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The Theory and Practice of Policies & Procedures

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 R ational Outcomes Ensure Consistent Performance and Outcomes

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The Theory and Practice of Policies & Procedures

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  1. The Theory and Practice of Policies & Procedures David Bailey, Vice President – KHEAA Will Shaffner, Director – MOHELA Colleen Slattery, Federal Compliance Officer – MOHELA

  2. 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 Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  3. Policy vs. Procedure • Examples of Policies • Security Policy • Philanthropy Policy • Customer Satisfaction Policy • Increasing the Number of College Graduates • Protecting Consumers Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  4. Policy Design Centralized Control Standard Approval Protocol Version Control Common Components Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  5. Policy vs. Procedure • Procedures • Who • What • When • Where • Why • How (Department level) • Should support Policy Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  6. 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 Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  7. Policy DriversInternal and External

  8. Policy DriversInternal • 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 Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  9. 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,” Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  10. Policy Drivers • FFELP • Federal Register/NPRM • IFAP • Professional Associations, NCHER, etc. • Federal Assets (DL, PUT, etc.) • CR / Change Request • Directives • Other • Sandy, etc. Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  11. Policy Design • Common Components • 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

  12. Procedure Design • Common Components • Standardized Format • 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

  13. Implementation Navigating the Sea of Change 2012 NCHER Knowledge Symposium

  14. Questions ???? Navigating the Sea of Change 2012 NCHER Knowledge Symposium

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