The Client’s Need
In 2014, the Office of the Deputy Administrator for Compliance (DAC) for the USDA Risk Management Agency had a problematic case backlog involving disputed Regional Compliance Office (ROC) Final Findings due to a significant personnel shortage. RMA contracted AvantGarde to support its Headquarters and Regional Compliance Offices (RCOs) by drafting Final Administrative Determinations (FADs) for old cases, reviewing handbook drafts, providing guidance concerning revisions to the Compliance Activities and Results (CARS) record keeping system, and assisting with crop insurance policy reviews pertaining to improper payments.
The combined AG team brought to the project over 90 years combined team of investigative and report writing experience, along with excellent knowledge of RMA policies and procedures.
- Prepare Workforce and Document Current State. Initially, each team member was assigned an inventory of old cases for which FADs were required. Team members also participated in conference calls with RMA staff to discuss the status of cases. Team members assisted with the identification of additional pending cases which had “slipped through the cracks” and helped reconcile discrepancies with the official case log.
- Compliance and Quality Control Reviews. When all old backlogged cases had been assigned, team members volunteered to process new cases. Team members also worked on improper payment cases for RCOs, both by conducting policy reviews, and by conducting required quality control reviews of work done by RCO personnel.
- Case Management Support. AG team members were routinely asked to assist others with understanding and interpreting various aspects of cases. Through a search of files, documents were found which facilitated the closure of numerous cases. A search was also conducted upon special request by RMA Appeals and Litigation (A&L) for files related to an A&L case.
- Policy Guidance and Training. Team members have responded to all RMA requests for assistance, and have taken extra steps to help RMA succeed. When new personnel have been assigned to draft FADs, RMA have depended upon the expertise and experience of AG team members to help the RMA staff member or contractor become acquainted with the process.
Once AG came onboard, there was an unprecedented effort to gain control of the backlog of disputed cases. From June 2015 through March 2017, the AG Team closed approximately 30 backlogged cases, relative to the collective 20 cases closed by two full-time RMA staff and two full-time contractors during the same period. The AG Team’s immediate accomplishments motivated the RMA staff to become more productive. In regard to CARS, the AG team’s review of the system shed light on RMA’s recordkeeping challenges. The AG team provided recommendations which helped improve overall records management, and resulted in the identification of cases which required additional processing. Under the leadership of the AG team, there has been a dramatic decrease in the agency’s backlog of disputed findings. To date, the AG team has completed FADs on approximately 40 cases and has compiled four CBCA files.