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 reliability standards and advises Registered Entities on program and procedure changes that are necessary to implement future standards.
Compliance Program Development and Training
MPC can fully develop a Registered Entities internal compliance program. We have templates that can develop a full program, including compliance program documents and standard specific compliance templates.
Our Master Compliance Program Templates can be easily adapted to an entities specific program design and organization. Our templates include all of the elements that are required by the regional Compliance Program Audit Worksheets (CPAWs). When developing the program for an entity, MPC specifically attempts to implement program requirements that align with the Registered Entities current business practices.
The Compliance Evidence Methodology (CEM) documents are the heart of a Registered Entities internal compliance program. MPC develops one CEM document for each Reliability Standard.
MPC will also develop, using MPC templates, an internal compliance training program to all involved personnel, as part of your internal compliance program, and will develop and deliver Reliability Standard specific training to all involved SMEs. MPC can tailor this training to the specific size and needs of your company.
Document and File Management
Organization of compliance evidence files is the most critical step any Registered Entity can implement to ensure compliance with the 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, RRO and the Registered Entities 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 CEM documents, allows for an easy format and organization for completing periodic internal compliance reviews for each Reliability Standard.
Compliance Program Evaluation
Most Registered Entities have set up internal compliance programs to regularly monitor compliance with the standards. The Regional Reliability Organizations have developed specific evaluation criteria in the form of a Compliance Program Audit Worksheet (CPAW), to evaluate a Registered Entities program. The CPAW uses a fairly rigid grading scale. A near perfect score is necessary to receive the highest program evaluations.
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 regions evaluation of your program using the CPAW. 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.
Compliance Program Management
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 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 constant 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, 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.
Reliability Standards Updates
All NERC and Regional Reliability Standards are currently under some form of revision. Many of the revisions are based on direct and detailed FERC instructions. As existing standards are revised or new standards implemented, a Registered Entity must update many programs, procedures, evidence files and subject matter expert training. The MPC Monthly Standards Report can provide the Registered Entity with an insight to the status of future standards changes that will affect the Registered Entity and allow for necessary changes to be implemented before the new or revised standards become effective.