Developing a culturally competent public health workforce

There’s a good chance that your organization is in the position of needing to do more with less under the strain of staffing constraints and competing initiatives. With fewer resources to work with, you’ll need to be persuasive to get the green light on new enterprise technology initiatives. To do that, you need to present decision makers with well-thought-out and targeted business cases that show your initiative will have impact and will be successful. Yet developing such a business case is no walk in the park. Perhaps because our firm has its roots in New England, we sometimes compare this process to leading a hiking trip into the woods—into the wild. 

Just as in hiking, success in developing a business case for a new initiative boils down to planning, preparation, and applying a few key concepts we’ve learned from our travels. 

Consensus is critical when planning new technology initiatives

Before you can start the hike, everyone has to agree on some fundamentals: 

Who's going? 

Where are we going? 

When do we go and for how long? 

Getting everyone to agree requires clear communication and, yes, even a little salesmanship: “Trust me. The bears aren’t bad this time of year.” The same principle applies in proposing new technology initiatives; making sure everyone has bought into the basic framework of the initiative is critical to success.

Although many hiking trips involve groups of people similar in age, ability, and whereabouts, for your business initiative you need to communicate with diverse groups of colleagues at every level of the organization. Gaining consensus among people who bring a wide variety of skills and perspectives to the project can be complex.

To gain consensus, consider the intended audiences of your message and target the content to what will work for them. It should provide enough information for executive-level stakeholders to quickly understand the initiative and the path forward. It should give people responsible for implementation or who will provide specific skills substantive information to implement the plan. And remember: one of the most common reasons projects struggle to meet their stated objectives (and why some projects never materialize to begin with), is a lack of sponsorship and buy-in. The goal of a business case is to gain buy-in before project initiation, so your sponsors will actively support the project during implementation. 

Set clear goals for your enterprise technology project 

It’s refreshing to take the first steps, to feel that initial sense of freedom as you set off down the trail. Yet few people truly enjoy wandering around aimlessly in the wilderness for an extended period of time. Hikers need goals, like reaching a mountain peak or seeing famous landmarks, or hiking a predetermined number of miles per day. And having a trail guide is key in meeting those goals. 

For a new initiative, clearly define goals and objectives, as well as pain points your organization wishes to address. This is critical to ensuring that the project’s sponsors and implementation team are all on the same page. Identifying specific benefits of completing your initiative can help people keep their “eyes on the prize” when the project feels like an uphill climb.

Timelines provide additional detail and direction—and demonstrate to decision makers that you have considered multiple facets of the project, including any constraints, resource limitations, or scheduling conflicts. Identifying best practices to incorporate throughout the initiative enhances the value of a business case proposition, and positions the organization for success. By leveraging lessons learned on previous projects, and planning for and mitigating risk, the organization will begin to clear the path for a successful endeavor. 

Don’t compromise on the right equipment

Hiking can be an expensive, time-consuming hobby. While the quality of your equipment and the accuracy of your maps are crucial, you can do things with limited resources if you’re careful. Taking the time to research and purchase the right equipment, (like the right hiking boots), keeps your fun expedition from becoming a tortuous slog. 

Similarly, in developing a business case for a new initiative, you need to make sure that you identify the right resources in the right areas. We all live with resource constraints of one sort or another. The process of identifying resources, particularly for funding and staffing the project, will lead to fewer surprises down the path. As many government employees know all too well, it is better to be thorough in the budget planning process than to return to authorizing sources for additional funding while midstream in a project. 

Consider your possible outcomes

You cannot be too singularly focused in the wild; weather conditions change quickly, unexpected opportunities reveal themselves, and being able to adapt quickly is absolutely necessary in order for everyone to come home safely. Sometimes, you should take the trail less traveled, rest in the random lean-to that you and your group stumble upon, or go for a refreshing dip in a lake. By focusing on more than just one single objective, it often leads to more enjoyable, safe, and successful excursions.

This type of outlook is necessary to build a business case for a new initiative. You may need to step back during your initial planning and consider the full impact of the process, including on those outside your organization. For example, you may begin to identify ways in which the initiative could benefit both internal and external stakeholders, and plan to move forward in a slightly new direction. Let’s say you’re building a business case for a new land management and permitting software system. Take time to consider that this system may benefit citizens, contractors, and other organizations that interact with your department. This new perspective can help you strengthen your business case. 

