To emphasize the need for compliant policies and procedures we need to refer to a quote from the great Yogi Berra, “If you don’t know where you’re going, you might not get there.” Over the years we have seen organizations doing everything right but without compliant policies and procedures as a road map to ensure consistent compliance, they have failed government audits. Other organizations that have compliant policies and procedures but have not shared them with the people who need them (i.e. they have them but they are gathering dust on the shelf and are probably obsolete), have also failed, because people did not know what the organization’s goals were or how to respond to compliance situations.
Times have changed. Your workforce is no longer content with staying at the same organization or in the same position for an extended period of time. With the continual movement of people in and out of organizations it is imperative that you establish a stable foundation of compliance. This is accomplished through the development of sound, compliant policies and procedures and continual employee education. When prepared and fully implemented, policies and procedures can:
- Ensure operating consistency from period to period and contract to contract;
- Decrease process variations eliminating waste and increasing performance;
- Provide an insurance policy against personnel loss and turnover; and
- Establish a “road map” for continued compliance.
Policies set the guiding principles and direction of the organization. Procedures establish the process for conducting your business and meeting the operating requirements of your policies. Both should include: (1) a statement of its purpose; (2) the establishment of the scope of coverage or applicability; (3) assignment of associated responsibilities for the execution of the policy or procedure; (4) a detailed statement of the policy or procedures requirements; (5) an effective date; and (6) timing of reviews and required updates.
It is extremely important that once written all personnel that will be involved in its implementation be trained and that any new personnel also receive training.
Policies and procedures must be established for the acceptance of your accounting system, cost estimating system, procurement system, and your ethics and business conduct program. DCAA and DCMA consider effective policies and procedures as the first line of defense against fraud, waste and abuse. If they determine, that they do not exist or are not adequately provided to those responsible for their implementation, you will fail.
For more information on the importance and value of compliant policies and procedures join our webinar “Policies and Procedures – A Road Map to Continued Compliance” on June 27, 2017. You can register at: https://attendee.gotowebinar.com/register/5346748407343387650