Transcript Document

Auditing RIM Programs
for
Improvement
Helen Streck
President/CEO
Workshop Agenda

Introductions

Understanding Audits

Lifecycle and Elements of an Audit

Findings and Developing Initiatives
2
Introduction
3
Introduction

Importance of Good Recordkeeping

Values for a RIM Program

Knowing Your Requirements
4

Strategic Review of Risks

Drivers for Continuous Improvement

Auditing’s Input
Value of RIM
IF - Information is a key asset to an organization
then RIM
 Establishes the controls for compliance

Improves efficiency

Element of reasonableness

Removes costs when value no longer exits

Facilitates effective/efficient decision making

Improves system performance
5
Knowing Your Requirements
SEC 17-A, sections 3 & 4
Government Paperwork
Elimination Act
6
NASD 3110
NASD 3010
Check 21
Gramm-Leach-Bliley Act
Sarbanes-Oxley Act
Drivers for Continuous Improvement

Industry Competition

Data Storage Costs

Excessive Costs of eDiscovery – Obsolete Data

Rising Costs of Human Labor

“Personalization” of Information

Increased Regulations and Inspections

Over-Regulating
7
Using Audits for Improvement
This session will focus on how to plan and use
an Audit (Assessment) to aid a RIM Program
in building the improved services that meet
the needs for continuous improvement.
8
Understanding Audits
9
Defining an Audit
A RIM audit is an independent, objective
activity designed to “add value and improve”
an organization’s operations for creating and
managing information.
10
Understanding Audits

Independent Objective Evaluation

Provide Assurances




Compliance
Efficiencies
Effectiveness
Evaluates




Governance
Controls
Processes
Risk Management
11
Auditing Characteristics

Holistic Approach

Consistent with Org’s Mission and Goals

Prioritized on a Risk-Based Approach

Conducted Routinely

Outside-Looking-In View
12
Audit’s Value Statement

Proves controls via documentation and
evaluation

Checks for controls that reduce or eliminate
unabated information growth

Ensures the application of rules that eliminate
obsolete information that may be discoverable

Determines the effectiveness of procedures

Identifies isolated instances of duplication
13
Risks with Poor RIM Programs

Loss of Intellectual Property

Delayed Decision-making/Filings

Increased Technology Costs

Increased eDiscovery Costs/Penalties

Poor System/Operational Responsiveness


Decreased Competitiveness
Unmanaged Liability
14
Using Industry Standards

Use industry standards and best practices
to benchmark

The Principles

ISO and ANSI standards

Best Practices

Sedona Principles
15
Elements of Compliant Programs

Accountability

Integrity

Information protection

Compliance

Information is available

Retention

Disposition

Transparency
16
Generally Accepted
Recordkeeping
Principles
www.arma.org
Audit Lifecycle
17
Audit Cycle
1
Planning
5
Follow-up
Follow-up
Reporting
4
4
Reporting
Reporting
1
Planning
5
2
4
3
Preparation
2
Preparation
Performance
3
Performance
18
18
Steps in an Audit

Planning

Define purpose, scope, criteria and objectives

Prioritize based on risk
19
The Purpose

Start with defining the purpose of the audit –
sets the tone

Looking for mistakes

Complying with requirements

Seeking opportunities to improve

Define the expected outcomes

What are the actions to follow
20
The Purpose

Why

To meet regulatory requirements

To verify the controls established to protect PHI

To check the processes that document the use of public
funds
21

Outcomes



Report of evaluation and findings
Findings are prioritized as high, medium or low the high
being the most severe
Actions

Develop corrective plan (initiatives) with timelines
Audit Objectives

Relate the elements of your program to the
Corporate goal

Examples of objects include

To determine the level of protection taken and routinely
followed to protect paper records

To assess management’s commitment by assignments
and participation on the Steering Committee

To measure the rate of the department’s completion of
the RIM learning course
22
Set Criteria Ratings
Next determine what you must have:

What program elements are critical

What program elements are important to have
23

What program elements are preferred but you
could live without
Set Criteria Ratings
Important
Critical


Program has
mission and
vision
statement
Program
mission and
vision
statement
endorsed by
executives

Mission and
vision
statement
are published
for
employees to
access and
see
Preferred

Program
mission
statement is
included in
business
unit’s goals
and mission
24
24
Program Element
Documentation
Available
Principle
Yes/No
Policy – Sample Only
Yes
Criteria
Last Revision
Date
C/I/P
Accountability
Critical
Current Rating
Un/NI/S/NA
Mar-08
Needs Improvement
Retention Schedule
Procedures (sampling only)
Transferring Hard Copy Records to Storage
Information Disposition Procedure
Decommissioning Plan/Procedure
Exiting Employee Procedure
System Taxonomy/File Plan
Training Materials
New Hire Training Slides
Communication
Website
Glossary
25
Decide on Ratings
Based on risk factors and known requirements how
does the current documentation and practices
measure up to the criteria?

