How to Reduce Costs when Complying with SOX 404

Section 404 contains the most onerous and most costly requirements you’ll ever encounter in the Sarbanes-Oxley Act (SOX). In this article, we?ll take a closer look at the salient points of this contentious piece of legislation as it relates to IT. We?ll also explain why companies are encountering difficulties in complying with it.

Then as soon as we’ve tackled the main issues of this section and identify the pitfalls of compliance, we can then proceed with a discussion of what successful CIOs have done to eliminate those difficulties and consequently bring down their organisation’s IT compliance costs. From this post, you can glean insights that can help you plan a cost-effective way of achieving IT compliance with SOX.

SOX 404 in a nutshell

Section 404 of the Sarbanes-Oxley Act, entitled Management Assessment of Internal Controls, requires public companies covered by the Act to submit an annual report featuring an assessment of their company?s internal controls.

This ?internal control report? should state management’s responsibility in establishing/maintaining an adequate structure and a set of procedures for internal control over your company?s financial reporting processes. It should also contain an assessment of the effectiveness of those controls as of the end of your most recent fiscal year.

Because SOX also requires the public accounting firm that conducts your audit reports to attest to and report on your assessments, you can’t just make baseless claims regarding the effectiveness of your internal controls. As a matter of fact, you are mandated by both SEC and PCAOB to follow widely accepted control frameworks like COSO and COBIT. This framework will serve as a uniform guide for the internal controls you set up, the assessments you arrive at, and the attestation your external auditor reports on.

Why compliance of Section 404 is costly

Regardless which of the widely acceptable control frameworks you end up using, you will always be asked to document and test your controls. These activities can consume a considerable amount of man-hours and bring about additional expenses. Even the mere act of studying the control framework and figuring out how to align your current practices with it can be very tricky and can consume precious time; time that can be used for more productive endeavours.

Of course, there are exceptions. An organisation with highly centralised operations can experience relative ease and low costs while implementing SOX 404. But if your organisation follows a largely decentralised operation model, e.g. if you still make extensive use of spreadsheets in all your offices, then you’ll surely encounter many obstacles.

According to one survey conducted by FEI (Financial Executives International), an organisation that carried out a series of SOX-compliance-related surveys since the first year of SOX adoption, respondents with centralised operations enjoyed lower costs of compliance compared to those with decentralised operations. For example, in 2007, those with decentralised operations spent 30.1 % more for compliance than those with centralised operations.

The main reason for this disparity lies in the disorganised and complicated nature of spreadsheet systems.

Read why spreadsheets post a burden when complying with SOX and other regulations.

Unfortunately, a large number of companies still rely heavily on spreadsheets. Even those with expensive BI (Business Intelligence) systems still use spreadsheets as an ad-hoc tool for data processing and reporting.

Because compliance with Section 404 involves a significant amount of fixed costs, smaller companies tend to feel the impact more. This has been highlighted in the ?Final Report of the Advisory Committee on Smaller Public Companies? published on April 23, 2006. In that report, which can be downloaded from the official website of the US Securities and Exchange Commission, it was shown that:

Companies with over $5 Billion revenues spent only about 0.06% of revenues on Section 404 implementation
Companies with revenues between $1B – $4.9B spent about 0.16%
Companies with revenues between $500M – $999M spent about 0.27%
Companies with revenues between $100M – $499M spent about 0.53%
Companies with revenues less than $100M spent a whopping 2.55% on Section 404

Therefore, not only can you discern a relationship between the size of a company and the amount that the company ends up spending for SOX 404 relative to its revenues, but you can also clearly see that the unfavourable impact of Section 404 spending is considerably more pronounced in the smallest companies. Hence, the smaller the company is, the more crucial it is for that company to find ways that can bring down the costs of Section 404 implementation.

How to alleviate costs of section 404

If you recall the FEI survey mentioned earlier, it was shown that organisations with decentralised operations usually ended up spending more for SOX 404 implementation than those that had a more centralized model. Then in the ?Final Report of the Advisory Committee on Smaller Public Companies?, it was also shown that public companies with the smallest revenues suffered a similar fate.

Can we draw a line connecting those two? Does it simply mean that large spending on SOX affects two sets of companies, i.e., those that have decentralised operations and those that are small? Or can there be an even deeper implication? Might it not be possible that these two sets are actually one and the same?

From our experience, small companies are less inclined to spend on server based solutions compared to the big ones. As a result, it is within this group of small companies where you can find a proliferation of spreadsheet systems. In other words, small companies are more likely to follow a decentralised model. Spreadsheets were not designed to implement strict control features, so if you want to apply a control framework on a spreadsheet-based system, it won’t be easy.

For example, how are you going to conduct testing on every single spreadsheet cell that plays a role in financial reporting when the spreadsheets involved in the financial reporting process are distributed across different workstations in different offices in an organisation with a countrywide operation?

It’s really not a trivial problem.

Based on the FEI survey however, the big companies have already found a solution – employing a server-based system.

Typical server based systems, which of course espouse a centralised model, already come with built-in controls. If you need to modify or add more controls, then you can do so with relative ease because practically everything you need to do can be carried out in just one place.

