Ombudsman Procedures and Guidelines Manual 

FDIC 

Office of the Ombudsman 

OO Procedures and Guidelines Manual Updated 4/18/08 

Federal Deposit Insurance Corporation 
 
Concepts and Guidelines Section 1

1 Concepts and Guidelines 

The FDIC Office of the Ombudsman (OO) 

is one of the federal financial regulatory 

agency ombudsman programs created 

pursuant to the Riegle Community 

Development and Regulatory 

Improvement Act of 1994 (Riegle). In 

accordance with provisions set forth in 

Riegle, the OO was created to “(A) act as 

a liaison between the agency and any 

affected person with respect to any 

problem such party may have in dealing 

with the agency resulting from the 

regulatory activities of the agency; and (B) 

assure that safeguards exist to encourage 

complainants to come forward and 

preserve confidentiality.” 

1.1 Mission, Vision, Values 

The mission of the OO is to be an 

effective, neutral, and confidential 

resource and liaison for the banking 

industry and the general public; to 

facilitate the resolution of problems and 

complaints in a fair, impartial, and timely 

manner; to provide prompt and meaningful 

feedback; and to influence positive change 

at the FDIC. 

The vision of the OO is to be highly 

respected by the financial community, the 

public, FDIC managers, and FDIC 

employees as a professional organization 

that provides quality liaison, facilitation 

and problem resolution services. The OO 

values its human resources and diversity, 

and will continue to foster a collaborative 

environment across FDIC divisions and 

offices in the resolution of issues as it 

remains a flexible, creative and efficient 

organization in fulfilling its mission. 

The values of the OO are confidentiality, 

neutrality, and independence. These 

values are described in Section 2 of this 

manual. 

1.2 History 

In 1993, acting FDIC Chairman Skip Hove 

announced that an Ombudsman would be 

located in each FDIC regional and field 

office to “facilitate action on complaints 

and questions from borrowers, lenders, 

and public officials” in connection with 

the FDIC’s liquidation activities. 

Oversight and policy direction for these 

regional and field office Ombudsmen was 

provided by the Washington Office of 

Congressional Affairs and Public 

Relations, which was part of the former 

Division of Depositor and Asset Services 

(DAS). The Resolution Trust Corporation 

(RTC) had a similar function that handled 

problems concerning all RTC activities. 

In this connection, the Resolution Trust 

Corporation Completion Act required that 

a client responsiveness unit responsible to 

the RTC’s ombudsman exist at every RTC 

regional office. 

The OO replaced the DAS Ombudsman 

function at the FDIC. In addition to 

establishing the OO, the FDIC Board of 

Directors, by Resolution (057628) adopted 

August 30, 1994, expanded the services of 

the OO to include problems or concerns 

resulting from the resolution, receivership, 

and asset disposition activities of the 

FDIC. FDIC Chairman Ricki Helfer also 

determined that the OO should serve as a 

feedback mechanism to the Corporation’s 

senior management, keeping them abreast 

of significant issues pertaining to 

corporate operations, and directed the OO 

to serve FDIC employees. 

Initially, the Corporation’s role as a 

receiver and liquidation agent had the 

greatest impact on contacts to the OO. 
Concepts and Guidelines Section 1

The most significant number of inquiries 

to the OO from 1996 to 1999 was from the 

general public and related to bank activity 

such as closed loans, sold loans and other 

disputed asset matters. However, as the 

FDIC’s role in addressing the banking 

crisis of the 1980s and early 1990s was 

completed, and the Corporation initiated 

downsizing in the late 1990s through 

2005, the OO returned its focus to the 

statutory mission of the office. The OO’s 

current focus is external and specifically 

directed toward the banking industry and 

public, with employee concerns addressed 

on an exception basis. 

