aca’s ppms tm foundational training on aca’s professional practices management system © 2015...

ACA’s PPMSTM

Foundational Training on ACA’s Professional Practices Management System

© 2015 ACA International. All Rights Reserved.

Welcome!


Meet Your Instructor – Pam Murphy


Pamela Murphy, Vice President, Privacy and Compliance Officer, joined ConServe in 1993 as Legal Manager and was promoted to Vice President, Privacy & Compliance Officer in 2004. Pamela has been instrumental in developing and implementing ConServe’s PPMS. Her leadership greatly contributed to earning ConServe the ACA Certification designation in August 2001. Currently, Pamela is serving on ACA’s PPMS Committee.

Pamela was awarded both the Scholar & Fellow degrees in Collection Business Management from ACA International. Additionally, Pamela is an ACA Professional Collection Specialist, ACA Certified Instructor, ACA Higher Education Collection Specialist, and an approved ACA PPMS Instructor.

Legal Disclaimer


Any content included in this presentation or discussed during this session (“Content”) is presented for educational and general reference purposes only. ACA International, either directly or through speakers, independent contractors, employees or members of ACA International (collectively referred to as “ACA”) provides the Content as a courtesy to be used for informational purposes only. The Contents are not intended to serve as legal or other advice. ACA does not represent or warrant that the Content is accurate, complete or current for any specific or particular purpose or application. This information is not intended to be a full and exhaustive explanation of the law in any area, nor should it be used to replace the advice of your own legal counsel. ACA is the sole owner of the Contents and all the associated copyrights. ACA hereby grants a limited license to the Contents solely in accordance with the copyright policy provided at www.acainternational.org. By using the Contents in any way, whether or not authorized, the user assumes all risk and hereby releases ACA from any liability associated with the Content.

The views and opinions of the speakers expressed herein are solely those of the presenters and not ACA International.

What to Expect

• Fast paced training that covers a crash course of the basics of PPMSTM

• Covers only the requirements of PPMSTM: the MUST HAVES versus the NICE to HAVES– How to use the sample manual– Understand the templates and tools

1© 2015 ACA International. All Rights Reserved.

What to Expect

• When you are done with this course you should:–Understand what is required to become

certified–Understand how to use the sample

materials/reference aids–Have a next step to get started


Introduction

The number of employees at my company is: a. 1-25 b. 26-100 c. 101-250 d. 250+

My level of experience with PPMSTM is: a. I’ve attended the PPMSTM online seminar class. b. I’ve attended the one-day face-to-face PPMSTM training. c. Our company is working toward PPMSTM Certification – I am here to get a “boost.” d. Our company is already PPMSTM Certified – I am here as a refresher or a new staff member. e. This is my first PPMSTM class of any kind.

What are you hoping to gain from this seminar?


Course OutlineAgenda:

1. Introduction – Overview of ElementsWrite a Client Issue/Non Conformity

2. Documentation Write a Procedure

3. AuditingPerform Root Cause Analysis

4. Overview of the PPMS Process5. Planning and next steps


PPMSTM

: Professional Practices Management System

• What is the purpose of the ACA PPMSTM?– The purpose of the ACA PPMS

TM

is to provide a framework that will help agencies continuously improve and save money!!!


Definition of Key Terms* • Professional Practices Management System (PPMSTM)• Certification• Subscription• Company Procedures (CP)• Company Forms (CF)• Company Work Instructions (WI)• Surveillance• Evaluation• Major Non-conformance• Minor Non-conformance• CliftonLarsonAllen LLP (Larson, Allen, Weishair & Company, LLP)

– *See pg 7 in Volume One: Reference Materials Manual under Tab01 Introduction for full definitions


Volume One: Reference Materials Manual Table of Contents

Tab01 Introduction………………………………………..……………....pg. 1Tab02 Overview & Setting Up….…………………................................pg. 19Tab03 PPMS Elements……………………………..…..………………..pg. 27Tab04 Planning…………………….……………………………………..pg. 195Tab05 Documenting……………………………………………….……..pg. 213Tab06 Implementing……….…………………………………………….pg. 271Tab07 Cost Reduction/Continuous Improvement………….…………pg. 323Tab08 PPMS Application…………………………….………………….pg. 345Tab09 The Advantages of the PPMS…………...........................……pg. 393Tab10 Auditing……………………………………........................……..pg. 407Tab11 Change Management…………….……….......................……..pg. 443Tab13 PPMS Q&A…………………………………........................……pg. 467Tab14 Compliance handouts………………….….......................……..pg. 474Tab15 Required Forms………….……………........................………...pg. 479Tab16 Element 18 Appendix…………………...........................……….pg. 499Tab17 CFPB Appendix…………………………………………………...pg. 575


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Volume Two: Sample Manual and how do I use it?

• The Manual is a complete sample for what you need in order to be certified. Turn to page 5 in the PPMSTM Sample Manual under the Procedures tab.

• Use these as templates to write your own procedures.• The naming convention begins with either a WI for Work

Instruction, a CM for Company Policy, a CP for Company Procedure or a CF for Company Form.

• Followed by the element #, a sequential number for tracking and the description


What is a Required form and how do I use them?

• A form that must be completed in order to acquire PPMSTM certification.

• You must keep the information that is on the form in a similar format.

• You cannot remove anything from the form but you can add to the form.

• If you have multiple offices and are certifying all offices, you must indicate on the logs, which office is represented by the issue. This is an example of something to add to the forms, office or location.


What is a Required form? (continued)

• You can rename the forms title (Client Concern versus Issue)

• The form must remain under the element they reside

• All forms must have the element number incorporated into the form name. See example in Volume Two: PPMSTM Sample Manual on page 19 CF Client Issues Log (302-2).


