OK, here are key statements taken directly from the PADI Pro web site.
In summary, individual PADI instructors/operators can participate in the program if they wish. The opposite is also true and has actually happened: a URP program may refuse to accept the student's certification if it was completed by a PADI instructor, meaning the student may pay for and complete the OW dives but not get certified if the referring instructor so pleases.
What follows is direct quotation, although some materials have been left out.
“Universal” or “Global” Referrals
PADI is not a proponent of “universal” or “global” referrals for several reasons. ...Generally, our legal advice has been that it will be difficult to defend, especially because the certifying instructor has not seen the student in the open water, and it can result (and has resulted) in customer service problems for the diver. However, if you choose to participate in this referral system, please make an informed choice.
How does the Universal Referral process work?
A student diver presents you with a “universal” or “global” referral. The student diver has taken his initial training through another training organization. The instructions on the form will direct you to conduct open water dives as outlined on the form and sign a statement on the referral document verifying that the student completed the dives. The student then carries the form back to his original instructor who is supposed to certify the student through his organization.
What is PADI’s position on the Universal or Global referral approach, and why?
PADI’s position on the Universal Referral program (and similar approaches) as regards divers receiving PADI credentials through such a process has also remained unchanged since the program was first presented to the RSTC in 1995. This position is based upon recommendations from legal counsel regarding the difficulty (perhaps impossibility) of defending a lawsuit resulting from a “universal” style referral process. The questions of how an instructor from one agency can be familiar enough with the standards and training requirements of a different agency to defend his actions; of how the referring (certifying) instructor can ascertain that the person conducting the open water dives was even a current, qualified instructor at the time the open water training occurred; of how the certifying organization can maintain any quality control whatsoever on the instructor conducting the open water training or have any reasonable way to know that its required open water skills were performed correctly by the student it will certify; etc.
One of diving’s most experienced attorneys, William Turbeville, as part of his analysis of the program for PADI, wrote this regarding the issue of an instructor authorizing certification for a diver whose open water training had been conducted by someone else: “It will be considerably more difficult to defend a claim of inadequate instruction if that instructor has never seen that student doing the single most important part of that student’s training – actually scuba diving.”
Upon completion of the open water dives under the Universal Referral process and issuance of a Universal Referral Temporary Card, can I consider the individual a certified diver?
This is a decision that is left to the individual dive center/resort or instructor. As with other certification agency credentials, PADI does not determine which agencies' certifications should be honored or recognized and which ones should not.
May I complete open water dives via the “universal” or “global” referral process and send the diver back to the originating instructor for certification?
Choosing to conduct a non-PADI program is completely up to you. These types of referrals are not within the scope of PADI standards and programs. Therefore, whether or not you accept them is your business choice. PADI recommends that you fully inform yourself before making such a decision by thoroughly researching the issue.
What problems have arisen from PADI Instructors accepting a “universal” or “global” referral?
So far we have seen customer service issues as well as potential liability issues that may arise after diving accidents suffered by two different Universal Referral divers. The customer service matter was that Universal Referral students had their open water dives conducted by a PADI Instructor, but the original instructor subsequently refused to issue their certifications. The students were understandably upset at everyone involved.
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Will insurance offered through Vicencia and Buckley cover me if I participate in “universal” or “global” referrals?
Yes, if you are the receiving instructor for a “Universal” or “Global” referral student and you do the open water training, you’re covered.