Paid Leave Oregon — Compliance Division

Building a Quality Assurance Program for the Division

Compliance ensures we follow the law. Quality Assurance ensures we follow our own standards. These are two different functions — and right now, only one of them exists.

Read the Proposal
Section One

Two Things That Are Not the Same

Before we can build a QA program, we need to clearly define what it is — and what it is not. These are distinct functions. Conflating them undermines both.

⚖️
Already Exists

Compliance

Measures conformance to law and rule
Standard is external — Oregon Revised Statutes (ORS) and Oregon Administrative Rules (OAR)
Results are binary — a requirement was met, or it was not
Does not require understanding internal processes — the law is the standard
Reviews can be conducted independently of how a section operates internally
📊
Proposed

Quality Assurance

Measures how well we follow our own standards
Standard is internal — documented SOPs, manuals, and established workflows
Results are scored — measuring degree of quality, not just yes or no
Requires stable, documented processes to function — no SOP means no standard to measure against
Requires subject matter expertise in the area being reviewed
💡

The question being asked — "Shouldn't Compliance handle QA?" — reflects a common misconception. Compliance already handles compliance: measuring conformance to law and rule. Quality Assurance measures something different, against a different standard. Both are necessary. Neither replaces the other.

Section Two

What Was Built — and What It Revealed

Compliance was tasked with creating QA review tools for each section. That work was completed. What the process revealed is the gap this proposal addresses.

The Assignment

Compliance tasked with building QA tools for each section

The original plan: Compliance would build QA review instruments, and each section would then conduct its own QA. This direction was documented in status reports and presented in senior leadership briefings.

The Discovery

Compliance met with every identified section

What was found: most sections already had some form of QA forms or checklists — but they were largely insufficient. More critically, most sections lacked stable Standard Operating Procedures and operational manuals. Without those, there is no documented standard to measure work against. Quality cannot be measured in a process that is not defined.

The Revised Approach

Compliance revised its own review metrics

Because QA requires stable internal process documentation that most sections did not have, Compliance revised its division-wide compliance metrics to focus on what compliance is actually designed to measure: conformance to law and rule. Each metric was tied directly to ORS or OAR — not to internal procedure. This was the correct scope for a compliance function.

December 2025

Customer Care took full ownership of QA

QA tools were built for Customer Care. In December 2025, Customer Care took full ownership of their QA program and has been running it since. The handoff was successful. QA was removed from Compliance's scope because the work was complete — not because it was abandoned.

Now

A gap remains — and this proposal addresses it

The plan was executed. What it surfaced is a structural gap: self-administered QA has inherent limits, three sections have no QA at all, and there is no independent, division-wide quality function. That gap is not a failure. It is a finding. And this proposal is the response to it.

Section Three

The Gap — What We Don't Have

Customer Care is running QA. That is meaningful progress. But self-administered QA is not the same as independent QA — and three sections have nothing at all.

Current State of QA Across the Division

Section QA Status Who Reviews Independent?
Customer Care Running — Dec 2025 Own leads & managers No
Benefit Eligibility SOPs stable — Ready for QA — Not yet — no QA running
Compliance Law/Rule Reviews CS2s + CS3s (internal) Compliance only
Appeals None — No
Investigations None — No
Employer Programs None — No
⚠️

The Independence Problem. When a section reviews its own work, the reviewer and the person being reviewed share the same accountability. Section leads who are responsible for outcomes cannot be objective evaluators of those same outcomes. This is not a criticism of section leadership — it is a structural limitation that no amount of good intentions or effort can overcome. Independence is what makes QA findings credible to anyone outside the section.

Five Gaps a Dedicated QA Function Closes

01

No Independence

Every section that has QA is reviewing itself. Self-attestation is not quality assurance — it is the absence of it.

02

Coverage Gaps

Three sections — Appeals, Investigations, and Employer Programs — have no QA process at all. A significant portion of division work goes entirely unreviewed.

03

No Calibration

Without consistent standards across sections, there is no way to compare quality or identify division-wide patterns. Each section applies its own interpretation.

04

No Corrective Action Loop

Even where QA findings exist, there is no structured path from finding to resolution to verified closure. Findings are reported — but not tracked, acted on, or confirmed resolved.

05

No Division-Wide Reporting

Leadership has no visibility into quality trends across the division. Individual section results stay within those sections. There is no aggregate picture.

Section Four

What a QA Program Actually Requires

Quality assurance is not a form. It is a system — with defined tools, a collection methodology, calibration, reporting, and a corrective action loop that closes findings.

📋

The Foundational Prerequisite. Quality cannot be measured in a process that is not documented. Before QA can be applied to any section, that section must have stable Standard Operating Procedures that reflect actual practice and do not change frequently. This is not a preference — it is the condition under which quality can be defined and deviation from it can be detected.

The Five Components

1

Review Tools

Structured, section-specific instruments with scoring rubrics tied to documented SOPs. Tools for Customer Care already exist. Additional tools built as sections reach documentation readiness.

2

Collection

Systematic, scheduled reviews. Target: 5 calls reviewed per staff member each month. All Compliance Specialists - QA share call review responsibility across sections — not siloed by assignment alone.

3

Calibration

Regular sessions led by the QA Lead where all specialists score the same work independently, then compare and align. This is what makes QA data valid and defensible across sections.

4

Reporting

Section-level results reported monthly to section leads. Division-wide trend data reported to leadership on a defined schedule. Individual findings and division patterns separated clearly.

