Policy Framework – Explanatory Note
Background:
The previous policy framework was endorsed by the Department's Board of
Management in September 1999 and subsequently approved by the Minister.
Following recommendations made by the 2004 Business Model Review (BMR) in
relation to departmental policy, delegations and procedures, a review of the
departmental policy framework was conducted, particularly addressing where tools
(eg. administrative directions and performance measures) that have been formulated
since the adoption of the policy framework fit within the framework.
Issues:
In the new Policy Framework (Attachment 1), there is a hierarchy of three core types
of policy instrument within the Department:
Government-endorsed Policy;
Departmental Policy; and
Departmental Procedures.
This is a slight modification of the previous policy framework of: Law; Policy;
Mandatory Procedure; Local Procedure. Each level of policy instrument has a
particular authorising environment and may have relating ancillary documents and
measurement tools.
Government-endorsed Policy
The “Law” category has been replaced with “Government-endorsed Policy”, providing
for policy issues approved by the Minister or Cabinet that authorise other
Departmental policy documents. Law was restricted to Acts and Regulations,
whereas “Government-endorsed Policy” incorporates Acts, Regulations, Election
commitments, Government priorities and Whole of Government (WOG) policies,
Directives and Guidelines (eg. Information Standards).
Government-endorsed Policy includes substantive Department-specific policy (eg.
Rehabilitation Policy) and would generally have a life of five to ten years. The major
tool for measuring and ensuring the effective implementation of Governmentendorsed Policy is the Queensland Government’s Charter of Social and Fiscal
Responsibility.
Departmental Policy
The “Policy” category has been replaced with “Departmental Policy” and includes
substantive Department-specific policy, not requiring approval by the Minister or
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Cabinet, but which generally refers to relevant authorising “Government-endorsed
Policy”.
Departmental Policy would generally have a life of four years (corresponding to the
life of the Strategic Plan). The major tool for measuring and ensuring the effective
implementation of Departmental Policy is the Department’s Strategic Plan, supported
by the monthly scorecard and quarterly Board of Management (BOM) Report.
Consistent with the Corrective Services Act 2000, the Strategic Plan and the 2004
BMR Report, Departmental Policy would be further subcategorised into:
Safety and Security;
Rehabilitation;
Reparation;
Criminal and Social Justice;
Support Services: and
Accountability.
Departmental Policy would also include:
The Code of Conduct;
Delegations, Limitations and Authorisations;
Authorisations to engaged service providers;
Approved Forms; and
Administrative Directions.
“Administrative Directions” should only be regarded as temporary or transitional
documents that have a life of no more than a year, when they would either expire or
be replaced with a specific policy instrument.
“Memoranda of Understanding” also sit at Departmental Policy level. As agreements
between agencies for implementing policy, such documents are not regarded as
policy instruments but as ancillary instruments.
Departmental Procedures
The “Mandatory Procedures” category has been replaced with “Departmental
Procedures”. This category covers all other policy instruments that are at a lower
level in the policy hierarchy.
Departmental Procedures would generally have a life of four years (corresponding to
the life of the Strategic Plan). The major tools for measuring and ensuring the
effective implementation of Departmental Procedures are the scorecard,
achievement plans and “Accountability Standards”.
“Operational Standards”, referred to in the BMR, have been replaced with
“Accountability Standards” to give clarity to their function. “Accountability” comes
from the range of components (Operational, Support, Accountability) described in the
BMR. Accountability Standards are not policy documents, but rather measurement
tools to assist with service delivery, management, audit, accountability, performance
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and benchmarking in relation to the effective implementation of policy. Accountability
Standards have application across the Department and private service providers are
required to comply with them as a minimum standard.
Until now, “Mandatory Procedures” had 13 further subcategories. Such a large
number of subcategories made it difficult to find the relevant procedure. To simply
the process, the categories have been reduced to four:
Offender Management (reflecting the Offender Integrated Management
Strategy (IOMS) principles);
Safety and Security (incorporating incident management);
Support Services (BMR); and
Accountability (BMR).
Ancillary documents
Departmental Procedures have a number of ancillary documents, including
appendices, administrative forms and local procedures. Approval of these ancillary
documents is delegated to the Executive Director, Strategic Policy and Services.
