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OVERSIGHT AS PRACTICED IN SUCCESSFUL ORGANIZATIONS;
INSIGHTS FOR EPA
Washiiigt
on,
20460
Program Evaluation Division
Office of Management Jsystems
and Evaluation $
U.S. Environmental Protection Agency
September 1983 J.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
I- INTRODUCTION
A. Why Is Oversight an Important Issue?,
B. Study Methodology and Focus
4
5
II. FINDINGS; OPERATING PRINCIPLES OF
OTHER ORGANIZATIONS
A. Basic Operating Philosophy
B. Role of the Central Office to Ensure Success
C. . Defining Purpose, Methods, and the Work
D. Maintaining Support and Motivation
9
13
15
18
III. CONCLUSIONS; IMPLICATIONS FOR EPA
A. Limitations on Translation
B. Opportunities for Improvement
32
32
35
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EXECUTIVE SUMMARY
This report describes how successful organizations approach
oversight, and suggests some opportunities for application of
that approach by EPA. It is based'on interviews with officials
in six private companies and two federal agencies, and was
prepared as resource material for the Deputy Administrator's
Task Force on State/Federal Roles.
CONTEXT FOR THE FINDINGS AND CONCLUSIONS
\
In EPA, "oversight" of delegated programs usually means
the review and evaluation of state programs to ensure that
requirements of federal law and policy are met and progress
is made toward specific program goals.
However, it became clear in the interviewing process
of this study that oversight defined as review and evaluation
was too narrow a focus. The companies and other agencies inter-
viewed 'could only discuss the function and mechanics of evaluation
within the larger context of ensuring the success of their field
units. Thus, both the findings regarding other organizations
and the conclusions for EPA address issues beyond review and
evaluation methods.
HIGHLIGHTS OF FINDINGS
1. Successful decentralized organizations have mechanisms
to ensure quality control and adherence to central office
policy by the field units. But they accomplish this through
a comprehensive approach that ensures the success of
the field units and the constant improvement of the
field work.
This comprehensive approach weaves together a
number of separate activities into a solid fabric of
continual support and motivation for the field units.
This usually includes some combination of the following
activities:
o tracking or monitoring
o formal evaluation or auditing
o training
o constant communication
o on-site consultation
o technical assistance
o staff details or exchanges
o financial assistance
o incentives
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No one activity by itself is sufficient to ensure success.
In the organizations studied, these activities reinforced
each other, forming a consistent performance and support
system for the- field units.
2. While different successful organizations use different
combinations of activities and techniques to support and
motivate their field units, they express the same attitude:
in the long run, the success of the organization depends
on the success of the field units; therefore, supporting
the field units must be a top priority of the central
office.
3. These organizations recognize that the human aspect of
the work is critical to its success. This was evidenced
in the priorities placed on constant communication and
on highly motivated, top quality employees.
4. Formal evaluation or auditing is important, but it is
not sufficient to ensure quality control and the success
of field units. Success needs to be worked on every
day, and evaluation needs to focus on improving the
operational work.
SOME IMPLICATIONS FOR EPA
EPA is not a business, and our mission is somewhat
different from that of the other federal agencies. Neverthe-
less, there are important operational similarities. The
principles and methods observed in other organizations can.
provide insights on opportunities for improvement in the way
EPA does its work — especially for program activities delegated
to state agencies. Such opportunities include the following:
1. EPA headquarters, EPA regions and states need to agree
on the general approach and attitude needed for EPA's
oversight of state programs, and to begin working
collaboratively, for each EPA program, on the details of
how to ensure the success of state programs. We need to
encourage existing successes, and work toward improvement
in other areas.
2. EPA needs to increase its on-going support to states with
delegated programs, in terms of:
o training for state personnel;
o travel to state offices for consultation and
problem-solving; and
o technical support for state programs.
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3. EPA needs to improve its capacity to provide quality
technical and program assistance, through:
o improving the access of states to EPA's existing
expertise;
o increasing the operational field experience of EPA
staff who provide technical assistance; and
o improving the quality and quantity of EPA expertise.
On-going support to states and internal capacity-building
in EPA will, of course, only be useful if the EPA program
staffs have determined clearly what specific work the states
need to be doing and what constitutes successful programs and
performance.
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I. INTRODUCTION
A. WHY IS OVERSIGHT AN IMPORTANT ISSUE?
In the past few years, the Environmental Protection Agency
has been delegating major operational responsibilities for environ-
mental programs to state agencies. This means that EPA's work
is shifting away from day-to-day program operations and toward
oversight of state programs and provision of assistance to states.
In an earlier study of EPA's progress in delegating program
responsibilities to the states, we found that there was confusion
among b6th state officials and EPA staff about EPA's role after
delegation. Lack of a clearly defined oversight role was slowing
the progress of delegation, and making oversight difficult to
carry out in a consistent way.
There was resistance to delegation by some EPA personnel
who were concerned that losing direct control of operating
activities might lead to a reduction in program quality, and who
saw no alternative means -of EPA influence over the states. This
was resulting in slower delegation by EPA. After delegation,
the concern about losing control of program quality was resulting
in oversight activities in which EPA staff "second-guessed"
state judgments on individual permit actions.
State officials interviewed in the delegation study generally
welcomed EPA oversight of state programs after delegation.
However, they were concerned that the Agency's oversight role
needed clarification. While the states' uncertainty about .EPA
oversight did not create an obstacle to their seeking delegation,
by far the strongest incentive to seek delegation was the prospect
of less intervention by the federal government in state environmental
programs. Nevertheless, the states viewed EPA oversight of state
programs after delegation as important for two reasons. First,
they believed that EPA has a responsibility to ensure that
minimum national standards are being met across the country.
Secondly, states wanted some assurance that their neighbors
would not be using relaxed pollution control regulation as a
strategy for attracting industrial development.
As a follow-up to the delegation study, we began work on
several studies to address how the Agency can best meet its
post-delegation responsibilities. This report presents
the results of one of those studies, which looked for ways to
improve EPA's oversight of delegated state programs.*
* Report prepared by Ellie McCann, manager of the study,
Program Evaluation Division. The study team which conducted
interviews and assisted with the analysis included: Joe Retzer,
Lew Crampton, Tom Kelly and Jerry Emison in EPA; and Joe Nay,
John Waller and Bill Foskett of the Performance Development
Institute.
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B. STUDY METHODOLOGY AND FOCUS
In this study, we wanted to examine alternative ways of
conducting oversight in order to develop the most effective
methods for EPA. Our approach was to interview senior managers
in private and public organizations who perform similar tasks in
overseeing geographically dispersed, relatively autonomous
operating units.
The objectives of the study were: (1) to provide infor-
mation on oversight methods of successful organizations which
might offer insights for EPA staff in conducting oversight; (2)
to provide resource material for the Deputy Administrator's
Task Force on State/Federal Roles; and (3) to identify ideas
or issues which might be pursued in more detail in future work.
