The Theory and Practice of Policies &
Procedures
David Bailey, Vice President – KHEAA
Will Shaffner, Director – MOHELA
Colleen Slattery, Federal Compliance Officer – MOHELA
Policy vs. Procedure
• Policies
– Designed to Drive Rational Outcomes
– Ensure Consistent Performance and Outcomes
– Created to Convey Intent
– Instilled to Document Commitment
– Driven by Boards or Government Organizations
2
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy vs. Procedure
• Examples of Policies
– Security Policy
– Philanthropy Policy
– Customer Satisfaction Policy
– Increasing the Number of College Graduates
– Protecting Consumers
3
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy Design
•
•
•
•
4
Centralized Control
Standard Approval Protocol
Version Control
Common Components
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy vs. Procedure
• Procedures
– Who
– What
– When
– Where
– Why
– How (Department level)
• Should support Policy
5
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy vs. Procedure
• Examples of Procedures
– Security - New Hire Badging
– Philanthropy - Charitable Giving
– Customer Satisfaction - Ensuring Satisfied Customers - Escalation
– Increasing Graduates - Greater Pell Accessibility or Broaden Admissions
– Protecting Consumers - Complying with SCRA or Greater Transparency
6
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy Drivers
Internal and External
Governance/Boards
Mission and Strategic
Plan
Policy
Procedure
Legislative/Statutory
Regulatory (CFPB,
FFELP, FSA – DL, other)
Policy
Procedure
Policy Drivers
Internal
• Business Need
– Requirements that an Organization Must Follow
– Achieve Goals and Objectives from Strategic Plan
– Meet Internal Metrics
• Best practices
– A Method or Technique that Consistently Shows Results Superior to those
Achieved by Other Means
– Efficiently Process and Service Loans
– Transparency or Open Records
8
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy Drivers
• CFPB
– Increased Oversight
• Private Loan Origination
• Loan Servicing
• Ombudsman/Complaint Management
– Servicemembers Civil Relief Act (SCRA), etc.
– Increased Risk
• The CFPB can obtain “any appropriate legal or equitable relief with respect to a
violation of Federal consumer financial law,”
9
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy Drivers
• FFELP
– Federal Register/NPRM
– IFAP
– Professional Associations, NCHER, etc.
• Federal Assets (DL, PUT, etc.)
– CR / Change Request
– Directives
• Other
– Sandy, etc.
10
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Policy Design
• Common Components
–
–
–
–
–
–
–
–
–
–
–
11
Purpose
Scope
Roles and Responsibilities
Management Commitment
Coordination among Organizational Entities
Compliance
Exceptions
General Information
Signatories
Terms and Definitions
Effective / Implementation Date
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Procedure Design
• Common Components
– Standardized Format
•
•
•
•
–
–
–
–
–
12
Purpose
Objective
Scope
Terms, Definitions, Acronyms
Desktop Procedures (step by step)
Review and Approval Process
Version Control
End User Acknowledgement
Annual Validation
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Implementation
13
Navigating the Sea of Change
2012 NCHER Knowledge Symposium
Questions
????
14
Navigating the Sea of Change
2012 NCHER Knowledge Symposium