This is the second article in a three part series on Registration 'Pain Points' for Schools. You can access part 1 here and part 3 here.
It can easily be agreed that school staff, and particularly teachers, are excellent risk managers.
School staff, students and their parents or guardians enter the school grounds every morning. After the parents depart, the staff conduct learning activities, care for the students, teach the curriculum throughout the day and leave at the end of the day - generally without critical or major incidents occurring. These frontline staff are excellent practical risk managers and should be applauded.
As we discussed in the first article in this three-part series, the registration standards, manuals, guides or guidelines in each state and territory set out the evidence and other requirements of compliance that the regulators expect to see during a school’s re-registration process. These are the requirements that a school must meet to be registered or re-registered as a school.
Policies are often one of the main pieces of evidence that a school is expected to provide. They are also used as ‘risk controls’ by schools to seek to manage their risks and to support the staff as the school’s first line of defence. Risk controls can also take the form of staff training, meetings and a wide variety of tasks and checklists.
Policies and policy development are usually the focus of schools in the lead up to re-registration. These three words come to mind regarding policy development in any organisation:
Time
Developing policy content takes time. Where does school policy content come from and whose time is being taken up to develop it?
In a great many schools both historically and today, policy content is written by members of the leadership team and, in some cases, even the school board members. In many schools these people are expected to be the most experienced at developing policy content. Staff in leadership roles may be great teachers, loved by their students and experts in their curriculum area. Having these qualities indicates that they would be the best people to write school policies, doesn’t it? Wrong.
School leadership teams are made up of extraordinary people with some or all of the above qualities but that does not mean that they are the best people or the most qualified to write policy content for the school. However, that has generally been the expectation placed on school leadership teams for many years. School leaders generally can and do articulate well their school’s procedures about how things are currently being done. This knowledge is gained through their extensive practical experience, but it doesn’t mean that they necessarily have the skills to interpret law and registration guidelines or requirements.
When a senior staff member sits down to write a new policy, where do they start? Do they know where to find the appropriate information and where to begin? Maybe with the guidelines. Do they read and take into account any legislation or the relevant manuals, guidelines or standards?
In my experience, and reflecting on the ‘re-registration nightmare’ discussed in the first article in this three-part series, when a school realises that they don’t have a registration policy nor the time to develop one, they contact a colleague at another school and ask for a copy of the policy that they are going to develop as it will save them time.
The school has now outsourced policy content from another school (or the internet), but have they asked any questions regarding what credentials the person who initially wrote this policy may have had? What was their experience? What knowledge was taken into account to develop the policy that they have copied? And they might want to ask those same questions if the content was developed internally at the school too.
I expect that not many school staff members ask the question about where the policies in the school came from. Why? Because they’re in a hurry and it would take time to investigate answers to these questions and they might not like the answers that they find.
Stress
Staff in schools are under more pressure than ever before. Legislative change is almost a constant and over the past year there’s been the added stress of staff and students potentially (and actually) being sent home under lockdown conditions at any moment. This is stressful enough without the additional stress caused by the need to develop policies on top of an already busy load and external pressures.
We have established that the most likely staff members to be developing policy content for a school are those on the leadership team and that they might not be the best people to be developing this content given knowledge and time constraints.
What other stress do we load onto our staff when they have been tasked with writing policies? It may come in the form of being unable to teach classes that they usually teach. It may affect their opportunity to attend PD and also impact on their ability to function in their role at full capacity. The flow on effect will most certainly impact other staff and students, extending the stress levels across the school community.
It is not unheard of for school leaders or executive staff to be given time out from their usual role for several months to focus on developing the policy resources for re-registration while another staff member steps up into their role in an acting capacity. This highlights how difficult it can be for a staff member to prepare for re-registration and carry out their usual responsibilities if it is common for staff members to have to step away from their roles entirely to prepare for re-registration.
Another stressor is identifying and actioning the evidence that is required to be collected to show that the school is implementing its policies. Are there best practice procedures in the policy that have been developed in relation to providing the evidence? Does the current practice of the staff in the school actually reflect what has been documented in the policy?
Collection of evidence is difficult after the fact and, if records have not been kept transparently, the evidence required to demonstrate compliance can sometimes slip into cyberspace or, even worse, the archive room. This can be a major cause of stress for staff developing policy-not knowing what information needs to be captured and not documenting the procedures.
Having a policy is only the tip of the iceberg. Being able to demonstrate the policy in action is crucial in today’s environment.
Cost
Time is money. If a policy has been developed that is not addressing the registration requirements or legislation and needs to be reworked, this will cost someone on the team more time.
What could it cost the school if litigation commences due to an ill thought-out policy? There are likely to be financial and emotional costs that will all cost time. Where will that time cost fall? Directly onto the shoulders of those same school leadership staff who developed the policy initially. Time costs any school money.
Burn out is yet another cost not only in human terms but also monetary terms. The weight on leadership teams is enormous and no more so now than after the year that was 2020. School leadership staff on the cusp of retirement have commented throughout 2020 that they wish that they had retired at the end of 2019 due to the increased pressure that the COVID pandemic has brought. What is the cost to schools if principals and leadership staff burn out and leave? It is a substantial cost to any organisation to recruit new staff.
School leadership teams are compensated according to their responsibilities and experience. The amount of time that they spend policy writing to satisfy the registration auditors and to control identified risks can be quantified through their salary rate multiplied by the number of hours that they spend on these tasks. How many schools have contemplated and calculated the actual financial cost of policy development by a senior staff member? How many hours were spent preparing for their last registration ensuring that all the policy content was up-to-date? Multiply staff by salary by hours and suddenly the cost of policy development begins mounting into the thousands of dollars.
Policy development and implementing additional risk controls is a costly business for a school but it needs to be completed and implemented well to support staff, so it is worthwhile considering carefully what cost a school is prepared to pay and who at the school is going to bear the burden.
What Should Schools Be Doing?
What solutions should a school employ regarding policy development and the adoption of policies into the school culture?
Schools should:
- consider outsourcing policy development to a trusted source. Outsourcing policy development to experts in policy writing will reduce the cost that staff will pay in both time and stress. There are many options available, and schools need to choose the best fit for them, whether it be an online policy and enterprise risk management package or bespoke policies written by independent lawyers or the Association for Independent Schools’ policy templates in the school’s state or territory
- ensure that there is both a documented and systematic approach to evidence gathering and identifying and recording risks and hazards in a central location to assist with reporting
- define school culture through staff training on school policy content. This type of approach of bringing policy to life will aid with continuous improvement and better risk management within the school.
Unfortunately, schools will never eliminate the monetary cost of policy development and management of this and other risk controls. However, whatever they decide to do should be based on more than the monetary cost. A school should determine if there is sufficient expertise on staff to write the relevant policies, whether or not they have the resourcing to do it properly (without adding further work and stress to staff) and when to look to expertise offered by external providers or associations.
It is crucial to address this long before registration is due. Policy development should result in ongoing compliance. Developing or updating policies in line with legislation and registration manuals and guidelines in the months or weeks before re-registration will simply stress out school staff and, if not done properly, it may lead to a poor assessment of the school by the regulators.
