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Policy? Guidance? Standard Operating Procedure?

Tips on how to achieve compliance with minimum red tape

Carolyn Bargoot, Associate Director Post-Award AdministrationSheila Freedman, Associate Director Audit and Compliance

Office for Sponsored Programs, Boston College

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Agenda– Policy• When is developing a policy necessary?• How should you go about creating a policy?

– Guidance• When issuing guidance might be the right path to

choose

– Standard Operating Procedures (SOP’s)• Why develop SOP’s? • How can they help you and your institution?

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Boston College Fun Facts – FY12– Located in Chestnut Hill, MA– Total Undergraduates 9,100– Total Graduate Students 4,900– Total Operating Expenses $795.7 million– Sponsored Awards $51.5 million– Research $31M– OSP Staff = 12– No A-133 audit findings!

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Why Develop Policies?– OMB Circulars• A-110 requires certain policies• A-21 further restricts• A-133 tests you on your policies

– Funders expect we have certain policies

– Ensure compliance

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You should know• You are always bound to your institutional policies• University and OSP Policies• In most cases it is best NOT to introduce new polices,

unless something more is required by Federal or State funding agencies or by law.

• It is important to remember if your policies are stricter than required you need to make sure that your systems and administrators can meet those stricter requirements.

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Policy Development– Research

• What is required for your institution? What type of institution are you?• Look at what other similar institutions are doing (websites)• Higher Ed is big on sharing

- Reach out to other institutions directly

– Analysis• What would work best for your institution• What does your institution need to include in the policy for compliance, regulatory or

other purposes?

– Consult within your department – Consult with other departments

• Most policies today affect multiple departments, therefore to be successful you must identify who needs to be part of the process and get their cooperation and buy-in

– Consider whether a policy is the right method!

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Include in your Policy– Clear Purpose– Scope– Assumptions– Requirements– Define Key Terms– Reference federal, state or other pertinent

regulations

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Successful Policy Development– Policies in your department/area should all have the

same look and feel– Keep it simple and include only necessary information– Make sure you can adhere to what is in the policy

• you do not want to increase your audit risk!

– Review regularly to make sure the policy is still relevant

– Resources available / Communication• Training, memos, forms, brochures, etc..

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A few examples of Policies your institution should have:– Cost Sharing Policy– Conflict of Interest Policy – Effort Reporting Policy– Intellectual Property Policy– Capital Equipment Policy– Travel Policy– Procurement Policy– Cost Transfer Policy

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Getting your policy approved:– Navigating the policy approval process at your

institution can be tricky!– Many departments might need to be involved based

on the topic of the policy• OSP• HR• Legal• Procurement• Provost Office• Controller’s Office

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Getting your policy approved:– Might help to ask for more authority if the policy is

only going to impact sponsored activity

– Get all major players in a room together to discuss and review

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After your policy has been approved:– Set a timeline for issuing your policy

• Policy effective date is important

– Training your audience on the impact of the new policy

– Decide where on your website the policy will reside

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Guidance– Unlike policy it is not mandatory

– Seeks to simplify a set of processes with regard to an established habit or practice

– Goal is to increase quality and consistency

– Guidance is a great way to raise the bar and get the research community to strive for best practices

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When should you issue “guidance”?– Ideally guidance should be developed in all major areas of

compliance even if you do not have a policy

– Guidance could become policy in the future

– If you are unable to get a policy approved you might consider issuing guidance instead

– Faculty and administrators should be trained

– Example

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Why create Standard Operating Procedures (SOP’s)?– Consistency, routine– Improve Productivity– Quality Control, Compliance– Training and cross-training (staff turnover)– Best practices can be established– Collaboration as a department in developing SOP’s can

increase morale– Employee evaluations– Help in an audit (internal or external)

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Standard Operating Procedures…where to begin?1. Identify

- Determine which areas of your work will benefit from a standard operating procedure

- Where would it help have consistency? - Where will you see the greatest success?

2. Risk and Controls- Focus on the areas where the risk is high

and controls are needed

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Standard Operating Procedures…where to begin? 3. Collaboration

- Determine who is going to take the lead to document each SOP- Brainstorm as a group on the SOP - discuss at least the high level controls needed

4. Development- Work as a team in development with one clear lead- Include an introduction or scope of the procedure- List all tasks and include descriptions of the tasks- Define any necessary terms upfront- Keep it short, without leaving out necessary informationor consider breaking into smaller SOP’s- Determine the best format – checklist, word doc, flowchart

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Standard Operating Procedures…where to begin?5. Test

- Ask a few of the team members to check the SOP when performing actual procedure

6. Notification- Notify necessary people of the new SOP- Give access to SOP document on website or server

7. Training- Provide training on the new SOP

8. Review- Establish process for reviewing SOP (e.g. annually)

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Questions?

Thank you!