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.

🏛️   Federal Precedent — U.S. Department of Labor

Benefit Accuracy Measurement (BAM)

Investigates whether benefit payments conform to law and policy. Reconstructs claim decisions. Results feed into federal improper payment reporting. This is compliance-adjacent — it measures against law, not internal process.

UI PERFORMS

A separate performance measurement framework that tracks how well states deliver unemployment insurance programs — including process quality and improvement planning. This is the QA layer. The Department of Labor runs these as two distinct, separate systems.

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 QA Form exists — use unknown Unknown No — manual pulled, not stable
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 and operational manuals 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 QA analysts share call review responsibility across sections — not siloed by assignment alone.

3

Calibration

Regular sessions led by the QA Lead where all analysts 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

📌   Requires SOP/Manual Work First

  • Benefit Eligibility — manual was released but pulled within two weeks; must be completed and stable before QA begins
  • 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 — Day-to-Day Lead
Leads calibration · Section reporting · Corrective action tracking · Moved from existing Compliance CS3 staff
Customer Care
Analyst 1QA Analyst
Analyst 2QA Analyst
Benefit Eligibility ★
Analyst 1Phase 2
Analyst 2Phase 2
Appeals ★
Analyst 1Phase 2
Analyst 2Phase 2
Investigations ★
Analyst 1Phase 2
Analyst 2Phase 2
Employer Programs ★
Analyst 1Phase 2
Analyst 2Phase 2
Active at launch
★ Phase 2 — active after section SOPs are stabilized

Why Two Analysts Per Section?

Peer Review Within Section

Two analysts can review each other's scoring before findings escalate to the QA Lead — catching inconsistencies early and strengthening the quality of the findings themselves.

Continuity of Coverage

When one analyst is on leave or transitioning, the section is not left without oversight. A single-analyst model creates unacceptable coverage gaps.

Foundation for Cross-Training

Two analysts per section, combined with shared call review responsibilities, creates the conditions for analysts to gradually learn adjacent sections — building long-term program resilience.

Call Monitoring — A Division-Wide Responsibility

All QA Analysts — regardless of their section assignment — share responsibility for call monitoring. The target is 5 calls reviewed per staff member per month. Given the sheer volume of calls Paid Leave Oregon handles, distributing monitoring across the full team is the only way to achieve meaningful coverage.

This shared responsibility also ensures every analyst understands the customer-facing dimension of operations — building the cross-section knowledge that makes genuine cross-training possible over time.

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 QA Analysts for that section. These are distinct review functions carried out by different members of the team in their respective areas of expertise.

What QA Analysts 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 Quality Assurance Lead
Day-to-day lead · Calibration · Reporting · Moved from existing Compliance CS3 staff
10
QA Analysts
2 per section · Subject matter experts · Internal postings
11
Total Positions
Phase 1: 5 positions · Phase 2: 6 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.