Adapting to Rapid Growth

September 6, 2022

The Opportunity

As an organization, CINC has grown exponentially over the past years, fueled by the growing need experienced across communities as part of the opioid crisis and the state’s mental health resource crisis. While expanding support services across the State, CINC has also had to pivot to re-evaluate its internal capacity to ensure that its operations, governance, and controls are keeping pace with the demands of current contract requirements.

CINC ran a lean ship and came to Atrómitos to evaluate its governance and administrative practice in order to “right size” its compliance, auditing, and Board oversight and reporting processes to both its expanded scope of operations and the changing State funding structure. CINC had three objectives:

• First, to ensure that its policies, procedures, and operations reflected industry compliance best practices and controls, despite the small size of its administrative staff;
• Second, to ensure that CINC management had adequate authority to operate nimbly and respond to contract requirements and business development opportunities; and finally
• To ensure that the processes established were practicable given CINC’s limited administrative staff and to ensure that they were followed in practice by creating clear lines of accountability and oversight.

Approach

In approaching this engagement, Atrómitos worked closely with CINC leadership to develop a workplan broken into a series of stages, each building upon each other. The workplan, the roadmap that laid out the tasks, activities, and objectives required to accomplish these goals in our designated time frame, were as follows: (1) Defining the Scope of Review and the objectives of the engagement; (2) Conducting a Gap Needs Assessment; (3) the Development of new and updated Financial, Administrative, and Board Policies, respectively; and (4) Actively integrating Board Leadership.

At each of these stages, Atrómitos’ approached centered on three principles:

• Listen first (and second) before moving to conclusions.
• Focus on creating “virtuous” systems that reinforce accountability and transparency.
• Ensure that a client is empowered, so that at the end of the engagement, they can work without us.

Defining the Scope and Objectives of the Engagement 
Our work began by explicitly defining the goals of the engagement, timeline, and CINC’s team members available to contribute to the work. We established a core project team, including leadership representatives and front-line staff members with direct experience in the organization’s administrative operations. The client’s engagement and participation was critical not only to ensure that we had complete information and were able to tailor our evaluation and recommendations to CINC’s needs. By providing the tools for CINC to tackle the challenge head-on, rather than giving the solution, Atrómitos ensured this approach enabled staff to feel engaged and take ownership, empowered to take the materials created, to adapt, and expand them over time. 

Conducting a Gap Assessment of CINC’s Policies and Procedures
In every compliance engagement, the first step is always to start with an evaluation of current operations and resources to identify risks and opportunities for improvement. This Gap Analysis compares an organization’s “current state” to the needed “future state” – based on compliance requirements and industry standards. It is necessary in order to anchor any compliance evaluation (and prioritize the various results and areas for action). While this Gap Analysis is the first step, that doesn’t mean starting by walking through with a clipboard and “taking off points.” Instead, after conducting a review of all policies and procedures, the first step is to listen. We talked with team members to understand the how, when, whys, and wherefores of given policies and procedures and the practices and processes that weren’t committed to writing. 

This kind of evaluation can feel overwhelming to many; this is why Atrómitos focuses on walking leadership and frontline staff through the results of the evaluation and the reasoning behind each recommendation. The Gap Analysis then serves as a basis for the workplan for tackling the policy redrafting and updating.

Working the Plan and Integrating Board Leadership
Following the conclusion of the Gap Analysis, Atrómitos presented its recommendations and a three-month workplan to CINC’s Board for its review and approval. A Board member was appointed as a liaison to assist the workgroup over the engagement.

Over the course of the next three months, Atrómitos developed a new policy architecture and policy manuals for (1) Financial Policies; (2) Administrative Policies; and (3) Board Policies. This included the creation of a charter for a Financial Committee, and a Compliance Committee, chaired by a Board member. These committees allowed for the participation of individuals from outside of the organization, appointed by the Board based on their knowledge or experience, allowing for expanding the resources available to the organization and creating a “pipeline” for the expansion of the Board and recruitment of future Board members. Drafts were reviewed iteratively, with feedback integrated and adopted.

Results

With the support of Atrómitos, CINC successfully:

• Conducted a Gap Analysis of current policies against contract and regulatory requirements and compliance and auditing best practices. Presented a dashboard summarizing priority areas and recommended results for the Board and instituted a four-month work plan.
• Created a policy architecture and controls that devolved greater authority for daily operations to management, allowing staff to operate more agilely as it responds to contract requirements.
• Updated Financial and auditing policies to ensure that industry best practices, including segregation of authority, were integrated and adapted to reflect the operational limitations of a small administrative staff. 
• Instituted meaningful controls to ensure board oversight of management operations based on expanded operational authority. This included forming a Finance Committee and planning for increased board training and engagement to fulfill strategic planning and compliance oversight responsibilities.

To that end, the operational evaluation, updates, and reorganization provided CINC with the resources to build upon its foundation. It facilitated streamlined controls and greater nimbleness, enabling the organization to pursue growth and development with increased efficiency and effectiveness.