
● Anyone may make a Report about a Church.
● Self reports may also be made by Church leadership. Self reports are required for Serious Reportable Issues. Serious Reportable Issues are fully defined in the SPA Membership Agreement.
The purpose of this disclosure is to promote self-reflection and accountability on the part of the Member and allow SPA to offer support or guidance. In general, the SRC’s response to a self-report will be to offer the church support and guidance in navigating the issue. The SRC will also follow up about the outcome and may invite the church to share any lessons learned with the broader SPA community.
At their discretion, the SRC may initiate an Investigation, including reaching out to potential harmed parties, and take Formal Actions in response to a self-report. The aim should still be on repair and improvement rather than punishment.
If there is ambiguity about whether something constitutes a Serious Reportable Issue, the Member is encouraged to reach out to a member of the Standards Review Process Committee for guidance on whether to report.
Reports should be submitted as promptly as possible, and generally within thirty (30) days of becoming aware of the Serious Reportable Issue.
2. Receiving a Report
● Reports may be made to SRC members via phone, Signal, direct email, a form created for this purpose, or any other channel of communication. See Section VI(B)3 on Reporting Mechanisms.
● SRC members should direct Complainants to official channels as soon as it is possible to do so without discouraging the Report.
It is important to be inviting, sensitive, and patient with complainants when they call, leaving the door open for further discussions.
During any initial contact, the SRC member shall, following their own discretion, speak with the potential complainant, provide them information on the SRP, and, as appropriate, provide them information on resources that the Complainant may find supportive.
● Any information shared with an SRC member is considered a Report if the individual making the report understands the SRC member to be receiving information in their capacity as a SRC member. A Report does not necessarily trigger an Formal Review: this is at the discretion of the SRC, taking into account the wishes of the Complainant.
○ If there may be ambiguity about whether a Complainant intends to share information with the SRC member as such, it is the responsibility of the SRC member to clarify as soon as possible.
● While Reports can be made anonymously—and these should not be discouraged —in order for a Report to trigger an Formal Review, it must be in writing and non-anonymous.
The committee may take anonymously reported information into consideration and inclusion as part of an Formal Review.
If the SRC is concerned by the anonymously or verbally reported information, they may at their discretion seek more information.
● Note that witnesses and other third parties may file a Report and therefore serve as a Complainant. A Report does not need to be directly from a harmed party, though they may be contacted as part of the SRC follow-up process.
3. Reporting Mechanisms
● The SRC will create mechanisms for receiving Reports, including by email to ethics@sacredplantalliance.org and the Standards Review Reporting Form. The form should be configured to send email notifications of Reports to SRC members via email.
● The Standards Review Reporting Form should include the following information in its header.
What steps are involved in the SRP.
Approximate timeline and possible outcomes of the SRP.
Recommendation that any complainant consider all legal options available to them and any related statute of limitations by speaking to an attorney. The SRC should advise the Complainant that SPA will not file a legal action on their behalf (unless compelled by law).
Expectation that they will be assigned a Point Person from the SRC, who will follow up personally within 10 business days.
Expectations around confidentiality
● All members of the SRC will monitor the Reporting Mechanisms.
● These Reporting Mechanisms may be made publicly available, e.g. on the SPA website.
● SPA Members must include the following statement in public communications about events:
“This community is a member of the Sacred Plant Alliance (SPA), a self-regulating association of churches that is dedicated to accountability and transparency in sacramental communities. When ethical concerns or adverse experiences occur, SPA strongly recommends first attempting to resolve the matter within your community with the resources available. However, if you feel the need to report a serious problem, or seek help from outside the community to resolve a challenging situation, you may make a report of an ethical concern, violation, or serious adverse event to SPA with this online form or this email: ethics@sacredplantalliance.org. The SPA Standards Review Process Policy is not intended to create a duty of care or make SPA in any way responsible for ensuring the safety of participants in ceremonies facilitated or other aspects of operation by SPA Members and Leaders.”
B. Initial Review
● When a written Report is received (by email or reporting form), the SRC engages an Initial Review. The purpose of this stage is to:
Determine whether the Report falls within the Scope of Review
Engage in basic fact-finding
Decide if the Report should trigger a formal SRP
● The SRC creates a Timeline document for the case, where all contact with parties to the case is recorded.