Expect teamwork

A group that doesn’t practice teamwork won’t last long in the wild. In order to facilitate and promote teamwork, it’s important to recognize the skills and contributions of each and every person. Some have a better sense of direction, while some can more easily start campfires. And if you find yourself fortunate enough to be joined by a truly experienced hiker, make sure that you listen to what they have to say.

Doing the hard work to present a business case for a new initiative may feel like a solitary action at times, but it’s not. Most likely, there are other people in your organization who see the value in the initiative. Recognize and utilize their skills in your planning. We also suggest working with an experienced advisor who can leverage best practices and lessons learned from similar projects. Their experience will help you anticipate potential resistance and develop and articulate the mitigation strategies necessary to gain support for your initiative.

If you have thoughts, concerns, or questions, contact our team. We love to discuss the potential and pitfalls of new initiatives, and can help prepare you to head out into the wild. We’d love to hear any parallels with hiking and wilderness adventuring that you have as well. Let us know! 

BerryDunn’s local government consulting team has the experience to lead technology planning initiatives and develop actionable plans that help you think strategically and improve service delivery. We partner with you, maintaining flexibility and open lines of communication to help ensure that your team has the resources it needs.

Our team has broad and deep experience partnering with local government clients across the country to modernize technology-based business transformation projects and the decision-making and planning efforts. Our expertise includes software system assessments/planning/procurement and implementation project management; operational, management, and staffing assessments; information security; cost allocation studies; and data management.  

Read this if your organization is planning on upgrading or replacing an enterprise technology system.

It can be challenging and stressful to plan for technology initiatives, especially those that involve and impact every area of your organization. Common initiatives include software upgrades or replacements for:

• Financial management, such as Enterprise Resource Planning (ERP) systems
• Asset management systems
• Electronic health records (EHR) systems
• Permitting and inspections systems

Though the number of considerations when planning enterprise technology projects can be daunting, the greatest mistake you can make is not planning at all. By addressing just a few key areas, you can avoid some of the most common pitfalls, such as exceeding budget and schedule targets, experiencing scope creep, and losing buy-in among stakeholders. Here are some tips to help you navigate your next project:

Identify your IT project roles and resources

While most organizations understand the importance of identifying project stakeholder groups, it is often an afterthought. Defining these roles at the outset of your project helps you accurately estimate the work effort.

Your stakeholder groups may include:

• An executive sponsor
• A steering committee
• A project manager
• Functional leads
• A technical team

Once you’ve established the necessary roles, you can begin reviewing your organization’s resources to determine the people who will be available to fill them. Planning for resource availability will help you avoid delays, minimize impact to regular business processes, and reduce the likelihood of burnout. But this plan won’t remain static—you can expect to make updates throughout the project.

Establish clear goals and objectives to keep your technology project on track

It’s important that an enterprise technology project has established goals and objectives statements. These statements will help inform decision-making, provide benchmarks for progress, and measure your project’s success. They can then be referenced when key stakeholders have differing perspectives on the direction to take with a pending decision. For example, if the objective of your project is to reduce paper-based processes, you may plan for additional computer workstations and focus technical resources on provisioning them. You’ll also be able to measure your success in the reduction of paper-based tasks.

Estimate your IT project budget accurately

Project funding is hardly ever overlooked, but can be complex with project budgets that are either underestimated or estimated without sufficient rationale to withstand approval processes and subsequent budget analysis. You may find that breaking down estimates to a lower level of detail helps address these challenges. Most technology projects incur costs in three key areas:

• Vendor cost: This could include both one-time software implementation costs as well as recurring costs for maintenance and ongoing support.
• Infrastructure cost: Consider the cost of any investments needed to support your project, such as data center hardware, networking components, or computing devices.
• Supplemental resource cost: Don’t forget to include the cost of any additional resources needed for their specialized knowledge or to simply backfill project staff. This could include contracted resources or the additional cost of existing resources (i.e., overtime).

A good technology project budget also includes a contingency amount. This amount will depend on your organization’s standards, the relative level of confidence in your estimates, and the relative risk.