In 2001, the OO conducted through 

contractors a needs assessment survey of 

its stakeholders, including their 

perceptions of what the OO does well, 

what it could do better, and how it might 

best provide services. Responses to the 

survey, which were anonymous, were used 

to assist the OO in development of a 

business plan and budget that focused 

resources on addressing the identified 

needs of its stakeholders. Analysis of the 

findings indicated that the OO’s chief 

priority should be aggressive marketing 

and external outreach to its stakeholders to 

better inform them of how the OO can best 

be of service to bankers and, in turn, the 

FDIC. Accordingly, the OO performed a 

thorough review of the analysis to identify 

stakeholder needs and desired internal, 

external, and programmatic actions 

During the 2000s, the OO has 

implemented a series of initiatives focused 

on the banking industry. In 2002, the OO 

created a five-year Industry Outreach Plan 

that included visits by the Regional 

Ombudsmen to DSC Regional Directors to 

present the OO’s Outreach Plan to 

bankers. The OO Regional Ombudsmen 

also visited and telephoned bank 

commissioners, bankers, and state banking 

associations to introduce the OO and its 

services. The OO met its goal of 

increasing awareness of the OO functions 

and services by participating in over 1,000 

in-person and telephone visits to bankers 

each year through 2006. The 2007 

Outreach Plan concentrated on assisting 

Minority and DeNovo banks. The 2008 

Outreach Plan focuses on new CEOs. 

The OO plays an important role in 

contacting and surveying institutions that 

have used the Supervisory Appeals 

Process. In this connection, the OO 

compiles the feedback and 

recommendations it receives from the 

industry regarding the Supervisory 

Appeals Process and periodically reports 

this information to the Supervision 

Appeals Review Committee (SARC). 

As may be requested by the Division of 

Resolutions and Receiverships (DRR), the 

OO also sends representatives to bank 

closings to communicate with the media 

and to help with matters of public 

confidence. 

1.3 Functions 

The key business functions of the OO are 

liaison and problem resolution; feedback 

and reporting; and outreach and 

awareness. 

1.3.1 Liaison and Problem 

Resolution 

Liaison and problem resolution services 

provided by the OO to stakeholders 

include: 

• Responding to inquiries and 

providing general assistance 
Concepts and Guidelines Section 1

• Making referrals, as appropriate, to 

internal FDIC or external sources 

• Facilitating the resolution of 

problems or complaints 

• Providing conflict management 

services 

• Providing industry feedback to the 

SARC relating to FDIC's 

Supervisory Appeals Process 

• Participating as a neutral in FDIC 

bank closings to enhance public 

confidence 

• Providing meeting facilitation 

services 

• Serving as a neutral source of 

management skills for special 

corporate projects (e.g. Regulatory 

Burden Relief, Hay Group Survey) 

1.3.2 Feedback and Reporting 

The OO performs the following 

management reporting activities: 

• Reports on general and systemic 

issues 

• Analysis of contacts and issues 

• Research and trend analysis 

• Feedback on problems or 

complaints regarding FDIC 

policies, procedures, or activities 

• Policy recommendations to 

facilitate change within the 

Corporation 

1.3.3 Outreach and Awareness 

The OO maintains an aggressive outreach 

program that includes: 

• Staff participation at national-level 

banking conferences (See Circular 

2710.14, “Corporate Outreach 

Program”) 

• External marketing to banks and 

state banking commissioners 

• Banking association conferences 

• National-banking conferences 

• Assistance to agencies that are 

developing ombudsman programs 
OO Independence, Neutrality, Confidentiality Section 2 

2 Independence, Neutrality, 

Confidentiality 

The OO has continuously studied 

ombudsmanry to identity, implement, and 

update best practices consistent with the 

Riegle Act mandate and mission of the 

FDIC. 

The OO has determined that the American 

Bar Association 2004 Standards for the 

Establishment and Operation of 

Ombudsman Offices (Standards) represent 

the most current and comprehensive 

statement of Ombudsman practice. Such 

standards were developed by a broad 

spectrum of ombudsman associations, 

practitioners, academics, lawyers, and 

other interested parties. This FDIC OO 

policy statement, therefore, recites and 

affirms the Standards to the maximum 

extent practicable, defining, limiting, and 

customizing the definitions and 

application of Independence, Neutrality, 

and Confidentiality as they relate to the 

FDIC OO. 

The fundamental underlying premise of 

the Standards is that all Ombudsmen must 

operate within certain basic authorities and 

essential characteristics. The Standards, 

therefore, provide practical advice and 

guidance on the structure and operation of 

Ombudsman offices so that individuals 

who avail themselves of their aid may do 

so with greater confidence in the integrity 

of the process. The Standards recognize 

that practical and political considerations 

may require variations, but that all 

Ombudsman programs are built upon the 

core values of Independence, Neutrality, 

and Confidentiality – without them, an 

Ombudsman office cannot function 

effectively. 

2.1 Values 

The application and limitations of these 

values within the FDIC OO are detailed in 

the “Establishment and Operations” and 

“Limitations” sections. 

