Policies & Procedures: What about Generic Manuals?

Last time, we discussed the purpose of policies and procedures and companies whose materials are generic to the industry and do not reflect a company’s reality.  This time, let’s look at another common issue among regulated organizations:

Creative manuals.  Creativity is a good thing, except when it holds you to a standard that’s impossible to meet. Recently, we’ve met clients who had comprehensive operational policies, but then cobbled together bits and pieces from others’ manuals to add to their own.  There’s nothing wrong with improving your materials if you find a process you like better.  However, we caution clients when doing this:

  • Others’ policy manuals are copyrighted and when someone shares his policies with you, and you copy them and make them your own, you may be violating the copyright.  In today’s culture, plagiarism abounds in academia and business, and the penalties continue to escalate.
  • Conflicts occur when you copy someone’s policy, although your own manual covers the same process, or, when the new material creates ambiguity.  More often than not, there are conflicting timeframes, requirements and guidelines, and the organization appears ‘schizophrenic’ to a regulator.  The question inevitably comes up: which process are you following?  Sadly, sometimes the answer is “Neither one.”
  • When you mix new policies with your own, you may introduce processes, or parts of a process, that speak to another regulator’s or accrediting organization’s standards. Even worse, those supplemental documents may mention another accrediting organization by name! Recently, a new client of ours had two sets of policy manuals, all in beautifully labeled and tabbed binders.  They had no idea what was contained in each set and more importantly, the materials referenced an accrediting organization that was not theirs.  Imagine the surveyor’s response to see that the client was committed to following a competitor’s guidelines!  Do you care to guess the outcome of that survey??

The best approach, if you find that your policy does not reflect your operational reality, is to rewrite the policy correctly yourself. This is not as difficult as you might think.  The benefit is that the resulting information will more closely resemble the guiding document it is intended to be, and it will be true for you.

Next time, in our last post of the series, we’ll discuss forms and their organization.

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