We interviewed officials in six businesses and two federal
agencies. In making the selection, we looked for a variety of
successful, well-managed organizations, seeking a mixture of
private and government organizations and both service and product
companies. The companies selected are considered by the business
community to be successful in terms of profitability and/or
good management. In addition, the companies have some operating
similarity to EPA, with multi-state operations and relatively
autonomous operating units. The federal agencies are generally
regarded as highly successful in carrying out their respective
missions. The agencies also have good reputations for working
with states and have some functions similar to EPA. The following
organizations were selected:
o Allstate Insurance (Northbrook, IL): Successful long-term
performance in the assessment and management of risk, where
decisions binding to the company are made in the field by
individual agents.
o Centers for Disease Control (Atlanta, GA): Reputation for
excellent relationships with state health departments, and
high credibility among health professionals and the general
public. Both CDC and EPA have environmental health programs,
state grants programs, and a cadre of scientific experts.
o Federal Highway Administration (Washington, DC): Good work-
ing relationship with state highway departments, and has
similarities to EPA's construction grants program.
o ETito-Lay Corporation (Dallas, TX): Reputation for excellent
management of far-flung operations. Also provides variety to
the selection since it is a product company rather than a
service organization. Focused on the delivery and sales
operations.
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° Hospital Corporation of America (Nashville, TN): Reputation
for financial success in building new hospitals and taking
over existing hospitals to manage. Similarity in its very
autonomous field units, and its cadre of technical experts
(physicians, nurses, etc.) who provide the health care services.
o Marriott Corporation (Silver Spring, MD): Reputation for
long-term excellent management and profitability. Focused
mainly on the "inns," which although part of the Marriott
system are owned and operated by an investor or franchisee.
Their autonomy is greater than that of the hotels.
o National Bank of Washington (Washington, DC): New operating
policy has turned the branch banks into individual profit
centers, placing new and higher performance demands on the
field units. Focused on the loan activities of the branch
banks.
o Quality International (Silver Spring, MD): primarily a franchise
hotel operation, with very autonomous units. Recent changes
in management and programs are being recognized in the business
community as successful.
The focus of this study was on the relationship between the
central office and the field units where the operational work is
accomplished. For the federal agencies, the field'units were
considered to be the corresponding state agencies. (See Figure
1 on page 7.)
Clearly EPA is not a business, and no oversight system
from another organization is transferable intact to EPA. Never-
theless, there are important similarities between EPA and these
selected organizations because each has geographically dispersed
and somewhat decentralized operations.
The following definitions are used in this study:
(1) Field Unit; the offices or persons that carry out the
front-line operational work.
Figure 1 shows the range of field units to be discussed
in this report.
(2) Central Office; all offices in the organization other than
the Yield units. Regional offices are therefore considered
part of the central office because they do not perform the
operational work.
It should be noted that for EPA operational activities
which are not delegated to the states, the regional
offices function as field units rather than as part of the
central office. However, in this study we are looking for
similarities to EPA's role in 'delegated programs, in which
the regional offices function as part of the central office.
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(EPA)
FIELD
OPERATING
UNIT
FIELD
OPERATING
UNIT
o National Bank of Washington
o Marriott Corporation
o Quality International
o Hospital Corp. of America
o Allstate Insurance
o Frito-Lay Corporation
o Federal Highway Administration
o Centers for Disease Control
(state
agency)
o branch bank
o hotel/inn
o hospital
o insurance agent
o salesperson
o state agency
Figure 1; Study Focus, on Similar Relationships Found in Other
Organizations
(3) Oversight; review and evaluation of field unit activities
for the purpose of quality control.
To the extent that it has been defined or developed in
specific EPA programs, oversight usually means "program
audit" of state programs for quality control to ensure
that requirements of federal law and policy are met. The
companies and federal agencies interviewed do not generally
use the word oversight when discussing quality control of
the field work. In this report the term oversight is only
used when discussing auditing or evaluation in EPA.
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It became apparent in the interviewing process of this
study that the issue of review and evaluation was too narrow
a focus. We found that the corporate and government officials
interviewed could only discuss the mechanics of evaluation
within the larger context of ensuring the success of their
field units. The rest of this report discusses both evaluation
approaches and the overall relationship between the central
office and its field units, since the two issues were found
to be inextricably connected. However, the findings regarding
other organizations and the conclusions for EPA address
issues beyond review and evaluation methods.
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II. FINDINGS: OPERATING PRINCIPLES OF OTHER ORGANIZATIONS
While all of the selected organizations conduct formal
review and evaluation of their field units, the specific methods
vary significantly, depending upon the mission or purpose of
the organization, the division of responsibilities between
the central office and field units, and the type of work
carried out by the field units. However, there was a consistent
pattern across all organizations in terms of why they conduct
formal evaluations: to improve the field work, and ensure
field unit success. We also found that formal evaluations
alone are not considered sufficient to ensure continuing
high quality work by the field units.
In addition, there was a consistent philosophy, or set
of values, in each organization that formed the basis for
the interaction between the central office and field units.
While the philosophy varied somewhat among the organizations,
the presence of.a simple and clear philosophy was common to
all.
This chapter presents the study's findings regarding how
other organizations ensure the success of field units, and
describes the overall relationship between the central office
and field units. The following sections discuss basic philosophy
and-some important operating principles and methods used by
the eight organizations interviewed. Illustrative examples
are included. In some cases the quotes used are a conden-
sation of much longer discussions.
Section A describes three specific values that were found
to be an important part of the overall philosophy of all the
organizations. Section B presents an overview of the role
of the central office, in terms of the many central' office
activities that directly or indirectly affect the ability
and motivation of the field units to successfully carry out
their work. The last two sections discuss in more detail
the approaches and methods for carrying out these central
office activities. Section C looks at the activities that
are prerequisites to successful performance of field units:
defining organizational purpose, methods, and the work.
Section D describes some principles and methods for keeping
the work going in a successful direction, through activities
that maintain support and motivation for the field units.
A. BASIC OPERATING PHILOSOPHY
An organization's philosophy sets the tone and direction
for its internal relationships and its operating principles and
methods. Although the exact philosophies varied among these
organizations, the following values were considered extremely
important by all eight organizations as a basis for auditing
and for the overall relationship between the central office
and field units.
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1. The success of the organization depends on the success
of the field units.
Senior managers in these organizations are aware that the
work that ultimately makes the difference occurs in the field
with the customer or client. This is true whether the work is
providing hotel rooms, selling potato chips, building highways,
or controlling diseases. Thus, the success of the organization,
and of the central office, depends on the success of the field
units in carrying out their work. The field units are, in an
operational sense, the primary clients of the central office.
