Create procedural instructions or guidance
Develop clear instructions and guidance for activities and processes, such as:
- instructions for collecting the right information to verify eligibility or entitlements
- procedures to help staff apply consistent and correct processes
- guidance to help staff make correct and ethical decisions.
Why this countermeasure matters
A lack of clear guidance and procedural instructions can lead to:
- high levels of non-compliance or errors due to inconsistent and unclear processes, rules and decision-making
- common use of shortcuts and workarounds
- a lack of transparency over actions and decisions
- poor management of fraud and corruption risks
- fraudsters taking advantage inconsistent practices and processes to commit fraud and avoid exposure or prosecution
- fraud or corrupt activity going unnoticed or unchallenged
- unknown and unaddressed systemic fraud or corruption.
How to put this countermeasure in place
Some ways to implement this countermeasure include creating:
- clear instructions for clients and third parties to follow
- clear program procedures and processing instructions for staff
- clear procedures for internal functions such as credit card acquittals
- clear guidance for managers who oversee processes and decisions.
How to measure this countermeasure's effectiveness
Measure the effectiveness of this countermeasure by using the following methods:
- Confirm that procedural instructions and guidance material exists.
- Confirm that staff can easily find and reference procedural instructions and guidance material.
- Confirm that staff can easily understand and apply procedural instructions and guidance material.
- Confirm that staff use procedural instructions and guidance material.
- Check that procedural instructions and guidance material is reviewed regularly and updated as required.
- Review statistics on the number of page visits to procedural instructions and guidance material to confirm staff are using it.