Anticipate the need for change management

Depending on the project, staff in many areas of your organization will be impacted by some level of change during a technology implementation. External stakeholders, such as vendors and the public, may also be affected. You can effectively manage this change by proactively identifying areas of likely change resistance and creating strategies to address them.

In any technology implementation, you will encounter change resistance you did not predict. Having strategies in place will help you react quickly and effectively. Some proven change management strategies include communicating throughout your project, involving stakeholders to get their buy-in, and helping ensure management has the right amount of information to share with their employees.

Maintain focus and stay flexible as you manage your IT project

Even with the most thought-out planning, unforeseen events and external factors may impact your technology project. Establish mechanisms to regularly and proactively monitor project status so that you can address material risks and issues before their impact to the project grows. Reacting to these items as they arise requires key project stakeholders to be flexible. Key stakeholders must recognize that new information does not necessarily mean previous decisions were made in error, and that it is better to adapt than to stick to the initial direction.

Whether you’re implementing an ERP, an EHR, or enterprise human resources or asset management systems, any enterprise technology project is a massive undertaking, involving significant investment and a coordinated effort with individuals across multiple areas of an organization. Common mistakes can be costly, but having a structured approach to your planning can help avoid pitfalls. Our experienced, objective advisors have worked with public and private organizations across the country to oversee large enterprise projects from inception to successful completion.

Contact our software consulting team with any questions.

Read this if your CFO has recently departed, or if you're looking for a replacement.

With the post-Covid labor shortage, “the Great Resignation,” an aging workforce, and ongoing staffing concerns, almost every industry is facing challenges in hiring talented staff. To address these challenges, many organizations are hiring temporary or interim help—even for C-suite positions such as Chief Financial Officers (CFOs).

You may be thinking, “The CFO is a key business partner in advising and collaborating with the CEO and developing a long-term strategy for the organization; why would I hire a contractor to fill this most-important role?” Hiring an interim CFO may be a good option to consider in certain circumstances. Here are three situations where temporary help might be the best solution for your organization.

Your organization has grown

If your company has grown since you created your finance department, or your controller isn’t ready or suited for a promotion, bringing on an interim CFO can be a natural next step in your company’s evolution, without having to make a long-term commitment. It can allow you to take the time and fully understand what you need from the role — and what kind of person is the best fit for your company’s future.

BerryDunn's Kathy Parker, leader of the Boston-based Outsourced Accounting group, has worked with many companies to help them through periods of transition. "As companies grow, many need team members at various skill levels, which requires more money to pay for multiple full-time roles," she shared. "Obtaining interim CFO services allows a company to access different skill levels while paying a fraction of the cost. As the company grows, they can always scale its resources; the beauty of this model is the flexibility."

If your company is looking for greater financial skill or advice to expand into a new market, or turn around an underperforming division, you may want to bring on an outsourced CFO with a specific set of objectives and timeline in mind. You can bring someone on board to develop growth strategies, make course corrections, bring in new financing, and update operational processes, without necessarily needing to keep those skills in the organization once they finish their assignment. Your company benefits from this very specific skill set without the expense of having a talented but expensive resource on your permanent payroll.

Your CFO has resigned

The best-laid succession plans often go astray. If that’s the case when your CFO departs, your organization may need to outsource the CFO function to fill the gap. When your company loses the leader of company-wide financial functions, you may need to find someone who can come in with those skills and get right to work. While they may need guidance and support on specifics to your company, they should be able to adapt quickly and keep financial operations running smoothly. Articulating short-term goals and setting deadlines for naming a new CFO can help lay the foundation for a successful engagement.

You don’t have the budget for a full-time CFO

If your company is the right size to have a part-time CFO, outsourcing CFO functions can be less expensive than bringing on a full-time in-house CFO. Depending on your operational and financial rhythms, you may need the CFO role full-time in parts of the year, and not in others. Initially, an interim CFO can bring a new perspective from a professional who is coming in with fresh eyes and experience outside of your company.

After the immediate need or initial crisis passes, you can review your options. Once the temporary CFO’s agreement expires, you can bring someone new in depending on your needs, or keep the contract CFO in place by extending their assignment.

