Compliance Program Management

McCoy Power Consultants (MPC) can assist an entity with the development and evaluation of an internal compliance program, including the setup of your electronic compliance folder and file structure for the organization of compliance programs documents and evidence.

MPC also offers a monthly Compliance Monitoring and Reporting Program (CMRP) that will completely implement a Registered Entity’s compliance program. MPC provides a Reliability Standard service that monitors changes to future NERC Reliability Standards and advises Registered Entities on program and procedure changes that are necessary to implement future Reliability Standards.

MPC can fully develop a Registered Entities internal compliance program. MPC has templates that can develop a full program, including compliance program documents and specific Reliability Standard compliance templates.

Our Master Compliance Program Templates can easily be adapted to an entity’s specific program design and organization. Our templates include all of the elements that are required in Reliability Standard Audit Worksheets. When developing the program for an entity, MPC specifically attempts to implement program requirements that align with the Registered Entities current business practices.

Compliance Policy Statements (CPS) documents are the heart of a Registered Entity’s internal compliance program. MPC develops one CPS document for each Reliability Standard. The CPS includes a narrative of compliance and evidence lists for each requirement. The information in the CPS can easily be used to complete a NERC Reliability Standards Audit Worksheet when needed.

MPC will also develop, using MPC templates, an internal compliance training program for all involved personnel, as part of your internal compliance program, and will develop and deliver NERC Reliability Standard specific training to all involved SMEs. MPC can tailor this training to the specific size and needs of your company.

Organization of compliance evidence files is the most critical step any Registered Entity can implement to ensure compliance with the NERC Reliability Standards. MPC has developed a detailed compliance program file structure template that can be customized and implemented for any Registered Entity.

Our file structure includes organization for the filing of FERC, NERC, Regional Entity and the Registered Entity’s program and documents and detailed folder / file structure for filing evidence for each Reliability Standard. This folder / file structure, when used in conjunction with the evidence lists developed in the CPS documents, allows for an easy format and organization for completing periodic internal compliance reviews for each Reliability Standard.

Most Registered Entities have set up internal compliance programs to regularly monitor compliance with the Reliability Standards. The Regional Entities have developed specific evaluation criteria to evaluate a Registered Entity’s program.

If a Registered Entity has a violation, its internal compliance program can help mitigate penalties or sanctions. The “credit” given for an internal compliance program is based on the Region’s evaluation of your program. Credit for self-reporting a violation and the quality of your internal compliance program can be the two most important factors in reducing a penalty or sanction.

MPC will evaluate your program using the Regional criteria. As part of the evaluation, MPC will provide feedback on suggested improvements that should be made to your internal compliance program.

Registered Entities now carry the responsibility of maintaining compliance with the NERC and Regional Reliability Standards. With this responsibility comes an enormous investment of time and financial resources. An even greater challenge is finding qualified employees to oversee and understand the complicated process of maintaining a current compliance program within an industry where the Reliability Standards are still developing and violations come with a hefty price.

A Registered Entity cannot risk a faltering internal compliance program or an audit with violations. However, there is a solution that can save a company time, staff resources and thousands of dollars in penalties and violations.

The MPC Compliance Monitoring and Reporting Program (CMRP), provides compliance monitoring for the Registered Entity and relieves the Registered Entity of many day-to-day compliance responsibilities; such as, internal compliance monitoring, monitoring of Regional compliance web portals, preparation and submittal of mandatory compliance reports, monitoring new, and revisions to, NERC Reliability Standards, monitoring changes to NERC and Regional compliance programs and industry updates regarding compliance matters. The MPC CMRP is designed in a modular format and can be custom designed to meet the needs of your company. All activities under the CMRP are addressed and the status is tracked and provided in a Monthly Report to the Registered Entity.

MPC offers evaluation of any company’s implementation of their procedures and programs. From this evaluation, MPC can help the company develop and implement processes and controls to ensure that procedures and programs are implemented by system operators, system planners and maintenance personnel. Correct implementation of procedures and programs can lead to increased reliability and ensure that adequate compliance evidence is maintained to demonstrate compliance with the NERC Reliability Standards.

A Root Cause Analysis (RCA) is typically used as a reactive method of identifying event(s) causes, revealing problems and solving them. Analysis is done after an event has occurred. Insights in RCA may make it useful as a preemptive method to prevent future similar issues or events.

MPC can conduct a root cause analysis for a company for a wide variety of issues or events. The results of the root cause analysis will then be used to improve a company’s business processes. In addition, an RCA can be useful in determining the cause of a NERC Reliability Standard violation.