From ECM 3.0
The selection and implementation of a task management system. The development of an effective task management system must start with a vision of what you are trying to effect. If tasks are the end result and the requirements dictating those tasks are not complex for your operations then your selection process for managing those tasks will be straightforward. Likewise, if management will not promote and support the implementation of a compliance system your options are limited and therefore your selection process will be simple. In these cases the focus should be to minimize costs and ensure that the identification and entry of your tasks can be accomplished quickly.
The first fork in the road will be to determine whether currently available tools and systems will ensure that your tasks are completed properly and timely or whether another alternative must be considered. If your personnel are familiar with an existing process for managing other tasks then it may be in your best interest to integrate your tasks into that system. If this is not an option you may choose to simply use spreadsheets or task calendars such as Outlook to enter your tasks. Serious consideration should be given to the investment of any money into a task management system if your objective is to simply remind you when to complete a known task because there are tools readily available on virtually every computer that will provide this function.
The increasing complexity and growing number of requirements that companies must comply with and the severity of the costs and consequences associated with failure to comply often justifies a closer look at more sophisticated task management solutions. Task management for these companies must become a part of the overall compliance management process rather than an end in itself and the selection process for managing those requirements will require more consideration. The first step in the process will be to evaluate whether an economic justification can be made to implement any type of system. Without a positive answer to this step you will have little chance of pursuing the project through procurement, implementation, training and rollout and the time spent pursuing this should instead be spent entering your tasks into a spreadsheet. Solution providers may provide Financial Impact Analyzers (FIA) to assist with this process and the results of any study that indicates a positive return on investment for the company should be prominent in the internal sales process and throughout the procurement, implementation and rollout to prevent the commitment from waning.
Failure to prove and maintain awareness of the financial benefits will tend to make the project request look like someone is simply trying to reduce their workload.
If you have determined that the complexity of your requirements and the financial impact of the implementation of a compliance system justify this venture then your next step is to assess the likelihood that you will have short term and long term success with the system. Consider the fact that there will be numerous obstacles to overcome and that many of those obstacles can be fatal. Flushing them out before expenses are incurred can be a career-saving endeavor.
- Will management even consider the implementation of a system to manage the compliance process? Regardless of what the FIA indicates, if it is believed that making personnel work harder can accomplish the same thing this will always beat the FIA unless you are being paid to implement a system.
- Will management consider the risk of non-compliance in the FIA and will an emphasis on this potential cost be counterproductive, i.e. “why do we have that risk when we are paying [Name] to keep us in compliance?”
- Will all entities necessary for moving the implementation through to completion remain on board to ensure successful delivery? Project fatigue and burnout increase exponentially as the scope of the implementation progresses.
- Will those responsible for compliance accept the heightened accountability when their compliance requirements are not limited to being in their head or only on their personal calendars?
- Will compliance personnel resist the effective implementation of a compliance system for fear that it will make them more dispensable?
- Will the persons to whom tasks are assigned accept a new system or will they work to undermine it and stay with what they are comfortable with, which may be nothing?
- Will management provide the support necessary to overcome the likely personnel hurdles to get the system rolled out?
- Will management continue to commit the resources to keep the system current?
If the answers to the considerations listed above ...
If the answers to the considerations listed above indicate that you are not likely to succeed with the implementation of a compliance management system then you should seriously consider entering your tasks into Excel, Outlook or an existing task management system already in place. If you have made it past those stopping points then you are ready to consider a more sophisticated compliance management system. Options for task management systems are numerous because it is not complicated to modify basic software to allow for the entry of tasks. More robust compliance management solutions are not as proliferous because they entail much more effort and expense to develop. They also offer a variety of features and functionality, all of which must be assessed in light of the benefit they will provide to you and the burden they will entail to learn and manage the system. In addition to learning the system initially you must evaluate the ongoing requirement to keep enough people familiar with the system to ensure that the departure of any single person, including yourself, will not result in the death of your compliance system.