Satisfactory
26

Needs Improvement

Unsatisfactory

N/A
Steps in an Audit

Planning


Define scope, criteria, and objectives
Prioritize based on risk
27
Steps in an Audit

Planning



Define scope, criteria, and objectives
Prioritize based on risk
Preparation

Create a checklist – what do you want them to produce
for you to review

What is required by law to have

Submit checklist, questions and document request to the
group being audited
28
Steps in an Audit

Planning



Preparation




Define scope, criteria, and objectives
Prioritize based on risk
Create a checklist – what do you want them to produce for you to
review
What is required by law to have
Submit checklist, questions and document request to the group being
audited
Performance

Collect and review of physical and electronic
recordkeeping documentation

Conduct interview(s) with department(s) personnel as
necessary
29
Steps in Performing an Audit

Ask the Department to identify your contact –
Records Coordinator, Management – someone who
can answer questions

Send checklist (what is being covered) in advance to contact

Obtain the list of names of employees to interview
in advance

Schedule meetings with interviewees

Prepare a list of documents you want the
department to provide you for review
30
Steps in an Audit

Planning



Preparation




Create a checklist – what do you want them to produce for you to
review
What is required by law to have
Submit checklist, questions and document request to the group being
audited
Performance



Define scope, criteria, and objectives
Prioritize based on risk
Collect and review of physical and electronic recordkeeping
documentation
Conduct interview(s) with department(s) personnel as necessary
Reporting



Draft Findings Report
Discuss steps for improvement
Recommend Timelines – be realistic
31
Steps in an Audit

Planning



Preparation





Collect and review of physical and electronic recordkeeping
documentation
Conduct interview(s) with department(s) personnel as necessary
Reporting




Create a checklist – what do you want them to produce for you to
review
What is required by law to have
Submit checklist, questions and document request to the group being
audited
Performance


Define scope, criteria, and objectives
Prioritize based on risk
Draft Findings Report
Discuss steps for improvement
Recommend Timelines – be realistic
Monitor the improvement steps
32
Using Audits for Improvement

Reviewing the risk, compliance requirements

Learning to rank initiatives

Understanding the resource requirements needed

Using a “Triage” approach
33
Using Findings to Create
Initiatives
34
Triage Approach: General Description

Develops a plan that prioritizes the most
pressing matters so that they receive immediate
attention.

Places longer term goals on a drawing board to
be reviewed with more analysis without
pressure.

Postpone tasks that are of low risk and not
urgent for the last phase of the project.
Triage approach prioritizes the needs and risks of
the project into manageable groups.
35
Triage Approach: General Description

Provides a means for “building onto” a Program
by ensuring the correct components are done
first.

Allows the Program owner to measure success
and “see” definable improvements and not wait
on project completion to be successful.

Separates project components based on risk
and need so that items which are most critical
get the immediate attention to reduce existing
or potential risks.
36
Prioritize Like Emergency Room

Stop The Bleeding

RIM initiatives that address the immediate findings to
achieve compliance
37
Levels of Process Improvements

Stop the Bleeding


RIM initiatives that address the immediate findings to achieve
compliance
Treat The Underlying Cause(s)

Address the root symptoms
38
Levels of Process Improvements

Stop the Bleeding


Treat The Underlying Cause(s)


RIM initiatives that address the immediate findings to achieve
compliance
Address the root symptoms
Establish Preventive Measures

Long-term initiatives and projects involving multiple
stakeholders, resources and automation to prevent
future problems
39
Levels of Process Improvements

Stop the Bleeding


Treat The Underlying Cause(s)


Address the root symptoms
Establish Preventive Measures


RIM initiatives that address the immediate findings to achieve
compliance
Long-term initiatives and projects involving multiple stakeholders,
resources and automation to prevent future problems
Create Ongoing Efficiencies