2.1.1 Independence 

To be credible and effective, the OO must 

appear, and actually be free from, 

interference in the legitimate performance 

of duties, including being free from 

control, limitation, or retaliation of anyone 

who is subject of a complaint or inquiry. 

The OO achieves this independence by 

reporting directly to the Chief Operating 

Officer. 

2.1.2 Neutrality 

The OO conducts impartial inquiries and 

investigations that are free from bias and 

conflicts of interest. Impartiality does not 

preclude the OO from developing an 

interest in securing changes; the OO 

advocates changing any process that is 

unfair. 

2.1.3 Confidentiality 

Confidentiality is essential in 

ombudsmanry. Confidentiality promotes 

disclosure from reluctant complainants, 

elicits candid discussions by all parties, 

and provides an increased level of 

protection against retaliation to or by any 

party. Confidentiality is another factor 

that distinguishes ombudsmen from others 

who receive and consider complaints such 

as elected officials, human resource 

personnel, government officials, and ethics 

officers. The OO will not voluntarily 

disclose and should not be required to 

involuntarily disclose any information, 

except where there is: 

• Imminent risk of serious harm to 

persons or property 
OO Independence, Neutrality, Confidentiality Section 2 

• Allegations of fraud, waste, or 

abuse 

• Express OO contact confidentiality 

waiver 

• Judicial process (e.g., subpoena, 

deposition, testimony) 

• General, public-domain 

information request 

 

2.2 Establishment and 

Operations 

The FDIC Ombudsman applies 

Independence, Neutrality, and 

Confidentiality to its day-to-day 

operations through: 

Establishment: explicitly by statute and 

defined by FDIC Board Resolution, 

Chairman and Chief Operating Officer 

directions. 

Reporting lines: independent from line 

management, and report directly to the 

FDIC Chief Operating Officer. 

Management access: direct access to the 

highest levels of FDIC senior management 

Information access: access to all 

information within the organization, 

except as restricted by law 

Legal counsel: access to resources for 

legal advice and counsel 

Records: creation and maintenance of the 

minimum records required by law 

 

Subject matter: complaints and questions 

about alleged acts, omissions, 

improprieties, and systemic problems 

within the OO’s jurisdiction as defined in 

the charter establishing the office 

Discretion: judgment to accept or decline 

to act on a complaint or question 

Initiative: acting on the OO’s volition to 

address issues within its prescribed 

jurisdiction 

Fairness: timely procedures to aid in the 

just resolution of a complaint or problem 

Resolution: reconciling issues at the most 

appropriate level of the entity 

 

Methodologies: 

1. Conducting fact finding and reporting 

such findings 

2. Developing, evaluating, and discussing 

options available to affected 

individuals 

3. Facilitating, negotiating, and 

informally mediating 

4. Making recommendations for the 

resolution of an individual complaint 

or a systemic problem to persons who 

have the authority to act upon them 

5. Identifying complaint patterns and 

trends 

6. Educating 

7. Issuing periodic reports 

Retaliation: protecting those seeking 

assistance from, or providing information 

to, the ombudsman from reprisal 

Written policies: incorporating the 

precepts of independence, neutrality, and 

confidentiality into all OO policies, 

including those addressing the broad areas 

of outreach, case processing, data input, 

and trend analysis and reporting. 

2.3 Limitations on the 

Ombudsman’s Authority 
OO Independence, Neutrality, Confidentiality Section 2 

To ensure the appropriate application of 

the OO’s independence, neutrality, and 

confidentiality, the OO’s authority must be 

limited. The OO should not, nor should an 

entity expect or authorize the OO to, 

function in the following capacities: 

Decisions: make, change or set aside a 

policy, administrative decision, or 

otherwise determine rights 

Compulsion: directly compel an entity or 

any person to implement the OO’s 

recommendations 

Formal disputes: accept jurisdiction over 

an issue that is currently pending in a legal 

forum 

Union: address any issue arising under the 

collective bargaining agreements or falling 

within the purview of any existing federal, 

state, or local labor or employment law, 

rule, or regulation, unless the OO is jointly 

authorized to do so by the FDIC and 

National Treasury Employee’s Union 

Role: act in a manner inconsistent with 

the granting of and limitations on the 

jurisdiction of the office when discharging 

the duties of the OO 

Notice: accept formal notice, or act in any 

way to suggest acceptance, on behalf of 

the FDIC in lieu of FDIC established 

procedures, mechanisms, and points-ofcontact. 
OO Customer Service Standards Section 3 

3 Customer Service 

Standards 

The telephone plays an important role in 

providing service to OO’s customers. It is 

sometimes the only means of timely 

communication. While far fewer in 

number, the OO also receives written 

inquiries. The OO telephone and other 

service standards are consistent with FDIC 

standards, policies, and procedures, 

including those outlined in Circular 

3110.1, for professional and courteous 

telephone service. The following 

guidelines are in addition to and 

supplement the aforementioned corporate 

policy on customer service standards. 