It follows that an important role of the central office
is to enable and encourage the field units to succeed. This
role was found to be both a fact and an attitude. The central
office's supportive attitude toward field units accurately
reflects operational reality and it motivates and influences
day-to-day relationships in a useful way.
Marriott:
Fact - An independent hotel joins the Marriott system
because the owner feels that Marriott knows how to run
hotels a better way, and that in the long run his hotel
will be more profitable.
Attitude of central office - "The only reason we're here
is because operating hotels have problems."
Frito-Lay:
Fact - Sales of salty snacks off the retail shelf are the
crucial point of Frito-Lay1s entire operation, and the key
to its success. The company therefore places heavy emphasis
on maintaining a supply of fresh products for its route
salesman and on finding possible new retail outlets for its
route salesman to follow up on.
Attitude of-central office - "Service to sales: what can
we do today to help the route salesman?"
Centers for Disease Control:
Fact - States have always had the constitutional authority
to protect the public health, and the CDC has always served
a support function. "We cannot carry out our mission to
ensure that the country is controlling diseases without the
participation of state health departments."
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Attitude of CDC - "The bottom line is service. Our people
assigned to the states are out there to serve, and they
know that. We're coining in to the state to solve a problem.
But there are two different problems to solve. We can
solve the technical problem. But it's something else to
maintain a good working relationship with the people who
are going to implement the technical solution."
2. High quality service and products are critical^ to the long-
term success of the organization.
These organizations are interested in long-term success and
profitability, as well as short-term profits, savings, or successes.
They believe that the basic requirement for such long-term success
is the provision of consistently high quality products and services,
Marriott: "We do it right! It may take more work, but
it's worth it in the long run."
Allstate: "You are in good hands with Allstate."
Quality Inn: "We insist on ruthless cleanliness and
exceptional service."
3. The humanaspect of the work iscritical to its success.
Five of the six companies are in the business of providing
services: banking and insurance services, temporary lodging,
and temporary health care. Frito-Lay provides a product to
retail stores that is backed up with service. The Federal
Highway Administration and the Centers for Disease Control
primarily provide services to state agencies. We found that
each of these organizations believes that the provision of
high quality service or products depends in large part on
highly motivated, top quality employees. This value is
expressed in the priorities given to activities such as the
following:
o hiring and maintaining top quality employees;
o extensive training of field staff who actually carry
out the operational work;
o promoting central office staff based on both their
expertise and field experience;
o keeping central office staff in close touch with field
staff, either by working or traveling in the field; and
o following up written communication to the field with
on-site, face-to-face communication whenever possible.
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These priorities reflect a strong emphasis on investment in
humanresources and on human interaction am3 motivation
in implementing the work. Thus these organizations spend
considerable time and resources on activities that are rather
difficult to measure or evaluate in the short termr because
they work toward the long term benefit.
Centers for Disease Control:
"We invest tender loving care in our employees. We pro-
vide lots of training: long term training at universities
and lots of short term practical training. We have a very
active employee development unit because it pays off.
CDC attracts and keeps high quality employees by focusing
on individual career development, esprit de corps, pride
in and commitment to the work, and maintaining high
standards. Talent attracts talent!"
Marriott:
"Our strategy for providing quality service to the customer
recognizes that people count 1 Operationally, we put the
employee first, the customer second, and the corporation
last. Standard operating procedures are no good without
the personal attention of good quality people to back up
the SOPs. Priority on the employees makes the customers
first and the operations profitable."
Frito-Lay:
From a trade publication: "The president of Frito-Lay
has a preoccupation with the quality of the people in
the organization - and that certainly has been one of
the key elements in the company's three-fold earnings
growth since he became president in 1975."
Quality Inn:
(Is there one factor that is most important in making
oversight by the central office work, and that EPA
should pay attention to?) "Yes: on-site liaison!
Bulletins and memos are not enough. We use them too,
but only 20% of the recipients ever read them, so we
have to follow-up with on-site discussions. Hotel
managers receive tons of paper from people trying to
sell them things. We're just somebody else trying to
sell them something. They're too busy trying to operate
a hotel to have time to read all that paper. So we depend
on our own personal follow-up."
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These three basic values - successful field units, high
quality service and products, and emphasis on the human element
- tend to influence many other activities in the organization,
including the approach to quality control of field operations.
B. ROLE OF THE CENTRAL OFFICE TO ENSURE SUCCESS
In this study we found that most of the activities of
the central office seemed to focus, at least in part, on
ensuring the success of the field units in carrying out
their work. The following principles help to describe the
wholistic view of these organizations regarding the direct
and indirect influence of central .office activities on the
success of field units.
1. Ensuring success requires central office provision of both
leadership and direct assistance
Leadership includes the development of a clear organi-
zational purpose and direction, translation of goals and
strategies into workable operations, and tracking of field
operations back to the goals and strategies so as to keep
all the field units going in the same direction. Assistance
includes the provision of specific tools such as instruction
manuals or special equipment, and continuing support, such
as training or technical assistance.
Centers for Disease Control: :
"When we've identified a major new health problem, we
work very hard at getting invitations for assistance
from the states. At times assistance includes strong
leadership, as well as collaboration, cooperation, and
response."
2. Quality control and assistance are difficult unless someone
has first carefully defined what the work consists of and
what constitutes success.
Thus there are several central office activities that
are prerequisites to succesful performance of work by the
field units:
o Find the right idea that works, or the right approach
to solving a problem, and describe it in terms of clear
simple goals and strategies;
o Simplify the work and delegate it to the lowest possible
level; and
o Define the expectations for work performance.
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Once the work and the expectations are understood, it is then
both useful and relatively easy to track the field operations
back to the goals and strategies, and to support and motivate
the field units in carrying out the work.
Marriott:
"We have a complete system for developing and operating
a Marriott hotel, from landscaping through operations
and renovation. We provide training, guidelines and
standard operating procedures. We then use an audit
check list that includes all functional areas, with a
short list of probing questions for each one. The
questions relate to the system they are supposed to be
following."
3. One reason why the central office in these organizations
can provide effective leadership and assistance to the
field units is because the central office's senior
managers have both technical expertise and extensive
operational field experience.
Marriott:
"The majority of people at the top of Marriott started
at the bottom getting operational experience. For
example, the Vice President for training began as a
hotel desk clerk."
Frito-Lay:
"About 75-80% of central office management staff came
to that job with .field experience. Those few 'conceptual
support1 staff hired by the central office without field
experience are sent out to the field for a training period
of six months to two years after a short initial stint in
the central office. Even the analysts go out in the field
and ride around in delivery trucks."
Centers for Disease Control:
\
"CDC employees start in the field with state agencies,
as part of the CDC career ladder. This gives them an
understanding of state problems. For CDC field repre-
sentatives, the first career step is to work in a state
venereal disease program. This gives them hands-on
experience of what a public health program is really
like. Even CDC's Deputy Director began his career as a
veneral disease "case chaser" in a state health department."