Considerations for hiring an interim CFO

Making the decision between hiring someone full-time or bringing in temporary contract help can be difficult. Although it oversimplifies the decision a bit, a good rule of thumb is: the more strategic the role will be, the more important it is that you have a long-term person in the job. CFOs can have a wide range of duties, including, but not limited to:

• Financial risk management, including planning and record-keeping
• Management of compliance and regulatory requirements
• Creating and monitoring reliable control systems
• Debt and equity financing
• Financial reporting to the Board of Directors

If the focus is primarily overseeing the financial functions of the organization and/or developing a skilled finance department, you can rely — at least initially — on a CFO for hire.

Regardless of what you choose to do, your decision will have an impact on the financial health of your organization — from avoiding finance department dissatisfaction or turnover to capitalizing on new market opportunities. Getting outside advice or a more objective view may be an important part of making the right choice for your company.

BerryDunn can help whether you need extra assistance in your office during peak times or interim leadership support during periods of transition. We offer the expertise of a fully staffed accounting department for short-term assignments or long-term engagements―so you can focus on your business. Meet our interim assistance experts.

Read this if your company is considering outsourced information technology services.

For management, it’s the perennial question: Keep things in-house or outsource?

For management, it’s the perennial question: Keep things in-house or outsource? Most companies or organizations have outsourcing opportunities, from revenue cycle to payment processing to IT security. When deciding whether to outsource, you weigh the trade-offs and benefits by considering variables such as cost, internal expertise, cross coverage, and organizational risk.

In IT services, outsourcing may win out as technology becomes more complex. Maintaining expertise and depth for all the IT components in an environment can be resource-intensive.

Outsourced solutions allow IT teams to shift some of their focus from maintaining infrastructure to getting more value out of existing systems, increasing data analytics, and better linking technology to business objectives. The same can be applied to revenue cycle outsourcing, shifting the focus from getting clean bills out and cash coming in, to looking at the financial health of the organization, analyzing service lines, patient experience, or advancing projects.  

Once you’ve decided, there’s another question you need to ask
Lost sometimes in the discussion of whether to use outsourced services is how. Even after you’ve done your due diligence and chosen a great vendor, you need to stay involved. It can be easy to think, “Vendor XYZ is monitoring our servers or our days in AR, so we should be all set. I can stop worrying at night about our system reliability or our cash flow.” Not true.

You may be outsourcing a component of your technology environment or collections, but you are not outsourcing the accountability for it—from an internal administrative standpoint or (in many cases) from a legal standpoint.

Beware of a false state of confidence
No matter how clear the expectations and rules of engagement with your vendor at the onset of a partnership, circumstances can change—regulatory updates, technology advancements, and old-fashioned vendor neglect. In hiring the vendor, you are accountable for oversight of the partnership. Be actively engaged in the ongoing execution of the services. Also, periodically revisit the contract, make sure the vendor is following all terms, and confirm (with an outside audit, when appropriate) that you are getting the services you need.

Take, for example, server monitoring, which applies to every organization or company, large or small, with data on a server. When a managed service vendor wants to contract with you to provide monitoring services, the vendor’s salesperson will likely assure you that you need not worry about the stability of your server infrastructure, that the monitoring will catch issues before they occur, and that any issues that do arise will be resolved before the end user is impacted. Ideally, this is true, but you need to confirm.

Here’s how to stay involved with your vendor
Ask lots of questions. There’s never a question too small. Here are samples of how precisely you should drill down:

• What metrics will be monitored, specifically?
• Why do the metrics being monitored matter to our own business objectives?
• What thresholds must be met to notify us or produce an alert?
• What does exceeding a threshold mean to our business?
• Who on our team will be notified if an alert is warranted?
• What corrective action will be taken?

Ask uncomfortable questions
Being willing to ask challenging questions of your vendors, even when you are not an expert, is critical. You may feel uncomfortable but asking vendors to explain something to you in terms you understand is very reasonable. They’re the experts; you’re not expected to already understand every detail or you wouldn’t have needed to hire them. It’s their job to explain it to you. Without asking these questions, you may end up with a fairly generic solution that does produce a service or monitor something, but not necessarily all the things you need.

Ask obvious questions
You don’t want anything to slip by simply because you or the vendor took it for granted. It is common to assume that more is being done by a vendor than actually is. By asking even obvious questions, you can avoid this trap. All too often we conduct an IT assessment and are told that a vendor is providing a service, only to discover that the tasks are not happening as expected.

