Spreadsheet Woes – Burden in SOX Compliance and Other Regulations

End User Computing (EUC) or end User Developed Application (UDA) systems like spreadsheets used to be ideal ad-hoc solutions for data processing and financial reporting. But those days are long gone.

Today, due to regulations like the:

Sarbanes-Oxley (SOX) Act,
Dodd-Frank Act,
IFRS (International Financial Reporting Standards),
E.U. Data Protection Directive,
Basel II,
NAIC Model Audit Rules,
FAS 157,
yes, there?s more ? and counting

a company can be bogged down when it tries to comply with such regulations while maintaining spreadsheet-reliant financial and information systems.

In an age where regulatory compliance have become part of the norm, companies need to enforce more stringent control measures like version control, access control, testing, reconciliation, and many others, in order to pass audits and to ensure that their spreadsheets are giving them only accurate and reliable information.

Now, the problem is, these control measures aren’t exactly tailor-made for a spreadsheet environment. While yes, it is possible to set up a spreadsheet and EUC control environment that utilises best practices, this is a potentially expensive, laborious, and time-consuming exercise, and even then, the system will still not be as foolproof or efficient as the regulations call for.

Testing and reconciliation alone can cost a significant amount of time and money to be effective:

It requires multiple testers who need to test spreadsheets down to the cell level.
Testers will have to deal with terribly disorganized and complicated spreadsheet systems that typically involve single cells being fed information by other cells in other sheets, which in turn may be found in other workbooks, or in another folder.
Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
Because Windows won’t allow you to open two Excel files with the same name simultaneously and because a succession of monthly-revised spreadsheets separated by mere folders but still bearing the same name is common in spreadsheet systems, it would be difficult to compare one spreadsheet with any of its older versions.

But testing and reconciliation are just two of the many activities that make regulatory compliance terribly tedious for a spreadsheet-reliant organisation. Therefore, the sheer intricacy of spreadsheet systems make examining and maintaining them next to impossible.

On the other hand, you can’t afford not to take these regulations seriously. Non-compliance with regulatory mandates can have dire consequences, not the least of which is the loss of investor confidence. And when investors start to doubt the management’s capability, customers will start to walk away too. Now that is a loss your competitors will only be too happy to gain.

Learn more about our server application solutions and discover a better way to comply with regulations.

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Why Predictive Maintenance is More Profitable than Reactive Maintenance

Regular maintenance is needed to keep the equipment in your facility operating normally. All machinery has a design lifespan, and your goal is to extend this as long as possible, while maintaining optimal production levels. How you go about the maintenance matters, from routine checks to repairing the damaged component parts?all before the whole unit needs to be tossed away and a new one purchased and installed. Here, we will break down the different approaches used, and show you why more industries and businesses are turning to proactive maintenance modes as opposed to the traditional reactive approaches for their?field service operations.?

Reactive Maintenance: A wait and see game

Here, you basically wait for a problem to occur, then fix it. It’s also commonly referred to as a “Run-to-Failure” approach, where you operate the machines and systems until they break. Repairs are then carried out, restoring it to operational condition.?

At face value, it appears cost-effective, but the reality on the ground is far much different. Sure, when the equipment is new, you can expect minimal cases of maintenance. During this time, there?ll be money saved. However, as time progresses there?ll be increased wear, making reliance on a reactive maintenance approach a costly endeavour. The breakdowns are more frequent, and inconsistent as well. Unplanned expenses increase operational costs, and there will be lost productivity during the periods in which the affected machinery won’t be in operation.?

While reactive maintenance makes sense when you’re changing a faulty light bulb at home, things are more complicated when it comes to dealing with machinery in industries, or for those managing multiple residential and commercial properties. For the light bulb, it’s easier to replace it, and failure doesn’t have a ripple effect on the rest of the structures in the household. For industries, each time there is equipment failure, you end up with downtime, production can grind to a halt, and there will be increased environmental risks during equipment start-up and shutdown. If spare parts are not readily available, there will be logistical hurdles as you rush the shipping to get the component parts to the facility. Add this to overworked clients in a bit to complete the repair and to make up for lost hours and delayed customer orders.

For field service companies, more time ends up being spent. After all, there?s the need of knowing which parts needed to be attended to, where they are, and when the servicing is required. Even when you have a planned-out schedule, emergency repairs that are required will force you to immediately make changes. These ramps up the cots, affecting your operations and leading to higher bills for your client. These inconveniences have contributed to the increased reliance on?field service management platforms that leverage on data analytics and IoT to reduce the repair costs, optimise maintenance schedules, and?reduce unnecessary downtimes?for the clients.