● A single Point Person may be assigned to the Complainant and the Respondent. Ideally the Complainant and Respondent should have separate Point Persons.
● All Reports should receive an immediate template response from a member of the SRC which includes the following information:
What steps are involved in the SRP.
Approximate timeline and possible outcomes of the SRP.
Recommendation that any complainant consider all legal options available to them and any related statute of limitations by speaking to an attorney. The SRC should advise the Complainant that SPA will not file a legal action on their behalf (unless compelled by law).
Expectation that they will be assigned a Point Person from the SRC, who will follow up personally within 10 business days.
Expectations around confidentiality
● The SRC will assign a Point Person to the Complainant. The Point Person will reach out to the Complainant within 10 business days with an invitation to schedule a Follow-Up Interview. They may include additional resources, at their discretion.
The Point Person will make every effort to schedule a follow-up interview with the Complainant within 30 days, however this will depend on availability of the complainant and representative.
Before this interview, the Complainant will receive information regarding the limits of confidentiality.The Complainant is also given a copy of SPA’s Standards Review Process Policy and offered the opportunity to ask questions about the next steps in the process.
During this interview, the Point Person:
Gathers more details around the facts of the Report
Asks the Complainant if they have any questions about the SRP
Explains to the Complainant the purpose of the SRP and the limits of SPA’s powers of resolution
Informs the Complainant that if a SRP is initiated, the SRC will instruct the Respondent not to contact the Complainant.
Informs the Complainant of SPA’s No Retaliation policy.
Asks the Complainant whether they would like to engage in the SRP.
Informs the Complainant on SPA’s Recordkeeping Policy, which states that the Initial Report will be deleted at the term change and future Committees will have no record of it if an Investigation is not initiated. If they change their mind, they would have to re-submit the Initial Report.
Asks the Complainant whether they have an ideal outcome to the SRP (but does not imply it is on them to find resolution)
Asks the Complainant if they consent to the disclosure of information to the Respondent.
Requests that the Complainant communicate with the Point Person or SRC via email for the duration of the Formal Review, unless a phone call is specifically scheduled.
If the Complainant does not want to participate in this Interview or a SRP, the SRC will determine appropriate steps to address the Report with the Respondent based on the applicable details and subject to confidentiality.
● The SRC debriefs after the interview within 30 days.
● The SRC may, at their discretion, choose to follow up with witnesses or the Respondent while deciding whether to proceed with the Formal Review.
A witness is any party who is not making a Report of their own, but may provide facts or perspective on the events that occurred which help the SRC contextualize the information they have received from either party
● The SRC determines whether to proceed with the formal SRP, based on the facts surrounding the Report.
The SRC may move forward with the SRP without Complainant involvement, particularly in cases of egregious harm, but should take steps to protect their confidentiality.
● It is possible that the SRC may receive multiple Reports about substantially related matters in a community. In this case, the SRC will conduct an Initial Review on each Report. As part of this Initial Review, they may decide to address additional Reports as parts of an ongoing Formal Review or to conduct separate Formal Reviews, as warranted by the circumstances and timeline of each Report.
In this case, the SRC will strive to interview each Complainant individually as part of the Initial Review. If they have already served as a witness in a related Formal Review, the SRC may decide that suffices to meet the SRP’s purpose of offering them a place to be heard.
If the SRC continues to receive Reports that are substantively related to Formal Review topics while the Formal Review is underway, they may opt not to address specific Reports if a Formal Review is already underway for substantively related topics.
C. Review
● A Complainant should never have to come in contact with or confront the Respondent.
● If the SRC decides to move forward with a Formal Review, the Complainant and Respondent will both be notified within 3 days.
The Complainant is notified that the process is underway and the Respondent will be notified.
Simultaneously, the Respondent is notified (ideally via a verbal conversation, e.g., a phone call) of the Formal Review. If they cannot be reached by phone, text or email is acceptable.
The Respondent is told to expect a formal letter within 15 days of this notice.
The Respondent is instructed to not contact the complainant and reminded of SPA’s No Retaliation policy.
The Respondent is asked to maintain confidentiality through the SRP subject to the Confidentiality section in this document. The SRC member may point out that it is to their advantage to not have the matter made public.