You are accountable for your whole team—in-house and outsourced members
An outsourced solution is an extension of your team. Taking an active and engaged role in an outsourcing partnership remains consistent with your management responsibilities. At the end of the day, management is responsible for achieving business objectives and mission. Regularly check in to make sure that the vendor stays focused on that same mission.

Artificial Intelligence, or AI, is no longer the exclusive tool of well-funded government entities and defense contractors, let alone a plot device in science fiction film and literature. Instead, AI is becoming as ubiquitous as the personal computer. The opportunities of what AI can do for internal audit are almost as endless as the challenges this disruptive technology represents.

To understand how AI will influence internal audit, we must first understand what AI is.The concept of AI—a technology that can perceive the world directly and respond to what it perceives—is often attributed to Alan Turing, though the term “Artificial Intelligence” was coined much later in 1956 at Dartmouth College, in Hanover, New Hampshire. Turing was a British scientist who developed the machine that cracked the Nazis’ Enigma code. Turing thought of AI as a machine that could convince a human that it also was human. Turing’s humble description of AI is as simple as it is elegant. Fast-forward some 60 years and AI is all around us and being applied in novel ways almost every day. Just consider autonomous self- driving vehicles, facial recognition systems that can spot a fugitive in a crowd, search engines that tailor our online experience, and even Pandora, which analyzes our tastes in music.

Today, in practice and in theory, there are four types of AI. Type I AI may be best represented by IBM’s Deep Blue, a chess-playing computer that made headlines in 1996 when it won a match against Russian chess champion Gary Kasparov. Type I AI is reactive. Deep Blue can beat a chess champion because it evaluates every piece on the chessboard, calculates all possible moves, then predicts the optimal move among all possibilities. Type I AI is really nothing more than a super calculator, processing data much faster than the human mind can. This is what gives Type I AI an advantage over humans.

Type II AI, which we find in autonomous cars, is also reactive. For example, it applies brakes when it predicts a collision; but, it has a low form of memory as well. Type II AI can briefly remember details, such as the speed of oncoming traffic or the distance between the car and a bicyclist. However, this memory is volatile. When the situation has passed, Type II AI deletes the data from its memory and moves on to the next challenge down the road.

Type II AI's simple form of memory management and the ability to “learn” from the world in which it resides is a significant advancement. The leap from Type II AI to Type III AI has yet to occur. Type III AI will not only incorporate the awareness of the world around it, but will also be able to predict the responses and motivations of other entities and objects, and understand that emotions and thoughts are the drivers of behavior. Taking the autonomous car analogy to the next step, Type III AI vehicles will interact with the driver. By conducting a simple assessment of the driver’s emotions, the AI will be able to suggest a soothing playlist to ease the driver's tensions during his or her commute, reducing the likelihood of aggressive driving. Lastly, Type IV AI–a milestone that will likely be reached at some point over the next 20 or 30 years—will be self-aware. Not only will Type IV AI soothe the driver, it will interact with the driver as if it were another human riding along for the drive; think of “HAL” in Arthur C. Clarke’s 2001: A Space Odyssey.

So what does this all mean to internal auditors?
While it may be a bit premature to predict AI’s impact on the internal audit profession, AI is already being used to predict control failures in institutions with robust cybersecurity programs. When malicious code is detected and certain conditions are met, AI-enabled devices can either divert the malicious traffic away from sensitive data, or even shut off access completely until an incident response team has had time to investigate the nature of the attack and take appropriate actions. This may seem a rather rudimentary use of AI, but in large financial institutions or manufacturing facilities, minutes count—and equal dollars. Allowing AI to cut off access to a line of business that may cost the company money (and its reputation) is a significant leap of faith, and not for the faint of heart. Next generation AI-enabled devices will have even more capabilities, including behavioral analysis, to predict a user’s intentions before gaining access to data.

In the future, internal audit staff will no doubt train AI to seek conditions that require deeper analysis, or even predict when a control will fail. Yet AI will be able to facilitate the internal audit process in other ways. Consider AI’s role in data quality. Advances in inexpensive data storage (e.g., the cloud) have allowed the creation and aggregation of volumes of data subject to internal audit, making the testing of the data’s completeness, integrity, and reliability a challenging task considering the sheer volume of data. Future AI will be able to continuously monitor this data, alerting internal auditors not only of the status of data in both storage and motion, but also of potential fraud and disclosures.