3.1 Standards 

Telephone coverage is during the business 

hours from 8:00 a.m. to 5:00 p.m. 

Regional offices shall observe the same 

business hours (adjusted for geographic 

location). When Regional Office staff is 

unable to adhere to the above hours of 

telephone coverage due to travel, etc., they 

will comply with the terms set forth in 4, 

below. 

1. All calls should be answered within 

three rings. 

2. As directed in FDIC Circular 3110.1, 

the OO strives for a 5 percent or less 

abandonment rate of the total number 

of calls received. Abandoned calls 

result when a caller hangs up after 

more than 10 seconds. 

3. During periods of high call volume or 

non-business hours, voice mail is 

available for the caller to leave a 

message. Voice mail messages are to 

be reviewed daily by Headquarters 

staff and responded to within one 

business day. 

4. OO staff unavailable during business 

hours because of training, leave, etc., 

will record a voicemail asking callers 

to leave a message if the matter is not 

time sensitive. Voice mail messages 

should include the FDIC Central Call 

Center’s toll free number as an 

alternate contact source, 1-877-275-

3342, option 1 for English, 1 again for 

bankers, and then 3 for the Office of 

the Ombudsman. 

5. When OO staff are absent from the 

office for extended periods, personal 

voicemail greetings should indicate the 

anticipated date and time of return, as 

well as the toll free number for the 

FDIC Central Call Center or the name 

and telephone number of another OO 

staff member as an alternate contact. 

6. Acknowledgment of all letters, 

facsimiles, or internet inquiries will be 

made by telephone or internet within 

three business days of receipt, if 

possible. In the event that no 

telephone number or internet address is 

available, every effort will be made to 

resolve the case as quickly as possible 

and respond appropriately to the 

written inquiry. 

3.2 Responsibilities 

OO managers shall: 

1. Foster an environment that emphasizes 

customer service. 

2. Routinely evaluate the OO’s service 

process for quality assurance and 

process improvement. 

3. Routinely review the information 

contained in the OO’s recorded 

announcements and menus, updating 

this information, as necessary, for 

correctness, ease of understanding, and 

mission objective.
OO Customer Service Standards Section 3 

• FDIC management promptly. This 

can include emerging issues, 

fairness issues, and matters 

involving FDIC’s image or 

reputation. This type of feedback 

is typically verbal and conveyed 

through meetings or calls by OO 

management or Regional 

Ombudsmen. Depending on the 

nature and complexity of an issue, 

talking points may be developed 

for the calls or meetings. A more 

comprehensive written report of a 

matter may follow initial oral 

contact. 

• Trending Issues – Information 

pertaining to known or potential 

trends. Data is watched and could 

be provided as feedback at some 

point depending on the issue. An 

early warning of a trend is 

typically verbal and conveyed 

through meetings or calls by OO 

management or regional 

ombudsmen and may be 

subsequently followed by a 

comprehensive written report. 

• Routine – Generally historical 

information, which may also 

include follow-up information 

regarding the status or results of 

actions taken. This type of 

feedback is written and can include 

briefing reports, summary reports, 

presentations, speeches, and 

talking points. 

3.3 Feedback content 

Feedback subject matter can include one 

or more of the following: 

• Policy issues 

• Fairness issues 

• Systemic or emerging issues 

(known or potential) 

• Efficiency opportunities 

• Potential for Congressional 

inquiries 

• Process issues 

• FDIC image and reputation 

• Issue resolution (how an issue was 

resolved) 

• Case resolution/facilitation 

examples 

• Success stories 

• Lessons learned 

• Potential national trends 

• Site-specific trends 

• OO initiatives and outreach 

• Input about the Chairman’s 

priorities 

• Other significant information, 

observations, or suggestions 

The primary client base for feedback and 

reporting is internal, and generally, FDIC 

management. External clients (e.g., 

bankers, public) are secondary. 

