11

Jun

HEALTHCARE ACCREDITATION: THE UNRESOLVED CONFLICT OF INTEREST

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Anil Jauhri

New Delhi | Thursday | June 11, 2026

My first encounter with healthcare accreditation came in late 2005 when, as head of management systems certification at BIS, I learned of the establishment of the National Accreditation Board for Hospitals and Healthcare Providers (NABH) within the Quality Council of India (QCI) and the launch of India's first hospital accreditation standard.
The concept intrigued me. In the ISO world, accreditation is understood as an attestation of competence of conformity assessment bodies such as testing laboratories, inspection bodies and certification bodies. Healthcare accreditation appeared to be something different.
Soon after, in January 2006, I joined QCI as Adviser. Curious to understand this emerging field, I requested Dr G. J. Gyani, then Secretary General of QCI and founder of NABH, to allow me to attend one of its programmes. He readily agreed. At a session in Pune, I listened to an outstanding lecture on quality by Dr Y. P. Bhatia, one of the pioneers of healthcare quality in India.
That experience helped me understand the essential distinction. Healthcare accreditation, much like accreditation in education, focuses primarily on processes and systems rather than on competence in the ISO sense. In many respects, it resembles process certification.
Over the years, I watched NABH grow impressively. It secured endorsement from the International Society for Quality in Health Care (ISQua), achieving international recognition. While serving as CEO of the National Accreditation Board for Certification Bodies (NABCB), I occasionally attended NABH Board meetings and observed its progress from close quarters.
Even so, my engagement with healthcare quality remained limited. I often argued that India needed to implement minimum standards for healthcare establishments, as envisaged under the Clinical Establishments Act, to improve quality at scale. Accreditation certainly showcases excellence, but given India's vast healthcare ecosystem, accreditation alone cannot address the quality needs of the entire sector.
My interest in the subject deepened considerably when the Ministry of Ayush invited me in January 2025 to chair a Working Group tasked with identifying Ayush products and services that meet global standards. The exercise culminated in the launch of the Ayush Quality Mark by the Prime Minister in December 2025.
During this work, I took a closer look at healthcare and education accreditation systems and discovered something that surprised me: the inherent conflict of interest permitted in healthcare accreditation.
Under the ISQua External Evaluation Association's Guidelines and Standards for External Evaluation Organisations (5th Edition, Version 1.1, March 2022), Criterion 1.7 requires only that there be a defined separation between external evaluation activities and consultancy services, and that this separation be communicated to stakeholders.
In other words, the same legal entity may provide both consultancy and accreditation, provided it maintains an internal separation between the two activities.
This approach differs fundamentally from the principles embedded in ISO-based accreditation and certification systems.
ISO 17011, the international standard for accreditation bodies, explicitly prohibits accreditation bodies and any part of the same legal entity from providing consultancy services. Similarly, ISO 17021-1, which underpins management systems certification worldwide, prohibits certification bodies and related entities from offering management system consultancy. ISO 17065, governing product and process certification, contains comparable restrictions.
These provisions are based on a simple and universally accepted principle: one should not audit one's own work.
Healthcare accreditation systems that permit consultancy and accreditation within the same legal entity may argue that different individuals perform the two functions. Yet this does not eliminate the underlying conflict. Internal separation is not the same as institutional independence. The issue is not merely actual conflict of interest but also the perception of conflict, which can be equally damaging to credibility.
This concern led the Ayush Working Group to prescribe additional requirements. We decided that accreditation bodies operating under the Ayush Quality Mark programme should not provide consultancy services. This may render some well-known accreditation organisations ineligible unless they modify their practices, but integrity, independence and impartiality must take precedence.
The issue extends beyond organisations themselves.
If an accreditation body is prohibited from consulting, should its personnel be allowed to do so independently? In my view, the answer should be no. Yet even ISO-based systems have weaknesses in this regard. Consultants are often empanelled as auditors, creating a marketplace where advisory and assessment roles overlap. The same concern naturally applies to healthcare accreditation systems.
Other potential conflicts also deserve attention.
Can an accreditation body owned by a hospital chain or healthcare consulting organisation truly be perceived as independent? Can an accreditation body remain impartial if it approves or empanels consultants who operate in the same market?
Such arrangements create incentives that may compromise objectivity. When assessors encounter an organisation that has been advised by an approved consultant, there may be an unconscious reluctance to identify significant deficiencies. Doing so could raise questions not only about the consultant's competence but also about the accreditation body's own approval processes.
For this reason, accreditation bodies should maintain as much distance as possible from consultancy activities and consulting networks.
This does not mean they have no role in capacity building. Since accreditation bodies develop and own accreditation programmes, they are often best placed to explain standards and expectations. Public training programmes on standards can therefore be entirely appropriate. However, they should avoid becoming providers of consultancy services aimed at helping organisations achieve accreditation.
A better solution would be to strengthen independent skills and training ecosystems. In India, sector skill councils already exist in many domains, including healthcare. Bodies such as the Healthcare Sector Skill Council could independently certify professionals and training programmes to meet sectoral needs, while accreditation bodies concentrate exclusively on conducting impartial assessments.
The distinction may appear subtle, but it is crucial. Accreditation derives its value from trust. Once doubts arise about independence or impartiality, the credibility of the entire system is weakened.
Healthcare is an especially sensitive sector because accreditation decisions influence patient confidence, institutional reputation and, ultimately, public welfare. The standards governing accreditation must therefore be held to the highest levels of integrity.
The Ayush Quality Mark programme has attempted to establish such a benchmark by prescribing clear safeguards against actual and perceived conflicts of interest. Whether these principles gain wider acceptance remains to be seen, but they reflect a simple conviction: independence and impartiality are not optional attributes of accreditation. They are its foundation.


The author is former CEO, National Accreditation Board for Certification Bodies, Quality Council of India

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