The most common mistake made in implementing a task management system is to view the task as the end result of the implementation. For sites with minimal requirements and infrequent changes or additions to the existing requirements you may get by with extracting the task from the rule and then relying on consultants, industry groups and your own research to keep the tasks current. When the number of regulations, permit conditions, company policies and industry standards are in the thousands and when there are numerous sites, this approach will result in an unmanageable list of disconnected tasks. The result will be that your system will atrophy and the list of tasks will be questionable, at best, because invariably the daily urgencies will push aside the long-term importance of maintaining your list of tasks. Your likelihood of failure to keep up the tasks in a task-based system warrants that you evaluate the implementation in the same manner as you would evaluate the creation of paper compliance manuals, i.e. approach it from the perspective that it will be useful for a limited time and will then have to be scrapped and replaced. Budgeting this in up front and including it in your FIA will prevent future frustrations.
The ideal task management system will allow you to capture the information associated with conducting a regulatory applicability review so that the completion of this required activity results in a populated system with the associated tasks and reminders. Systems are available that make this association between the regulations and the tasks so that implementation is streamlined and management of the tasks is directly related to management of the rules that generate those tasks. These systems move the focus away from being task-based to being Driver-Based®. A fully integrated Driver-Based approach will track regulation changes, indicate how those regulation changes impact your operations, update your compliance system, alert the responsible contacts associated with the rules and ensure that those new requirements are fully satisfied. These same benefits are provided to the management of company rules, permit conditions and any other requirements with which you must comply since the fully integrated Driver-Based approach manages all drivers in the same manner from one centralized database. A fully implemented Driver-Based system will allow you to progress to a higher level of compliance assurance with the Perpetual Audit functionality. Those responsible for signing the legal documents verifying that all compliance requirements have been identified and that all noncompliance issues have been addressed will find a great deal of comfort when those documents submitted to them for signature are accompanied by the comprehensive compliance reports generated from the Perpetual Audit implementation. Task-based systems cannot provide this level of compliance assurance and attempts to incorporate Perpetual Audit into the task list will increase the inherent complexity of managing your task list.
Less advanced systems allow you to link drivers to the tasks after you have generated the task separately. These systems may then allow you to run a query to determine which tasks are affected by specified drivers. You are still left with the burden of tracking rule changes, manually updating the system and manually alerting affected personnel but they simplify the process of determining which tasks must be updated in your system once you have separately identified the changes in the drivers. These driver-linked enhancements are valuable but you still face the inevitable likelihood that the system will become obsolete because any driver changes not identified and not manually entered into your system will be lost. With the fully integrated Driver-Based approach all pertinent changes will be identified such that you can implement those changes and alert all personnel with two clicks in the system.
With the simplicity of implementation that comes with the Driver-Based approach to compliance management there are now companies who will offer to implement the system as part of a defined service agreement. These service agreements will vary in scope and length of the term but it is likely that they can be structured such that expenses you are already incurring for regulatory compliance can be rolled into the service agreement with minimal or no budget increase. This can reduce the risk of moving forward with a compliance management process when the service agreement includes the licensing and implementation along with other services that you already pay for. If this option is chosen you should select a service provider who is committed to working themselves out of a job, i.e. implementing the system with the detail and clarity that you will need to take it over internally if desired or required.
Regardless of whether the compliance management system is going to be implemented and/or managed by a third party it is still critical that you select a system that can be easily managed by your internal personnel. Take the system for a test drive and ensure that you can quickly make the changes that will inevitably be a part of your routine operations. Look for the ease of adding assets and implementing the requirements for those assets. If personnel are replaced or shuffled, ensure that you are able to quickly reassign the tasks and reset the authorization status. Evaluate the effort involved to add detail or attach documents to existing tasks, to change due dates, to have more than one person receive the task notice. Consider the rollout and the various user levels to assess the likelihood of user acceptance. Picture the system from the perspective of the user’s initial reaction to the rollout, their anticipated acceptance and understanding after training and their potential aversion to enter the system anew after a time period of not interacting with the system. Implementation of the considerations listed in this paper will result in a much higher likelihood of success in the selection and implementation of your task management system or compliance management system.
