BPI Policy/Regulation Changes – Examples
Blog: Biz-Performance, David Brown
BPI Policy/Regulation Changes – Examples
Example #1 illustrates required policy changes concerning the core process of a small agency (200 employees) that distributes funds for research grants: Making Grant Decisions and Delivering Payments. The major objective of the exercise was to lower staff workload by 30% without reducing the perceived quality of service offered to clients. A number of policy changes directly affecting workload were proposed to management who had to decide how far to adjust existing control mechanisms and service standards.
Example #2 provides a more detailed analysis of policy changes required within a large government department responsible for social assistance programs. The redesigned process calls for the scanning of application forms and the sharing of client information with other government agencies. Before proceeding with implementation of each solution, it must first be determined whether citizensÕ fundamental right to privacy are being unfairly sacrificed in the name of cost efficiency.
Disposal of Hardcopy Applications
The Issue
The Business Solution proposes that applications be scanned electronically so that all client information, including the clients signature, is maintained on the client file.
This recommendation raises two issues. First, does scanning of the hardcopy, including signature, provide an acceptable form of information storage, given the legal requirements for the information in future? Second, must the hardcopy be maintained by the government, or can it be shredded and maintained in machine readable format only?
Intent of Current Legislative Wording
Current government legislation does not define, nor was it intended to prescribe, the management of client application forms. Accordingly there is no governing legislation which precludes the scanning of completed applications, or destruction of hard copy.
Nature of Required Change Action
Neither the legislation nor the regulations which directly govern this organization would require revision to enable implementation of this proposal.
The legal status of scanned information and signatures is yet to be confirmed, and is currently under assessment by Legal Services in the context of specific cases. Discussions on this issue with Legal Services will be required, as will research into statutes at other levels of government describing valid forms of evidence. It is also recommended that the Internal Audit groups of other key government agencies be advised of this initiative.
The restrictions on implementation of the scanning/shredding proposal are those imposed by the governmentÕs own defined guidelines for information handling. A prescribed process has been developed for scanning of information and disposing of hard copy. This would have to be followed in the transition period, and then described fully in the operational policies as an on-going procedural guide.
Sharing of Client Information
The Issue
Implementing the redesigned service delivery network will require the sharing of information between its various internal programs, as well as with programs of other government departments and agencies.
Enhanced information sharing is required to “make it as easy as possible for our clients to deal with us“, to provide clients with “one stop shopping“, and, to make it possible for those clients who are eligible for multiple benefits “to receive them in a consistent, integrated manner“. One of the earliest redesign principles was: “any future program delivery must be interconnected and linked, allowing for sharing of information between other branches, programs and departments, and between other countries and governments“.
Enhanced information sharing will enable the organization to:
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obtain missing information to complete determination of eligibility/entitlement, without going back to the client
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identify candidates for and perform the adjudication of presumptive applications
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obtain information that may be required to respond to Ministerial Inquiries
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combine application forms
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combine payments for different benefits going to the same client
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use information collected for one program to corroborate eligibility for another
Intent of Current Legislative Wording
Legislative wording currently prevents unrestricted sharing of client information between government departments. The original intent was to protect the privacy of the client and to restrict the use of client information for audit and control purposes.
Nature of Change Action
Any changes to the acts that will enhance sharing of information must be demonstrated to be for the good of the client. While administrative and operational efficiency may be a by-product of increased information sharing, the prime rationale and defence must be improved client service, and the ability to reach an increased number of eligible clients. In addition, any changes must ensure that confidential information is protected, and that data obtained from other programs or departments will not be used for the purposed of investigative detection or persecution, unless there is already evidence of fraud, or under-or over-payment.
To enable sharing of information between programs, operational policies must be revised to guide the on-going procedures for information sharing.
For facilitating increased sharing of client information between government departments, it will be necessary to include provisions that enable sharing of information as and when needs are identified, as opposed to specifically identifying each item of information that can be shared. (Otherwise, legislation would have to be changed every time a department identifies a new piece of information that it needs from another department.) Such broad provisions, however, must be firmly grounded in wording that defines and limits the circumstances under which information sharing is permissible, (e.g., with written client consent) and the purpose for which the information can be used.
In line with sharing of information between programs and departments, there is an essential requirement to standardize definitions of commonly used terminology. The definition of marital status and custody, for example, must be the same for all programs that share information on such details.
Example #3, a Diagrammatic Presentation of Issues provides an analytical framework for presenting policy issues to management. Placement of policy issues along its axes helps to identify priorities, based on expected difficulty, time-frame for implementation and degree of interaction with external stakeholders.
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