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NAPBS Accreditation - A Suggested Approach by Derek Hinton
December 22, 2012 posted by Steve Brownstein
The blond spent an hour filling out the application for NAPBS Accreditation. The last question was the hardest, but finally, beside “Sign Here,” the blond’s memory came through and with a flourish, she boldly penned in “Sagittarius”.
I think I’ll be in trouble with the wife and daughter for that one.
Let’s be honest though, most of the standards in the accreditation process are a little more difficult, even for you brunettes. It seems a lot of the difficulty is organization—how to begin, how to create an infrastructure to complete the project. I’d like to take one standard/Clause and suggest an approach. It’s one of the easier clauses, 5.2, “Current Employment”.
5.2 Current Employment
CRA shall have procedures in place to contact consumer’s current employer directly only when authorized by client and/or consumer.
This is fairly straightforward, is it not? You need to ensure that when performing an employment reference, you do not contact the current employer unless authorized by the client and/or the consumer.
The first step of course is to make sure you are abiding by the standard. When I was growing up I got some basketball injury to my thumb. I told my Dad “Dad, it hurts when I bend my thumb this way.” My Dad looked at me and said “Son, don’t bend your thumb that way.” If you are contacting current employers regardless of authorization, well, don’t do that.
You should type the clause and state that you comply and how you comply.
Measure & Documentation Typically Subject to Desk Audit
The second step is to document, in writing, your policy and procedures used to reasonably ensure the standard is followed. So you will need to develop a policy and procedure. It might be something like this:
Verifying Current Employment Policy and Procedure
When performing verifications, <CRA’s> policy prohibits contacting a consumer’s current employer directly unless authorized by client and/or consumer. Specifically, our procedure is to only contact a consumer’s current employer if authorization is provided on the employment application, explicit authorization is provided within the Disclosure/Authorization signed by consumer, AND/OR our CRA Verifications Leader has enabled the verification after initially being blocked by our technology platform.
Now, this is important. Create another document “Policy and Procedure Manual.” Copy and paste this 5.2 policy and procedure into the Policy and Procedure Manual Document.
Potential Verification for Onsite Audit
Abiding by the standard and creating a Policy and Procedure that gathers dead flies and curled up spiders on the shelf is not good enough. You will be audited on-site audit and the auditor may verify the following:
CRA shall make available to auditor tools or systems used (except actual personally identifiable information) to demonstrate procedures in place to prevent unauthorized contact with current employer. If interviewed, CRA employees responsible for verification of current employment shall demonstrate knowledge of authorization requirement and describe methodology by which they receive learn about such requirement. CRA employees responsible for current employer contact shall be able to access current copy of documentation, AND/OR CRA employees shall identify person/s responsible for such contact.
So how, exactly will you demonstrate this? You will look at the attributes of and Suggestions for Onsite Audit that the auditor will look for in policy, procedure and activity.
Attributes of and Suggestions for Onsite Audit What auditor should look for in policy, procedure, activity
For this standard/Clause, here’s what the auditor will be looking for:
CRA may provide information regarding verification of current employment to employees who are responsible for such verification by using various methods which include, but are not limited to: 1) written manuals, 2) online manuals or instructions, 3) classroom training, 4) on-the-job training, and/or availability of expert to provide assistance when needed. If classroom or on-the-job training is used, a training outline or manual should be used. Methods used to reasonably ensure consumer's current employer is contacted only with authorization include, but are not limited to: 1) authorization provided on employment application, 2) explicit authorization provided within Disclosure/Authorization signed by consumer, AND/OR 3) technology shall prevent verification of current employment by CRA employees until CRA Leader has so enabled.
So,you will need to provide information regarding this stipulation to employees who are responsible for verifications by using various methods which include, but are not limited to:
• Written manuals,
• Online manuals or instructions,
• Classroom training,
• On-the-job training, and/or availability of expert to provide assistance when needed. If classroom or on-the-job training is used, a training outline or manual should (not “may”, “should”) be used.
If you do not have a written manual for your verification employees, it might behoove you to create one. So, to help comply with this clause you might write a verification employee instruction such as:
Verification Employee Instruction Regarding Current Employment
When a consumer’s current employer is contacted for a verification, it has the potential to negatively affect the consumer if the consumer’s current employer does not approve of the consumer’s activities.
Therefore, prior to contacting a consumer’s current employer you need to ensure that authorization is provided on the employment application, explicit authorization is provided within the Disclosure/Authorization signed by consumer, AND/OR your CRA Verifications Leader has enabled the verification after initially being blocked by our technology platform.
Now, again, create a new document. Maybe you call it “Verification Employee Instruction Manual”. Copy and paste the above language into this new Verification Employee Instruction Manual. There will be other clauses you will later add to this manual.
Needless to say, this example was an approach to the process. You or the supervisor will have to sit down with your verification employees and go over all the verification clauses and procedures. If the auditor asks them a question, you don’t want them looking off into space, blowing bubbles or idly scratching something that itches.
And throughout the process keep in mind: Accreditation is not the end—it’s the means. The process itself, the task, will go a long way to improve your processes, make you more efficient, educate your employees and have them do a better job. Your liability (and any resulting attorney expenses) will go down with a tight, compliant, CRA ship. And of course, along the way, you will learn your business better and as an accredited firm have an edge on the competition.