The analysis won’t stop there.
AI will measure the performance of the data in meeting organizational objectives, and suggest where efficiencies can be gained by focusing technical and human resources to where the greatest risks to the organization exist in near real-time. This will allow internal auditors to develop a common operating picture of the day-to-day activities in their business environments, alerting internal audit when something doesn’t quite look right and requires further investigation.

As promising as AI is, the technology comes with some ethical considerations. Because AI is created by humans, it is not always vacant of human flaws. For instance, AI can become unpredictably biased. AI used in facial recognition systems has made racial judgments based on certain common facial characteristics. In addition, AI that gathers data from multiple sources that span a person’s financial status, credit status, education, and individual likes and dislikes could be used to profile certain groups for nefarious intentions. Moreover, AI has the potential to be weaponized in ways that we have yet to comprehend.

There is also the question of how internal auditors will be able to audit AI. Keeping AI safe from internal fraudsters and external adversaries is going to be paramount. AI’s ability to think and act faster than humans will challenge all of us to create novel ways of designing and testing controls to measure AI’s performance. This, in turn, will likely make partnerships with consultants that can fill knowledge gaps even more valuable. 

Challenges and pitfalls aside, AI will likely have a tremendous positive effect on the internal audit profession by simultaneously identifying risks and evaluating processes and control design. In fact, it is quite possible that the first adopters of AI in many organizations may not be the cybersecurity departments at all, but rather the internal auditor’s office. As a result, future internal auditors will become highly technical professionals and perhaps trailblazers in this new and amazing technology.

People are naturally resistant to change. Employees facing organizational change that will impact day-to-day operations are no exception, and they can feel threatened or fearful of what that change will bring. Even more challenging are multiyear initiatives where the project’s completion is years away.

How can your agency or organization help employees prepare for change—and stay motivated for an outcome—many years in the making?

Start With the Individual

Organizational change requires individual change. For the change to be successful and lasting, an agency should apply organizational change management strategies that help lead people to your desired outcome.

With any new project or initiative, people need to understand why the project is happening before they support it. Communicate the reasons for the change—and the benefit to the employee (what’s in it for them)—so each individual is more inclined to actively support the project. Clearly communicating the why at the onset of the project can help employees feel vested in, and part of, the change. As Socrates said, “The secret of change is to focus all your energy, not on fighting the old, but building the new.” A clear vision can inspire each employee’s desire for the “new” to succeed.

Shift to Individual Goals

It’s a challenge to maintain your employees’ motivation for an organizational change occurring over the long haul. Below are some suggestions on how to sustain interest and enthusiasm for multi-year projects:

1. Break the project down into smaller, specific milestones. Short-term goals highlight important deadlines and create tangible progress points to reach and celebrate. The master project schedule should be an integration of the organizational change management plan and the project management plan so any resource constraints you identify in the project management plan also become an input when identifying change management resources and activity levels. This integration also highlights the importance of key organizational change management milestones and activities in an effort to ensure they are on a parallel tack as traditional project tasks.
2. Effectively communicate status updates and successes. In large, agency-wide projects, there are often a variety of stakeholders, each with different communication expectations and needs. The methods, content, and frequency of communication will vary accordingly. Develop a communications strategy as part of your organizational change management plan, to identify who will be responsible to send communications, when and how they will be sent, key messages of the communications, and what feedback mechanisms are in place to continue the conversation after initial delivery. For example, the project team needs a different level of detail than the legislature, or the public. Making the content relevant to each stakeholder group is important because it gives each group what they need to know so they don’t drown in a flood of unneeded information.
3. Create buy-in by involving employees. A feeling of ownership naturally results from participation in a project, which helps increase enthusiasm. Often the time to do this is when discussing changes to business processes. Once you determine the mandatory features of the future state, (e.g., financial controls, legal requirements, legislative mandates) consider including stakeholder feedback on decisions more focused on preference. It is important for stakeholders to see their suggestions accepted and implemented, or if not implemented, that there was at least a structured process for thoughtfully considering their feedback, and a business case for why their suggestions didn’t make it into the project.
4. Conduct lessons learned assessments after each major milestone. The purpose of conducting lessons learned activities is to capture what worked and what didn’t. Using surveys or other feedback systems, such as debrief meetings, allows stakeholders to voice their thoughts or concerns. By soliciting feedback after each milestone, leadership can quickly adapt to challenges, address any misunderstandings or concerns, and capitalize on successes.
5. Reinforce how the project meets the goals of the agency or organization. Maintaining enthusiasm and support for a long-term goal takes a constant reminder of the overall organizational goals. It is important for senior leadership to communicate the impact of the project on the agency or organization and to stakeholders and keep the project at the forefront of people’s minds. Project goals may change during the duration of the project, but the project sponsor should continue to be active and visible in communicating the goals and leading the project.