Regulation and Task Management Combined Regulation management is not about managing rules but is instead about keeping your compliance engine operating at peak performance. It is the regulations, permits, industry standards, etc. that “drive” your required action items, yet the historical approach has been to extract the action items out of the driver and put them into various forms of reminders and management tools. This inherently places the regulated entities in the mode of managing compliance from the perspective of managing driving by focusing on the actions required in the mechanic shop and fixing breakdowns as opposed to preventing them. While the mechanic shop is a critical part of the driving experience, it is not what gets you to your destination.
The Driver-Based approach properly shifts the focu...
The Driver-Based approach properly shifts the focus to the entire driving experience and makes it possible for you to consistently arrive at your destination with no accidents and no aimless wandering. The steps to make this happen are as follows:
- Convert the rule into fuel
- Inject the fuel into an engine that is effective, efficient and flexible
- Maintain the fuel to keep it fresh and high octane
- Maintain the engine to ensure consistent top performance
The Evergreen Compliance Manager (eCM) receives its fuel from the Evergreen Regulation Manager (eRM). In eRM the drivers are formatted with the information necessary to allow that rule to become an active part of your compliance program. This gets you on the road to compliance quickly because the act of making an applicability determination in eCM – a requirement for every regulated entity – lays out the map and action items for your route to compliance. Capturing the knowledge at this point is the key to compliance success and to eliminating the redundancy so common in compliance programs. eCM makes it possible for you to quickly capture all of the rules applicable to your operations and effectively manage the action items associated with those rules. The thorough implementation places you in the position to quickly prepare for inspections and audits and uniquely prepares you to implement Perpetual Audit for a level of compliance assurance that will allow those signing off on compliance certifications to rest assured that their signature is well justified.
The task-based approach leaves you with no alternative but to rip only the “important pages” out of your owner’s manual and stopping points rather than the entire map because the glove box was not designed to hold the entire book. What seemed important and complete at the time the pages were ripped out may not be the same list when the critical warning light appears on your dashboard or when the person who knew the route is replaced by a person who does not have the same experience. These situations routinely force companies to call out the wrecker service to retrieve the missing pages or to go through the manuals and maps again to make a better selection of the pages to rip out.
The interaction between eRM and eCM updates the fuel automatically and alerts you and every person associated with any driver to changes, detours and warnings related to your compliance route. The historical process of tracking rules to find changes, determining the impact of those changes on your task list, implementing those changes, alerting the appropriate personnel of the changes and verifying compliance with the changes is replaced in eCM with the click of a button. The importance of this benefit cannot be overstated. In the old process if you got behind on updates to your system it was nearly impossible to catch up. With eCM, two clicks will update every change into every aspect of your system. Additionally, every change can be flagged with a note to those responsible for the rule if you wish to alert them that their compliance requirements have been updated.
This update process is not limited to regulatory actions but will also allow you to instantly communicate any issue of importance. For example, the EPA has recently announced that storm water compliance is a major focus due to the belief that entities are not reaching the compliance standard they desire. A note attached to any rule related to your storm water requirements can be automatically propagated to every person responsible for compliance with that driver because eRM knows whether that rule is part of your subscription and eCM knows who is responsible for the driver. You won’t have to worry about whether the rule has an active task associated with it because any applied rule will propagate the information. The same communication enhancement applies to your company rules, industry standards and all other drivers managed through the Evergreen system. When the action items are separated from or only loosely connected to the driver it becomes extremely difficult to update your map appropriately and prevent your driving experience from ending up in the ditch.
eCM was designed with a maintenance plan and program to ensure consistent top performance. Getting on the road to effective compliance management takes a fraction of the time typically associated with the implementation of a compliance program because simply clicking on the regulations, company policies, permit conditions, etc. that apply to your operations builds the compliance system with the default tasks, frequencies and other information associated with each driver. It is equipped with tools for the administrators to easily maintain the system and user levels to make it refreshingly simple for those who only need to sign off tasks.
We invite you to get behind the wheel of the newest release of the Evergreen Compliance Manager. We believe you will find the driving experience to be uniquely refreshing.
Copyright 2010 – Argent Consulting Services, Inc.
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