Best Practices to Improve Policy & Procedure Management
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Properly written (and applied) policies and procedures have the power to drive incredible efficiencies throughout your processes and operations while helping you stay more compliant. A comprehensive set of policies and procedures can ensure continuity in each department of your collection business and can be used as a training tool for new associates and the collections team at the same time.
We recently sponsored a webinar that highlighted the importance of essential best practices for policy and procedure management. Hosted by Mike Gibb of AccountRecovery.Net, the webinar outlined simple steps to developing policy and procedures to help you gain significant advantages, both in terms of productivity and compliance. If you don’t have well-laid-out policies, or if you haven’t reviewed them in a while, it’s time to get started, using the below-mentioned steps discussed in the webinar.
Scenario 1: Building your policies and procedures from scratch
If you don’t have policies in place, build on regulatory law, or as an approach, write policies for all activities covered under the lifecycle of an account. Before you start, know that a policy should not be meant as an off-the-shelf or one-size-fits-all solution. Hence, don't just use a policy template and put your name on it. Start with listing out anything that you are doing in your company that requires policy and procedure guidelines.
A thoughtfully designed mission statement is basic to a functional policy. It should express the long-range focus of the policy. It’s important to include a section in the policy that spells out the specific roles and responsibilities for all activities. This helps streamline operations, prevent redundancy, and improve productivity. Each position listed should contain a job description (not specific names). To enhance clarity, provide an organizational chart detailing the reporting channel.
Each policy should have an owner, reviewer, and approver. Ideally, the owner and approval cannot be the same person for each policy. Policies on information security, back-office support function, data security, and call monitoring should be written by departmental heads and then reviewed by a compliance person to add a layer of compliance security. They should ultimately be approved by subject matter experts.
Scenario 2: Expanding your policies and procedure policies
As you build out the library of policies, continue assessing your risk areas. All processes associated with these risk(s) will need policies in place on priority. Once you are done with policies related to laws, move to policies for all operations and call handling. In relevant policies, have a script in place for calls to make sure they all begin with a similar message and train any employees on how to handle anticipated problems, such as angry and defiant consumers, consumers who claim to be unable to pay, and those who claim not to have incurred the debt.
Your policy can be as general or as specific as you would like, just keep in mind that to arm your employees with knowledge and predefined best practices and procedures, it is necessary to list out solutions to resolve all possible issues related to the subject of the policy document. Policy titles such as " Call handling – Mini Miranda" and "Attorney Representation" should include a reference guide as well. The reference guide, which should always include important resources such as supervisory advice from CFPB and the list of FDCPA violations, should be updated regularly as laws change.
Scenario 3: Using technology to keep your policies and procedures up to date
Other than just maintaining your policy and procedures, you also need to make policies easily accessible to your employees. To achieve this, make sure all the policies and documented procedures are uploaded to your compliance management system (CMS). Each policy should have a table of contents and be "keyword search" enabled for ease of use. An advanced CMS like IPACS can help you test these policies with tracking approval workflows, timely certification, employee acknowledgments, and policy version controls.
Your policy should be structured and consistent but also flexible, so it can adapt to changing times and uncertain environments. The regulatory landscape across the ARM industry has been changing rapidly, and as a result, policies and procedures can become outdated. Hence, your policies must be routinely updated in response to the changing economy, regulatory landscape conditions, and competitive environment. If you have CMS-integration enabled, it’s also possible to automate re-certification and re-training of employees as needed.