CPA, CFE, PMP, Managing Partner – Government and Public Sector Advisory
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A Four-Step Approach to Effective Policies & Procedures Management for Government Agencies
Despite good intentions and earnest efforts, there remains a lack of quality and consistency in policies and procedures (P&P) across government agencies, as well as for private and public companies. Agencies struggle with creating effective P&P due to the multitude of laws and regulations relevant to each program, the decentralized nature of implementation guidance and updates, and the lack of clear roles and responsibilities for monitoring and updating the P&P.
Although the barriers to effective P&P are many and likely long-lasting, the fact remains that P&P is a crucial part of agency management. Without effective P&P in place, there will be inefficiencies and waste within your programs, an increased opportunity for fraud and abuse, and a decrease in management’s ability to properly monitor programs, all of which can lead to audit findings and recommendations.
Therefore, no matter the agency or program, the need for excellent P&P documents is the first step in maintaining and exceeding compliance requirements.
Although agencies have generally made an effort to consolidate the rules and regulations for any given program into a P&P manual, the following issues frequently prevent that manual from being top quality:
1. The manual sends the user to an outside source, creating the need for additional research and opening the door for potential confusion or inaccuracy
2. Updates are not made according to a schedule or incorporated into the manual, creating the need for additional information sources and increasing uncertainty among users as to whether they have the complete and up-to-date set of documentation
3. Manuals do not include enough detail or leave room for multiple interpretations, leading to errors and insufficient supporting documentation (audit findings)
To overcome these obstacles and create effective P&P, the below four-step approach is recommended for government agencies.
Step 1: Research and consolidate
Assemble a diverse and inclusive team of intelligent, motivated, and committed employees to be your P&P champions for a given program. Have those champions divide the responsibility for performing a deep dive of the laws and regulations relevant to the program, with each champion only responsible for researching a few requirement sources. Those champions can then meet, discuss, and compare the various requirements of the different laws and regulations to create a single complete, accurate, detailed P&P manual that has been vetted by several of your highest-performing team members. This detailed manual becomes the one-stop shop for program managers and upper-level management to run and monitor the program.
Step 2: Simplify
Everyday users do not consistently read what is required to perform their work. Making the average user refer to the detailed policy and procedure manual is asking for trouble. The champions should identify the most important requirements and thresholds for a one- to two-page quick start guide. This will provide users with an easy-to-read reference point to know when there is a requirement and who to ask for more information.
Having your champions review existing templates and forms or create new ones is also key to simplification. Having standard forms that only include relevant information is crucial for the efficient management of any program. Program managers can easily scan the form noting any incomplete sections; incomplete sections of the form would mean incomplete documentation – an audit finding.
Step 3: Train
Conduct live (in-person or web-based) training seminars at the onset and after each update. Conducting these sessions in a live format increases the presenters’ ability to focus on the most important requirements, highlight common errors, and connect with users, increasing the likelihood of those users reaching out when they have issues. Making recordings of these training sessions available on demand is also a great idea, as it allows users to refresh and retrain themselves regardless of what time it is or who is available.
Step 4: Monitor and update
Monitor monthly, update quarterly.
Monitor: Your champions should be responsible for performing monthly checks for updates and changes to the rules and regulations for which they were responsible for understanding during step one.
Update: When changes are noted, the champions should reconvene to discuss the impact of those changes and to determine which rules and regulations will be the most stringent after update implementation. Because many updates are issued with a forward-looking effective date, documents can often be updated quarterly, keeping formal review processes to a minimum. Version control should still be performed by updating the “last updated” date of P&P manuals even when no updates were required during the quarter. This allows users to depend on the periodic version control to easily determine that they have the latest version in hand and that leaders within the agency have reviewed that P&P manual to ensure it is complete, accurate, and timely and reflects the direction of the agency.
By revisiting and improving policies and procedures within your organization and following this four-step approach, you can help ensure that your programs are being run and monitored in ways that reduce or eliminate fraud, waste, and abuse at its roots.
Some of the clearest examples of the importance of concise, consolidated P&P are:
- Improper Payments Information Act (IPIA) of 2002, as amended by the Improper Payments Elimination and Recovery Act (IPERA) of 2010 and the Improper Payments Elimination and Recovery Improvement Act of 2012: We can see immediately that having and following clear, concise, and consolidated P&P is the easiest, fastest, and most important part of reducing those improper payments.
- Government Accountability Office (GAO) reports: You can easily find reports that are 40+ years old or as recent as this past year with titles like Cash Management Policy and Procedures Need Improvement and Financial Management: NOAA Needs to Better Document Its Policies and Procedures for Providing Management and Administration Services.
- Regulatory bodies leading by example, like the Office of Management and Budget (OMB) undergoing the initiative to consolidate numerous OMB Circulars into a single source of consolidated P&P: the Uniform Administrative Guidance.
Alex Ng, CPA, PMP
Manager, Government and Public Sector
CohnReznick Advisory
301.280.1852
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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.