● The Respondent is given a formal notification letter from the SRC within 15 days from the notification phone call. This letter:
Details the nature of the issue. This is a summary of the Report written by the SRC; it is not the direct words of the Complainant.
Includes a copy of SPA’s Standards Review Process Policy
Includes information about what to expect next from the SRP
Includes any SPA policies related to confidentiality through the SRP
Schedules a Follow-Up Interview
● During the Respondent’s Follow-Up Interview, the SRP listens to their response to the Report and seeks to understand the facts from their perspective.
The SRC is a fact finding body and should ask questions of the Respondent to help elicit the facts and the Respondent’s view of what happened. The SRC should not confront the accused party in their testimony. Rather, the SRC should ask for clarification where needed.
Attorneys may attend an Interview, but cannot speak “as counsel.” An Interview is not an adversarial proceeding, and SPA will not have attorneys representing SPA in the hearing. Where this Formal Review is not a legal matter, SPA does not represent any application of attorney-client privilege.
● Particularly where the facts detailed by the parties do not align, the SRC may interview witnesses or other parties to the events for additional information.
● During the SRP, additional information may surface gradually throughout the process. Additional meetings may be necessary with either party or witnesses until the SRC feels confident that they have allowed each party to address any facts that are in dispute.
● If a Formal Review includes multiple Reports or Complainants, the SRC may adjust the process accordingly, for example, having a single Respondent Interview to allow response to multiple Reports.
● Respondents should have the opportunity to respond to all allegations and all evidence received by the SRC.
● The Review stage completes once the SRC believes new details received are unlikely to change the Determination on core issues raised.
D. Determinations
● After all interviews are complete, the SRC meets to discuss the case and arrive at Determinations. The SRC should seek to initiate their Determinations phase within six months of the receipt of the initial Report.
● Based on this meeting, the SRC prepares a Determinations document detailing:
the basic timeline of the case,
the alleged violations, and
the SRC’s findings as to whether the violations occurred.
● The Determinations document is due within 30 days of the Determination Meeting.
● The Determinations document will either outline SPA’s Recommendations, including which Formal Actions will be taken or note that a separate document will come within 30 days outlining the Recommendations and Formal Actions. (See Follow Up Section below.)
● When deciding upon Formal Actions, the SRC or the Board (see below) are encouraged to consult with SPA’s legal counsel to understand the implications of the Formal Actions being considered.
● When the Respondent does not admit to the allegations, the standard of proof for the SRC is the preponderance of the evidence (>50% certainty).
There may be “reasonable doubt” that a violation occurred, but if the evidence is 51% to 49% in favor of unsafe, harmful, or negligent, then the SRC must act on the matter on the presumption that it is inappropriate for the Member or Leader to continue without corrective actions.
● Within 30 days of the meeting to decide preliminary Determinations, the SRC meets again to vote on individual violations. This vote may happen over email if need be. Majority support of the SRC members is needed to find a violation occurred.
If a minority opinion was strongly in opposition to an issue, this can be stated in the Determinations.
● The SRC may also prepare a document of Internal Findings summarizing the complaints and additional details for SPA Board or internal use. The purpose of this document is to document SPA’s internal process and offer more context and detail for interpreting the Determinations, while protecting anonymity of all involved.
● Within a week of the SRC vote, the SRC shares with the Board:
The draft Determinations for review
Internal Findings Report (if applicable)
A suggestion for timing of the Board vote
Any other relevant context
● If the next regularly scheduled Board meeting is soon (within 30 days) the Board may wait until the next Board meeting to discuss and vote. Otherwise, they may call a special meeting with the SRC where they have the opportunity to learn more details and ask questions about the case and to vote.
The sections of Board meetings where Ethics cases are discussed should be closed.
● The Determinations are considered final once the Board votes to approve them.
● Within 3 days of the vote, the SRC notifies the Complainant that the Respondent will receive the Determinations the next day. Ideally, they are notified verbally by phone.
● The next day, the SRC sends them to the Respondent and, if applicable, the Complainant. In this email, the Respondent is also notified of their right to appeal, timeframe, and contact information for the Board.
