ORD Policy Development

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ORD Policy Development

• SRA October 2005
• Brenda Cuccherini, Ph.D.
• VA Office of Research Development

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As I write

• Deep into that darkness peering, long I stood
  there wondering, fearing,
• Doubting, dreaming dreams no mortals ever dare
  to dream before.
• Edgar Allan Poe
• The Raven

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Fearing

• Not logical
• To complex
• Overly proscriptive
• Unrealistic
• Short sighted
• Causes immediate non-compliance

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Dreaming

• Does not induce sleep
• Everyone understands it
• Meets todays need
• Not outdated in years to come
• Ensures compliance
• ORO site visit no recommendations

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Why Have Policies?

• Defines specific required actions
• Serves as basis for procedures functions
• Provides a framework for how an institution
  functions
• Ensures consistent standards
• Clarifies roles responsibilities

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Instigating Factors (Why Do I Have to Do This?)

• Response to an event
• IG or GAO investigation
• Clarification of regulations
• Formalize a standard of practice

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The Basis for Policies

• Statutes
• Enacted by legislation
• Federal statutes codified in US Code (USC)
• Title 38 is VA statutes
• Regulations
• Promulgated by an Agency
• Usually defines what is set forth in a statute
• Framework for compliance with statues
• Federal regulations codified in the Code of
  Federal Regulations (CFR)
• Regulations are published in Federal Register to
  notify public and request comments

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The Process (1)

• Evaluate existing policies and regulations
• Determine if there is existing policy
• Determine if current policy needs to be changed
• Determine if new policy will conflict with
  current statues, regulations, or policies.
• Outline the scope of the new policy

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The Process (2)

• Identify the short or long range impacts of the
  policy
• Identify a small group of experts
• Think on a national level
• Develop background information
• Brainstorm with experts

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Issues to Decide

• How proscriptive?
• Can facilities comply?
• Is there any impact on other entities?
• Can compliance be measured?
• Is there authority to develop it? (Statutory,
  regulatory)

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Drafting the Document

• 1st draft
• Ideas from a small group
• Draft developed
• Shared with a small group
• 2nd draft
• Based on 1st round of comments revised further
• Circulated to larger group (field CO)
• 3rd draft based on comments
• Shared with a 3rd larger group depending on the
  topic
• Final draft goes into concurrence

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Concurrence (1)

• ORDs final draft
• Agreement by all service directors senior ORD
  staff
• Entered into EDMS (correspondence tracking)
• Assigned to specific VA VHA offices

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Concurrence (2)

• Review all comments
• Redraft
• Sent to publications (placed into VA-ese)
• Review by Under Secretarys office
• Under Secretary signs policy

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Importance of Field Input

• Institutional memory past history of the issue
• Experience expertise in the topic area
• Hands on experience
• Knowledge of other VAs and institutions
• Real world prospective
• Insight into implementation process
• Difficulties with compliance

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Reconciling Conflicting Suggestions (1)

• Number of persons offering the suggestion
• Same suggestion
• Similar or related suggestion
• New or previously considered suggestion
• Importance for compliance consistency with
  other policies or practices

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Reconciling Conflicting Suggestions (2)

• Discussion within CO
• Discussions with those offering comment
• Final decision based on
• Purpose of policy
• Inciting issue
• VHAs overall direction

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Working with ORO

• Why
• Wide range of experience
• Common finding on site visits
• Active in Interagency groups
• Benefits of agreement before concurrence
• Seamless transition from policy development,
  implementation, and oversight/monitoring

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Communication to Field

• E-mail to all research offices
• ORD web-site
• ORD conference call
• Publicize name of contact
• Listed in document or
• Available by contacting ORD

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Major Issues Requiring Time Effort

• Publication in the Federal Register or
• Amending CFR

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A Thought On Reading Policies

• nothing contributes so much to tranquillize
  the mind as a steady purpose
• Mary Shelley
• Frankenstein

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