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4. A composite picture of the key elements and activities
that are necessary for ensuringsuccessfulfield units
can be summarized as follows:
o clearly articulated mission or purpose,
o clearly defined work and work objectives or expectations,
o clearly defined responsibilities and areas of autonomy
for the field units,
o constant two-way communication between central office
and field units,
\
o frequent tracking of field activities,
o on-going technical and management support for the
field units, and
o frequent evaluation of work performance measured
against purpose and objectives.
5. Ensuring the success of the work and of the field units
is not a static process. The work changes over time,
in order to improve the quality, or.to respond to market
changes or new problems and challenges. But these
organizations have a consistent operational approach
to keeping the work going forward in a successful
direction;
o watch for successes and keep them going,
o enable necessary adaptations, and
o monitor failures and correct them quickly.
Each of the key elements and activities necessary for
successful field units is discussed in more detail in the
rest of this chapter. Specific examples from the organizations
illustrate not only the seven elements and activities, but
also this operational approach to implementing them. The
first three elements are discussed in Section C, while the
last four are discussed in Section D.
C. DEFINING PURPOSE, METHODS, AND TH.E WORK
1. Clear organizational goals and values help to establish
a common direction and motivation for the work. Often
the development of clear goals in these organizations
is the result of one person, or a few people, who had a
long-term vision of what that organization could become.
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Hospital Corporation of America:
From the HCA Newsletter: "From the outset, the fledgling
company had a strong set of values that have evolved into
a corporate mission. This mission, posted in every HCA
hospital, is: "Delivery of quality patient care at a
reasonable cost.' In retrospect, HCA's approach to
hospital management seems obvious: to bring modern
management discipline to a troubled industry. But at
the time, this .was a new concept. The HCA founders
believed patients and profits could reinforce each
other."
Centers for Disease Control:
"CDC grew out of a success, but the subsequent direction
was set in large part by the vision of one man." CDC
began in 1942 as a wartime agency established to control
malaria. At the conclusion of WWII, the Office of
Malaria Control in War Areas had assembled a highly
competent group of disease control specialists with
effective working relationships with the states. To
meet new emerging needs^ the U.S. Public Health Service
decided, to establish a permanent organization with
prominence in laboratory science, training, and epide-
miologic investigation for assisting the states in
vectorborne disease control. Then Dr. Joseph Mountin
of the PHS conceived of the "centers of excellence" con-
cept. Dr. Mountin envisioned several centers that
would make available to the state health departments
certain highly specialized competencies which few states
could afford to maintain on their own staffs. Each
center would concentrate on a broad segment of public
health, e.g., communicable disease control, environmental
sanitation, etc"i
In 1946 the Office of Malaria Control in War Areas became
,the Communicable Disease Center, in large part following
Dr. Mountin's organizational concept. The mission of CDC
was to help states control communicable diseases, through
provision of technical assistance and training where
problems either exceeded the states' resources for
their solution or were interstate or national in nature.
Thus CDC has, since 1950, functioned as a federal service
organization to provide specialized assistance to states.
This pattern, expanded and tailored to meet changing
needs, has persisted^over the years.*
What is most impressive about CDC is that the agency
has translated its mission into a very practical, con-
sistent and action-oriented operational approach: "Solve
* Condensed from: "Centers For Disease Control," William
H. Foege, JOURNAL OF PUBLIC HEALTH POLICY, March 1981.
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the health problems in the field, using whatever means
and resources are available. This includes working
hard to get'ourselves invited in by the states. Take
action, and let the accountants sort it out later."
Marriott:
"There is a commitment to quality service because the
man at the top is geared that way. Bill Marriott will
periodically walk through hotels and pick up loose
paper. When hotel managers are brought together in
meetings, the absolute top people speak directly with
them, from the president on down. If any hotel receives
less than 92% positive guest comments, Bill Marriott is
personally informed, and he demands an explanation.
Bill Marriott picking up loose bits of paper or noting
a drop in customer satisfaction ratings has a strong
effect. There is interest and commitment at the top!"
2. A clear division of responsibilities between, central
office and field units ensures efficiency at all levels,
and prevents unnecessary intrusion on local autonomy.
In these organizations, the assigned responsibilities
tend to reflect each organizational unit's area of
special expertise.
Federal Highway Administration:
The states site and build highways, while the federal
government enforces standards and finances highways.
Hospital Corporation of America:
The hospitals provide health care and are responsible
for the quality of service, while the corporate office
provides business and financial management.
Quality Inn:
The hotels provide lodging service, and the central
office provides sales promotion, computerized reserva-
tions system, and quality control.
3. The operational work is simplified and standardized as
much as possible in order to maximize efficiency and
consistency. The work is then delegated to the lowest
possible level, and areas of autonomy defined for the
field units.
National Bank of Washington:
Branch managers are given authority to act independently
in making loans up to a certain dollar limit. Above
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that limit, loan actions must be approved by a review
committee in the central office. Policy guidance is
more or less strict according to the flexibility of the
market. Consumer loans are very strict, while commercial
loans are very flexible.
Hospital Corporation of America:
The corporate office sets a limited number of objectives
for each hospital - mostly straightforward business or
financial objectives, and holds the hospitals accountable.
.But it leaves the specific approach to meeting objectives
and solving problems to the local administrator. " The
corporate office doesn't try to fix things that aren't
broken."
Marriott:
The franchisee buys an established product: name, license,
and a "system" or way of operating the hotel which includes
general guidance and standard operating procedures. But
personnel matters of the franchised inns are strictly.the
responsibility of the franchisee.
Centers for Disease Control:
"We push decision-making to the lowest possible level,
while centralizing information. But we can successfully
delegate technical decision-making because we recruit and
maintain excellent staff. We also push the decisions out to
the states as much as possible, and focus our energies on
building the capacity of the states to make good decisions."
D. MAINTAINING SUPPORT AND MOTIVATION
1. These organizations ensure quality control through a
comprehensive approach that ensures the success of field
units and constant improvement of the field work.
This comprehensive approach weaves together a number
of separate activities into a solid fabric of support and
motivation for the field units. This includes some workable
combination of the following activities:
o tracking or monitoring
o formal evaluation or auditing
o training
o constant communication
o on-site consultation
o technical assistance
o staff details or exchanges
o financial assistance
o incentives
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No one activity by itself is sufficient to ensure the success
of the field operations. Each of the organizations studied
uses a combination of activities to form a strong performance
and support system for the field units. Every activity is
focused on preventing and solving operational problems, and
improving the operational work.
Quality Inn:
"Our time spent in the field ic in a 40/60 ratio: 40%
of the time is policing and 60% is consulting for business
improvement. Quality control works because it makes good
business sense. It is in the interest of the hotel licensee.
Marriott:
"Success of the hotels depends on a combination of auditing,
training, communication, and incentives - i.e., bottom-line
profit. We have high standards, but we achieve them through
training and constant communication, even more than with
standard operating procedures.