5

After Action

Finding → Root cause analysis → Corrective Action Plan assigned to section lead → Implementation tracked → QA re-audit verifies closure → Documented. Nothing sits on a shelf.

Section Readiness — Where We Can Start

Not every section can begin QA immediately. The following reflects where each section stands relative to the documentation prerequisite. Sections that are not yet ready will be supported — not penalized.

✅   Ready for QA Now

  • Customer Care — QA already running; shifts to independent oversight
  • Benefit Eligibility — SOPs stable; ready for independent QA

📌   Requires SOP Work First

  • Appeals — process documentation not stable; QA phased in after
  • Investigations — process documentation not stable; QA phased in after
  • Employer Programs — process documentation not stable; QA phased in after
🤝

The QA team's first engagement with Appeals, Investigations, and Employer Programs will be a documentation readiness review — supporting those sections in building and stabilizing their SOPs so that QA can eventually be extended to them. This is a partnership, not a gatekeeping function.

Section Five

The Proposed QA Team

An independent QA function requires dedicated, trained staff — positioned outside the sections they review, and specialized in the work they evaluate.

Team Structure

Program Oversight
Compliance Manager
Owns the QA program · Division-level accountability · Escalation
Quality Assurance Lead
CS3 or OPA3 — Day-to-Day Lead
Leads calibration · Section reporting · Corrective action tracking · Moved from existing Compliance staff
Customer Care
Specialist 1CS - QA
Specialist 2CS - QA
Benefit Eligibility
Specialist 1CS - QA
Appeals ★
Specialist 1Phase 2
Investigations ★
Specialist 1Phase 2
Employer Programs ★
Specialist 1Phase 2
Active at launch
★ Phase 2 — active after section SOPs are stabilized

How Specialists Are Assigned

Customer Care — Two Specialists

Customer Care handles the highest volume of staff and interactions in the division. Two specialists provide the depth of coverage that section requires — independent peer review of findings before escalation and no single point of failure.

All Other Sections — One Specialist

Each remaining section receives one dedicated specialist with deep expertise in that section's SOPs and processes. Focused, section-specific knowledge is what makes QA findings credible and actionable for section leadership.

All Staff Review Customer Care Calls

Due to the volume of calls Customer Care handles, every Compliance Specialist - QA contributes to Customer Care call monitoring each week — regardless of their section assignment. Volume requires a team response, not a single-section one.

Call Monitoring — A Division-Wide Responsibility

All Compliance Specialists - QA — regardless of their section assignment — contribute to Customer Care call monitoring each week. The volume of calls that section handles makes this a team responsibility. No single specialist or pair can achieve meaningful coverage alone.

This shared responsibility also ensures every specialist understands the customer-facing dimension of operations — building cross-section knowledge and grounding the entire team in how Paid Leave Oregon interacts with claimants.

Call monitoring is not the same as processing QA. Quality assurance for processing work — determinations, case documentation, correspondence, and other section-specific output — remains with the assigned Compliance Specialist - QA for that section. These are distinct review functions carried out by different members of the team in their respective areas of expertise.

What Compliance Specialists - QA Do

Section-Specific Duties

  • →Conduct structured reviews using section-specific instruments
  • →Score work against documented SOPs and established standards
  • →Document findings and submit monthly to QA Lead
  • →Track corrective action items through to verified closure
  • →Attend section team meetings and stay current on process changes

Division-Wide Duties

  • →Participate in all-team calibration sessions led by QA Lead
  • →Complete monthly shared call review quota
  • →Work toward cross-section competency over time
  • →Maintain subject matter expertise as section policies and laws evolve
  • →Support documentation readiness reviews for Phase 2 sections
Section Six

The Ask

This is what it takes to build a QA program that is independent, comprehensive, and sustainable — not a form, not a checkbox, but a function.

The Staffing Request

1
CS3 or OPA3 Quality Assurance Lead
Day-to-day lead · Calibration · Reporting · Moved from existing Compliance staff
6
Compliance Specialists - QA
2 per ready section at launch · Phased assignments as sections mature
7
Total Positions
Phase 1: 4 positions · Phase 2: 3 additional

What This Delivers

🔒

Independence

An external QA function not subject to the self-attestation problem. Findings are credible because reviewers have no stake in the outcomes they review.

📐

Consistent Standards

Calibrated scoring across all sections. Leadership can compare quality data across the division for the first time — apples to apples.

🗂️

Division-Wide Coverage

Every section eventually covered. The three sections currently without any QA have a clear path to inclusion as their documentation matures.

🔁

Findings That Close

A structured After Action process means QA findings do not sit in a report. They are assigned, tracked, re-audited, and documented as resolved.

📈

Trend Visibility for Leadership

Monthly and quarterly reporting gives the Director and Deputy Director a quality picture of the division — not just individual incident data.

🎓

Long-Term Capability

Cross-training over time builds a team that understands the full operation — and strengthens the organization's resilience against turnover and change.

This is not a proposal for Compliance to do more.
Compliance does compliance.
This is a proposal to build the function that Compliance cannot be — and that the division needs.

We welcome the opportunity to discuss this proposal with you — to work through questions about structure, phasing, and staffing, and to plan the path forward together. The program is designed to start small and scale deliberately. The earlier those conversations begin, the better positioned the division is to move when the decision is made.

One thing that does not need to wait: Compliance. Its reviews, its metrics, and its reporting schedule are ongoing and will continue on their current timeline regardless of where this proposal lands. We ask only that leadership recognize these as two separate tracks — and allow Compliance to keep moving while the QA question is worked through at whatever pace makes sense for the organization.