● The final Determinations, or an edited version, may also be sent to the Complainant on a case-by-case basis. Complainants do not have a right to appeal.
● If the Respondent wishes to appeal the decision, they may contact the SPA Board directly. Their request for an appeal should be received by the Board within 15 days of the Determinations.
● If the Respondent appeals, the SPA Board will call a special, closed meeting to hear the Respondent directly and may choose to alter the Determinations based on this meeting. The Complainant should be notified of the appeal and also have the opportunity to speak directly to the Board. These meetings should be scheduled within 60 days of the appeal request.
The Respondent and Complainant should not be encouraged to interact directly. The Board should schedule separate meetings for the Respondent and Complainant.
When the Board hears an appeal, they receive all the notes and materials the SRC used in making its decision, and may request further information from both parties, if needed.
In cases of appeal, the Board may need additional training and ethics process education as determined by the SRC.
● After the Board meets with the Respondent and potentially, the Complainant, they meet to finalize the Determinations. They discuss any changes to the Determinations, if any, and vote on a finalized document. This should happen within 30 days of the Appeal Meeting, and may happen immediately following it.
● The next day, the Board sends a revised Determination letter to the Respondent. This decision is final.
● In such cases where a Respondent is no longer a SPA Member or requests no receipt of a Determination due to legal concerns that are reasonable and valid, the SRC may prepare Internal Findings for internal use.
● The Formal Review is considered complete when:
15 days have passed since the Respondent received the final Determinations, and they did not appeal, or
The Board issued a final Determination post-appeal.
VII. Follow Up Process
A. Follow Up Process
● If the Determinations found violations of the Standards of Conduct or other SPA Policies, the SRC will write a formal Recommendations letter taking Formal Actions based on the type of violation.
● The Recommendations will be shared in writing with the Respondent within 30 days of the Determinations, if they are not already stated in the Determinations.
● The SRC will take Formal Actions based on criteria such as, but not limited to, whether a violation was of omission vs. commission, the degree of intent, and the severity of an adverse outcome as a result of the violation.
● The Complainant will not receive notice of the Formal Actions or participate in the Follow Up Process.
● Certain Formal Actions may need to be approved by the Board, as detailed below.
● SPA may be nuanced, delineate between Leaders and their communities, and find flexible solutions in determining Formal Actions.
For instance, when a violation is isolated to the actions of a single Leader, SPA may utilize the organization’s fellow Leaders to facilitate rehabilitation, growth and development. However, in cases where violations are systemic and/or committed by multiple Leaders, the SRC may determine that outside oversight is necessary or consider whether to continue allowing SPA Membership.
● The SRC will follow up with the Respondent for a specified amount of time, determined on a case-by-case basis, to ensure accountability with the Formal Actions. This process will be specified in the Recommendations letter. Once the SRC has verified that the Formal Actions have been addressed, the case is officially closed. The SRC should strive for a Follow-Up Process that lasts no more than 6 months from the Recommendations letter, except in cases warranting Probation or Suspension.
B. Types of Formal Actions
● When the SRC has found violations, they may enact one or more of the following Formal Actions:
1. Counseling and Mediation
2. Private Advisory
3. Recommendation of Institutional Changes
4. Internal Statement
5. SPA Membership Statement
6. Probation
● The SRC may also enact the following Formal Actions, with Board approval:
7. Suspension, with conditions for reinstatement
8. Removal from SPA
9. Public Notice
The SRC is not limited to the Formal Actions listed here. They may think creatively about what Formal Actions may assist the organization or Leader in remediating issues.
1. Counseling and Mediation
Counseling and Mediation is primarily an extended remedial discussion between the Complainant and the Respondent, with facilitation by the SRC or another appropriate person(s). This response may be appropriate when the SRC determines that the violation led to minimal harm caused by easily correctable mistakes, such as innocent miscommunication. This response may also be appropriate even when it has been determined that no violation was committed, but the SRC believes that intentional reconciliation between the parties will be a learning experience for all, promoting harmony and personal growth.
Before recommending Counseling and Mediation, the SRC should check with the Complainant to find out if this response would be of interest to them. The SRC should not recommend Counseling and Mediation if the Complainant does not want to participate.