"We have a set way of doing things, accomplished by setting
objectives, not in a cookie cutter fashion. We demand the
same operational style. We can't be rigid because the
hotels are serving different markets. Our SOP manuals are
written in plain language, with some flexibility allowed.
There are minimum directions needed to ensure consistency.
"Marriott has a huge support system behind its operating
techniques! Every hotel system has similar SOPs. But
Marriott's system works because we have the resources and
commitment to implement the approach and the SOPs — i.e.,
the quality product. This is done through high quality
training and local responsibility. We give lots of respon-
sibility to the hotel general manager, but he also gets
lots of help.
The attractiveness of joining Marriott is easier financing,
better resources, and the quality we insist on. In the
management agreement, the franchisee pays the corporation
to look over their shoulder. This is regarded as either
a pain or a resource, depending on the experience of the
franchisee. We use every method to get them to run a
tight ship - we cajole, threaten, push, and hopefully
sell the advantage of a quality product. A key ingredient
is that Marriott has something worth selling to a franchise
hotel. But there's a big trust issue! We have a better
relationship with those hotels that have been in the
system the longest: we've built trust, and they've seen
the benefit of auditing for quality and therefore view
it more as consultation than as a pain."
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20
Centers for Disease Control:
According to CDC top officials, the agency has five major
functions:
(1) Epidemiolpgy - surveillance and data collection.
(2) Nations's back-\3p clinical laboratory - to verify
state lab results and pursue rare diseases.
(3) Training - especially for state employees.
" We train state trainers, and we train the individual
health worker to keep him on the leading edge in both
biology and management. A major part of our mission
is capacity.building in the public health community."
(4) Operations - supporting the states.
"We get involved in issues where the federal govern-
ment should take the lead, and we support state
programs with people and money. Grants are thought
of as operational programs, not just grant programs.
If states weren't interested in a new program, the
CDC promoted it, convinced them that the states
need these programs. For example, we cannot require
state immunization laws, so we use promotion. it
helps to have a federal employee on-site in the
states. We are unique in having federal employees
who physically become members of state agencies,
but maintain allegiance to CDC. CDC is a service
organization, similar to the Agricultural Extension
Service. Even without a grant program, CDC would
have a concern as the federal government's oversight
organization to ensure that the country is controlling
disease. But we would still work with and through
the state health departments."
(5) Standard setting for public health departments.
"We set national standards, and national priorities
and quantitative goals. Setting national goals is
a collaborative process with the states, and assumes
both state and federal resources. And we help the
states set their own targets, through negotiation
and analytical support."
From the receiving end, one state health department director
listed the following kinds of support that CDC provides
to state agencies, in order of importance to states:
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21
(1) Personnel - loans or assignments of federal employees
to state agencies, including Epideraiologic
Intelligence Service (EIS) officers and
Public Health Advisors, to advise and
assist the state epidemiologist and to
run state grant programs.
(2) Categorical Program Grants.
(3) Technical Assistance - including laboratories, emer-
gency response, and field
research.
(4) Conferences and training - in both technical and
management areas.
(5) Program evaluation - both formal (periodic) and
informal (upon request).
(6) Data processing and statistical support.
A senior CDC official agreed with the State Director's
priorities. "Our field staff are the most important com-
modity that CDC has. They have the unique capacity of
recognizing national goals and guiding states toward that,
but they're also seen as state employees."
Contact by the central office with field units is so
frequent as to be almost continuous. Such constant
communication ensures timely response to the problems
and needs of field units, and informal reinforcement of
goals and values.. On-site liaison efforts are seen as
particularly important to ensuring quality control and
the success of field units.
Quality Inn:
"On-site liaison is what makes oversight work. Our
regional directors spend four days a week on the road
visiting hotels."
Hospital Corporation of America:
"If I don't hear from a hospital during a month, I'll
contact them."
Federal Highway Administration:
FHWA facilitates communication by locating a federal
office in every state, usually next door or down the
street from the state highway department. "If I find
out something in an audit that I didn't already know,
then I'm not doing my job." FHWA staff also have a lot
of contact with state staff through professional
engineering societies: "We're just like a big family."
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Centers for Disease Control:
CDC facilitates communication and influence primarily
through its assignment of personnel to state and local
health agencies: "Oversight is so imbedded in state
operations as to be invisible. We're out there all
the time, and we know what's going on." About 15% of
CDC employees currently work directly for state and
local agencies. CDC also tends to "infiltrate" the
public health community with former CDC employees who
still identify with the agency, so the communication
continues through permanent professional networks.
N.
3. Part of the strategy for ensuring successful field opera-
tions is to avoid making big mistakes. These organizations
test new ideas or activities before implementing them
throughout the system. This is done in one of two
ways:
- solicit reaction and ideas from field managers; or
- conduct a pilot with a few field units.
These organizations involve their field managers in planning
new activities, since their participation, enthusiasm, and
understanding are necessary to the success of any new effort
or change of operations. The central office also.counts on
field managers to tell them when a proposed new product or
strategy simply will not work in the field.
Marriott:
"Control of experienced franchisees may initially be more
difficult, but we look for experienced hotel operators
because they bring new ideas. Hotels are encouraged to
develop and test new ideas, but the ideas are not instituted
throughout the system until confirmed. Often the improve-
ments to SOPs are suggested by hotel employees." A senior
manager said, "I recently came up with a new sales promotion
idea, but all the hotel managers I contacted told me it
wouldn't work, so I dropped the idea."
4. These organizations have realistic expectations. -They
do not expect perfection. They recognize human fallibility
and the need to make adaptations. They also recognize
that local conditions vary, and they vary the standards
for individual field units accordingly.
Centers for Disease Control:
"CDC recognizes that we will not always have good relations
with states. It changes over time. We just accept some
dissent and live with it."
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23
National Bank of Washington:
"Allow deviations and errors to occur, but not to re-occur.
Give managers room to act? don't unnecessarily inhibit
action with quality control. Correct patterns, not
mistakes. When somebody screws upf that's too bad.
Put a tracer on it so that the mistake does not get
worse. But don't try to reverse the single error.
Counsel the mistaken manager on reversing the trend or
pattern that the error represents, and monitor to determine
whether other such mistakes continue to occur before
taking further action."
Marriott:
"Anybody who is functioning effectively and we therefore
ignore, quickly becomes a problem! We must pay attention
to all our hotels. They need frequent visits, constant
checking of the property, and input. You need to maintain
comfort on an operational level. If you stay away too
long from the operation or group, they begin to stray
from the program: it's human nature to want to do it.
their way. Field units need constant attention!"
National Bank of Washington:
"We use flexible standards for individual banks, because
their local markets vary tremendously. We have high
goals for each one, but they're not all the same. They
have to make sense in terms of market reality. We'll
compare a bank in a poor neighborhood with another bank
in a different poor neighborhood, but. not with one in a
rich neighborhood."