For instance, if you need to implement high availability or perform backups, you can easily apply redundancy in a cost-effective way – e.g. through virtualisation – if you already have a server-based system. Aside from cost-savings in SOX 404 implementation, server-based systems also offer a host of other benefits. Click that link to learn more.

Not sure how to get started on a cost-effective IT compliance initiative for SOX? You might want to read our post How To Get Started With Your IT Compliance Efforts for SOX.?

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Mobile Workforce Management in a nutshell

It is fairly common for businesses to have staff working across many different locations across the country or even the world. Engaged in various activities like door-to-door sales, delivery and installations, service maintenance, conducting inspections & investigations or even data collection.

Managing and co-ordinating tasks, scheduling activities, planning and monitoring activities and communicating can often be challenging.

Mobile Workforce Management is the automation of the entire end-to-end workflow management and operations of any field service workers.

Mobile Workforce Management Synonyms

Mobile Workforce Management is also known as

Field Service Management
Job Scheduling Software
Job Management Software

Advantages of Mobile Workforce Management

It is increasingly clear that there needs to be a certain sense of discipline and streamlining of field operations and important to automate certain tasks within field sales and operations, primarily because it helps you to track your assets remotely and ensuring contact with your workforce when required. Enabling your team to get in touch when required.

Most importantly, engineers, sales representatives and customer care executives can easily send information, scan receipts, Invoice customers and retrieve other crucial information in a standardized and streamlined manner. Assisting in regulating your business and also bringing some order to what is usually a very chaotic mode of working.

Why choose Mobile Workforce Management

Work Force Management tools help you to stay in control. They assist in automating what can and should be automated leaving only the crucial human-human interactivity. Helping you to keep a record of all interactions and important data within a database, without you having to manually go through sales receipts, complaint slips and other such details.

A Field Force Management tool is a time-saver and efficiency tool for companies. Moreover, these tools help to automate several aspects of your day to day operations, leading to an increase in productivity and motivation.

Streamlining operations, will also ensure that important stakeholders are well informed and management visibility is enhanced. Helping your business to make smarter decisions and help serve your customers better.

Field Force Management is similar to an Enterprise Resource Planning (ERP) solution but is vastly different. It is specifically targeted at staff that work on the field and is intended to make their and your work more streamlined, transparent and easy to track.

Cloud based solutions help you automate

Field Force Management is usually cloud based which means all data is stored and accessible on secure cloud servers. There is no question of losing important data or not being able to retrieve something important. If something goes missing, there will usually be a backup available. Field force management tools include the software, the hardware and also the kind of training that is required for users to use it efficiently.

The software usually helps in saving and processing information while the hardware helps employees to enter important data into devices while they are on the job. Sometimes, field force solutions can also be a mobile app which negates the need for a specific or special device.

This is very important when it comes to field jobs as carrying different devices can prove to be a cumbersome job. At the end of the day, field force solutions are meant to reduce the burden on staff and not actually inadvertently increase it.

Denizon?s FieldElite Mobile Workforce management application provides significant improvements in efficiency and service with a switch to digital working and the elimination of paperwork.

All the information that is stored on the cloud can be run through analytics software so that you get the kind of reports that you are looking for to improve your business.

Field Force Management Process

A field force management tool helps you to remain in contact with your staff while they are at work on the field. This helps you to track your personnel in real time. Field personnel or your staff can log in and enter their attendance using a smartphone. You can assign that particular day?s task remotely using a web console or your own smartphone.

Next, they can carry out whatever duties they need to while you get all the alerts that you set to receive. This helps to increase transparency. You can choose to receive alerts on your phone or on your desktop.

Finally, staff can tag completed tasks with audio and images, instead of they having to type reports. This helps to focus more on the job than on job reporting. Last but not the least, location tags help you to ensure that the job is done at the right place. Your staff will not be able to take your generosity for granted.

All in all, a field force management tool helps you to track and control your staff without you having to be physically present with them and this is the beauty of this tool.

Summary

Field Force Management helps companies to reduce administration expense and improve productivity. This helps to automate data integration which is usually done with the help of cloud servers. Moreover, you can set invoice parameters that help you to also keep track of stocks, inventories and engage in P.O. and task management.

A number of field force management users also use it as a tool to engage in credit management. Banks and insurance companies particularly find this tool helpful as payments can be received on the job, instead of asking customers to pay online or offline. This also helps in building valuable customer relationships and enhance loyalty.

Thirdly, a field force management tool helps to increase planning efficiency. This means, you will be able to allocate tasks and optimize routing. All this helps to increase your ROI at the end of the day and get back the money you invest on field force management.

Finally, you will have more control over productivity and sales thanks to automation of data collection. You will also have more control over the execution of tasks and that will invariably make your company leaner and smarter.

Transformation to a process based organisation

Today’s global marketplace rewards nimble organisations that learn and reinvent themselves faster than their competition. Employees at all levels of these organisations see themselves as members of teams responsible for specific business processes, with performance measures tied to the success of the enterprise. As team members, they are “owners” of the process (or processes) to which they are assigned. They are responsible for both the day to day functioning of their process(s), and also for continuously seeking sustainable process improvements.