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All Required Forms

All forms are in Volume Two: PPMSTM Sample Manual under the Forms tab • Management Review Checklist (101-1)……………………………...…..pg. 6• Trend Analysis Form (Jan-June) (102-1)………………………….……..pg. 7• Trend Analysis Form (July-Dec) (102-2)…………………………...…….pg. 8• Client Issues Log (302-2)………….……………….……………………....pg. 19• Non-conformity & Corrective/Prevention Action Report (1201-1)……...pg. 29• Non-conformity & Corrective Action Log (1201-2)..................................pg. 30• Continuous Improvement Project Log (1201-3)……………………….....pg. 31• Continuous Improvement Status Report (1201-4)…………………….....pg. 32• Internal Audit Checklist (1503-1)…………………………………………...pg. 42• Training Course Log (1603-1)…………………………………...………....pg. 54• Newly created form, not yet in Sample Manual: Consumer Issue/Concern Log 1402-1


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What is an Element?

• Principals• Assumptions• Mindset


All PPMSTM Elements*List of PPMSTM Elements

1 - Management Responsibility

2 - Management System

3 - Review Of Client Issues

4 - Document & Data Control

5 - Purchasing

6 - Control of Client & Customer Supplied Data

7 - Data Identification & Traceability

8 - Process Control

9 - Inspection & Testing

10 - Inspection & Test Status

11 - Identification of Nonconformity

12 - Corrective Action, Preventive Action & Continuous Improvement

13 - Handling, Storage, Preservation & Delivery

14 - Management of Records/Data

15 - Internal Management Audits

16 - Training

17 - Process & Client Satisfaction Measurements

18 - Information Management Systems & Data Protection

*For a list of the elements and their full descriptions see Tab: 03, page 31 in the Volume One: Reference Materials Manual


Element 1 : Management Responsibility

• Discuss Element 1: What management responsibility means

• Review a sample management policy statement• Review the Annual Management checklist• Review the Trend Analysis logs


1 - Management ResponsibilityReviewing vision, mission, goals and expectations

• What is it?• Documentation of executive management’s

business policy concerning:• information security• client satisfaction• continuous improvement• prevention of negative impacts on the collection industry

• Periodic review of the management system to compare performance to management policy


1 - Management ResponsibilityReviewing vision, mission, goals and expectations

Example(s)•Executives review annual agency results

• Performance– i.e. recovery percentages

• Management Review Checklist (101-1) – Required Form – Forms Section (PPMS™ Sample Manual) page 6

• Trend Analysis Forms (102-1) & (102-2) – Required Forms

– Forms Section (PPMS™ Sample Manual) page 7-8

•Information & Communication• Manager meetings• Staff meetings• Employee performance reviews


* Please submit either the minutes of the meeting or the presentations for 2 of the above subjects listed on the agenda.

Management Review Checklist (101-1)Management Review Check Sheet

Date Time Location

Agenda* Presented By Date Completed

1 Financials

2 Management Policies and Objectives

3 Client Issues

4 Compliance Programs

5 Client Satisfaction

6 Continuous Improvements (Progress of Projects)

7 Audit Results

8 Performance Measurements against Goals

9 Legal Review

10 Information Security

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Element 1 Sample Policy

– PPMSTM Sample

Manual page 18-19 under

PPMS Policies tab


• What is it?• Documented management program (i.e.,

Company Manual) that:• implements the organization’s policies, plans

and objectives• reflects key management practices

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2 - Management SystemWriting company policies, procedures and work instructions


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2 - Management SystemWriting company policies, procedures and work instructions

• Example(s)• Sample Professional Practices Manual

• PPMSTM Policies Section (PPMS™ Sample Manual) pgs. 7-39• Procedures Section (PPMS™ Sample Manual) • Work Instruction Section (PPMS™ Sample Manual)

• New hire training manual• Employee Handbook• Operational Guides• Information Technology Administration Policy

• Technical Infrastructure Administration• Data Administration• Software Administration• IT Operations & Support


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Client Issue Form and Log Element 3

• Discuss Element 3 client issue what it is and examples

• Element 3 Form – How to use it – Client Issues Form (302-1) – Sample 1 on page 18

• How to log– Client Issues Log (302-2) – Required Form


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3 - Review of Client IssuesDetermining company’s ability to meet client’s needs and expectations

• What is it? – A formal comparison of client requirements against an

agency’s ability to meet those requirements• Define client’s needs & expectations• Review and track client’s needs & expectations and

concerns or issues• Review regulatory requirements• Define communication protocol• Track amendments to agreements


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3 - Review of Client IssuesDetermining company’s ability to meet client’s needs and expectations

• Example(s) – Listing accounts under the wrong client number– Health care account sent to agency without patient names– Client complains about a collector– Client has service interruptions– Client Issues Form (302-1)

• Forms Section (PPMS™ Sample Manual) page 18


Client Issues Form 302-1


CI Log #

Client Received By

Action Assigned

To:

Date Received

*NCAR #

Date Closed

Client Issues Log (302-2)

*NCAR - Non-conformance Corrective Action Requirement


Exercise: Writing a Client IssueObjective: Understand how to write a client issue and to become

familiar with the form and the log.

• Scenario #1: A client e-mailed you stating that the electronic new business file that was sent two weeks ago has not been loaded. They never received an acknowledgement of the business or confirmation that it was loaded.

• Please use a blank client issue, found under the Tab03 PPMS Elements on pages 53 in the Reference Materials Manual to complete this homework assignment, complete the forms.