Centers for Disease Control:
"We have different goals and expectations for each state
because the incidence of disease varies among states. We
set national goals for reducing the incidence of specific
diseases, and then divide that quantitative national goal
among the states. But it's based on the past distribution
of the disease, and not every state has problems with every
disease. It only makes sense to recognize local, differences,
5. In all of these organizations, extensive oh-the-job
training and specialized, job-related courses are an
integral part ofthe operations.
Federal Highway Administration:
All employees are expected to spend at least three years
in the field, with multiple assignments in different
states, before they move into the FHWA management system.
It is a period of training in which .the values of the
organization are adopted.
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National Bank of Washington:
"Training is a key to staff and functional development,
and is the key to improved performance." Good performers
get an increase in authority. Poor performers do not
suffer a decrease in authority, but receive an increase
in training and counselling. Training includes OJT,
through apprenticeship assignments; formal/internal
training through .weekend sessions devoted to skill'
transfer; or formal/external training, in which outside
experts use professional training curricula to impart
attitudes and skills.
6. Technical assistance for field units is a major activity
of all the organizations.It is a vehicle for quality
control and for helping the field units become successful
operations. Some companies insist on providing technical
assistance; others offer it as a service.
Marriott;
Marriott has a package of technical services that will
carry a hotel from initial development/redevelopment
through on-going^ operations. These are services that
franchisees are required to utilize to initiate Marriott's
system. Many franchisees were reported to complain
about the initial expense of the extensive assistance;
but Marriott has found that as success is realized and
trust develops, the resistance declines. "The hotels
must purchase the technical assistance from Marriott:
the investment makes them serious."
7. Tracking systems in these organizations are generally
designedfor operational purposes rather than for
evaluation purposes.
In the organizations interviewed, tracking systems support
review and evaluation by keeping the central office constantly
informed on the status of the operational work in the field.
This information is used by the central office to plan future
strategies, changes in the work, or to spot current operational
problems. Information from tracking systems is also used as
input to formal performance evaluations of field units, or to
indicate the need for a special targeted evaluation, but that's
not the main focus of such systems.
Allstate:
Allstate is a very decentralized operation. They are able
to bind risk quickly in the field, settle claims quickly
on the spot, and successfully underwrite in a delegated
environment. One reason is that much of the operations
are "mechanized"'- i.e., computerized and interactive, .
and the data in the computer is real and accurate.
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"Unlike many companies, our computer is not a tracking
system, it is our actual operating system." The central
office receives weekly reports, which are used to modify
operational plans and takes the next steps to improve
the operations. These reports also provide a source of
data to evaluate how well the operations are doing.
"We have very set standards for quality measures.
These measurements take place all the .time and are
running in real time. They are non-speculative,
operational data 'and measures. So if they go bad we
know. Of course, a management problem might not show
up in this way for 6-9 months."
8. Formal evaluation or auditing is important, but it is
not sufficient to ensure quality control and policy
implementation.
As the previous discussion shows, quality control must
be continuous rather than episodic. In these organizations
quality control is built into the basic operations and occurs
continuously, through communication, consultation, training,
tracking, etc;, rather than being only problem-triggered or
narrowly focused at particular parts of the organization or
times of the year.. Success needs to be worked on every day,
and evaluation needs.to be focused on improving the operational
work.
). •
The function of evaluation, like that of the other ele-
ments of a support and motivation system,, is to help improve
the field work and the success of the field units, by identifying
problems, motivating improvement or maintenance of performance,
triggering assistance and communicating values. Evaluation
is an integral part of the operations of the organization.
9. We found in all these organizations that the success of
evaluation depends primarily on the attitude and
experience of those conducting the evaluation.
The central office conducts evaluations with a positive
attitude of assistance and cooperation, not in an adversarial
manner. While the central office takes the results seriously,
and will make sure that major problems are corrected, the spirit
and use of evaluation is to help sustain successes and improve
the work, not to catch people making mistakes.
Marriott:
"The objective of an audit is to encourage the hotel
general manager to do things correctly, not to catch
them doing things wrong. We're trying to create an
opportunity for correction."
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National Bank of Washington:
Correct patterns, not mistakes. Make loans, review the
results, and adjust future actions as necessary to improve
the results. "Give line managers the authority to act
independently up to a certain limit. Concur in actions
above that limit; review a sample of actions within the
limit for quality. . The purpose of 'the review is not to
reverse line actions, but to identify trends which may
jeopardize overall performance."
Centers for Disease Control:
Prom a state health department director: "We consider
program evaluation to be one of the services that CDC
provides. It shows us where we need improvement, and
we usually get help in solving the problems."
Quality Inn:
"If the hotel managers are experienced, they accept audits
as good management tools. If they're not so experienced,
they feel it's a pain in the neck. In the 1973-74
economic crunch our business went down. We needed more
and different services, and we created the regional •
directors then. .The audit checklist was!a tool to help
improve. We can't drop the regional directors now.
The franchisees depend on them..."
Formal evaluations are effective in motivating change
or maintaining quality performance in part because central
office personnel conducting evaluations have both technical
expertise and extensive field experience. Most of these
organizations have highly experienced, senior personnel
conducting evaluations. This allows for immediate and effective
on-site consultation or targeted follow-up assistance.
Being evaluated by experienced staff, who can effectively
answer as well as ask questions, encourages the cooperation
of field personnel. Finally, the use of experienced personnel
to review and evaluate the performance of field units
indicates the high priority the central office places on
ensuring the success of the. field units.
Allstate: • . '
"Our folks get out to a region every month or six weeks
for two days, for visits, discussions, to stay in touch,
to get a feel for how things are going. We conduct
'walking around evaluation': management by evaluation
and inspection. That is an especially informative
way, but it requires a certain expertise and experience."
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Quality Inn:
"Our Regional Directors provide quality assurance, along
with on-site consultation and liaison with the hotels.
It is critical that they are knowledgeable about the
business. The minimum requirement for Regional Directors
is five years of operating experience as a general manager
of a hotel. Regional Directors average about 15-16 years
in the hotel industry." We use a lot of judgment accumu-
lated through years of experience. The sharp hotel
managers, above 70-75%, are glad to >see us come."
Marriott:
"Evaluation is not a full-time job, but it is done by
knowledgeable, high-level headquarters staff."
Centers for Disease Control:
"We put our best people in the field."
10. It is important that an evaluationdesign reflects major
rather than minor concerns of the central office.
Evaluation is both an active and reactive activity. The
specific evaluation design (i.e., which measures, standards,
how often, etc.) is determined by:the nature of the operational
work". But the evaluation also influences the work itself, by
explicitly identifying for the field units the priority concerns
of the central office.
