Chapter 4. Managing, Controlling and Proving Compliance
Building a tracking system, conducting the self-assessment, and the four kinds of proof of compliance.
Create and implement a tracking system.
Create and Implement a Tracking System
The Accreditation Manager will need to create a tracking system that will provide quick reference to the status of each folder. Some Managers use a large white board, others a spreadsheet. This should be convenient and easy to use. A status board makes it easy for the Chief or Sheriff and other interested parties to visualize the agency's progress.
Self-Assessment
The self-assessment should begin as an exercise in comparison. Once the filing system is organized, the Accreditation Manager starts comparing current agency policy to the accreditation standards. Most Managers quickly come to the conclusion that the agency is closer to compliance than anticipated. Law enforcement adapts to the ebb and flow of legislative changes, and agencies adopt policy that is consistent with the law.
As the Accreditation Manager compares what must be covered for accreditation purposes, he or she will probably find that some fine-tuning is necessary. One of the biggest mistakes committed by new Accreditation Managers is in rushing the job. There is a generous two-year time limitation on the MSLEAC process. The Manager may want to address high-liability areas first in order to get any necessary changes in agency policy into the hands of those it affects as quickly as possible. Property and evidence control, arrest procedures, and similar functions are some of these high-liability areas.
Cross-Compliance and Reference
When comparing agency policy to the standards, the Manager will need to be mindful of cross-compliance and reference. Is there a separate policy on this — or any — one element? If so, the Accreditation Manager will need the separate policy in the compliance folder, or may opt to submit a draft combining the two.
Compile Supportive Documentation
There are several ways to prove compliance on just about every standard. Accreditation Managers are not bound by conventional wisdom when it comes to proving compliance with standards. The Standard Compliance Form (SCF) designates four types of proofs of compliance: written directive, other documentation, interviews, and observation.
Written directive. A policy of the department issued by the Chief/Sheriff or designee as an order, generally codified in the General Operating Manual.
Written documentation. Examples of written documents include, but are not limited to, lesson plans, memos, emails, state law sections, or judicial policies and law. Agency policy is usually considered a written directive and will most often be the first item the Manager has available to prove compliance.
Other documentation. May include photographs, video, log sheets, agency forms, training rosters, evidence bags or any number of items. The key element in this category is that the proof does not require specific action be taken, but is an instrument of the person taking the action.
Interviews. Interviews will be conducted by the assessment team. The Manager may want to list individuals on the SCF who are most knowledgeable about the agency action in a specific area. For example, the director of personnel for the jurisdiction may be listed as a potential interview to prove compliance with certain personnel standards. The lead dispatcher may be listed as the best source of information on dispatch responsibilities during high-speed pursuits. Listing the names of individuals does not insure that the assessment team will interview the person. However, if the team does choose to interview the suggested person or persons, the Manager has already supplied them with the name — and the proper spelling — of the interviewee. This makes the assessor's job easier, and that makes the assessment go faster.
Observation. This is the final category on the SCF. This type of proof is the easiest for the assessor and probably the least utilized. There are several standards where simply observing the action or a piece of equipment is proof that the agency is in compliance with the standard. Standards addressing markings on agency vehicles, alternate sources of power for communications equipment, or instructions for citizen complaints are examples of observation compliance.
Accreditation Managers should also be aware that the best assessors do not settle for a single proof of compliance unless it is overwhelming in nature. The wise Manager will list proofs in at least two categories, and in some cases, all four categories. The more ways a Manager can show the agency is truly doing what they say they are doing, the better. The assessors will be looking to find compliance with the first few items they look at in the folder. Having additional proofs will never hurt, but not having enough is a common shortcoming.
Train Agency Personnel in Policy Changes
Whenever appropriate, the Manager should utilize the briefing schedules set up early in the process. The Manager may want to have other agency personnel present the changes — including the Chief/Sheriff or other high-ranking officer — or may simply coordinate with shift commanders. The important point is that agency personnel know about the newly adopted policy as soon as possible. Any new policy should include a training component for those it affects, and the Accreditation Manager should remember that the assessment team may desire to interview agency rank and file on the particular issue addressed.
