This paper presents socio-cognitive environment (SCE) as an alternative conceptual framework to organizational culture to study dynamic development policy environments where groups of stakeholders engage in high degrees of organizational boundary-crossing to achieve collective aims. This paper summarizes a two year study of a group of Cambodian mid-level managers who were charged with implementing a participatory development policy. Such an effort required staff to engage in a collective sensemaking process that spanned organizational, cultural, social, and historical boundaries. SCE serves as a useful device to consider how both macro and micro interactions influence mid-level manager sensemaking. This paper presents a review of the key bodies of literature which have supported the development of the SCE model, before presenting the analytic model itself. The paper concludes with a discussion of how this model might be useful in other contexts.