Allstate:
"Rhetorically we have high goals, but we focus on a
small number'of items. Of 27 things we could watch, 3
to 5 are our bread and butter and maybe 5 to 7. more
bear close watching. Everybody at Allstate understands
this pretty well. So we can have both as long as every-
body understands what each means and is used for."
National Bank of Washington:
"People should know that 'the bank is always watching.1
This does not mean that every detail is scrutinized,
but that there are three or so high .priority areas in
which the employee should expect careful review."
11. The following is a composite list of characteristics of
evaluation or audit systems in these organizations:
o Objectives and standards for field units reflect their
real operating environment, by allowing for variable.
local conditions.
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o Objectives reflect high expectations, and help
stimulate action.
o Measures reflect the fundamentals that are a basic
part of the operations. There are therefore no
.surprises.
o Measures are key indicators that make the biggest
difference in .the success of the operational work.
o Measures include a mixture of types: long-term results
measures and short-term procedural measures; direct
and indirect; quantity and quality; objective and
subjective.
o Measurements used include those of third parties,
such as clients, professional groups, or peer groups.
o Measurement is efficient and non-burdensome. At least
some information for evaluation is taken from existing
information needed for operational purposes. Often
only a small number of measures is used.
o Reports required- from field units as part of evaluation
are useful to the field units as well as to the central
office.
o " Written reports are augmented by personal observation.
This involves frequent on-site contact with field per-
sonnel on a continuous basis,, by experienced personnel.
o Existing technical or professional standards are used
whenever possible.
o Evaluation is consistent and even-handed among field
units, rather than overly responsive to those field
units with the most problems. All field units need
constant attention to stay on track, and those with
persistent problems would tend to use up a dispro-
portionate amount of resources from the central
office.
o Evaluations are frequent enough to find problems early,
and thus are able to nudge change in-the field units
while the problems are still minor ones.
12. What happens when a field unit does poorly in an audit
or evaluation? The answers vary, particularly between
bus-iness and government organizations, but they all
reflect again the positive attitude toward and use of .
evaluations: to sustain successes and improve the work,
not to catch people making mistakes.
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29
Centers for Disease Control:
"What happens if states don't comply with grant conditions
or annual objectives? Legally we could defund, but there's
no point because there's no one else to do the job. Our
• most viable option is to build up their capacity and con-
duct problem-solving analysis. The states know they
have us over a barrel, because CDC can't carry out its
mission without the state health departments. But they
don't take advantage of that because they need our
cooperation and assistance."
Marriott:
"Our ultimate clout is to pull the franchise. But we've
never done this.' There are legal problems. There might
be a fight—you know, the big corporate monster beating
up on the. small businessman. We'd rather avoid that kind
of problem by simply helping them improve their operation.
About 10% of the time they want to do it their way, but
90% of the time they want to do it right. That's what we
reinforce. There's no pat answer to solving the problem.
We use a combination of blitzing (with a swat team of.
experts), convincing, and encouraging."
Quality Inn:
. Quality Inn- uses a carrot-stick approach. Quality Inn
tries to make their system so attractive that members
will respond positively to audits on key factors' that
are important,.to the value of their joint product. But
any member hotel can withdraw or be expelled. Systematic
attempts of assistance and upgrading are made before a
member is expelled. Nevertheless, some are expelled every
year.
National Bank of Washington:
"Good performers get an increase in authority. Poor per-
formers do not suffer a decrease in authority, but receive
an increase in training and counselling. Change people
when it is not working, either through training or a job
shift. Only in extreme or stubborn cases have we resorted
to firing managers who can't or won't change."
13. Does everything work perfectly or easily in these organi-
zations? No, of course not. But these systems and
approaches and attitudes work much more often than they
fail. And many of the organizations encourage risk-taking
and learning from mistakes, as long as everything is
still working toward the organizational purpose.
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30
Centers for Disease Control:
"CDC and the states have the same constituency and the
same goals. Nevertheless, there is often conflict on
the method toward those goals, in terms of national and
state priorities and levels of resources. But the
areas of conflict are only on the margins, and we work
things out." .
National Bank of Washington:
"To introduce change you must be willing to shake up
an organization. People must be taken out of dead-end
jobs and forced into growth positions. This means
emphasizing management skills over technical expertise
as the basis of leadership assignments. It also means
risking failure of an employee in a 'sink or swim1
situation."
Marriott: ..
"When a new franchisee joins the Marriott system, it's
often a painful start-up—lots of squeaks. But the
resistance goes down as they see the benefits to them, "•-•
Allstate:
"We're.all in this together* Let's try to do it. If it
fails, let's find out. If it succeeds, let's find out.
We'll all be involved in the next thina too."
14. Do theseorganizations haveany advice for EPA? Some did:
\
Marriott:
"EPA needs to market its areas of excellence. The result
is that it builds pride in the organization and improves .
service. You need to convince the states of the benefit
of new programs; they have to want to participate."
Quality Inn:
"EPA should use on-site liaison with state agencies!
Bulletins and memos are not enough. You need personal
follow-up."
Allstate"
"Your list of priorities must not be too long and must not
be too low. You need to constantly watch what is really
important."
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Centers for Disease Control:
"It would be very effective to have EPA assignees in
state agencies to speed communication. They would be
there to carry out national objectives, but also to
help carry out local work.
"It took a long time to develop the good CDC/state
relationship. But the time is ripe for the EPA/state
relationship. It's a hot issue. The states are looking
for leadership in the environmental area."
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III. CONCLUSIONS: IMPLICATIONS FOR EPA
The purpose of this study was to provide information on
the approaches of successful organizations to oversight of
their field units. It is important to acknowledge that these
ideas and principles are not news to many EPA employees—
especially in the regional offices, which both receive and
deliver certain support-services. But this report serves to
document these principles and values, and their operational
importance to successful organizations.
This study also provides resource material for further
discussion and detailed work needed to draw out both the
limitations on translating these ideas to EPA and specific
opportunities for improvement in EPA. A beginning has already
been made in such discussions, by reviewing and discussing
.the results in a briefing to several audiences of EPA and
state staff, including two EPA regional workshops and the
EPA Task Force' on State/Federal Roles. The following sections
present more initial ideas on limitations and opportunities.
A. LIMITATIONS ON TRANSLATION
A great deal of work remains to be done to translate these
ideas, as appropriate, to fit EPA's specific situation. The
two federal agencies studied look surprisingly similar in
their operating styles to the companies, because they are
primarily technical assistance agencies. These agencies and
businesses are very different from EPA in a number of ways.
Only CDC comes close to EPA's circumstance, in that CDC is
now involved in the environmental arena and works closely
with two regulatory agencies - EPA and OSHA. Some of the
major differences include the following:
1. Regulatory agencies suchas EPA have certain unique
problems, mandates, and relationships with other organi-
zations and groups, including states, that non-regulatory
agencies do not face.