If the SRC cannot provide this, it would be the obligation of the Respondent to pay for it. The SRC shall take care not to recommend ongoing Counseling and Mediation sessions beyond which a Respondent can reasonably afford.
2. Private Advisory
Private Advisory may include training or counseling around the issues of violation for the SPA Member or Leader. Such training or counseling may occur in an individual or group setting.
When the SRC recommends Private Advisory, it is because a violation requires additional learning, training, and/or improvement of a SPA Member or Leader; this work may be performed by individuals within or outside of SPA. This does not bypass Counseling and Mediation between the parties, but is an additional step in cases where a Member or Leader made a significant error, lapse in judgment, or failed a competency that requires further SRC and Board intervention.
The Board may agree to use general SPA funds to pay for this, and/or the Board may deem the Respondent liable for some or all of these expenses.
3. Institutional Changes
The SRC may recommend specific internal policy, procedural, or personnel changes in direct response to issues raised during the Report.
4. Internal Statement
The SPA Member may be required to prepare a summary of the Determinations to share with their church community. In this case, the SRC will review and approve the text of the summarized Determinations before it is disseminated. The SPA Member may be encouraged or required to share this summary with other SPA Members as well, as detailed below.
5. SPA Membership Statement
Membership Statements are distributions of details about the Report and Formal Review to SPA Members. The SRC may ask the Respondent to communicate this to other SPA Members directly, or the SRC or Board may communicate with the Membership about the case.
Membership Statements should be mindfully communicated by the SRC or the Board so as not to shame Members or Leaders. The primary purposes are to be educational or to alert the Membership to matters of collective concern, such as explaining why a violation did not lead to a Removal or any potential impact to the collective’s public standing.
6. Probation
Probation is appropriate in the case of violations that are significant and systemic, but where the SRC believes the Member or Leader can be brought into good standing if they take corrective actions. The SRC specifies the conditions for return to good standing in the Recommendations, along with an expected timeframe.
The intention of probation is to allow time for the Member to implement the SRC’s Recommendations in a structured and overseen process. The probation process should complete within a reasonable timeframe, such as 6 months. The SRC oversees the probation process. At the end of the process, they must meet and determine that the conditions of probation were met before returning the member to good standing. If a member fails to meet the conditions of probation within a reasonable timeframe they may be suspended.
While a Member is on probation, their Leaders will not be able to serve on the SPA Board and they will not be able to vote in Board elections. They are still responsible for membership dues during this time and may continue to have access to other SPA resources.
Other terms of the probation may be determined by the SRC on a case-by-case basis, as appropriate given the nature of the violations.
7. Suspensions
Suspensions are appropriate in the case of violations that are severe, but where a long-term reconciliation is possible with a remediation process. Fundamentally, a Suspension means the Member or Leader must enter into an agreement about wrongs done and rehabilitation required with the Board. The Board oversees the Suspension and may appoint a small mentoring team of Board, SRC, and/or SPA Members to implement the process.
Suspensions have reinstatement terms that must be met; there is no guarantee of a reinstatement, but there are objective benchmarks that can be reached. Suspensions are for an indeterminate period of time, such as “for at least a year,” with any prohibitions of activity stated in the Recommendations.
Suspensions must be approved by the Board. When the Board has determined a Suspension is necessary, the Suspension is effective immediately while the Board determines terms of reinstatement. The Board will meet within 30 days to set these terms and communicate them to the Respondent within 15 days of their meeting.
If the Respondent wishes to enter into the reinstatement process, they must sign a letter that specifies the terms of the suspension and reinstatement. The mentoring team will meet with them two to four times a year to assist in the rehabilitation process and to rebuild trust. A lead mentor may be assigned to have more regular check-ins if the Board deems it supportive.
If the Member does not wish to engage in the remediation process they will be removed from SPA.
8. Removal
In this response, a Member of Leader is removed from affiliation with SPA. In order to recommend Removal, the SRC must determine that the Member or Leader is responsible for the alleged wrongdoing and is unlikely to repair and discontinue practices that endanger participants. Once removed, there is no path to reinstatement in SPA.
Further, Removal should be recommended if a Member or Leader is recommended for Suspension but refuses to agree to the terms of the reinstatement process.