Transforming a traditionally designed “top down control” enterprise to a process-based organisation built around empowered teams actively engaged in business process re-engineering (BPR) has proven more difficult than many corporate leaders have expected. Poorly planned transformation efforts have resulted in both serious impacts to the bottom line, and even more serious damage to the organisation’s fabric of trust and confidence in leadership.

Tomislav Hernaus, in a publication titled “Generic Process Transformation Model: Transition to Process-based Organisation” has presented an overview of existing approaches to organisational transformation. From the sources reviewed, Heraus has synthesised a set of steps that collectively represent a framework for planning a successful organisational change effort. Key elements identified by Hernaus include:

Strategic Analysis:

The essential first step in any transformation effort must be development of a clear and practical vision of a future organisation that will be able to profitably compete under anticipated market conditions. That vision must be expected to flex and adjust as understanding of future market conditions change, but it must always be stated in terms that all organisational members can understand.

Identifying Core Business Processes:

With the strategic vision for the organisation in mind, the next step is to define the core business processes necessary for the future organisation to function. These processes may exist across the legacy organisation’s organisational structures.

Designing around Core Processes:

The next step is development of a schematic representation of the “end state” company, organised around the Core Business Processes defined in the previous step.

Transitional Organisational Forms/ Developing Support Systems:

In his transformation model, Hernaus recognises that information management systems designed for the legacy organisation may not be able to meet the needs of the process management teams in the new organisation. Interim management structures (that can function with currently available IT system outputs) may be required to allow IT professionals time to redesign the organisation’s information management system to be flexible enough to meet changing team needs.

Creating Awareness, Understanding, and Acceptance of the Process-based Organisation:

Starting immediately after the completion of the Strategic Analysis process described above, management must devote sufficient resources to assure that all organisation members, especially key managers, have a full understanding of how a process-based organisation functions. In addition, data based process management skills need to be provided to future process team members. It is not enough to schedule communication and training activities, and check them off the list as they are completed. It is critical that management set behavioural criteria for communication and training efforts that allow objective evaluation of the results of these efforts. Management must commit to continuing essential communication and training efforts until success criteria are achieved. During this effort, it may be determined that some members of the organisation are unlikely to ever accept the new roles they will be required to assume in a process-based organization. Replacement of these individuals should be seen as both an organisational necessity and a kindness to the employees affected.

Implementation of Process Teams:

After the completion of required training AND the completion of required IT system changes, process teams can be formally rolled out in a planned sequence. Providing new teams with part time support by qualified facilitators during the firsts weeks after start-up can pay valuable long term dividends.

Team Skill Development and Continuous Process Improvement:

Providing resources for on-going skill development and for providing timely and meaningful recognition of process team successes are two keys for success in a process-based organisation. Qualified individuals with responsibility for providing training and recognition must be clearly identified and provided with sufficient budgetary resources.

The Hernaus model for transformation to a process based organisation is both well thought out and clear. His paper provides an ample resource of references for further study.

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A Business Case for Sharing

We blogged about sharing services in a decentralised business context recently, and explained why we think why these should be IT-Based for speedy delivery. This is not to say that all shared services projects worldwide have been resounding successes. This is often down to the lack of a solid business case up front. We decided to lay out the logic behind this process.

Management Overview ? The overview includes a clear definition of why the current situation is unacceptable, the anticipated benefits of sharing, and an implementation plan were it to go ahead. The project should not proceed until the stakeholders have considered and agreed on this.

Alternatives Considered ? The next stage is to get closer to the other options in order to determine whether an alternative might perhaps be preferable. Substitutes for shared services are often doing nothing, improving the current method, and outsourcing the service to a third party.

The Bottom Line in Business ? Sharing services comes at an initial cost of infrastructure changes, and the impact on human capital (the latter deserves its own blog). The following need careful consideration from the financial angle:

Numbers to Work Through

Manpower to design and roll the project out in parallel with the existing organisation.

Capital for creating facilities at the central point including civil works, furniture and equipment and IT infrastructure.

The costs of travel, feeding and accommodation. These can be significant depending on the time that implementation takes.

The opportunity loss of diverting key staff – and the cost of temporary replacements – if appointing line staff to the project team.

Crystal-clear project metrics including (a) the direct, realisable savings (b) the medium and long-term effects on profit and (c) where to deploy the savings

Risk Management

Shared services projects don’t go equally smoothly, although planning should reduce the risk to manageable levels. Nonetheless it is important to imagine potential snags, decide how to mitigate them and what the cost might be.

We believe in implementing shared services on a pilot basis in the business unit that eventually provides them. We recommend building these out to other branches only when new processes are working smoothly.

Moving On From a Decision

We recommend you revisit your management overview, the logic behind it, the assumptions you made, and the costs and benefits you envisage before deciding to go ahead

The final step in proving a business case is doable should be fleshing out your roadmap into a detailed operations plan with dependencies on a spreadsheet.