3.4 Procedures 

The steps involved in analyzing data for 

feedback purposes can vary depending on 

the type of analysis required, depth and 

breadth of that analysis, purpose and 

nature of the feedback being given, and 

time constraints 

3.4.1 On-going internal data 

review 

OATS data is reviewed monthly. Senior 

Ombudsman Specialists review findings, 

such as issues requiring further analysis, 

observations, and statistical data. The OO 

staff member assigned primary 

responsibility for feedback and reporting 

generally undertakes this review. In 
OO Customer Service Standards Section 3 

addition, other types of data review may 

be conducted, including: 

• Variance analysis – review of raw 

numerical contact data across issue 

codes and over time to identify and 

quantify trends. 

• Systemic/trend analysis – review 

data to identify issues that are 

national or regional in scope. 

Systemic issues can be based on 

frequency, sensitivity, potential for 

recurrence, or indication of a 

process failure. 

3.4.2 Identification of emerging 

or sensitive issues 

When an OO staff member becomes aware 

of a significant or sensitive issue; he or she 

is responsible for immediately bringing it 

to OO management’s attention. The 

employee would still handle the matter 

and attempt to resolve the matter at the 

lowest possible level of FDIC 

management. 

3.4.3 Reporting and recording 

issues and findings 

Each staff member is responsible for 

reporting significant issues and activities 

routinely and for timely recording of those 

issues in OATS. In addition, OO 

management will ensure that feedback 

reports are available to all OO staff. 

3.4.4 Assigned feedback and 

reporting projects 

OO management periodically assigns one 

or more staff members to prepare a report. 

These reports can vary in size and scope 

and include quarterly reports, year-end 

retrospectives, and a variety of ad hoc 

reports focusing on one issue division or 

office. 

For reports requiring extensive and 

thorough review of data, the responsible 

OO staff member should develop a project 

plan that identifies: 

• Scope and purpose of the feedback 

• Proposed audience 

• Proposed format and content 

• Research methodologies to be used 

• Resources allocated to project 

• Responsibilities of other OO staff 

to provide input 

• Reporting milestones 

• Time line for completion 

3.5 Systemic Issues 

A basic function of the OO is to serve as 

an agent for positive change in the FDIC. 

The OO is in a unique position to bring 

issues to the attention of FDIC 

management and to make 

recommendations related to FDIC 

processes, procedures, policies, systems, 

or regulations. 

For an issue to be considered systemic, 

two conditions must be met: (1) the issue 

must have broad corporate implications 

(either national or regional in scope), and 

(2) the issue must indicate a need for 

change to FDIC processes, procedures, 

policies, systems, or regulations to 

improve efficiency or to correct patterns of 

inappropriate behavior, inconsistent 

enforcement, non-responsiveness, or 

unfairness. For the purposes of these 

procedures, “national in scope” means 

problems or issues that have appeared or 

have a clear potential to appear in two or 

more geographical locations (otherwise, 

the problem or issue would be considered 

regional in scope). 
OO Customer Service Standards Section 3 

A systemic issue may be identified by the 

existence of multiple cases relating to an 

issue or by fewer cases (sometimes only 

one case) where the OO determines that 

the issue has significant impact on the 

effective and efficient accomplishment of 

the FDIC’s mission. 

When a systemic issue is identified, a 

Systemic Issue Case (SIC) shall be 

created by the OATS administrator. A 

SIC is a separate case in OATS that is 

opened subsequent to, and to provide 

follow up and resolution of, an original 

case that has been identified as being 

potentially systemic in nature. This case 

shall be assigned to an OO employee 

designated by the Director or his designee 

to handle an approved systemic issue. 

Every OO employee is responsible for 

identifying and bringing forward any 

observed systemic issues. Whenever OO 

management rejects an issue as being 

systemic, that determination and the 

rationale will be communicated to the 

identifying employee.

3.5.1 Potential Systemic Issues 

Potential systemic issues are typically 

identified in one of two ways: 

• An OO staff member handles an 

individual case that he or she 

believes has systemic implications, 

or 

• Analysis of OATs data uncovers a 

possible systemic issue. 

Any OO employee who believes that 

he/she has identified a potential systemic 

issue first notifies and discusses the issue 

with appropriate Ombudsman. Research 

of a potentially systemic issue requires 

approval by OO management. 

