Knowledge
Human Resources Policy Development: Securing a Positive Audit
The Department of Labor (DOL) is the federal leader in encouraging
government
management training in human resources (HR) policy, process and
procedure construction. Due dilligence is required for HR policies and related procedures pertaining
to safety, accessibility, representation and anything that applies to
companies receiving federal money.
Policies and procedures
that do not reflect actual skills and worker relationships often fail
because they are created by a manager in a vacuum. Including all
managerial stakeholders (CEO, chief financial officer, program
manager, supervisor, employees) in the
feedback loop will ensure a better process. Hiring an outside analyst
who has no stake in the outcome is often the best way to get a clear
statement of corporate will.
Completing a positive audit is a best practice for ensuring that
all
procedures have been reviewed. The audit process for procedures remains
the same whether it involves safety, information technology (IT),
accounting or security. Companies need to ask themselves if they have a
set of policies governing procedures, a process that governs how
procedures
are created and a record that the company actually follows
goverment-required policies, processes and procedures. A positive audit
is that record.
Definitions
- A policy is a statement of purpose.
- A process is how a company develops procedures from stated policies.
- A procedure is a step-by-step instruction on related work in accordance with a policy.
Company Responsibility
A Corporate Executive Board white paper details a process for
creating and managing HR
policies. It details the role of the central policy group,
prioritization and
creation of policies and enforcement and review of existing
policies. The combination of a central authority connecting to all
the stakeholders and a guarantee of employee feedback helps contracting
companies gain buy-in from both managerial authorities and all
employees.
Employee Responsibility
Employees will feel less bound to a policy if they are left out of the
review. They need to give feedback to all policy groups because any
change may directly affect their jobs. An example would be if
a disabled employee discovers a direct federal policy violation when a
new building is being erected with no easy wheelchair access. Although the
employee's supervisor is not responsible for the problem,
the employee should still follow every HR chain of command until a
solution has been
reached. The procedure for the employee HR complaint follows the set
policy in federal regulations (Section 508). A policy auditor will see
the complaint and
its resolution and report back to the central policy group.
Policy Development Tips
Considering the responsibilities previously stated, what does it mean to have a
good policy and procedure and to pass a government audit of that
procedure? One example from federal
government IT policy is that the originator of a code cannot
be its reviewer and an auditor cannot be the originator or the reviewer. This
requirement means that three separate people with three separate signatures are needed to pass a
review process.
A security procedure needs to follow a similar course. The person who initially
enters a new employee into the database cannot be the person who
verifies the information nor the person who cross-references the
electronic signatures into a common file to ensure a secure audit trail.
The Positive Audit
A positive audit is a complete documentation of what a procedure
should look like if all known procedures are followed. It is often a
single piece of paper with all the necessary signatures. Even a
negative audit, such as the previously mentioned 508 complaint, shows
good
governance if an auditor can look at the document, see that a given
procedure was followed to its logical conclusion; the
appropriate departments were notified, consulted and documented in the
procedural
discussion and that a procedure was changed to address the need.
Policy and Procedure Auditing
An independent policy auditor assures that policies and procedures
follow federal contracting guidelines, current complaints to the
HR department are initially addressed from a policy standpoint and
that procedures are rewritten to fix the problem. As the DOL has
promulgated many procedures that cover all employers using federal
money, a well-trained HR workforce kept up-to-date with policy
development is required. A
corporate best
practice is to ensure an independent auditor meets with
the central policy group on an annual basis, receives permission to
interview all
managers
and reports a list of findings to be resolved. The bottom line on
auditing is that every single policy needs to be reviewed internally.
Catching procedural flaws before the procedures are set and audited by
an outsider is a more desirable outcome..
Useful
Links
Corporate Executive Board: Creating and Managing HR Policies
http://hr-management.hr.toolbox.com/research/creating-and-managing-hr-policies-10169?sp=cm
How Do Internal Auditors Add Value? Characteristics Common to Top-Rated
Audit Shops Help to Shed Light on the Nebulous Concept of Adding Value
http://findarticles.com/p/articles/mi_m4153/is_1_60/ai_98009241/