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4 - Document & Data ControlMaintaining both electronic and paper documents (policies, procedures, work instructions) and removing obsolete information

• What is it?– Controls over documents & data to ensure

• that they are current • that they are accessible where needed• that they are reviewed & revised as necessary• that obsolete documents are removed from places

where they might be used


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4 - Document & Data ControlMaintaining both electronic and paper documents (policies, procedures, work instructions) and removing obsolete information

• Example(s)– Procedures to enter new accounts and cash

process were updated, but someone (in the agency) used the old procedure• Unhappy clients• Irate consumers• Happy attorneys

– Policy in Employee Handbook was updated, however, it was not distributed to all employees


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5 - PurchasingManaging the purchasing process (major products and services only)

• What is it?– Controls specific to the agency’s purchasing process that

have a direct impact on services• Definition of precise purchasing requirements in P.O.s

and contracts (e.g., define criteria first)– Controls specific to vendor management

• Risk Assessment (what are the risks compared to benefits of outsourcing)

• Evaluation of vendors (Due Diligence) who have an impact on your service offering (e.g., letter services, etc.)

• Contractual Agreement(s) (see sample HIPAA BA agreements)

• Vendor Control Environment (i.e., Does vendor have a SSAE 16?)

• Compliance Monitoring


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5 - PurchasingManaging the purchasing process (major products and services only)

• Example(s)– Selecting “Letter Vendor” based solely on price– Selecting “Phone Vendor” based solely on price

• Agency selected a phone system on price• System & dialer went down

– (i.e., no incoming or outgoing calls)• Vendor did not have the technical ability to service the

system• Took over 2 days to get the phone system working again

– Software system– Payroll services– Healthcare benefits packages for employees– Retirement services for employees (401K)


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6 - Control of Client & Customer-Supplied DataSecuring and controlling all data flowing into the office

• What is it?– Administration of customer-supplied data (electronic & paper) to ensure integrity

& confidentiality – Controls related to the protection of customer-supplied data that is the

responsibility of the agency including:• Identification of data (by client/customer)• Maintenance• Security (During Transaction/At Rest)• Storage (On-site & Off-site)


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6 - Control of Client & Customer-Supplied DataSecuring and controlling all data flowing into the office

• Example(s)– Information Security (NOT PRIVACY) Issues (FDCPA & HIPAA)

• Destruction of CDs with customer-supplied data prior to disposal• Shredding vs. throwing records in the trash• Agency was sued for violating FDCPA when an attorney for a consumer pulled

confidential records from the dumpster (i.e., found in plastic trash bags)• Laptop Security – ensuring laptop computers are secured when not on agency

premises • Electronic Data Storage Media – ensure data backup tapes are secured both

on-site at the agency and at the off-site storage facility


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7 - Data Identification & TraceabilityUnderstanding company information and where it belongs

• What is it?– A requirement regarding identification & traceability of incoming data, in-

process data, and final data• Identification means:

– The ability to distinguish data from other data• Traceability means:

– To be able to follow the data through the collection process– This also includes consideration of data that is transmitted to a 3rd

party in support of agency services (e.g., letter generation)• Concerns only data in control that is the responsibility of the agency


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7 - Data Identification & TraceabilityUnderstanding company information and where it belongs

• Example(s)– Managing accounts

• Ability to tie data to your client• Ability to document when an account moves to a new stage in the collection

process• Ability to flag account status (e.g., do not call)

Most collection software on the market will do the above– Human resource files and human resource processes

• Checkout of an employee file• New employee benefits setup or benefits termination when they leave• Knowing the status of an employee-current, past, contractor, part-time, etc.


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8 - Process ControlMaintaining procedures or instructions for consistent performance (new business entry, cash application, collection call, etc.)

• What is it?– Requirement that an Agency:

• Identify, plan & control the steps to deliver the service

• Complies with industry standards• Monitors & controls work procedures and

processes


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8 - Process ControlMaintaining procedures or instructions for consistent performance (new business entry, cash application, collection call, etc.)

• Example(s) – Collection Process

• Initial communication letter was sent• Letter was not responded to by consumer• Before 30-day validation period expired, a demand payment

request was made to pay immediately - a violation of the FDCPA– Additional Example(s)

• New business data entry• Communication in an attempt to collect a debt• Skip tracing and asset searching• Settlements• Solicitation of Payments• Written consumer disputes• Compliance with collection laws and regulations• Obtaining a money judgment• Post judgment actions• Payroll – sign offs for pay increases


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9 - Inspection & TestingTesting, reviewing and verifying planned work processes (new business entry, cash application, collection call, etc.)

• What is it?– Requirement that informal audit processes be in place to

ensure that the service conforms to specified requirements for:• Incoming service

– new account listings• In-process service

– collection cycle• Finished service

– cancellation or paid-in-full• User Accounts

– New user IDs were not added prior to first day of employment

– User IDs for terminated employees were disabled or deleted no later than the last day of employment


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9 - Inspection & TestingTesting, reviewing and verifying planned work processes (new business entry, cash application, collection call, etc.)

