Chapter 7. What

1
Chapter 7.Whats Your Strategy? Thinking Through
the Error Reduction Challenge
2
Chapter 7. Section 1. Introduction

• Learning Objectives
• Assess, analyze and cure QC findings
• Develop implement a long-term error resolution
  plan

3
Getting Ready

• Its time to begin thinking about taking the
  Summit information home.
• In the Chapters 6 7 we are changing the nature
  of the conversation
• From What PHAs must and must not do
• To Short and long term strategies for responding
  to the RIM reviews and implementing an effective
  error reduction program.

4
Getting Ready

• Discussion
• What will be the most challenging part of an
  error reduction initiative at your PHA?

5
This Chapter

• Focuses on strategies for
• Identifying root causes of errors
• Developing a plan for correcting and preventing
  errors
• Includes a 2-part problem solving model that will
  be used to think about
• Responding to RIM reviews
• Reducing and preventing future errors

6
Approach to Error Reduction
Clarify Area of Concern
Understand What Really Happened
Problem Analysis
Identify Reasons for Errors
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
7
What People Often Do

• I have a problem. Lets make a plan.
• They forget the steps that come before the plan.
• They solve the wrong problem!
• Find out what the problem is before you fix it!
• As you go through the examples, you may say, I
  know what needs to be done we need to do
  training. But lets go through the steps to see.

8
RIM Reminder

• Within 45 days
• Correct individual tenant file errors identified
  by the RIM
• Corrective action plan for any errors not
  resolved in 45 days
• Within 6 months
• Implement corrective actions to resolve systemic
  findings and prevent future errors
• Corrective action plans that exceed six months
  must be approved by HUD Headquarters.

9
Chapter 7. Section 2.Problem Analysis Strategy
10
Section 2. Problem Analysis Strategy

• Our strategy starts with problem analysis.
• But dont we already know whats wrong?
• HUDs RIM reviews may have identified some
  problems
• But knowing what to do about the problems
  requires a deeper understanding of exactly what
  happened and why.

11
Problem Analysis
Step 1 Clarify Area of Concern
Step 2 Understand What Really Happened
Problem Analysis
Step 3 Identify Reasons for Errors
12
Step 1 Clarify the Area of Concern

• Work with one issue at a time
• Well use Child Care as a running example
• Use as many sources of information as possible
• RIM review findings
• Quality control results
• Complaints (internal/external)
• After an assessment of each issue, think about
  how they fit together

13
Clarify the Area of Concern

• Identify the requirements Is it clear how each
  issue should have been handled?
• To be sure, review
• HUD and PHA policies and procedures
• Forms, checklists and other tools
• Ask yourself
• Are policies and procedures clear?
• Do they ensure consistent handling of files?
• Are any situations not covered?

14
Concern Child Care

• Page 7-5. The RIM Reviewer found that
• Staff didnt follow PHA policy for determining
  which family member is enabled to work
• Staff did not ask if child care costs were paid
  or reimbursed by a third party
• 3rd party verifications were missing with no
  explanation
• No documentation of the reasonableness of the
  child care expenses
• Ineligible expenses counted as child care

15
Concern Child Care

• Page 7-5 (continued)
• Where would we find what should have happened?
• HUD regulations 24 CFR 5.603 and 5.611
• PHAs Administrative Plan
• Housing Choice Voucher Program Guidebook
  7420.10GA
• Notice PIH 2001-15 (HA) expired
• PHA forms Interview form, third-party
  verification form

16
Concern Child Care

• We have clarified the area of concern. We know
• What the RIM Reviewer (or our own QC process)
  tells us happened.
• What should have been done according to HUD and
  PHA policies.
• Next step Understand what really happened.

17
Approach to Error Reduction
Clarify Area of Concern
Understand What Really Happened
Problem Analysis
Identify Reasons for Errors
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
18
Step 2 What Really Happened?

• Begin to assess the underlying problem
• Who made the errors (everyone, several people,
  one person)?
• How frequently were errors made?
• What kinds of errors were made?
• Did a special situation cause the error?
• Start with your experience but dont jump to
  conclusions

19
What Really Happened?

• To understand the underlying problem you may
  decide additional data collection is needed.
• If so
• Pick files processed by different specialists
• Select enough files to pick up on problems and
  see trends
• Choose cases that are likely to have the type of
  error you are analyzing

20
What Really Happened?

• Talk with people
• Consider the advantages of individual vs. group
  conversations
• Consider how to get diverse perspectives.
  Variety is the key!
• Best/worst performers?
• Oldest/newest staff?
• Members of different teams?
• Talk to enough people, but not too many

21
What Really Happened?

• Think about how you ask the questions.
• Can you walk me through this part of the
  process? (Not Why did you )
• What is the hardest or most confusing part?
• What do you do if you have a question? (Not Why
  dont you know )
• What would help you do this more easily/more
  accurately.

