Section 4: Policies and Procedures

The assurances in Section 725(c) of the Act require that CILs “use sound organizational and personnel assignment practices” and “practice sound fiscal management.” To meet these and the numerous other requirements of grant and nonprofit management, CILs need to develop written policies and procedures, starting with a well-thought-out set of bylaws. In addition to bylaws, most nonprofits also have fiscal and personnel policies that guide the day-to-day functions conducted by the ED and the staff. The CILs with the strongest management practices also have policies concerning disaster planning, strategic planning, board policies for meetings, grant applications or other resource development, and a variety of other matters. Certain additional policies can be incorporated into the fiscal policies (such as risk management processes) and the personnel policies (such as a code of ethics for staff). An efficient way of providing all CIL policies to board and staff is with a policy handbook. Policies provide structure that, when operational, assures reasonable oversight of the Center.

Do not adopt what you cannot follow. Any external audit of your CIL, including those by either your Designated State Entity or by the Office of Independent Living Programs, will examine not only your written policies, but also your implementation of them. Make sure that you fully implement any policy you adopt.

Before developing policies and procedures, your board must establish the processes the board and staff will use to fashion new policies and procedures or revise existing ones. Policies and procedures will require review and updating on a regular basis. Doing this routinely is preferred to only reviewing them when there a problem.

  • Ensure that your board and staff are fully engaged in the development process. The more support and involvement there is from board members (committees and full board) and key staff members, the easier it will be to both adopt and implement your new policies and procedures.
  • Determine roles and responsibilities for board committees, the board, executive director, and accountant or bookkeeper in developing policies.
  • Determine a process for review and approval, including final approval by the full board.
  • Ensure that board minutes reflect the date of adoption of the policies and procedures and of any revisions.
  • Ensure the policies and procedures documents show the date of adoption or revision by the full board. Show the adoption date on the cover page and in headers or footers of additional pages. It is useful for the policy document to list dates of revisions as they occur, in addition to the original adoption date, to show your continual efforts at sound CIL management.
  • Establish a time period in which the policies and procedures document will be reviewed and updated. For example, annual review might be appropriate.
  • Schedule initial and periodic training for all staff whose job responsibilities will be affected by the policies and regulations above.[1]

Bylaws—As a legally incorporated 501(c)(3) organization, your CIL will already have in place a set of bylaws. Bylaws are the rules and procedures that your CIL must follow to ensure legality and productivity. As with all policy documents, bylaws should be reviewed regularly and amended when necessary for your CIL’s efficient operations. There are many resources on the Internet that provide helpful tips on what should and shouldn’t be in a set of bylaws, including example templates you can work from.

Fiscal Policies—The IL-NET Sample Fiscal Policies and Procedures Handbook contains a complete set of example policies and procedures that your CIL can use as a template to develop your own. The example policies will need to be modified to fit your CIL’s specific circumstances, but they will provide you and your board with a framework to get started (https://www.ilru.org/il-net-sample-fiscal-policies-and-procedures-handbook).

Personnel Policies—Because personnel law varies so much from state to state, the IL-NET cannot provide specific guidance on what your CIL policies will need to include. You should consult a local authority, such as an attorney or a nonprofit management center, for information on specific personnel policy requirements in your state.

Typically, bylaws, fiscal policies, and personnel policies address the broad subjects in the lists. Items marked with an asterisk (*) are required by ACL.

Typical Issues Addressed by Bylaws, Fiscal Policies, and Personnel Policies

Bylaws

  • Official name
  • Membership requirements (if any)
  • Scheduling of meetings
  • Board composition
  • Board elections
  • Board terms
  • Voting rules
  • Officer duties
  • Resignations, terminations, and absences
  • Committees
  • Amending bylaws

Fiscal Policies

  • Annual budget process
  • Accounting and auditing guidelines
  • Nature and frequency of financial reports
  • Separation of duties and other internal controls
  • Bank reconciliation
  • Cash management
  • Allowability
  • Procurement
  • Method for conducting technical evaluatons of proposals and selecting providers/vendors
  • Conflict of interest*
  • Code of ethics
  • Payroll and time and effort reporting
  • Travel and reimbursement
  • Inventory controls
  • Risk management
  • Document retention

Personnel Policies

  • Benefits and insurance*
  • Code of ethics
  • Computer and information security*
  • Conflict of interest* (2 example forms are available in Financial Management for CILs)
  • Confidentiality,* including informing consumers about protections
  • Drug-Free Workplace*
  • Leave* (paid and unpaid, sick, vacation, holiday, bereavement, parental, military, jury duty, voting, extended, etc. )
  • Nondiscrimination, equal opportunity and diversity*
  • Performance evaluation
  • Professional development
  • Record keeping requirements (time and effort, other requirements)
  • Separation
  • Travel and reimbursement
  • Wage Payment (frequency, manner)
  • Whistleblower
  • Workplace harassment

These lists cover broad subject areas and are not intended to be detailed or exhaustive. Other policies and procedures—such as those related to service delivery and Consumer Information Files (https://www.ilru.org/topics/consumer-information-files)—are required and necessary but are beyond the scope of this tool kit. Please see the resources below for more in-depth information on policies and procedures. References to policies and procedures can also be found in Sections 5 (Budget and Finance), 8 (Intersection of Disability and Diversity), 9 (Engaging and Supporting the Board of Directors), 10 (Compliance and Independent Financial Statement Audits), 11 (Risk Management), 13 (Strategic Planning), 14 (Advocacy vs. Lobbying) and 16 (Staff Retention).

Procedures: Putting Policies into Action

While necessary, policies are only worth the paper they are written on if they are not accompanied by procedures—detailed instructions on how to implement the policies. Procedures describe the steps that staff and board will take to carry out the intent of the policy. Procedures can define vague terms that sometimes appear in policies, such as “notify your supervisor in a timely and appropriate manner.” What is “timely”? Does that mean a week before (such as requesting leave), a day before, an hour before? What is “an appropriate manner”? Is that a phone call, an email, a face-to-face meeting, a form that needs to be filled out, all of the above?

Procedures make it possible for anyone coming into the organization to understand how things are done. If the bookkeeper or accountant is on vacation or called away suddenly, the steps for bank reconciliation or running payroll will be available and those important processes can still be carried out.

Resources for a Deeper Dive

[1] Adapted from Heveron, J. F., McElwee, P. L., Petty, R., Jones, D. L., IL-NET Sample Fiscal Policies and Procedures Handbook: A Set of Policies and Procedures with Annotations for Use in Training for Centers for Independent Living. Houston: Independent Living Research Utilization, 2020.