Local procedures will now require an authorising Departmental Procedure. In
keeping with departmental principles, local procedures should only contain policy
information that is location-specific either due to geography, staffing or budget
constraints. Any policy material that has whole of Department application should be
contained in a Departmental Procedure and not duplicated in a local procedure.
Appendices contain information ancillary to relevant procedures and may take the
format of a manual, guideline, example or training material and include prescriptive
detail not included in the procedure. An administrative form may also include a
checklist.
As a general principle material should not be repeated in an ancillary document that
is stated in the related, authorising policy instrument. This overcomes the need to
change an ancillary document if the authorising document is amended.
Accountability Standards
The development and approval of Accountability Standards is the responsibility of the
relevant directorate and should be consistent with IOMS principles. The directorate
must consult with Strategic Policy and Services with respect to risk management and
performance issues and the standards must also be compliance checked prior to
approval to ensure consistency with departmental policy instruments.
Accountability Standards should be brief and complement the related policy
instruments. While policy instruments focus on qualitative issues, Accountability
Standards address quantity, timeliness and cost factors.
The relevant Executive Director must approve Accountability Standards.
The Policy and Analysis Branch is responsible for the publication of standards and
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the management of version control. A risk assessment process would be required to
support any proposed amendment to approved standards.
Definitions
Appended to the policy framework is a series of definitions to ensure consistent
meaning is given to various terms across the Department. The definitions situate
various terms within the framework and compare terms of a similar type in relation to
the hierarchy or level of authority (eg. project, strategy, action plan, manual,
guideline).
Risk Management
The Department will take a risk-based approach to the renewal of policy instruments.
The development and review of policy instruments should be collaborative, timely
and actively managed.
Instruments should be progressively reviewed within the Policy Framework in
collaboration with other units within the Department.
Internal Audit, Ethical
Standards and the Chief Inspector routinely target and review departmental
operations.
Further, various activities across the Department (such as the
implementation of IOMS and the review of Legislation) necessitate review of various
policy instruments at particular times. By working collaboratively with these units,
Policy and Analysis reduce duplication by targeting areas for review not currently
targeted by other units.
The Department has established Service Standards to ensure that identified requests
for policy change are managed in a timely manner. When the request for policy
amendment is made to Strategic Policy and Services, the request must be
categorised to assist with prioritisation in order to provide a timely response.
Category 1:Priority
Requests from the Minister, the Director-General, Board of Management or
required by legislation, generally accompanied by a due date.
Category 2:Significant
Tasks that involve consultation with multiple business units, generally
requiring the assigning of a business unit to take the lead in the development
of the policy instrument.
Category 3:Technical
Tasks that involve minimal consultation with business units.
The Department’s Partnership Agreement for the delivery of Strategic and Corporate
Services to Correctional Operations of June 2005 indicates the relevant unit within
the Department responsible for the development or amendment of a policy
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instrument. The unit with the lead responsibility for the policy instrument must
actively manage the progress of the instrument through to the time of its approval.
The new framework clarifies the process for the development and review of local
procedures and operational standards, which in turn will assist the review of existing
policy instruments. For example, existing procedures can be streamlined and
become more focused on policy intent and qualitative requirements, resulting in
briefer, less cumbersome and easier to navigate documents. Other material may be
moved to relevant appendices, local procedures or standards, if required.
When a request is made to develop a new policy, the framework can be used to test
for the need for the policy and to situate where the policy fits. Questions could
include:
Who would be required to authorise this document?;
What existing policy instruments exist that would authorise this document?
(eg. legislation, WOG directives); and
Is there a need for the proposed policy (eg. is there a need for a specific
departmental application)?
On occasions a substantive, stand alone policy document may be appropriate. On
other occasions, a short policy statement, placed at the beginning of a departmental
procedure, may be all that would be needed to state the policy and to operationalise
its intent.
Policy instruments are generally published both on the intranet and the internet,
unless there is an identified and justified “risk to the security or good order of a
corrective services facility” (section 189(3) and (4) of the Corrective Services Act
2000). There are some documents that should not be made available to the public or
to all staff that may lie outside the definition of “risk to the security or good order of a
corrective services facility”, for example, contingency plans. Such documents are not
statements of policy but are more designed to operationalise particular policy
decisions. In accordance with the Information Standard 18 – Information Security,
such documents would be made available to the public and/or to staff in accordance
with the requirements of the applicable category: Public, Unclassified, “X”-InConfidence, Protected or Highly Protected.