22
What Happened Child Care

• Page 7-8.
• Staff automatically used the spouses income to
  cap child care.
• PHA policy says use family member with lowest
  income unless information shows someone else is
  enabled to work
• Staff didnt ask about reimbursement from other
  sources.
• Some staff said they didnt know to do it others
  said they knew, but forgot to ask

23
What Happened Child Care

• Page 7-8 (continued)
• Missing third-party verifications
• Staff reported that third-party providers often
  dont cooperate, so they used other verification
  method to get work done quickly.
• Missing documentation of reasonableness
• Staff are confused about how they are to handle
  reasonableness

24
What Happened Child Care

• Page 7-8 (continued)
• Ineligible expenses allowed for a 15-year old
  child with a disability
• The staff member knows the rule.
• A review of her other cases found no other
  errors. She just made a mistake.
• Now we understand what happened. Next Why did
  it happen?

25
Approach to Error Reduction
Clarify Area of Concern
Understand What Really Happened
Problem Analysis
Identify Reasons for Errors
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
26
Step 3 Identify Reasons for Errors

• To understand why
• Reflect on what you know from looking at files
  and interviewing staff
• Remember, the stated reasons may not get to the
  root problem

27
Reasons for Errors

• Keep asking why? For example
• Staff didnt know how
• Why didnt they know?
• No one told them why didnt someone tell them?
• Someone told them but they misunderstood? Why
  did they misunderstand?
• They knew it but forgot why did they forget?

28
Reasons for Errors(See Chart on p. 7-10)

• Stated Reason
• Staff didnt know WHAT to do
• Staff didnt know HOW

• Root Cause
• Policy/Procedures?
• Lack of Knowledge
• Inadequate supervision?
• Inadequate training?
• Knowledge/training?
• Skill or ability?
• Clear procedures?
• Inadequate supervision?

29
Reasons for Errors

• Root Cause
• Inadequate infrastructure
• Excessive workload
• Forms/ other tools
• Computer capacity?
• Organizational Culture
• Inadequate supervision
• Lack of clear procedures

• Stated Reason
• Staff COULDNT
• Staff WONT/DONT
• Always done it
• Didnt know why it was important or didnt
  believe it was important

30
Reasons for Errors

• Page 7-11
• Common Root Causes of Errors
• Inadequate Written Tools
• Inadequate Computer Hardware and Software
• Inadequate Communication.
• Limited Staff Capacity
• Inadequate Facilities
• Inadequate Supervision
• Non-productive Organizational Culture
• Policies and procedures

31
Reasons Child Care

• Page 7-12
• Capping the deduction
• Stated Reason Staff Confused
• Root Cause Newer staff dont have knowledge and
  skills to make the decision
• Checking for costs were paid by others
• Stated Reason We forgot, doesnt happen often
• Root Cause Interview form doesnt have a question

32
Reasons Child Care

• Page 7-12 (continued)
• Missing 3rd party verifications
• Stated reason Small providers dont respond so
  we move on to other forms
• Root cause
• No place to explain why 3rd party wasnt used
• Staff are focused more on timeliness than
  compliance.
• Verification form may be too complicated for
  small providers.

33
Reasons Child Care

• Page 7-12 (continued)
• Staff didnt document reasonableness
• Stated Reason Were confused
• Root Cause Staff dont have knowledge and skills
  to make this decision
• Counted expenses for 15 year old disabled child
• Stated Reason I forgot
• Root Cause Carelessness, isolated incident

34
Problem Analysis Review

• Before trying to solve a problem, have you?
• Clarified the area of concern?
• Determined what really happened?
• Identified reasons for the errors?
• If yes, its time to develop a strategy.

35
Chapter 7. Section 3.Response Strategy
36
Section 3. Response Strategy
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
37
Section 3. Response Strategy
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
38
Step 1 Find Appropriate Solution

• Dont jump to conclusions about what to do.
• Do you have a personal preference or bias about
  addressing errors?
• Sometimes a problem needs to be tackled from more
  than one angle
• For example, you may need to remind staff about
  rules and improve policies and improve forms)

39
Find Appropriate Solutions

• Timing can be a barrier.. Think about solutions
  for the
• Short-term.
• Medium-term
• Long-term
• Doable vs. deluxe. The ideal solution is not
  always possible. Consider
• A quick fix, followed by a long term solution
• How much effort is really needed

40
Solutions Child Care

• Page 7-17.
• Capping the deduction
• Root cause New staff (especially) need
  information
• Solutions Case studies/discussion
• Checking for costs paid by others
• Root Cause Interview form didnt have a question
• Solution Revise the form
• Missing 3rd party verification
• Root Cause Combination of procedure and attitude
• Solutions Fix form enhance procedure remind
  staff