• Example(s)– Duplicating work - entered new business twice

because it is in the wrong pile– Setting your agency up on the system as a dummy

account to see if you are getting the correct letter in a timely manner

– Verifying that employees have timely performance reviews

– Periodic review of user IDs compared to active employee listing to validate user ID was added/deleted at the appropriate time


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10 - Inspection & Test StatusVerifying that company processes occur in sequence

• What is it?– Requirement(s) that all steps in the collection process take place– Requirement(s) that all processes in support of internal operations

take place (i.e., accounting, etc.)– Requirement(s) that all steps occur in the proper sequence


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10 - Inspection & Test StatusVerifying that company processes occur in sequence

• Example(s)– Canceling accounts before the work standard has been satisfied– Human resources processes

• When a new employee comes, test to make sure the following have been set up on the appropriate date and are working properly:

– Phone– ID– Password & Login– Work space

• Make sure other staff know new employee is arriving or existing personnel have resigned or been terminated

• Training checklist


Nonconformity: Element 11

• Discuss Element 11 • What is a Nonconformity• How to use the form and the log

– Nonconformity & Corrective/Prevention Action Report (1201-1) – Required Form

– Forms Section (PPMSTM Sample Manual) page 29


11 - Identification of Non-conformityIdentifying and recording mistakes or problems

• Example(s)– Client requirements not followed– Internal agency procedures not followed– Nonconformity & Corrective/Prevention

Action Report (1201-1) – Required Form• Forms Section (PPMS™ Sample Manual)

page 29


Nonconformities

Major Nonconformance• A Major Nonconformance is a major breakdown in the

organization’s system that could or has impacted the company or its clients. If left unchecked it could result in losing a client or a lawsuit being filed.

Minor Nonconformance• A Minor Nonconformance is most often an internal

mistake which does not impact the client directly, will not result in a lawsuit but nonetheless costs the organization because of the inefficiency and rework it necessitates.


Department: Corrective/Preventive Action #:

Date opened Corrective/Preventive Action: Targeted/Proposed Resolution Date

1. Describe Non-conformity or Goal of Preventive Action:

Written by: Supervisor’s Signature: Date:

ACA Element #:

2. Action taken to contain non-conformity (i.e., if applicable):

Action taken by whom: Date:

3. Team or individual assigned to solve problem or potential problem:

4. Root Cause of the problem or potential problem:

Date:

5. Corrective/Preventive Action recommended to solve problem:

Date:

6. Date Corrective/Preventive Action implemented:

7. Describe effectivity results (i.e., did the corrective/preventive action solve the problem):

Compliance Officer Signature: Date Corrective/Preventive Action closed:

8. Date reviewed for trend analysis:

9. Comments:

Major Non-conformance Minor Non-conformance

Nonconformity & Corrective/Prevention Action Report (1201-1)


CorrectiveAction

Number

DateOpened

Assigned Team or

Individual

* Projected Corrective Action Solution Due Date

Date Corrective

Action Implemented

Date Corrective

Action Reviewed

for Effectivity

Date Closed

Element of the PPMSTM

(*Major Non-conformance)

Nonconformity & Corrective Action Log (1201-2)


Exercise: Write a Nonconformity and log it

Objective: Understand how to write a Nonconformity and to become familiar with the form and the log. Please write a Nonconformity and log it on the Nonconformity log form (Refer to page 105 in your Reference Materials Manual to complete the exercise).

Scenario 1: XYZ agency’s procedures state that collection center personnel will be periodically reviewed for performance and that training will be provided for those found to be deficient in education, knowledge or skills. You, the auditor, come across 3 people in the collection center who were hired 3 months ago. When you review their training records, you find no evidence of any training in FDCPA or telephone collection techniques. You decide to review their personnel files and find no previous experience in the collection industry.


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Continuous Improvement: Element 12

• Discuss Element 12• What is a continuous improvement• How to log and track continuous improvements

– Nonconformity & Corrective Action Log (1201-2) – Required Form– Forms Section (PPMSTM Sample Manual) page 30


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12 - Corrective Action, Preventive Action & Continuous ImprovementCorrecting and preventing problems by finding a better, faster or more reliable way to accomplish work

• What is it?– Investigation & elimination of root causes of Nonconforming

activities at any point in an agency’s service– Testing or proving the adequacy of procedures/processes to

prevent occurrence of Nonconforming services in the first place– Re-engineering processes to improve services & reduce cost


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12 - Corrective Action, Preventive Action & Continuous ImprovementCorrecting and preventing problems by finding a better, faster or more reliable way to accomplish work

• Example(s)Turnover is high• Corrective/Preventive Action

– Revamping the interviewing process to include behavioral based question to better define candidates’ abilities whereby reducing turnover.

– Start conducting second interviews to get the candidates back into the office, observe additional behaviors, getting others involved for second opinions.


Assigned Team or Individual: File Locator ID:

Date Continuous Improvement Started ACA PPMSTM Element #:

A. Briefly Describe Continuous Improvement Project:

Written by: Date:

B. Key Status Milestones, if any (example – planning stage, training, pilot program, implementation, etc.):

Written by: Date:

1. First Milestones - Describe what was accomplished: Scheduled Completion Date:

Written by: Date:

2. Second Milestones - Describe what was accomplished:

Scheduled Completion Date:

Written by: Date Completed:

3. Third Milestones - Describe what was accomplished: Scheduled Completion Date:


4. Fourth Milestones - Describe what was accomplished: Scheduled Completion Date:


5. Project Completed - Describe what was accomplished: Scheduled Completion Date:


Continuous Improvement Status Report (1201-4)


Description of Continuous

Improvement Project

Assigned Team or

Individual

File Locator

ID

Date Project Started

Date Project

Completed

Element of PPMSTM

Continuous Improvement Project Log (1201-3)


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13 - Handling, Storage, Preservation & DeliveryDisaster planning and delivery of information

• What is it?– Extension of Element 6 - Control of Client & Customer Supplied Data– Extension of Element 8 - Process Control– Integrity of Agency Business Transactions

• Tracking of Money• Daily Cash Journals• Formats of Client Reports

– Data (electronic) Storage & Backup• Acceptable Storage Media• Frequency/Rotation of Backups• Off-site Storage

– Business Continuity• Areas impacted, technology plan, backup site, etc.

