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Audit Readiness: Preparing for the Inevitable

Disclaimer: MRO is committed to providing non-binding guidance to industry stakeholders on important industry topics. Subject matter experts from MRO’s organizational groups have authored some of the articles in this publication, and the opinion and views expressed in these articles are those of the author(s) and do not necessarily represent the opinions and views of MRO. The following article was written by Jamison Cawley, Reliabllity Compliance Engineer, from Nebraska Public Power District..

Audit Preparation is Part Science, Part Art

When I was a teenager, back in the mid-1980’s, I remember a family gathering during which my cousin revealed that he had been selected for an IRS audit. I remember the dread that all the adults expressed when they heard about it. Condolences were shared, as if he had lost a friend: “I’m so sorry to hear that, your secret’s safe with me”. I wasn’t familiar with audits, taxes, investing, or laws. I didn’t understand being an adult, but I surely knew now that audits weren’t a good thing. Like car accidents, they were to be avoided if possible.

This feeling is human nature. The next time you’re with a group of people, suggest that you might be the subject of an upcoming audit. Gauge the reaction. In my experience, the majority will express condolences, like they did for my cousin. In our line of work, we’re used to having an audit every few years, so we grow accustomed to them. Even so, if you’re like me, you still get a bit of a knot in your stomach when the notification arrives. But ultimately, it’s just another day at the office. For many of our Subject Matter Experts (SMEs), though, very real anxiety arises when they learn that the standard for which they’re responsible is included in audit scope.

Because human emotions are involved, the act of preparing everyone for an audit is a little bit science and a big part art. In our industry, our SMEs are top-notch. They know their standards backward and forward, and they know their day-to-day work even better. This should not be a surprise: our SMEs are selected for their technical prowess. They’re competent, organized, and understand how to maintain compliance. But those qualities don’t mean they’re going to be able to communicate well under the stress of an audit interview. As compliance professionals we should do our best to help our SMEs prepare for what is possibly the most stressful thing they’ll do all year: participate in an interview with an audit team. After all, the thought of failure in an audit may be quite extreme, at least in their mind. “If they find a mistake, and if I made it, I’ll surely get fired.” It may be an extreme and unreasonable thought, but it’s still a real thought.

As part of audit preparations, we should work with our SMEs in anticipation of audit interviews. During this work we might try to keep a few things in mind, based on the specific SME with whom we’re working. Some have been in high-stress situations in the past: workshop presentations, executive-level meetings, public town halls, or question-and-answer sessions, and previous audit interviews are some events that may influence their stress. These folks fall into a “seasoned” category and are typically less apprehensive. Other SMEs, perhaps new to the job, may not have had similar experiences, and sitting down in front of a team of auditors might be their first taste in the spotlight in a professional setting. These are more “unseasoned” SMEs who may need additional help before the interview. Both seasoned and unseasoned individuals have characteristics that might need some attention.

The Seasoned SME

While experience in audits is generally a benefit, it may be cause for concern as well. Deep knowledge of and passion for a subject might unintentionally come out as a sense of superiority or arrogance. This can be hard to coach someone through, but it should be done because the affliction is off-putting. Past success in any situation may foster in someone a false sense of security, or worse, inattention to detail. We can tend to become complacent in situations where we’ve experienced success. This false sense of security might lead to a lack of preparation. Conversely, if we experience something negative in a situation, we might be apprehensive about the negative experience repeating itself. If a person experienced a near-drowning event as a child, they may be fearful of water for the rest of their lives. It stands to reason that audit experiences can be similar.

The Unseasoned SME

The unseasoned SME can also have issues that need to be addressed. If we have very little experience with something that’s stressful, our amygdala may trigger a fight or flight response, which can be very hard to suppress during the interview. The awkward mannerisms associated with this discomfort may appear to be confusion or cluelessness about the topics of discussion. The stress chemicals may manifest as irritability, rudeness, or speech patterns that project a less-than-stellar level of knowledge and command of the material. We may project demeaning arrogance as part of our subconscious defense mechanism.