41
Solutions Child Care

• Documenting Reasonableness
• Root Cause Staff didnt know how
• Solutions Case studies and discussion
• What else?
• PHA counted expenses for 15 year old disabled
  child
• Root Cause Carelessness, isolated incident
• Solution Fix the file, no further action

42
Coordinating Solutions

• Few PHAs have only one type of error.
• Even though each issue is analyzed separately,
  solutions should be coordinated.
• Set priorities that focus on errors with large
  financial impact or that happen frequently.
• Be realistic about resources required.
• Look for efficiencies such as training on several
  error topics at the same time.
• Adjust timeframes to avoid overloading a few
  staff.

43
Section 3. Response Strategy
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
44
Step 2. Develop An Implementation Plan

• Why an implementation plan?
• Understanding is not enough, action must follow
• Writing down a plan increases the chances it will
  be successful
• Tips for developing the plan
• Identify key players and bring everyone on board
• Remain flexible. Be ready to revise based upon
  the suggestions of other players.

45
Implementation Plan

• More tips
• Get specific and detailed. Now is the time to
• List all of the steps
• Think strategically about who can best carry out
  each task
• Assign responsibilities and deadlines.
• Designate staff with appropriate interest and
  skills.
• Consolidate the individual plans to identify
  overloaded individuals and confirm priorities.

46
Implementation Plan

• Page 7-20 Child Care Example
• Column 1 What we decided to do in general terms
• Column 2 Who needs to take what specific
  actions
• Columns 3-6 When will this be done?

47
Implementation Plan

• Page 7-21 A summary plan that
• Addresses errors related to Child Care
• Illustrates the results of other analyses.
• Page 7-22 - Summary of the Problem Solving
  Process including
• What to ask
• What to do

48
Chapter 7. Section 4.The Error Reduction Process

• Two Examples
• Best Housing Authority (BHA)
• Quality Housing Authority (QHA)

49
Introduction

• Purpose of the two examples
• More illustrations of the problem solving process
• Consider solutions for additional types of errors
• We will give overview now you can study the
  details when you go home

50
Overview of the Process
Solution
Problem
51
Approach to Error Reduction
Clarify Area of Concern
Understand What Really Happened
Problem Analysis
Identify Reasons for Errors
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
52
Clarify the Concern

• The Scenario HUD conducted RIM reviews at both
  PHAs and found identical errors
• 3rd party verifications are not being
  consistently obtained.
• No explanation provided for why another form of
  verification was used
• Inadequate documentation of differences between
  file data and HUD-50058 data

53
Best Housing Authority(BHA)
Problem Analysis Strategy
54
Approach to Error Reduction
Clarify Area of Concern
Understand What Really Happened
Problem Analysis
Identify Reasons for Errors
55
BHA Problem Analysis Steps

• Step 1 Clarify the areas of concern
• We did that (same for both PHAs)
• Step 2 Understand what really happened
• What did really happen?

56
What Really Happened - BHA

• File reviews confirmed the problem
• Errors were concentrated among new staff (more
  than 50 on the job less than 2 years)
• Staff reported they were complying when possible
• Staff confused about what 3rd party means (e.g.,
  Dont payroll stubs come from a 3rd party?)
• Staff indicated there were reasons for making
  changes to the familys final income but there is
  no place to document this.

57
Step 3 Identify the Reasons for Errors

• Page 7-26 (review chart)
• Column 2 Stated Reason for Error
• Problem 1 No 3rd party verification in file
• Some staff didnt know the paper work they were
  accepting was not 3rd party
• 50 of staff are new and lack of experience
  affected the error rate

58
Reasons for Errors - BHA

• Page 7-26
• Column 3 Possible Root Causes
• Problem 1
• Inadequate policies and procedures
• Staff lack skills
• Supervisors arent catching errors.

59
Step 3 Identify the Reasons

• Problem 2 Lack of 3rd party documentation
• Stated Reason Staff said they didnt know where
  to put information about why they took a lesser
  form of verification
• Possible Cause Inadequate forms no establish
  method for recording the decisions to take
  something less than third party written
  verification

60
Step 3 Identify the Reasons

• Problem 3 Lack of change documentation
• Stated Reason Staff did not understand the
  importance of documenting changes in income
• Possible Cause
• Inadequate forms
• Inadequate skills
• Inadequate supervision

61
Best Housing Authority(BHA)
Response Strategy
62
Approach to Error Reduction
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
63
Response Strategy BHA

• Page 7-28 Possible Solutions to problems
• (look at column 3)
• BHA will focus on
• Improving policies, procedures, forms
• Skills of staff
• Effectiveness of supervision