For the sake of seeking membership consensus on difficult decisions, the Board may deem it necessary to call for a vote of all SPA Members to approve Removals.
Members will be removed according to the terms of the Membership Agreement.
9. Public Notice
Public Notices are distributions of information about the Report, Formal Review, and/or Formal Actions in SPA channels and/or to individuals, churches, or other institutions, depending on the nature of the offense.
When the SRC recommends a Public Notice, it is because a violation has risen to a level of seriousness and/or community awareness that demands a public response, and where other Formal Actions are insufficient to prevent future harm.
Public Notices are primarily necessitated when the question of public safety or public trust needs to be addressed. If a Member is Removed, the SRC and Board should strongly consider issuing a Public Notice.
The SRC may decide to anonymize some details, particularly in cases where there is legal risk or risk of retaliation to SPA, Complainants, or other parties. The focus of the Public Notice should be on public safety, public trust, and education, rather than the shaming of a Member or former Member.
When drafting a public notice, all efforts should be made to protect the privacy of Complainants, while still providing information necessary for public safety.
VIII. Subsequent to Review;
Further Grievances and Recourse
● Nothing in the above Report review and resolution process prohibits individuals from filing a grievance elsewhere, taking legal action, or seeking other means of mediation and resolution.
● We ask those who file a Report to engage in this process to notify the SRC when filing a state or accrediting board grievance, engaging a mediator, or taking legal action. Seeking other means of mediation or resolution may affect the process outlined here.
Appendix A: Framework Summary
By signing their Membership Agreement, SPA Members agree to follow the SPA Standards of Conduct, SPA Membership Policy, SPA Standards Review Process Policy, and other SPA Policies.
This Standards Review Process Policy specifies a process by which SPA Members may come under review for their compliance with the Standards of Conduct, Membership Policy, and Membership Agreement.
SPA Members and their Leaders commit to cooperate with a Standards Review Process (SRP) in the spirit of openness and mutuality and in a way that is consistent with their position as mature community leaders.
The SRP has two functions:
a. To provide a mechanism for members of SPA Member communities to be heard in cases of harm by a SPA Member.b. To support the SPA Member in repair related to harm done and establishing appropriate internal policies and procedures to reduce the likelihood of similar situations in the future.
The SRP is executed by the SPA Standards Review Committee, which is a subsidiary of the Board. The SRC Chair is appointed by the Board and is the same as the Ethics Committee Chair. The SRC Members are appointed by the SRC Chair. Any SPA Member Representative may serve on the Ethics Committee, which is responsible for internal ethics education and occasional revisions of this framework.
All SPA Members are required to make their community members aware of the SRP through specific language included in their regular internal communications (e.g., newsletters, member-facing website, intake forms and/or feedback forms).
The SRP is intended as an escalatory process. Communities should have internal processes for resolving conflict and addressing harm, and those should be enacted before a community member engages the SRP.
The SRP has a specific scope, which is specified elsewhere in this document.
The SRP is not a legal proceeding aimed at determining innocence or guilt, but rather, a method for supporting churches in making improvements to better serve their communities. It also serves to assess a church’s eligibility to continue their SPA Membership in cases of severe violations of SPA Policies.
There are several potential outcomes of an SRP, ranging from specific recommended changes to church procedures or counseling for Leaders to removal from SPA. These are also specified elsewhere in this document.
Members are encouraged to review this document in its entirety so they are clear about what their ethical and membership obligations are and how the SRP works.
Appendix B: Standards Review Process Summary and Timeline
This summary of the SRP is provided for the reader’s ease of reference. Please refer to Sections VI &VII for the definitive process.
Please note: These timelines are estimates. The SRC or SPA Board may adjust the timelines of the process at their discretion, particularly to allow for the potentially circuitous nature of an ethical review process.
Acknowledgments and History
Out of conversations with members and outside parties, the structure of the SPA ethics process emerged primarily as an adaptation of an ethics model of a rabbinical organization, the OHALAH Ethics Training and Information Booklet.
While SPA is deeply grateful for the offering of OHALAH’s ethics documents as the primary source material for this document, this was not done with any formal relationship with OHALAH, and should not be construed as OHALAH in any way recommending or endorsing SPA or SPA’s Standards Review Process Policy.