If a possible systemic issue is identified 

during analysis of OATS cases, OO 

management may assign a staff member to 

research the issue and open a SIC in 

OATS. 

After a potential systemic issue is 

approved for further research, the 

employee conducts a thorough analysis of 

the issue. The analysis should include the 

following factors: 

1. FDIC programs and geographical areas 

involved; 

2. Research conducted; 

3. Frequency and scope (regional or 

national); 

4. Results of analysis and impact; 

5. Recommendations. 

Discussion with other OO employees and 

managers and a review of OATS records is 

encouraged and would generally be 

appropriate at any point in the process. 

Findings are presented in a memo from the 

employee to the Director within 30 days of 

the identification of the potential systemic 

issue. These guidelines may be shortened 

at management discretion due to 

sensitivity. 

At any time during this review, OO 

management can determine that the 

subject matter does not rise to the level of 

a systemic issue. 

3.5.1.1 Documenting Systemic 

Issues in OATS 

When an issue is approved as potentially 

systemic, the OO employee assigned the 

matter opens a SIC in OATS. The 

employee then begins the systemic issue 

analysis as described below. 
OO Customer Service Standards Section 3 

The SIC should be completed as described 

in the OATS User Manual. The SIC 

should include the following: 

Characteristics of issue: 

1. FDIC programs and geographical areas 

involved; 

2. Research conducted; 

3. Frequency and scope (regional or 

national); 

4. Results of analysis and impact; 

5. Recommendations; 

6. Final determination by OO 

management; 

7. If not approved, stated reasons; 

8. If approved as a SIC, steps taken to 

raise the issue to appropriate FDIC 

management; and 

9. Final disposition of the issue (what 

FDIC did to resolve the matter). 

3.5.1.2 Approval of Systemic 

Issues and Strategy for 

Systemic Change 

The Director or his designee reviews the 

analysis, requesting any clarification or 

additional information, and approves or 

disapproves the issue as systemic. 

If the issue is not approved as systemic, 

the employee records the reasons in the 

SIC as specified in the OATS User 

Manual. 

It is expected that the Director or his 

designee will approve or reject an issue as 

systemic within 30 days of receipt, which 

would be within a maximum of 60 days of 

identification. If an issue is determined to 

be systemic, the Director or his designee 

provides guidance and recommendations 

for systemic change to senior FDIC 

managers who, along with the OO 

Director, determine an appropriate course 

of action. 

All decisions regarding systemic issues 

will be documented in OATS and 

communicated to the concerned OO staff 

as soon as possible, including any 

decisions by FDIC management to take no 

action. 

3.5.1.3 Monitoring and 

Communicating Progress 

OO staff actively monitors both potential 

and substantiated systemic issues. The 

following steps will be taken to ensure 

consistency in the process: 

The Associate Ombudsman or his 

designee assigns an employee for each 

approved systemic issue. The employee 

will: 

• Monitor systemic change activity, 

• Input relevant activity into the sic 

in a timely manner, at least 

monthly, 

• Facilitate internal OO coordination 

and communication, and 

• Perform any task associated with 

the systemic issue. 

An alternate employee may be designated 

for each systemic case to update the SIC in 

the absence of the designated employee. 

OO managers periodically inform the OO 

employee of corporate-wide systemic 

efforts and progress achieved. 

Systemic issues are routinely discussed 

and monitored by OO management. 

Contact Follow-up. The initial individual 

or group of individuals raising the issues 

may be informed that their case has been 
OO Customer Service Standards Section 3 

referred for high-level management 

review. The respective OO employee 

shall be responsible for keeping the 

contact apprised of the progress of the case 

to the extent possible without violating the 

OO’s confidentiality policy. These 

updates will generally occur monthly. 

3.5.1.4 Resolution of Individual 

Case(s) Giving Rise to 

Systemic Issue 

When an individual case becomes part of a 

systemic change effort, the individual case 

generally is not pursued by itself on a 

parallel track. If an individual case has 

multiple issues, those issues not included 

in the systemic problem can be pursued on 

a parallel track. If non-systemic issues are 

pursued in parallel, OO staff members 

must take care to defer to the centralized 

systemic effort to avoid disruption of 

OO’s systemic activities and 

miscommunication across divisions and 

offices. To accomplish this, the 

designated employee and the involved OO 

employees must maintain continuous 

communication with each other.