– Disaster Recovery PlanWork Instructions Section (PPMSTM Sample Manual) pages 45-57


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• Example(s)– Tracking of the accounting function within the office requires the creating of the

checks for Accounts payable to be done by one person, while the signature of the check can only be done by a separate individual

– Establishing a Data Storage & Backup program that identifies the following:• Type of Storage & Backup• Data Backup Schedule• Tape Rotation/Retention• Tape Inventory Management• Data Backup Storage

– On Site– Off Site


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• Example(s) (continued)– Disaster Recovery Documented Plan

• Scope• Network Recovery Procedures• Server Recovery Procedures• Workstations Recovery Procedures• Database Recovery Procedures• Application Recovery Procedures• Voice Communications Recovery Procedures

– Disaster Recovery Plan Approval• Business Continuity Plan


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• Example (continued)– Disaster Recovery Plan (1302)

• Procedures Section (PPMS™ Sample Manual) page 42• Forms Section (PPMS™ Sample Manual) page 355.0 Procedure

5.1 - General Manager Responsible for all oversight of recovery activities.

5.2 - MIS Supervisor Determine if company's computer equipment is operational and can be moved to a new work location. Arrange for rental equipment if computer equipment is not operational. Recover backup tapes from off-site storage area.

5.3 - Collection Supervisor If the disaster requires work operations to be moved to another location contact telecommunications vendors and arrange for a temporary service at the new location. Recover hardcopy files (i.e., client & responsible party information) from off-site storage area.

5.4 - Etc.© 2015 ACA International. All Rights Reserved.

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14 - Management of Records/DataHandling, storing, retrieving and depositing of information (supporting records/forms)

• What is it?– Effective control and management of records and data– It includes:

• Archiving of records• Identification & indexing of records• Retrieving of stored records

– (e.g., one business day)• Storing records effectively

– (e.g., preventing deterioration)• Proper disposition of records

– (e.g., privacy considerations)


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14 - Management of Records/DataHandling, storing, retrieving and depositing of information (supporting records/forms)

• Example(s)– Policies on what Data and Records you want to keep and what you should throw away– Storing of Records

• IRS Records (e.g., keep 7 years)• Dispose of client issues (e.g., after 1 year)

– Destroying of Records And Data• Shredding• Burn Bag• Trash

– Ensuring personnel records are stored and locked to prevent unauthorized personnel from accessing, as well as proper disposition of out of date records


Audit: Element 15

• This element will be discussed later in the presentation.


Training Checklist : Element 16

• Discuss the training element and requirements

• Discuss the log and how to use it– Training Course Log (1603-1) – Required Form– Forms Section (PPMSTM Sample Manual) page 54


16 - TrainingContinuous training of all staff

• What is it?– A structured process to support staff training

needs that will allow employees to perform job requirements efficiently and effectively including:

• Development of a training plan by role or individual• Training of personnel to meet training needs and

certification requirements• Maintaining records of individual qualifications and

accomplishments in support of performance evaluations and certification requirements


16 - TrainingContinuous training of all staff

• Examples– ACA International’s Code of Ethics (Required Annually) – FDCPA Training– FCRA Training– Credit & Collection Compliance Officer Workshop (CCCO)– Telephone Collection Techniques– Skip Tracing Training– HIPAA Training– Application Systems Training– Technical Infrastructure Training– Basic training on job duties for new hires, ensuring that records

are kept for those sessions and ongoing training is conducted for staff

– Training Course Log (1603-1) – Required Form• Forms Section (PPMS™ Sample Manual) page 54


Training Course Log (1603-1)Description of Training Course Date

No. of People in Attendance

Length of Course (hrs.)

Reminder: Attendance at this training program satisfies the requirement that one training program is necessary per year.to become certified and one training program per year to maintain certification after the first year.


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17 - Process & Client Satisfaction MeasurementsMeasuring results internally and externally

• What is it?– Identification of measurements to prove that your

service is working properly (effectiveness = quality)– These measurements should support the following:

• That an agency is conforming to Internal Requirements

• That an agency is conforming to Client Requirements

• That an agency is conforming to Regulatory Requirements

– Identification of measurements to help your agency improve (efficiency = profits)


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17 - Process & Client Satisfaction MeasurementsMeasuring results internally and externally

• Example(s)– Measuring turnover– Measuring payroll as a % of Revenue– Measuring profit trends– Improvement Targets - Example Plan (1701-EX)

• Forms Section (PPMS™ Sample Manual) page 56


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18 – Information Management Systems & Data ProtectionEnsuring availability of systems, integrity of applications and data, and confidentiality of information

– This element is covered in greater detail in the Element 18 Appendix tab.

– Only requirement for this element is the one required procedure.

– Sample forms: Hardware Asset Inventory (1801-1) and Software Asset Inventory (1801-2)

– Forms Section (PPMSTM Sample Manual) page 57-58


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Developing a PPMSTM

StructureElement 2 - Management System

Work Instructions

Policies

ProceduresDET

AIL

President, Owner, Top Managers

NU

MB

ER O

F W

OR

DSManager,

Supervisor

Front line worker & all


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Developing a PPMSTM

Structure2 - Management System

• Procedures– Procedures are a requirement of the ACA PPMSTM

Program. You must have one procedure for each element at a minimum

– Focus on processes (standardization & consistency)– Help reduce mistakes (i.e., who is responsible for what

actions and sometimes how to perform a task)– Identifies any records and forms that support the procedure– Help as training tools


1.0 PURPOSE (WHY)Briefly state why the procedure is necessary.

2.0 SCOPE (WHEN/WHERE)Describe the areas the procedure will impact or influence.

3.0 DEPARTMENTS RESPONSIBLE FOR IMPLEMENTATION (WHO)Index the responsible functions.

4.0 GENERAL (WHAT)General description of how the CP will impact the company.

5.0 PROCEDURE (HOW)Describe steps necessary to accomplish the task set forth in the CP; follow a logical sequence. The responsible parties should be identified for each step.