Waiting for the machinery to break down actually shortens the lifespan of the unit, leading to more replacements being required. Since the machinery is expected to get damaged much sooner, you also need to have a large inventory of spare parts. What’s more, the damages that result will be likely to necessitate more extensive repairs that would have been needed if the machinery had not been run to failure.?

Pros of reactive maintenance

Less staff required.
Less time is spent on preparation.

Cons of reactive maintenance

Increased downtime during machine failure.
More overtime is taken up when conducting repairs.
Increased expenses for purchasing and storing spare parts.?
Frequent equipment replacement, driving up costs.?

This ?If it ain’t broke, don’t fix it? approach leads to hefty repair and replacement bills. A different maintenance strategy is required to minimise costs. Proactive models come into focus. Before we delve into predictive maintenance, let’s look at the preventive approach.?

Preventive Maintenance: Sticking to a timetable

Here, maintenance tasks are carried out on a planned routine?like how you change your vehicle?s engine oil after hitting a specific number of kilometres. These tasks are planned in intervals, based on specific triggers?like a period of time, or when certain thresholds are recorded by the meters. Lubrication, carrying out filter changes, and the like will result in the equipment operating more efficiently for a longer duration of time. While it doesn’t completely stop catastrophic failures from occurring, it does reduce the number of failures that occur. This translates to capital savings.??

The Middle Ground? Merits And Demerits Of Preventive Maintenance

This periodic checking is a step above the reactive maintenance, given that it increases the lifespan of the asset, and makes it more reliable. It also leads to a reduced downtime, thus positively affecting your company?s productivity. Usually, an 80/20 approach is adopted,?drawing from Pareto’s Principle. This means that by spending 80% of time and effort on planned and preventive maintenance, then reactive maintenance for those unexpected failures that pop up will only occur 20% of the time. Sure, it doesn’t always come to an exact 80/20 ratio, but it does help in directing the maintenance efforts of a company, and reducing the expenses that go into it.?

Note that there will need to be a significant investment?especially of time, in order to plan a preventive maintenance strategy, plus the preparation and delegation of tasks. However, the efforts are more cost effective than waiting for your systems and machinery to fail in order to conduct repairs. In fact, according to the US Dept. of Energy, a company can save between 12-18 % when using a preventive maintenance approach compared to reactive maintenance.

While it is better than the purely reactive approach, there are still drawbacks to this process. For instance, asset failure will still be likely to occur, and there will be the aspect of time and resource wastage when performing unneeded maintenance, especially when technicians have to travel to different sites out in the field. There is also the risk of incidental damage to machine components when the unneeded checks and repairs are being carried out, leading to extra costs being incurred.

We can now up the ante with predictive maintenance. Let’s look at what it has to offer:

Predictive Maintenance: See it before it happens

This builds on preventive maintenance, using data analytics to smooth the process, reduce wastage, and make it more cost effective. Here, the maintenance is conducted by relying on trends observed using data collected from the equipment in question, such as through vibration analysis, energy consumption, oil analysis and thermal imaging. This data is then taken through predictive algorithms that show trends and point out when the equipment will need maintenance. You get to see unhealthy trends like excessive vibration of the equipment, decreasing fuel efficiency, lubrication degradation, and their impact on your production capacities. Before the conditions breach the predetermined parameters of the equipment’s normal operating standards, the affected equipment is repaired or the damaged components replaced.??

Basically, maintenance is scheduled before operational or mechanical conditions demand it. Damage to equipment can be prevented by attending to the affected parts after observing a decrease in performance at the onset?instead of waiting for the damage to be extensive?which would have resulted in system failure. Using?data-driven?field service job management software will help you to automate your work and optimise schedules, informing you about possible future failures.

Sensors used record the condition of the equipment in real time. This information is then analysed, showing the current and future operational capabilities of the equipment. System degradation is detected quickly, and steps can be taken to rectify it before further deterioration occurs. This approach optimises operational efficiency. Firstly, it drastically reduces total equipment failure?coming close to eliminating it, extending the lifespan of the machinery and slashing replacement costs. You can have an orderly timetable for your maintenance sessions, and buy the equipment needed for the repairs. Speaking of which, this approach minimises inventory especially with regards to the spare parts, as you will be able to note the specific units needed beforehand and plan for them, instead of casting a wide net and stockpiling spare parts for repairs that may or may not be required. Repair tasks can be more accurately scheduled, minimising time wasted on unneeded maintenance.??

Preventive vs Predictive Maintenance?