Change is difficult—change that is years in the making is even more challenging. Applying a structured organizational change management process and using these tips can help keep employees energized and help ensure you reach the desired project goals.

Good Practices Are Not Enough

When it comes to IT security, more than one CEO running a small organization has told me they have really good people taking care of “all that.” These CEOs choose to believe their people perform good practices. That may be true, but who defines good practices and how they administer them? And when? If “security is everyone’s job,” then nobody is responsible for getting specific things done. Good practices require consistency, and consistency requires structure.

From an audit perspective, a control not written down does not exist. Why? Because it can’t be tested, measured, or validated. An IT Auditor can’t assess controls if they were never defined. Verbal instruction carries by far the most risk. “I told him to do that,” doesn’t pass the smell test in court.

Why Does it Matter?

Because it’s not IT’s job to write policies. Their job is to implement IT decisions made by management. They’re not at the right level to make decisions that impact the entire organization. Why should small organizations concern themselves with developing policies and procedures? Here are two very good reasons:

1. Regulatory Requirements
2. Lawsuits

No matter how small your organization, if you have a corporate network (even cloud-based) and you store credit card transactions, personal health information, client financial information or valuable intellectual property, being aware of state and federal regulatory requirements for protecting that information is vital. It is the responsibility of management to research and develop a management framework for addressing risk.

Lawsuits happen when information is stolen and/or employees are terminated for inappropriate activities. If you have no policies that mandate what is and isn’t acceptable, and what the penalties are for violations, your terminated employee has grounds for a wrongful termination lawsuit: policy should not be written by the IT Department.

If confidential data you are responsible for is stolen and clients sue you, standing up in court and saying “We don’t have any written policies or procedures,” is a sure way to have both significant financial losses and a negative impact on your reputation. For a small organization, that could mean going out of business.

Even if data is stolen from a third-party vendor who stores your data, your organization owns the data and is responsible for ensuring the data is secure with the vendor and meets organizational requirements. Do you have a vendor management policy? If you work with vendors, you need one.

Consider, too, that every organization expects to grow its business. The longer management doesn’t pay attention to policies and procedures, the more difficult it becomes to develop and implement them.

Medium and Large Organizations Need to Pay Attention, too

A policy document provides a framework for defining activities and decision-making by everyone in the organization. A policy contains standards for the organization, and outlines penalties for non-performance. The organization’s management team or board of directors must drive their creation.
Policies also maintain accountability in the eyes of internal and external stakeholders. Even the smallest organization wants their customers and employees to have confidence the organization is protecting important information. By defining the necessary controls for running business operations that address risk and compliance requirements (and reviewing them annually), your management team demonstrates a commitment to good practices.

Procedures are the “How”

Procedures don’t belong in a policy. Departments need to be able to design their own procedures to meet policy requirements and definitions. HR will have procedures for employee privacy and financial information, finance must manage credit card, student, banking or client financial documentation, and IT will need to develop specific technical procedures to document their compliance with policy.

If all those procedures are in a policy, it makes for unwieldy policy documents that management must review and approve. Departments need to change and update their procedures quickly in order to remain effective. For example, a policy may mandate the minimum number of characters in a password, but IT needs to develop the procedures to implement that requirement on many platforms and devices.

What is a “Plan” Used For?

Consider that organizations commonly have a Business Continuity Plan as well as an Incident Response Plan. How is a “plan” different from a policy or procedure?