As you can see, there are several risks that, if realized, could taint an audit interview based simply on the personal characteristics and quirks of the people participating. So, what can we do to guard against these individual behaviors? We must dip our toes into the pool of psychology.

Audit Preparation Strategies

I have a mentor who’s retired from the Air Force. During a conversation one day, as he was sharing with me how his military experience benefited him, he said, “the military is good at taking you out of your comfort zone.” This, he shared, was great for his personal growth. This reinforced something I already knew: the best way to strengthen something is to stress it. One way to prepare for the stress of an interview is, well, to have a stressful interview! A mock audit is an opportunity to place someone in a situation to help them grow.

If you choose to conduct a mock audit, consider making it less than easy. We’re not looking to push too hard, but it should be representative of what might be experienced in a real interview. You could enlist the help of someone unknown to the subject to act as the auditor, possibly one of the members of your Internal Audits Department. Things might become uncomfortable in the real audit, and you want the subject to understand that. It’s also good to know how our SMEs react to stress; will they become talkative, combative, guarded? As stated, though, we can’t push too hard. A very wise man once said, “whole life is balance, Daniel-San.” We’re not trying to start a fight or get someone to throw up their hands in frustration, we just want to help them best prepare for what’s to come. This strategy must be balanced between silky and abrasive. Explain this to them before and after the mock audit, and things should go smoothly.

Another way we can provide value during an audit is to be present during the interview, to provide support and oversight. Support as a familiar face providing some comfort for a potentially uncomfortable colleague. Oversight to ensure the interview doesn’t go off the rails, which can happen if some of the traits mentioned earlier take over. It’s also a good idea, if possible, to have a trained auditor present. Auditors understand each other, and they have a language that many of us don’t speak.

Training, in addition to mock audits, is valuable and worthwhile. The folks on the interview list, as well as those who might be called as part of follow-up interviews, should be briefed on good standard practices to keep in mind. Things like being organized and prepared, mindful of appropriate body language, and gaining agreement on actions to be taken if a question is not clearly understood or outside the SME’s area of expertise: ask the auditor to repeat the question. If it’s still unclear, ask the auditor to restate the question. Finally, if the answer to the question is still not clear, it might be time for a caucus, or recess, to discuss with others who might better understand the question. These are the “three R’s”: repeat – restate – recess. Ultimately, the question must be understood clearly before any response is provided.

Only one question at a time should be considered. Too many questions in play at a time can get confusing. And everyone should remember that an interview isn’t an auction. If you’ve ever been a bidder during a live auction, you know how exciting things can get. It’s easy to be caught up in the action when your adrenaline begins to flow, and before you realize it, your bid is more than you want to spend. Just between you and me, I was so excited at my first auction I outbid myself! We have to do everything we can to make sure that nobody experiences emotions like these during an interview.

Silence can be uncomfortable. I’ve heard radio personalities state that silence during a broadcast is called, “dead air”, because it’s deadly. Silence is a tool that’s used frequently by interviewers because people are inherently uncomfortable in it. It’s often filled with information beyond the topic of conversation. You should try using it with someone today – ask a friend a question about something they’re passionate about and intentionally leave gaps of silence. Pay attention to the information they share, and I’ll bet you a nickel that they share things outside the scope of your question.

Finally, if the interview is virtual (as so many of them are these days), have a communications plan in place for you and your colleagues. If you can’t all be in the same room, have a process in place if a caucus is necessary. This way, if anyone on your team needs to request a recess from the interview, all the people in the caucus will know how to communicate with each other.

I’m sure there are other ways to prepare for an audit that I haven’t mentioned, but hopefully some of the tips in this article have sparked ideas that you can use to improve your next audit experience.

About the Author

Jamison Cawley

Jamison Cawley has been with Nebraska Public Power District (NPPD) in various roles since February 2000, and has worked in NPPD’s Reliability Compliance group for over ten years. He collaborates with NPPD Subject Matter Experts (SMEs) focused on NERC Operations & Planning (O&P) standards at NPPD’s power plants and transmission facilities to ensure compliance with NERC standards. Jamison has participated in four successful on-site compliance audits, and has teamed with SMEs to prepare for those audits and compile evidence of compliance for in-scope requirements.