How to Avoid Policy Proliferation in Procedure Management
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How to Avoid Policy Proliferation in Policy & Procedure Management

Written by ComplianceBridge Policies & Procedures Team on April 24, 2017

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Spring cleaning is a ritual for many households. Done regularly it removes clutter and items that are no longer wanted or needed. Keeping your house orderly makes it easier to know what you have and where each item is. A similar spring cleaning of policy and procedure management should be done in every organization to avoid policy proliferation.

There are many reasons that policies proliferate. Here are a few:

  • Policies get out of date. Even the best policies can outlive their usefulness. If policies are not routinely reviewed, they may continue to exist in the policy manual when they are no longer meaningful. These policies may cause pain in compliance audits because they are still on the books and must therefore be followed. They can also encourage a lax attitude about policies in general.
  • Policies are redundant. If there is insufficient collaboration, different groups can end up publishing similar but separate policies. If there is insufficient oversight of the entire policy set, then gaps and overlaps between policies is a risk. Either way, you end up with redundancy.
  • Policies are too narrowly constructed. If policies are too narrowly defined, more policies are created and it becomes more difficult to manage them all.
  • Policies are reactive. When bad things happen, it is easy to have a knee-jerk reaction. When policies stem from a one-time incident or from a single employee’s bad behavior they can be seen as unnecessary by the rest of the organization.
  • Policies encourage the wrong behavior. Many policies reflect the desire to improve clarity, accountability and measurement. These are only good, however, if they encourage behavior that is consistent with the real goals of the organization.

Why Policy Proliferation is Bad

More is definitely not better when it comes to policies. Of course, there must be policies in place to ensure compliance with laws and regulations. There should be policies to protect health and safety. It is easy, though, for policies to get out of hand and that can have severe consequences. Here are a few:

  • Productivity declines. Every extra minute spent creating, learning, teaching and enforcing policies is a minute of lost productivity. The more policies there are, the more time spent on these activities. The more rules imposed on the workplace, the more time spent figuring out how to work within the rules.
  • Morale declines. If you have an over-abundance of policies there is a good chance you have low morale in your workforce. The more control that is exerted over employees the less empowered they will feel. Nobody enjoys that.
  • Innovation declines. Innovation requires thinking outside the box. It is risky and often results in failure before success. Organizations with tight controls and penalties for violating rules are clearly telling their employees to play it safe.
  • Rules are disregarded. When there are too many policies it can be difficult to enforce them all. Employees and managers alike may be unaware of or forget policies that are rarely relevant. Policies that cannot be easily monitored may be ignored.
  • Talent leaves. Policy proliferation can stifle creativity and can also give the appearance of shoddy management. Top talent will go somewhere else.
  • High cost. Policies have an inherent cost in overhead. When policies are not well managed, the costs and compliance risk escalate.

Avoiding Policy Proliferation in Policy & Procedure Management

Like a rolling snowball, the size of your policy management task can quickly grow. Fortunately, there are ways to keep policies under control.

  1. Define a regular policy review cycle. Regular review is one of the best ways to ensure that policies remain current. Every time you create a new policy, set a review date as part of the policy publication process. Make sure you have a system in place so that your team is automatically reminded to review the policy.

    Similarly, assign a review schedule for all policies currently in effect. This may take some time to work through, but it is a valuable way to determine that your policy set is up-to-date.
  2. Provide unfettered access for editors and target stakeholders. Those involved in the review process should be able to easily access other policies to check for redundancies and conflicts. Add document links, references, keywords and other identifiers to all policies. Provide search tools that enable your team to identify similar policies.
  3. Question every policy. Make it a priority to question the value of every policy. Actively prune policies that no longer make sense. Modify policies that are too narrow or restrictive. Combine policies that overlap.
  4. Properly classify your documents. Different kinds of documents have different enforcement requirements. Your policy management system should be able to handle procedures, guidelines and best practices along with policies. Take the time to determine which is the most appropriate designation for each bit of content you create.
  5. Encourage feedback from all stakeholders. If you really want to know how relevant and readable your policies are, ask your stakeholders. They will tell you. A strong feedback loop can give you early insight into how policies show be changed or rewritten to focus and clarify. It can also give you insight into the relationships between policies and where new policies may be needed.
  6. Support a review workflow. Your policy management system should allow you to designate the team for each review, proactively notify editors as a policy moves through the workflow, and enable version control. A clear workflow makes the revision process more efficient and improves teamwork. As policies move through the cycle, editors can see each other’s change intentions. This can help the team avoid the pitfalls of decision by committee and deliver solid new policies for the organization.
  7. Target your policy distribution. Make sure that policies are sent to those stakeholders specifically affected by them. If you distribute too broadly, you risk that your audience stops reading your notices. If you distribute too narrowly, you risk not reaching your real audience. Don’t send a notice to all employees about a new policy that affects only one department.
  8. Require acknowledgement. When you do publish, require those affected to acknowledge receipt and understanding. Track compliance and follow up with those who are non-compliant. For some policies, you may also want to require a test to confirm that the material was indeed understood. The acknowledgement process can help you avoid policy proliferation by increasing both understanding and compliance. Give your stakeholders an opportunity to give feedback in this process to improve your odds of knowing where there are gaps and overlaps in policy.
  9. Focus on performance and compliance. Policies and other related documents should always support your organization’s goals—performance and compliance. If your policies do not help your organization achieve its mission within a compliance framework, they are not working for you. Approach each policy from the perspective of its contribution to success and you will be much more likely to avoid policy proliferation.

ComplianceBridge Policies & Procedures Team

The ComplianceBridge Team has more than a decade of experience in compliance management and solution development. We cover stories of interest to Compliance Officers and provide tips and tricks for maximizing compliance.

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