ERO Compliance Enforcement Authority Staff Training
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1 ERO Compliance Enforcement Authority Staff Training
2 Vision Comprehensive ERO CEA staff training program that promotes high quality and consistency in the conduct of audits The methods to accomplish the vision Common training distance learning and classroom On-the-job training (OJT) Continuing education workshops Regional specific needs 2 RELIABILITY ACCOUNTABILITY
3 Key Points Not burdensome or bureaucratic Consider providing CEH credit Incorporate FFT experience as it develops Engage with regional compliance and training staffs Improve online delivery for more engagement, better content and scheduling flexibility 3 RELIABILITY ACCOUNTABILITY
4 Auditor Curriculum Fundamentals for CEA auditors Advanced Audit Training for Team Leaders and Audit Managers Compliance Investigations Critical Infrastructure Protection Auditor Mitigation Plans and Risk Assessment Compliance Enforcement Initiative Training 4 RELIABILITY ACCOUNTABILITY
5 What s new? Reference point is current Auditor Fundamentals training More emphasis on performance application exercises, assignments, use of tools for audit deliverables Updated content vs version Better content and delivery Expanded topics/components CEI Standards reliability standards, auditing standards Soft Skills Introduction to BPS (optional based on need) 5 RELIABILITY ACCOUNTABILITY
6 Implementation Initial Auditor Training - knowledge, skills to conduct audit ERO background; Principles and standards for Auditing - GAGAS Planning, Fieldwork and Audit Reporting/follow-up Team and Entity communications; interviewing skills; managing relationships Application of Standards Practicals - Conduct of audit OJT Qualification guide for key tasks Intro to BPS (if needed, based on experience) o Options online NERC provided; classroom NERC provided; Regional Entity provided 6 RELIABILITY ACCOUNTABILITY
7 Updating Auditor Fundamentals Focus on performance Update the program Short term quick fix to existing content on DAC Better delivery with D2L distance learning platform o Improve content and participant engagement Review, update, and develop training materials NERC & Regional Entity input, review, comment o Regional Compliance reps o ERO Training & Education Group 7 RELIABILITY ACCOUNTABILITY
8 D2L Distance Learning Platform 8 RELIABILITY ACCOUNTABILITY
9 Key milestones Program description Learning objectives and activities/exercises Develop content Use best available Develop new materials Regional entity review, comment during development Pilot the training Adjust and finalize Communicate the changes 9 RELIABILITY ACCOUNTABILITY
10 Audit Team Leader Course Content Authority and responsibilities in conducting a compliance audit GAGAS auditing standards and their application to ERO compliance audits Maintaining independence during an audit ERO compliance audit process and FFT Roles and Responsibilities of Observers CANs and CARs NERC Directives, Alerts and Bulletins Internal Compliance Program Information gathering methods The audit report Interviewing techniques and conflict management (dealing with differing viewpoints and goals for successful outcome) References and audit tools 10 RELIABILITY ACCOUNTABILITY
11 Audit Team Leader Instructor led, conducted quarterly Feb SERC May SPP Aug RFC Oct NERC Add/offer one or two day add-on for vendor provided communications/conflict management course Improve interviewing skills module Add more engagement/activities during the course Input from Team Leaders, Compliance Managers 11 RELIABILITY ACCOUNTABILITY
12 Summary and Next Steps Complete the auditor training program improvements Course topics, learning objectives and delivery methods Regional review and comment along the way Begin revised training by the end of 2Q12 Auditor is first priority CEI is parallel effort 12 RELIABILITY ACCOUNTABILITY
13 Compliance Enforcement Initiative Training January 2012
14 Background and Purpose of the Compliance Enforcement Initiative Refocus efforts on reliability excellence, eliminate undue regulatory burdens, streamline paperwork requirements, and encourage continued timely and thorough selfreporting and mitigation. Differentiates issues of noncompliance based on the level of potential risk to the reliability of the bulk power system. All instances of noncompliance will continue to be identified and mitigated.. Matters that pose a lesser risk to reliability will be processed on a find, fix, track and report spreadsheet that will be submitted on a monthly basis to FERC as an informational filing. 14 RELIABILITY ACCOUNTABILITY
15 Implementation Timeline Phase I Begin September 2011 Possible Violations identified in all compliance monitoring methods qualify for FFT consideration Phase II Late 2012 or 2013 CEA auditors make FFT determinations in the field for PVs CEA Enforcement staff determinations for other monitoring methods 15 RELIABILITY ACCOUNTABILITY
16 Training & Education Frequent Communications to inform ERO and Industry Webinars for ERO and Registered Entities o October, December, February, April Webinars following 6 month and one-year filings o Regional and Registered Entity updates o Auditor informational update May-June Workshop opportunities Standards & Compliance Workshop October 11 Regional Staff CEI Workshop November 11 CEA Staff Workshop February, October RELIABILITY ACCOUNTABILITY
17 Training & Education Training activities Added to quarterly Audit Team Leader course beginning November 11 Include in Basic Auditor on-line course in 2012 CEI online course for all Team Leaders & Auditors Includes process improvements, lessons learned from 6 month report Allow for process to mature Begin training prior to Phase II implementation Required completion prior to Phase II audit participation 17 RELIABILITY ACCOUNTABILITY
18 CEI Course Outline Purpose, background Program guidance and process description FFT decision process and guidance Sufficiency of evidence and documentation commensurate with risk Mitigation actions Completing FFT report and final disposition Examples/case studies Course completion evaluation 18 RELIABILITY ACCOUNTABILITY
19 Summary Auditor training improvements focus for 2012 CEI training in 2012 for new team process We want your input on gaps, best practices 19 RELIABILITY ACCOUNTABILITY
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