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Regulatory & Audit Response

A finding with a deadline. Closed on paper, or closed in the work?

ForCROs and chief audit executivesCOOsTransformation leads
CLOSED AS A PROJECT
Finding
Remediation project
Closed on paper
Recurs at next audit
CLOSED IN THE OPERATING MODEL
Finding
Operating requirement
Built into the work
Evidence produced every time it runs
A small team reviewing audit findings together
The problem

Findings that come back

An audit or regulatory finding sets a date. The usual response is a remediation project: fix the instances found, document the fix, close the finding. The next audit samples the same work and finds the same thing, because the work that produced the finding never changed.

A finding stays closed when the requirement is built into how the work runs.
How ZBTOS helps

Treat the finding as an operating requirement

The Operating Requirements Model tests any requirement, including one handed to you by an auditor, against five questions. A finding that answers all five is built into the work and produces its own evidence.

CONDITION
What must change?
REACH
Where must it hold?
AUTHORITY
Who owns and decides?
ENABLEMENT
What does it take?
EVIDENCE
How will we know?

Writing requirements that pass all five is taught in the Foundation Course. Applying it to a live finding with a deadline is the Practitioner Intensive.

Where it is taught

Learn it, then apply it to your own transformation.

What the auditor sees
Many audit findings are a 0:0: activity the process requires that never appears in the record.

Closing one in the operating model means making that activity happen, and leave its record, at the source. Another downstream review only finds the gap again.

Questions

What is the difference between remediation and operating change?

Remediation fixes the instances the auditor found. Operating change alters the work that produced them, so the next sample comes back clean.

Where does ZBTOS teach this?

The Foundation Course teaches a cohort to write operating requirements that pass all five lenses. The Practitioner Intensive applies it to a live requirement, such as a finding with a deadline.

Stay current. New reads on controls that run in the work. Published by ETEGY.

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