As systems are operating smoothly and consistently,
opportunities for streamlining arise
40
Immediate
Implementation
(<6 mo.)
Scheduled Implementation
(4-12 mo.)
Delayed
Implementation
(8-24 mo.)
41
Triage
Immediate
Implementation
(<6 mos)
Program
governance
Scheduled
Implementation
(6-15 mos)
Phase in Program
Governance to employees
Delayed
Implementation
(15-24 mos)
Records
Management
criteria for system
designs
Program
assessment and
strategy
Create educational
curriculum and course
content
Process to manage
orphaned data
Program
infrastructure
Data from departing
employees.
Create business
case and workflow
for RM S
Communication
plan and program
toolkit
Protocol for
decommissioning systems
Audit criteria
42
Immediate Project (<6 months)
Description
Program governance
 Revised
global program policy
 Revise/consolidate records retention schedule
 Identify global processes and draft protocols
 Review and revise or create standards for
archiving records and data
Program assessment and Strategy
 Conduct program assessment
 Realign and revise
vision and mission
 Create Program strategy and timeline
Program Infrastructure
 Complete
entity appointed Records Managers
 Refine roles and responsibilities
 Draft Executive Sponsorship oversight role
 Identify and formalize key partnerships (CCO,
GC, CIO)
Communication plan and toolkit
 Develop
communication plan for build out
 Create tools and support communication for
infrastructure
 Create communication templates
Benefit
Approach
 Clearly defined rules and
 Identify all associated
expectations
 Developed center of expertise
 Policy simplification and
alignment
 Flexible implementation
policies/revise and align
Review/collapse and
reformat RRS
 Revise/create standards
for archiving paper and
electronic records
 Clearly articulated vision
 Conduct interviews
 Measurable and achievable
action steps towards a mature
program
 Identifiable resources &
dependencies
 Strengthen
knowledge base
 Distributed implementation
involvement
 Executive sponsorship and
support
 Concise and consistent
messaging
 Increased employee
awareness
 Support for entity Records
Mgrs
with
identified key employees
 Assess current goals and
roles and responsibilities
 Identify risks and
conduct gap analysis of risk
and service
 Define roles and
responsibilities and
support
 Engage entity senior
management in selection
and requirements
 Create Executive roles
and responsibilities
Cost
43
Scheduled Projects (6-15 months)
Description
Phase in Program Governance
 Create employee
awareness
 Develop new hire orientation material
 Develop web page and includes links in governance
documents
Employee Education
 Create educational curriculum and strategy
 Identify all available modalities
 Draft course content for Program components and
Benefit
 Assess current process and situation
 Partner with IT to determine
employee data location
and system requirements and controls
 Develop process for preserving data/records of
departing staff to comply with legal holds and retention
requirements
Decommissioning Systems
 Draft decommissioning
compliance requirement
needs that need to be met
 Create decision tree
 Draft protocol for decommissioning systems
Cost
 Ensure global awareness
and feedback
 Awareness for new hires
 Provides point-in-time
resource
 Improved
program
awareness
 Enable employee
compliance
44
compliance requirements
Exiting Employees
Approach
 Risk avoidance of deleting
litigation relevant data
 Inform supervisors of
responsibility at point-in-time
 Ensures compliance with
legal and RIM requirements
 Ensures preservation
and
required data
 Avoids over retention of
obsolete data
 Reduces expenses
Scheduled Projects (15-24 months)
Description
Phase in Program Governance
 Create employee
awareness
 Develop new hire orientation material
 Develop web page and includes links in governance
documents
Employee Education
 Create educational curriculum and strategy
Benefit
Approach
Cost
 Ensure global awareness and
feedback
 Awareness for new hires
 Provides point-in-time resource
 Improved
program awareness
 Enable employee compliance
 Identify all available modalities
 Draft course content for Program components and
45
compliance requirements
Exiting Employees
 Assess current process and situation
 Partner with IT to determine
employee data location
and system requirements and controls
 Develop process for preserving data/records of
departing staff to comply with legal holds and retention
requirements
Decommissioning Systems
 Draft decommissioning
compliance requirement
needs that need to be met
 Create decision tree
 Draft protocol for decommissioning systems
 Risk avoidance of deleting
litigation relevant data
 Inform supervisors of
responsibility at point-in-time
 Ensures compliance with legal
and RIM requirements
 Ensures preservation
and
required data
 Avoids over retention of
obsolete data
 Reduces expenses
Make Audits Work for You!

Audits of RIM Programs should be viewed as a
mechanism for healthier programs

Plan, prepare, evaluate and report

Use the findings to create initiatives and identify
needed resources

Focus on continuous improvement
46
Thank You !
Helen Streck
President/CEO
Kaizen InfoSource