6.0 RECORDS (Optional)Identify where the records are to be maintained.

7.0 FORMS Identify any forms to be used in accomplishing the CP requirements.

8.0 DEFINITIONS (Optional)Define any unusual terms.

9.0 REFERENCE DOCUMENTS (Optional)ACA PPMSTM, other specifications.

Procedure Format (Sample Format) (201-1)Volume One Reference Manual, Tab 5, “Documenting” page 236


Developing a PPMSTM

Structure2 - Management System

• Remember:– Professional Practices Manuals are a

requirement of the ACA PPMSTM Program, but the content is up to your agency (i.e., procedures must cover each element of the ACA PPMSTM to qualify for Certification).


What MUST I do to be certified?

–At a minimum, a Manual shall contain the following: • Table of Contents• Procedures - at least one per element• Management Policy Statement• Required Certification Forms• Three months of logs


Develop Documentation Format2 - Management System

• Establish a consistent format• Numbering documents

– Should be flexible enough to allow growth and change– ACA Certification requires that you use the numbering system that

the ACA PPMSTM Elements use (i.e., for broad categories)• Example:

– 3 – Client Issues– 11 – Nonconformity

• How to name your documents– Include: Dept., location/office, Element #, description

• Element 4 helps you setup controls for documentation


Develop Document Control System4 - Document & Data Control

• Meaning of control– Current version (i.e., review & revised as necessary)– Easy to locate (i.e., know location of all controlled documents)– Available at location where used– Obsolete documents are removed from points of use– How will you structure and organize your folders?

• \ppms• \ppms\workinstructions• \ppms\forms



• How to control– Procedures

• e.g., revision # or issue date

– Outside documents• e.g., date stamps & logs

– Master Index of control document• e.g., Company Procedures Master Index (204-1)• Forms Section (PPMS™ Sample Manual) page 13

• Who is responsible for changes?– e.g., compliance officer modifies procedures



• Examples of controlled data/documents– data sent from client– agency procedures– collection letter/CNR Process– information sent & received from credit

bureau– industry standards & regulations (e.g.,

code of ethics, FDCPA, PPMSTM)


Where to Begin

• Your first procedure could be:– How to write a Procedure– How to write a Client Issue– How to write a Nonconformity


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How do I begin?

• Training staff on documentation formats and procedure– Explain why you chose the document structure you did

(i.e., levels and types of documents)– Provide examples of the document formats– Explain document control issues

• Why is it important• What documents should be controlled• How your agency will control important documents


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Developing Documentation

• Write new and/or modify existing procedures– Assign procedures & due dates (i.e., keep to the dates

on the project plan)– Each department needs to write procedure(s) that

pertain to their area of the PPMSTM

• This would include Work Instructions (where necessary) and records to support their procedure

– It is a good idea to include the employees in their work areas when writing procedures.

– In areas that overlap more than one department, the procedure should be written as a collaborative effort between the departments.


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Exercise: Writing a Procedure

• Document a PPMS Procedure using the sample Procedure Format (CF 201-1) (You can find a blank procedure form on page 237 in your Reference Materials Manual).

Objective: To become familiar with the procedure template, practice writing a procedure, understand the components of a procedure.

You will be assigned one of the following topics to write a procedure. You will want to follow the template for a procedure and complete the following sections of the procedure: Purpose, Scope, Dept, General and Procedure. Under Tab: 05, see pages 235-237 in Volume One: Reference Materials Manual.


Exercise: Writing a Procedure

1. Element 3: Client IssuesYou will want to answer the following questions in your procedure:

Who will write them up? When will a client issue be written?

Who do you assign them to and who assigns them? Who will log them? How long do you want them open? Provide a guideline. How do you escalate an issue? How do you communicate the issue to others and the solution? Are you going to rank client issues (severe, minor, etc.)?


Exercise: Writing a Procedure 2. Element 11: Nonconformity

You will want to answer the following questions in your procedure:

Who will write them up? When will a Nonconformity be written? Who do you assign them to and who assigns them? Who will log them? How long do you want them open? Provide a guideline. How do you escalate an issue? How do you communicate the issue to others and the solution? Are you going to rank Nonconformities (severe, minor, etc.)? If so, how? Who manages the process? Who does the 30 – 45 day follow-up? What happens when one is not closed?


1.0 PURPOSE

2.0 SCOPE

3.0 DEPARTMENTS RESPONSIBLE FOR IMPLEMENTATION

4.0 GENERAL

5.0 PROCEDURE

6.0 RECORDS

7.0 FORMS

8.0 DEFINITIONS

9.0 REFERENCE DOCUMENTS

Blank Procedure (201-1)


Auditing-Element 15

• When we review this required form we will be showing you what the end of the process will be.

• Once you have all these items in place and satisfactory, you are ready to pursue for certification.


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15 - Internal Management AuditsEnsuring procedures and policies are followed and the management system is working by having all departments inspected on a regular basis

• What is it?– A planned process for conducting internal audits of your

management system– It includes:

• Planning & scheduling audits according to status & importance of activity• Carrying out audits using independent personnel• Documenting audit results & any follow-up activity• Communicating audit results to appropriate personnel, including

management• Initiating corrective action• Verifying & recording effectiveness of corrective action taken


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15 - Internal Management AuditsEnsuring procedures and policies are followed and the management system is working by having all departments inspected on a regular basis

• Example(s)– Auditing the Human Resources function to ensure

training records are kept on all employees– Internal Audit Checklist (1503-1) – Required Form

• Forms Section (PPMS™ Sample Manual) page 42• This form demonstrates exactly what you need to have in

order to be ready to submit for certification. All the requirements should be satisfactory once audited.


