9 months ago

Annual Performance Plan 508

Annual Performance Plan 508

Management Objective:

Management Objective: Departmental Clearance Reduce the time and complexity of the clearance process by establishing and enforcing clear protocols for drafting and reviewing documents placed in departmental clearance. OVERVIEW Departmental clearance of policy documents to be publicly issued by HUD is a necessary and important step prior to public issuance. The objective of departmental clearance is to ensure requisite agreement by applicable HUD leadership on the subject matter and content of the policy, and involves review by HUD offices with expertise, policy or legal, with the subject matter of the policy and is further undertaken to ensure no conflict with other HUD policy or Administration policy. Certain offices, such as the Office of General Counsel (OGC) and the Office of the Chief Financial Officer (OCFO) are tasked with reviewing every office in departmental clearance. For some significant policy documents, submission of the document for departmental clearance is the first time that key HUD policy and support offices such as OGC and OCFO are seeing these documents. The volume of documents HUD places into departmental clearance (documents that consist of not only rules, but policy notices issued by the program offices, HUD handbook and guidebooks) is high, and the volume of documents and unfamiliarity with their content, contribute to the slowness of the departmental clearance process. Additionally, the absence of collaboration with key HUD offices can result in a lengthy clearance process if major disagreements exist. There are also less significant policy documents that only need abbreviated review which go through the full clearance process unnecessarily. To address these challenges, HUD has established guidelines for development of significant policy documents that include a preclearance process and protocols for clearance of these documents. HUD has also established guidelines designed to institute a significant reduction or no clearance of routine or less significant policy documents. STRATEGIES • Establish guidelines for development of pre-clearance process. The purposes of preclearance collaboration and review are to begin to develop a written record of the need for rulemaking or guidance, to define the requirements for the rule or guidance, identify risks, begin to develop implementation strategies, and identify stakeholders outside of HUD. Protocols that have been issued clarify that the preclearance process is for significant policy documents, such as documents that implement new law (e.g., the Violence Against Women Reauthorization, 2013, defining Qualified Mortgages for HUD, or new Notices of Funding Availability (NOFAs) or changes to longstanding HUD policies and practices such as Affirmatively Furthering Fair Housing. With respect to the clearance process itself, the review time will be tailored dependent upon whether the clearance item presents new significant policy or legal mandates. Such items will go through full clearance, with a goal of completing review in two weeks. Clearance items not falling into this category will go through an abbreviated and limited review process. 124 Achieving Operational Excellence Management Challenges and Objectives

• Ensure transparency by utilizing a department-wide clearance calendar. The Clearance Calendar allows everyone within HUD to see the current version of a document in clearance, all clearance comments and resolutions, and the context, major issues, and priorities for each document. By increasing use of the clearance calendar, the clearance process will be much more transparent. This will also provide an electronic record of the time taken for a document to go through clearance. LEADING THIS OBJECTIVE Helen Kanovsky General Counsel Office of General Counsel FY14 APG PROGRESS UPDATE HUD was successful in establishing guidelines for development of a preclearance process. And we are working to actively identify other painpoints in the clearance process revealed as we collect this data for the first time in FY15. MAJOR MILESTONES 9/30/2014 Establish guidelines for development of pre-clearance process. Complete. Protocols have been issued and clarify that the preclearance process is for significant policy documents and clearance process review times will be tailored dependent upon new significant policy or legal mandates. The expectation is that, under the new protocols, fewer documents will undergo departmental clearance, specifically minor documents that do not necessitate review by other HUD program offices or key support offices will be eliminated, and the preclearance process will ensure familiarity with the policy to be put forth in significant policy documents that will facilitate review by clearing offices. Achieved as of this publication. MEASURING OUR PROGRESS To track our progress towards this objective, HUD will monitor the following key performance indicator. Percentage of documents that complete the clearance process by the deadline HUD will monitor percentage of documents that complete clearance review by the clearance deadline, with a goal of resolving any outstanding issues within 2 weeks following the clearance deadline. FY12 Actual FY13 Actual FY14 Actual FY14 Target FY15 Target FY16 Target No Data No Data No Data NA 127 80% 90% 127 HUD’s Clearance Calendar was launched in August 2013. This performance indicator will first report in FY 2015.. Achieving Operational Excellence Management Challenges and Objectives 125

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