64
Develop Implementation Plan

• Possible Solutions
• Need Action Plan to implement solution
• Need Strategy to carry it out
• Who needs to do what by when

65
Develop Implementation Plan

• Review policies and procedures to ensure that 3rd
  party requirements are clear
• Whos going to do it
• When is it going to be done?
• Review chart on pages 7-29 and 7-30
• Time frames ranging from Now to greater than
  six months

66
Quality Housing Authority(QHA)
Problem Analysis Strategy
67
Approach to Error Reduction
Clarify Area of Concern
Understand What Really Happened
Problem Analysis
Identify Reasons for Errors
68
Step 1 Clarify the Area of Concern

• Were they the same as BHA?
• Will the causes, solutions, and implementation
  plan be the same, do you think?

69
Step 2. Understand What Really Happened

• File reviews confirmed the problem
• Team A staff report supervisor says no point
  wasting time if 3rd party wont respond
• Staff think the PHAs priority is on-time
  reexaminations.
• Since they were following policy, they believed
  no documentation was needed

70
Step 2. Understand What Really Happened

• Verification form is confusing to employers
• Fax machines are not working well making it
  difficult for employers to return verifications.
• Computer software doesnt provide a place for
  notes to explain why 3rd party wasnt used

71
Step 3. Identify Reasons

• See chart on page 7-33

72
Quality Housing Authority(QHA)
Response Strategy
73
Approach to Error Reduction
Find Appropriate solutions
Response Strategy
Develop an Implementation Plan
74
Reason for the Errors - QHA

• Page 7-33
• Column 2 Stated Reason
• Supervisors communicated that on-time reexams are
  more important than verifications
• Employers have little incentive to cooperate and
  complain verification form is unclear
• FAX verifications not effective
• Staff didnt understand importance of documenting
  changes in income .

75
Reason for the Errors QHA (continued)

• Page 7-33
• Column 3 Possible Root Causes
• Inadequate supervision some supervisors have
  given faulty information
• Organizational culture emphasis on timeliness
  at the expense of accuracy
• Inadequate training of staff
• Inadequate tools
• Inadequate facilities (poorly maintained faxes)

76
Response Strategy - QHA

• Page 7-36 Possible Solutions
• Initiate a long-term culture shift focused on
  balancing timeliness with error-free processing
• Education for staff
• Input from employers re forms and process
• Develop forms and procedures for documenting use
  of other than 3rd party and changes to income.

77
Implementation Plan

• Strategy for who is going to do what by when
• Review chart on page 7-36 and 7-37

78
Chapter 7. Section 5.Using the Error Reduction
Process
79
Section 5. Using the Error Reduction Process

• Back Home. How to start
• Break the problems into manageable steps
• Go step by step
• Keep an open mind
• Think broadly about causes and solutions
• Resource limitations may require implementation
  in several stages.
• RIM findings take priority, but dont stop there.
• Start (enhance) your QC program as soon as
  possible

80
Exercise Where Do We Go From Here?

1. Identify your PHAs 2 largest error issues
2. Identify the two most likely root causes of these
   errors
3. Identify one possible solution for each root
   cause.
4. What are the two most important messages you will
   be taking home from the summit to supervisors and
   staff in your agency?

81
Learning Objectives

• Assess, analyze and cure quality control
  findings
• Develop and implement a long-term error
  resolution plan

82
What Have We Learned?
83
Can you now . . .

• Develop systems, standards and practices that
  will reduce income and rent errors?
• Achieve successful results in future RIM reviews
  by improving the PHAs understanding of the RIM
  process?
• Develop well-conceived policies and effective
  procedures, taking into account mandatory
  requirements and prohibitions vs. areas of policy
  discretion?

84
Can you now . . .

• Gather, analyze and document information through
  improved interviewing and analysis
  skill-development?
• Apply HUD requirements and standards for
  effective verification techniques?
• Understand and address difficult aspects of rent
  calculation where errors are most likely to occur?

85
Can you now . . .

• Create and maintain a quality control system to
  reduce rent calculation errors
• Assess, analyze and cure quality control
  findings
• Develop and implement a long-term error
  resolution plan

86
YES!!!!
87
Assessment

• Heres how it works . . .
• 1. You have 2 Scantron sheets, both to be filled
  out, plus an assessment with questions
• One to take home
• One to turn in
• 2. When finished, you will turn in the
  assessment with your Scantron sheet

88
Assessment

• You have until 1115 to complete it
• In about 2 weeks, you can log onto the same
  website you registered on (wwww.nmauniversity/rhii
  p) and get the answers for the test then
  compare to your Scantron sheet
• VERY IMPT! Each test will be listed by the
  Summit you attended and the type of program
  covered (HCV or Public Housing)