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I have documented all my procedures, now what?

• Once documentation is in place it is time to perform the annual management audit.

• You need to have been logging your client issues and nonconformities and completing the other required forms.

• Select an auditor or audit team.• Make sure the team is cross functional.• You cannot audit your own team or processes.• Select an area of the company to audit first.• Audits can be done throughout the year.


Internal Audit Checklist (1503-1)Element # Requirement Compliance Check Recommended Records

{*element requires record(s) or document}

Comments{Satisfactory

} {Needs

Improvement}

{Unsatisfactory}

{NA}

If needs improvement or unsatisfactory must indicate

Corrective Action # or Continuous

Improvement File ID

1 - Management Responsibility

1.a Management Policy

1 Management must develop a policy statement.

1. Verify that the management policy exists & is documented.2. Is the policy relevant (e.g., if the policy includes client satisfaction, how is it being supported).

* Documented Management Policy

1.b Organization

2 The organization must have the resources and the proper delegation of responsibility and authority to carry out its management policy.

1. Review company manual, procedures & job descriptions (i.e., if available) to verify responsibilities & authority of personnel.2. Through observation and inquiry, ensure that appropriate administrative, technical and physical controls have been implemented to mitigate defined risks.

1. Organization charts2. Assignments of responsibilities & authority listed in company manual, procedures & job descriptions.

1.cRisk Assessment

3 Management must assess risk to identify threats that could impact strategic, operational, financial and regulatory goals and objectives.

Review periodic risk assessments to ensure high risk areas have been identified and steps have been taken to mitigate these risks

Risk Assessment charts/tables for each business unit and function

1.dPlanning and oversight of Technology and Information Systems

4 Information Technology – to ensure initiatives and purchases and in support of the agency’s business goals and objectives. Information Security – to ensure the appropriate infrastructure is available to maintain the integrity and confidentiality of data

Examine the Information Security and Technology plans to ensure that the directives are aligned and have been implemented as expected.

A documented and detailed Information Security and Technology plan

1.eManagement Review

5 Senior management must annually compare its performance to its management policy.

Examine management review records * Management review records - (i.e., the records should show participation, & agenda covered).


**You can find the full Internal Audit Checklist starting on page 300 in your Reference Materials Manual under Tab 06, Implementing.

Internal Audit Checklist (1503-1) (Continued) Element # Requirement Compliance Check Recommended

Records{*element requires

record(s) or document}

Comments{Satisfactory}

{Needs Improvement}

{Unsatisfactory} {NA}



Improvement File ID

3.a Review 11

The process should:1. Define & review client needs & expectations2. Review of regulatory requirements3. Define communication protocol with clientAgencies will establish level of service if the client does not state.

1. Check a sample of contracts to see if they were reviewed prior to acceptance 2. Review client complaints, checking whether there were problems caused by inadequate understanding of customer requirements.

* 1. Client contracts 2. Client complaints

3.b Amendments to Contract

12

Track amendments to contracts 1. Check a sample of contract change orders to see that they were reviewed and accepted2. Check how various functions are informed about changes

* Contract change orders

3 - Review of Client Issues

11 General

31

Agencies must identify accounts and contracts that have not been served according to internal procedures or client or legal requirements.

Review non-conformance log and check against various other reports to see if non-conformances are being identified

1. Supervisor activity reports2. Call monitoring reports3. Internal audits reports4. Customer complaints

11 - Identification of Non-conformity


Internal Audit Checklist (1503-1) (Continued)

12.a Structured system

32 Agencies must establish a structured system for correcting problems (i.e., handling of client complaints, investigation of non-conformities, & legal concerns) & preventing problems.

Are there procedures in place that outline the methods to be used for correcting and preventing problems?

Corrective & preventive action procedures

12.b Action plans

33 are important to the client 1. Review the customer complaint files to verify that the complaining clients receive a response.2. Note how long it takes to process a complaint and whether there is a system to track complaints.3. Review corrective action requests, noting whether requests are processed in a timely manner and are properly closed out (e.g., are there logs or a tickler file to ensure corrective actions are timely followed up).4. Check on actions that have been taken to prevent recurrence of non-conformances.5. Check for evidence that quality records & process performance data are being regularly reviewed and analyzed to determine where preventive actions may be required.

* 1. Corrective Action request2. Various reports established in the course of implementing solutions & verifying their effectiveness.3. Letters and reports evidencing communication with the complaining customers & with other functions concerned. 4. Corrective action request5. Logs

Element # Requirement Compliance Check Recommended Records

{*element requires record(s) or document}

Comments{Satisfactory}

{Needs Improvement}

{Unsatisfactory} {NA}



Improvement File ID

12 - Corrective Action, Preventive Action & Continuous Improvement


93

Root Cause Analysis

Procedures/ProcessInformation/Req.

Why? Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

Why?

People Equipment

Client calls complaining about recoveries.

Problem Statement


94

Team Exercise

• Root Cause Analysis• Each team will be assigned one of the following non-conformances and should

identify all the reasons why the situation may have occurred finding the possible root cause.1. Wrong first notice was sent2. Accounts listed under wrong client3. Payment posted to wrong account4. Incorrect monthly statement sent to client 5. Debtor was contacted after a cease communication6. A new employee was hired and started on the first day with no one within the company knowing they were starting– See blank Root Cause Analysis (Volume One: Reference Materials, Tab: 06,

page 294)


95

So I finished my audit…what is next?

