Assessments

Today's energy companies are facing the most intense governmental scrutiny of their operations than at any time in the history of the industry. Particularly difficult is the regulatory environment, determining whether certainty and consistency exists at the compliance implementation level. The answer has been disappointing for many companies because not many organizations tend to broadcast their compliance practices. FERC's rulings are often confusing and most industry associations have only taken a minimal, piecemeal approach to responding to FERC. ProComply has developed the first, state-of-the-art, risk-based approach to managing the risks associated with complying with FERC rules.

Our Assessment Services are based on three specific product offerings:

Audits — ProComply conducts a full third-party audit, including Data Requests, Interviews and Inspections. The major differences between a FERC audit and a ProComply audit include:

a. FERC audits for specific rule elements, ProComply audits are across-the-board;

b. FERC will almost always find something that needs to be "fixed" when they come to visit;

c. FERC uses inconsistent compliance standards, depending on which enforcement personnel are assigned; ProComply gauges compliance across a spectrum of possible compliance conditions;

d. The company can implement corrective actions on their own terms and not as prescribed by regulators.

Assessments — Less formal than an Audit, a ProComply assessment includes recommendations for corrective actions or implementation of Best Practices. From working with hundreds of industry personnel, our library of risk-based compliance measures includes cost-efficient practices that are designed to minimize personnel distraction from core duties, while maintaining company compliance policies. We can also train our client's internal audit personnel on how to conduct annual audits.

Surveys — ProComply can spot-check certain compliance areas or perform a quick evaluation of a company's compliance program. The Survey can gauge whether a company might need immediate corrective action in particular areas of concern.

How a ProComply Assessment Works

The assessment process includes the following steps:

ProComply meets with company regulatory and operational staff and develops an Assessment Plan;
ProComply develops and delivers an Initial Data Request, similar to the ones used by FERC;
After company personnel have delivered responses to the Data Requests, ProComply follows up with on-site interviews and facility inspections (when necessary);
Concluding the data collection process, ProComply analyzes the company's compliance status against a set of compliance criteria and standards;
ProComply delivers a Final Report that includes the findings of the assessment.

Remember: If you haven't conducted a purposeful compliance assessment of all of the individual elements of FERC rules, you cannot state with informed certainty that your company is complying with FERC rules.