CDC/National Institute for Occupational Safety and Health:
NIOSH is one of CDC's six centers. It is a scientific
research and investigation unit which (a) makes recommen-
dations to the Occupational Safety and Health Administration
in that agency's development of regulatory standards,
and (b) responds to requests to investigate workplaces.
NIOSH's clients have been OSHA, labor unions and
corporations.
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33
"NIOSH is different from the rest of CDC, in that our
clients have not been primarily the states. We are just
beginning the process of having field representatives in
state health departments. The states deliberately
dismantled state occupational health programs when OSHA
was formed. .
"The general philosophy of NIOSH is that states should be
involved. But how states are involved depends on their
existing relationships with other agencies. For infectious
diseases, the responsibilities are very clear. But the
role of state health departments and federal agencies
are very unclear for occupational health and environmental
health. Roles in these regulatory areas are complicated
by turf battles among federal agencies and by the effect
of political dogma. State health departments want help
from the feds, but they don't know who-to talk to. They
see no clear mandates in their area of interest at the
federal level, because regulation and enforcement are
not the same as health care service.
2. The environmental protection area has its own unique
characteristics, including intensely competing interest
groups and more scientific and technical problems to .•;._-.
solve than solutions currently exist for.
Centers for Disease Control:
"CDC recognizes we will not always have good relations with
the states. . In the area of infectious diseases, there was
no confusion.on objectives.. Now, as we move into environ-
mental areas, there is confusion ahead. Acute diseases you
can see. But with chronic diseases, there is argument on
what you can see. We've, also never had anyone defend
disease. But in the environmental area we are suddenly
faced with companies defending pollution. The dynamics
are entirely different."
"CDC does not do much basic research.. Our labs try out
. new procedures from the scientific literature in order
to solve problems in the field. We develop technical
methodologies for use by state labs. But in environ-
mental areas, we need operational research just to
define the problems 1" .
3. Thesource of operational priorities for government
agencies is very different from that of business.
The source of business revenues and corresponding priorities
comes from the bottom - i.e., the field operations. The
operational work drives the organization's priorities. But
in government, the source of revenues and priorities comes
from.the top - from executive and legislative bodies. On-going
operational demands and realities in 'government can be out
of sync, or even in conflict, with current political priorities.
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34
4. The states arenot, in fact, operating units for EPAin a
strict legal sense, given that they are not even part of
the same organization.
While EPA and state agencies may have broad political
missions and professional goals in common, they nevertheless
have different priorities, methods, management planning
cycles, and resources for accomplishing those missions and
goals.
5. EPA is not a homogeneous organization.
Each of its.programs, dealing with air, water, pesticides,
etc., is unique. Each has different laws, regulations and
standards, different technical and scientific problems to
solve, different relationships with the states, and often
deals with entirely different agencies in the same state.
EPA is perhaps more analogous to a corporate conglomerate
than to a single business operation. Yet the work of EPA's
separate programs also directly affects each other - in
terms of cross-media environmental impacts, competition for
resources, working with the same state agency or on the same
pollution site, etc.
In addition, EPA's regional structure operates so that
policy-making as well as implementation is often decentralized.
As a result, the regional offices are often unique in their
approach and solutions to problems in the field.
6- None of the organizations studied have "delegated"
responsibility and authority for implementing activities
in quite the waythat EPA is doing it.
In the companies, responsibilities were clearly divided
between the central office and field units from the beginning.
For the federal agencies, the states were in business first,
and the federal agencies were created to supplement and
support the states, who remained the primary service deliverers,
In discussing this study recently with the EPA Task.Force on
State/Federal Roles, one member remarked: "The problem with
oversight is that EPA staff are being asked to give away and
then oversee programs they once ran themselves. The human
response is to feel as if delegating amounts to shooting
themselves in the foot. It's no wonder they're confused
about what oversight means."
Despite these major differences in EPA's organizational
structure, mission and type of work, there are nevertheless
opportunities to apply the approach of these organizations to
the way EPA carries out its work and relates to states. These
opportunities are discussed briefly in the following section.
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8. OPPORTUNITIES FOR IMPROVEMENT
While EPA is not a business, and our mission is somewhat
different from that of other federal agencies, there are never-
theless important operational similarities. It was interesting
to observe in the interviews with businesses a rapid shift
in rhetoric as the discussion proceeded. It usually began
with: "In business, if.you don't agree with the program,
you don't work." It usually ended with: "We have to convince
the field units of the benefits to them? we have to sell
them on new ideas." We believe that these ideas and principles
from other organizations can provide insights on opportunities
for improvement in the way EPA does its work, and especially
for program activities delegated to state agencies.
This study and our discussions to date suggest the
following principles for EPA management of delegated state
programs; . .
1. The states are, in a broad sense, the implementation
arm for federal environmental programs. Without them,
EPA cannot achieve its goals of successful environmental.
protection programs and positive, measurable environ-
mental results. ' .
2. The E-PA/state relationship must be clear and mutually
beneficial. States must be actively involved in
the development of regulations and programs that they
must implement.
3. EPA needs to focus on the real work, and on defining
priorities and success. Clearly.describing the goals,
expectations and work to be performed by the state
agencies will increase their ability to successfully
implement the programs.
4. "Oversight" as practiced by EPA (i.e., program audits)
is not enough to ensure the success of state programs.
There must be a more comprehensive approach to the
support and motivation of state agencies.
5. Program audits are an essential management tool, but
they must help to improve the work and the success of
the state agencies, not just find mistakes.
Some specific opportunities for pursuing these principles
might begin with the following:
1. EPA headquarters, EPA regions and states need to agree
.on the general approach and attitude needed for EPA's
oversight of state programs, and to begin.working
collaboratively, for each EPA program, on the details
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of how to ensure the success of state programs.
We need to encourage existing successes, and work
toward improvement in other areas.
2. EPA needs to increase its on-going support to states
with delegated programs, in terms of:
o training for state personnel;
o travel to state offices for consultation and
problem-solving; and
o technical support for state programs.
3. EPA needs to improve its capacity to provide quality
technical and program assistance, through;
o improving the access of states to EPA's existing
expertise;
o increasing the operational field experience of EPA
staff who provide technical assistance; and
o improving the quality and quantity-of EPA expertise..
On-going support to states and internal capacity-building
in SPA will, of course, only be useful if the EPA program
staffs have determined clearly what specific work the states
need to be doing and what constitutes successful programs
and performance.
The principles and ways of pursuing them suggested in
this section are by no means an exhaustive list of opportunities
for improvement available to EPA, nor have they been approved
in any way by EPA's senior management. They reflect input
from some EPA and state staff during informal discussions of
the findings of this study. This is only a beginning. The
intent here is to identify some ideas or issues which might
be pursued in more detail in further discussions and future
work.
U. ?. "—M ronmental F"*J
I..-'- -. Boom 2404
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