• You should have your company manual complete• Table of Contents• Procedures (at least one per element)• Management Policy Statement• Required Certification Forms and at least 3 months

of logs

• You will request the forms from ACA for certification, but let’s review the entire process one more time


96

Overview of Certification and Subscription Process for Submitting - Certification Level*

Submit application, evaluationagreement and fees to ACA

Submit documentationand records to CliftonLarsonAllen, LLP

Attested by a local CPA firm(depends on certification cycle)

Evaluation of documentation and records by CliftonLarsonAllen, LLP

Yes

ApprovedNo

Agency meetscertification requirements

Submit additional information

Attend PPMSTM

Training Seminar and one additional compliance online seminar

Surveillances:submit partial documentation

for evaluation

Re-certification:submit full documentation

Follow-up questions ifinformation is lacking or incomplete

*For more information on this process refer to the Reference Manual, Tab 08 starting on page 346.© 2015 ACA International. All Rights Reserved.

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What do I have to do in order to become certified?

• Write a procedure for each element• Use the required forms and logs for minimum of 3 months

before submitting for certification initially.• Conduct the audit and complete all required forms.• Complete the application to request to be certified and

send to ACA.• Have a CPA attest to your PPMSTM.

• Send your required information to auditing firm (see Tab 08, pages 385-386 in Volume One: Reference Manual).


Where should I start?

• Important to select a leader that is responsible for the project

• Obtain management buy in and ownership• Conduct a short education and overview of

PPMSTM

• Talk about what will happen and how things will be better, better process, less mistakes, etc…

Refer to Tab11 pages 444-445 and Tab09 page 405 for more information.


Select a Project Leaderand Assign a Project Team*

• The Leader:– is accountable for the project– reports to senior management– can get things done

• The Team: – is usually cross-functional (members from various departments)– reports to project leader– plans the project and schedule– assigns activities and responsibilities– monitors project progress– resolves problems and manages change– makes status reports of progress to management

*See Tab04 Planning starting on page 196 in the Reference Materials Manual for more information


Developing a Project Plan

• Things you should consider when putting together a Project Plan– Scope

• Goals (e.g., example - to become a certified agency in 6 months)• Objectives (e.g., measurables - see project plan)

– Project plan• task list (see Sample Project Plan on the pages that follow)• resources required (e.g., people, money, time)• schedule (e.g., due dates)

– Other considerations• project budget (see Sample Project Budget on the pages that

follow)• training• determine reviews & approvals• determine communications & status reporting


101

Typical Project Plan

• Scheduling Software– Fast Track Schedule by AEC Software - $190– Microsoft Project Software - $400– Microsoft Excel– Microsoft Outlook

• Flowcharting Software– VISIO

• Both available through Micro Warehouse: 800-696-1727• ACA Templates are in Microsoft Word• Developing a Project Plan

Start FinishActivity Name Responsibility Date Date 1 7 14 21 28 4 11 18 25 1 8 15 22 29

Steering Committee Meetings MD7/5/96 8/5/96

9/7/96

Agree on Certification Scope Steering Cmte 7/5/1996 8/5/1996Define Quality Policy Steering Cmte 7/5/1996 8/5/1996Design Document Structure Proj Team 7/6/1996 7/20/1996Design Document Control System Proj Team 7/20/1996 8/3/1996Design Document Format Proj Team 8/3/1996 8/10/1996

Employee Information Meetings QM7/15/96 8/18/96

Compare present QMS against ACA PPMS Proj Team 7/5/1996 8/5/1996Determine Traing Needs HR Manager 8/5/1996 8/30/1996Rough draft Quality manual QM 8/5/1996 8/19/1996Rough draft procedures Dept. Managers 8/19/1996 9/29/1996Etc.

Jul-96 Aug-96 Sep-96


102

Project Plan

• What should you include in the project plan???– Break work into tasks & assign responsibilities– Set time frame to accomplish activities

• Determine target certification date & work backward• Assign completion dates to activities• Revise target certification date

– Remember, a decision without a deadline is just a discussion!


Reference Materials to Help

– Sample Manual, forms and templates– CD-Rom with another sample manual– Reference Materials

• Good to Great• One Minute Manager• Who Moved My Cheese?• First Break All the Rules• Sacred Cows Make the Best Burgers• Critical Chain• Raving Fans• The Six Thinking Hats


Where do I start?

– Start with writing Nonconformities and client issues, that will drive documentation to be completed.

– Why?

– Because an issue cannot be closed until the documentation exists!


105

Exercise:

• Discuss what your next step is and develop your action plan.

• Share with the group what your next steps are going to be when you get back to the office.


106

Reminder: New Compliance Requirement

• To fulfill the compliance portion of PPMS, attendees must also attend at least one of the following ACA online seminars: Introduction to Collection Industry Compliance, Advanced Compliance: Conducting a Risk Assessment or Advanced Compliance: Controls and Corrective Actions.

• Or, if someone from your company holds the ACA Credit and Collection Compliance Officer (CCCO) designation that would qualify as well. Please refer to ACA’s event page online for upcoming dates on these seminars.


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Summary :

What is PPMSTM, elements and required forms. Wrote a client issue/Nonconformity and logged. Learned how to document a procedure and practiced writing

a procedure. Learned how to conduct the audit, what is required for

certification, how to submit for certification and what steps to take next to get the team going.

Questions????


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Thank you!

• We appreciate your comments. Please complete the Seminar Evaluation. They are part of our continuous improvement program.

• Also, please visit the PPMS pages of ACA Online at www.acainternational.org. There are answers to frequently asked PPMS questions on the PPMS FAQ pages.


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