Think of Sarbanes-Oxley as the catalyst we all need to finally get our reporting, analysis, and decision-support systems where they should be. Keep in mind that the long-term mission is to evolve this effort into an effective enterprise performance-management capability. Here's a plan to get you started:
First month: Increase the urgency
Obtain agreement from the executive team to conduct a "current state" corporate-accountability review. Have some anecdotal but credible evidence that everything isn't perfect and that you'll need to do better. Define the organization and process scope of the review. Focus on areas that need immediate attention and offer significant possible rewards. Do these first and use the experience to help fix other areas later.
Interview representatives throughout the company to get an accurate account of the nonfinancials that impact your business. Existing literature offers good ideas on where to start. Gather financial documentation; look for areas that are weak, out of date, or lacking in rich analytics.
Examine data-handling processes for potential problem areas that could impede real-time transparency—areas where extensive manual recoding or reconciliation is required or where only highly summarized information is available without effective links back to the original transactions. Look for prototype opportunities among the financial-reporting systems that are deemed most trustworthy and timely. If some things are working well, ask why everything isn't working as well as those examples of best practices.
Launch a communications campaign to get everyone thinking about what needs to be done.
Second month: Begin prototyping
Interview key process owners to see what they use—and need but don't have—to make the decisions that affect operational performance. Use the interview process to sustain the "this is for real" message.
Complete the current-state analysis and realistically assess the priorities for immediate action, the risks of not taking action, and the costs. Be sure to keep the rest of the executive team in the loop.
Work with the CFO to build a prototype reporting process on a manageable scale to see the unexpected consequences of literal versus "above and beyond" Sarbanes-Oxley compliance. Using the prototype, assess how fast you can bring the area under review into compliance.
Draw up an improvement plan, including systems work, process change, data cleanup, and training. Consider getting input from external groups with an interest in the outcome. And give the board progress reports.
Third month: Think big
Start thinking about how to scale the prototype out to more processes or business units and "up" into a more thorough analysis. Look at where the company needs continuous rather than periodic reports. If you don't use corporate dashboards, think about what one should look like, who should see it, and what it could be used for.
Keep up the communications and training efforts for line executives and business decision makers, and monitor whether they're really using the tools and information you're making available to them.
Present your findings to the CFO, the executive team, and possibly the board.
