# Presentation: 198598

## ORD Policy Development

- SRA October 2005
- Brenda Cuccherini, Ph.D.
- VA Office of Research & Development

## As I write...

-    “Deep into that darkness peering, long I stood there wondering, fearing,
-    Doubting, dreaming dreams no mortals ever dare to dream before.”
- 						Edgar Allan Poe
- 						“The Raven”

##  Fearing...

- Not logical
- To complex
- Overly proscriptive
- Unrealistic
- Short sighted
- Causes immediate non-compliance

## Dreaming...

- Does not induce sleep
- Everyone understands it
- Meets today’s need
- Not outdated in years to come
- Ensures compliance
- ORO site visit: no recommendations

## Why Have Policies?

- Defines specific required actions
- Serves as basis for procedures & functions
- Provides a framework for how an institution functions
- Ensures consistent standards
- Clarifies roles & responsibilities

## Instigating Factors (Why Do I Have to Do This?)

- Response to an “event”
- IG or GAO  investigation
- Clarification of regulations
- Formalize a standard of practice

## The Basis for Policies

- Statutes:
- Enacted by legislation
- Federal statutes codified in US Code (USC)
- Title 38 is VA statutes
- Regulations
- Promulgated by an Agency
- Usually defines what is set forth in a statute
- Framework for compliance with statues
- Federal regulations codified in the Code of Federal Regulations (CFR)
- Regulations are published in Federal Register to notify public and request comments

## The Process (1)

- Evaluate existing policies and regulations
- Determine if there is existing policy
- Determine if current policy needs to be changed
- Determine if new policy will conflict with current statues, regulations, or policies.
- Outline the scope of the new policy

## The Process (2)

- Identify the short or long range impacts of the policy
- Identify a small group of experts
- Think on a national level
- Develop background information
- Brainstorm with experts

## Issues to Decide

- How proscriptive?
- Can facilities comply?
- Is there any impact on other entities?
- Can compliance be measured?
- Is there authority to develop it? (Statutory, regulatory)

## Drafting the Document

- 1st draft:
- Ideas from a small group
- Draft developed
- Shared with a small group
- 2nd draft
- Based on 1st round of comments; revised further
- Circulated to larger group (field & CO)
- 3rd draft based on comments
- Shared with a 3rd larger group depending on the topic
- Final draft goes into concurrence

## Concurrence (1)

- ORD’s final draft
- Agreement by all service directors & senior ORD staff
- Entered into EDMS (correspondence tracking)
- Assigned to specific VA & VHA offices

## Concurrence (2) 

- Review all comments
- Redraft
- Sent to publications (placed into “VA-ese”)
- Review by Under Secretary’s office
- Under Secretary signs policy

## Importance of Field Input

- Institutional memory & past history of the issue
- Experience & expertise in the topic area
- Hands on experience
- Knowledge of other VAs and institutions
- “Real world” prospective
- Insight into implementation process
- Difficulties with compliance

## Reconciling Conflicting Suggestions (1)

- Number of persons offering the suggestion
- Same suggestion
- Similar or  related suggestion
- New or previously considered suggestion
- Importance for compliance & consistency with other policies or practices

## Reconciling Conflicting Suggestions (2)

- Discussion within CO
- Discussions with those offering comment
- Final decision based on:
- Purpose of policy
- Inciting issue
- VHA’s overall direction

## Working with ORO 

- Why
- Wide range of experience
- Common finding on site visits
- Active in Interagency groups
- Benefits of agreement before concurrence
- Seamless transition from policy development, implementation, and oversight/monitoring

## Communication to Field

- E-mail to all research offices
- ORD web-site
- ORD conference call
- Publicize name of contact
- Listed in document or
- Available by contacting ORD

## Major Issues Requiring Time & Effort

- Publication in the Federal Register or
- Amending CFR

## A Thought On Reading Policies

-    “...nothing contributes so much to tranquillize the mind as a steady purpose...”
- 							Mary Shelley
- 							_Frankenstein_

## Slide 21