How is predictive different from preventive maintenance? For starters, it bases the need for maintenance on the actual condition of the equipment, instead of a predetermined schedule. Take the oil-change on cars for instance. With the preventive model, the oil may be changed after every 5000?7500 km. Here, this change is necessitated because of the runtime. One doesn’t look at the performance capability and actual condition of the oil. It is simply changed because “it is now time to change it“. However, with the predictive maintenance approach, the car owner would ideally analyse the condition of the oil at regular intervals- looking at aspects like its lubrication properties. They would then determine if they can continue using the same oil, and extend the duration required before the next oil change, like by another 3000 kilometres. Perhaps due to the conditions in which the car had been driven, or environmental concerns, the oil may be required to be changed much sooner in order to protect the component parts with fresh new lubricant. In the long run, the car owner will make savings. The US Dept. of Energy report also shows that you get 8-12% more cost savings with the predictive approach compared to relying on preventive maintenance programs. Certainly, it is already far much more effective compared to the reactive model.?

Pros of Predictive Maintenance

Increases the asset lifespan.
Decreases equipment downtime.
Decreases costs on spare parts and labour.
Improves worker safety, which has the welcome benefit of increasing employee morale.
Optimising the operation of the equipment used leads to energy savings.
Increased plant reliability.

Cons of Predictive Maintenance

Initial capital costs included in acquiring and setting up diagnostic equipment.
Investment required in training the employees to effectively use the predictive maintenance technology adopted by the company.

The pros of this approach outweigh the cons.?Independent surveys on industrial average savings?after implementing a predictive maintenance program showed that firms eliminated asset breakdown by 70-75%, boosted production by 20-25%, and reduced maintenance costs by 25-30%. Its ROI was an average of 10 times, making it a worthy investment.

The Matrix Management Structure

Organizations exploit matrix management in various ways. A company, for instance, that operates globally uses it at larger scale by giving consistent products to various countries internationally. A business entity, having many products, does not assign its people to each product full-time but assign those to different ones on a part time basis, instead. And when it comes to delivering high quality and low cost products, companies overcome industry pressures with the help of many overseeing managers. In a rapidly changing environment, organizations respond quickly by sharing information through a matrix model.

Understanding the Matrix Management Structure

A basic understanding of matrix management starts with the three key roles and responsibilities that applies in the structure.

Matrix Leader ? The common person above all the matrix bosses is the matrix leader. He ensures that the balance of power is maintained in the entire organization by delegating decisions and promoting collaboration among the people.
Matrix Managers ? The managers cooperate with each other by defining the respective activities that they are responsible for.

Matrix Employees – The employees have lesser direct authority but has more responsibilities. They resolve differing demands from more than one matrix managers while they work things out upwards. Their loyalty must be dual and their relationships with managers must be maintained.

Characteristics of a Matrix Structure

Here are some features that define the matrix management structure:

Hybrid Structure ?The matrix structure is a mix of functional and project organization. Since it is a combination of these two, matrix management is hybrid in nature.

Functional Manager ? When it comes to the technical phases of the project, the functional manager assumes responsibility. The manager decides on how to get the project done, delegates the tasks to the subordinates and oversees the operational parts of the organization.

Project Manager ? The project manager has full authority in the administrative phases, including the physical and financial resources needed to complete the project. The responsibilities of a project manager comprise deciding on what to do, scheduling the work, coordinating the activities to diverse functions and evaluating over-all project performance.

Specialization ?As the functional managers concentrate on the technical factors, the project managers focus on administrative ones. Thus, in matrix management, there is specialization.

Challenge in Unity of Command ? Companies that employs matrix management usually experience a problem when it comes to the unity of command. This is largely due to the conflicting orders from the functional and project managers.

Types of Matrix Structure

The matrix management structure can be classified according to the level of power of the project manager. Here are three distinct types of matrix structures that are widely used by organizations.

Weak Matrix ? The project manager has limited authority and power as the functional manager controls the budget of the project. His role is only part-time and more like a coordinator.

Strong Matrix ? Here, the project manager has almost all the authority and power. He controls the budget, holds the full time administrative project management and has a full time role.

Balanced Matrix ? In this structure type, both the project and functional managers control the budget of the project. The authority and power is shared by the two as well. Although the project manager has a full time role, he only has a part time authority for the administrative staff to report under his leadership.

Successful companies of today venture more on enhancing the abilities, skills, behavior and performances of their managers than the pursuit of finding the best physical structure. Indeed, learning the fundamentals of the matrix structure is essential to maximize its efficiency. A senior executive pointed out that one of the challenges in matrix management is not more of building a structure but in creating the matrix to the mind of the managers. This comes to say that matrix management is not just about the structure, it is a frame in the mind.

How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

that you have reviewed the report;
that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
that you are responsible for establishing internal controls over financial reporting; and
that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud