Use RAM to Improve Compliance

The RACI model has been used to help manage projects successfully. Could it also be used to help manage obligations?

In this blog post we explore how meeting obligations can be improved using a RACI model to clarify compliance responsibilities. It's time to add RAM to our compliance.

RACI for Projects

The RACI model was introduced in the 1950s to clarify roles and responsibilities for project tasks. At the basic level responsibilities are categorized by roles (R)esponsible, (A)ccountable, (C)onsult and (I)nform known by the letters RACI.

Typically, one person will be accountable (one neck to grab principle) for the task itself to make sure that it is done correctly, on-time, and on-budget. Whereas, one or more persons will be responsible to perform the work, provide knowledge, or required to be kept in the loop when a decision is made or a task is complete.

This mapping is represented as a Responsibility Assignment Matrix otherwise known as RAM. Here is an example of RAM for baking a cake:

Project: Bake a Cake
Task	Mom	Dad	Children
1. Select a recipe	A/R/C	C	C
2. Purchase ingredients	I	A/R	R
3. Prepare ingredients	A/R		R
4. Bake cake	A/R	I	I
5. Serve cake	R	A/R	R

For the first task, Mom is both accountable and responsible for selecting a recipe for the cake. She will consult with the rest of the family as to what kind of cake they would like to have.
Dad is accountable to purchase the ingredients and is responsible along with the children to go to the grocery store to buy them. Mom needs to be kept in-the-loop to know when all the ingredients are ready.
Mom then is accountable for preparing the ingredients by following the recipe. The children are responsible to help her with that.
Mom then places the cake into the oven and lets the rest of the family know when the cake is ready to eat.
The last step Dad is accountable to serve the cake and clean up afterwards. Of course, everyone is responsible to eat their own portion of the cake.

Using a responsibility assignment matrix (RAM) is a powerful tool that helps to:

avoid "too many cooks" in the kitchen
avoid overwhelming team members with unnecessary information
remove confusion as to who does what and when
provide clear lines of accountability
keep everyone who needs to be (stakeholders) in the loop

A RACI Model for Compliance

Variations to the basic RACI model are used to accommodate different kinds of project work. This is also the case for projects associated with compliance.

Meeting compliance obligations can be considered as a project and will benefit from using an adapted RACI model such as RACIV to help clarify compliance responsibilities:

Project	Definition	Compliance	Definition
(A)ccountable	to answer for the correct and thorough completion of the work.	(A)ccountable	to answer for the effectiveness of the work.
(C)onsult	to provide subject matter expertise.	(C)onsult	to provide subject matter expertise.
(R)esponsible	to perform the work.	(R)esponsible	to achieve compliance objectives.
(I)nform	to be kept up-to-date.	(I)nform	to be kept up-to-date
		(V)erify	to provide confidence (assurance) that objectives are achievable.

To apply the RACIV model each obligation is considered as a micro project where objectives instead of tasks are used and associated with a responsibility assignment matrix (RAM).

Objectives are promises that organizations make to meet mandatory or voluntary obligations.

Promise theory tells us that obligations are evaluated by the obligee – the person, organization, or institution that imposes the obligation. This is usually performed by an external auditor or certification body. However, verifying that promises are being kept is the responsibility of the obligor and the reason for adding the (V)erify role to the RACI model.

In the following example, an organization has promised to achieve 4 objectives to satisfy the obligation of reaching net zero carbon emissions by 2050. In practice, objectives (which have been simplified here) should be specific, measurable, achievable, realistic, and time-bounded (i.e. they should be SMART goals).

Obligation: Achieve net zero carbon emissions by 2050
Objectives	Plant Manager	Environmental Specialist	Plant Managers / Supervisors	Audit Team	Stake-holders
1. Achieve 40-50% below 2005 levels by 2030.	A	RC	RC	V	I
2. Establish targets for 2035, 2040, and 2045 ten years in advance.	A	RC	RC	V	I
3. Establish measures and strategies to achieve targets.	A	CR	R	V	I
4. Report yearly on progress against each target.	A	R	C	V	I

Using a RAM increases visibility of who is accountable for each objective and ultimately answerable for it. Accountability for obligations of this kind are delegated following an accountability structure for the organization. Organizations in highly-regulated, high-risk sectors will establish a clear line of sight from the top to the bottom for critical to compliance obligations.

A RAM also shows who is responsibility to provide subject matter expertise, perform the work to achieve the objective, who will verify that standards have been followed and targets have been achieved, and who needs to be kept in-the-loop when material changes have been made with respect to meeting the overall obligation.