A plan (for example, an Information Security Plan, or Privacy Plan, etc.) is a collection of related procedures with a specific focus. I have seen these collections called “programs,” but most organizations use “plan” (plus, the Federal government uses that term). The term “program” implies a beginning and an end, as well as tending to be a little too generic (think “School Lunch Program”).

Three Ways Not to Develop Policies, Procedures and Plans

Consider the Unique Aspects of Your Organization

What electronic information does your organization consider valuable? During an assessment with a state university, we discovered that the farm research the agriculture school was performing was extremely valuable. While we started out with questions about student health and financial information, the university realized the research data was equally critical. The information might not have federal or state regulations attached to it, but if it is valuable to your organization, you need to protect it. By not taking a one-size fits all approach to our assessment, we were able to meet their specific needs.

Multiple Departments or Locations? Standardize.

Whether your organization is a university, non-profit organization, government agency, medical center or business, you frequently have sub-entities. Each sub-entity or location may have different terms for different functions. For example, at a recent engagement for another university, Information Security “Programs,” “Plans” and “Policies” meant different things on different campuses. This caused confusion on the part of all stakeholders. It also showed a lack of cohesion in the approach to security of the university as a whole. Standardizing language is one of the best ways to have everyone in the organization on the same page, even if the documents are unique to a location, agency or site. This makes planning, implementation, and system upgrade projects run more effectively.

Demonstrate Competence

No matter what terms your organization chooses, using consistent terms is a good way to demonstrate a thoughtful approach. Everyone needs to be talking the same language. Having documents that specify management decisions provides assurance to internal and external stakeholders. Good policies, procedures and plans can mean the difference between a manageable crisis and a business failure.

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A year ago, CMS released the Medicaid Enterprise Certification Toolkit (MECT) 2.1: a new Medicaid Management Information Systems (MMIS) Certification approach that aligns milestone reviews with the systems development life cycle (SDLC) to provide feedback at key points throughout design, development, and implementation (DDI).

The MECT (recently updated to version 2.2) incorporates lessons learned from pilot certifications in several states, including the successful West Virginia pilot that BerryDunn supported. MECT updates have a direct impact on E&E systems—an impact that may increase in the near future. Here is what you need to know:         

Then: Initial Release

In February 2017, CMS introduced six Eligibility & Enrollment (E&E) checklists. Five were leveraged from the MECT, while the sixth checklist contained unique E&E system functionality criteria and provided a new E&E SDLC that—like the MECT—depicted three milestone reviews and increased the Independent Verification and Validation (IV&V) vendor’s involvement in the checklists completion process.

Now: Getting Started

Completing the E&E checklists will help states ensure the integrity of their E&E systems and help CMS guide future funding. This exercise is no easy task, particularly when a project is already in progress. Completion of the E&E checklists involves many stakeholders, including:

• The state (likely more than one agency)
• CMS
• IV&V
• Project Management Office (PMO)
• System vendor(s)

As with any new processes, there are challenges with E&E checklists completion. Some early challenges include:

• Completing the E&E checklists with limited state project resources
• Determining applicable criteria for E&E systems, especially for checklists shared with the MMIS
• Identifying and collecting evidence for iterative projects where criteria may not fall cleanly into one milestone review phase
• Completing the E&E checklists with limited state project resources
• Working with the system vendor(s) to produce evidence

What’s Next?

Additionally, working with system vendors may prove tricky for projects that already have contracts with E&E vendors, as E&E systems are not currently subject to certification (unlike the MMIS). This may lead to instances where E&E vendors are not contractually obligated to provide the evidence that would best satisfy CMS criteria. To handle this and other challenges, states should communicate risks and issues to CMS and work together to resolve or mitigate them.

As CMS partners with states to implement the E&E checklists, some questions are expected to be asked. For example, how much information can be leveraged from the MECT, and how much of the checklists completion process must be E&E-specific? Might certification be required in the near future for E&E systems?

While there will be more to learn and challenges to overcome, the first states completing the E&E checklists have an opportunity to lead the way on working with CMS to successfully build and implement E&E systems that benefit all stakeholders.

On July 31, 2017, CMS released the MECT 2.2 as an update to the MECT 2.1.1. As the recent changes continue to be analyzed, what will the impact be to current and future MMIS and E&E projects?

Check back here at BerryDunn Briefings in the coming weeks and we will help you sort it out.