On SDR reconciliation, energy companies find reasons to exceed requirements

On SDR reconciliation, energy companies find reasons to exceed requirementsPosted by Mike Prokop, Director, Deloitte & Touche LLP

At a panel discussion I recently facilitated on swap data repository (SDR) reconciliation, fewer than half the energy industry attendees said they have a solution in place for that function. Still, at least one participant said reconciling data in the SDR is a good idea because it enhances end-users’ understanding of the information being reported and serves as an internal risk mitigation measure. Our October 3, 2014 discussion was part of Deloitte’s Dodd-Frank Compliance Leadership Academy.

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Energy companies eye compliance monitoring; panel advises close ties with business

Energy companies eye compliance monitoring; panel advises close ties with businessPosted by Paul Campbell, Principal, Deloitte & Touche LLP and Ron Chovanec, Specialist Leader

Trade surveillance is a rising concern in the energy industry, and regulators have an increasing expectation that companies in the industry will have trade monitoring solutions in place. At Deloitte’s Dodd-Frank Compliance Leadership Academy on October 2, 2014 we joined a group of industry representatives in a panel discussing where trends are headed.

Establishing a trade monitoring and surveillance program isn’t just to avoid regulatory scrutiny. Internally, it can also make the gathering, review, and presentation of trade data a lot easier. But there are challenges involved. When you gather more data, regulators may ask for more data. Compliance teams will need to partner with people on the operational side to review what they learn. Management buy-in, budget, and other resources can stand between the blueprint and the reality. And while a monitoring system may be simple in concept, applying it across multiple divisions can be less simple, especially in a global organization.

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In compliance data, quality rivals quantity

Energy companies eye compliance monitoring; panel advises close ties with businessPosted by Paul Campbell, Principal, Deloitte & Touche LLP and Howard Friedman, Director, Deloitte & Touche LLP

“Our best metric is still a gut feel.” That’s how one panelist summed up his company’s approach to making sure its compliance program provides the most useful feedback.

That comment was part of a panel discussion on compliance data benchmarks we facilitated on October 2, 2014 as part of Deloitte’s Dodd-Frank Compliance Leadership Academy. The participants were eager to get in front of compliance trends so they could apply the indicators today they’ll need to report on tomorrow. And while many of those indicators arise directly from the compliance function, we found it’s just as important to keep abreast of operations-related data, such as the management of physical assets.

But first, back to that “gut feel.” One theme that ran through our discussion was the need to take a broad view of what constitutes useful compliance data.

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Responding to Medicare’s New Short Stay Rules

Responding to Medicare's New Short Stay RulesPosted by Kelly Sauders, Partner, Deloitte & Touche LLP

The issue of short inpatient stays is probably the biggest Medicare challenge that hospitals currently face. This issue has been an ongoing challenge for years, but until now many hospitals didn’t know how to tackle it ¬ or didn’t think they had to. That all changed on October 1, 2013, when the Centers for Medicare & Medicaid Services’ (CMS) new ‘2 midnight rule’ went into effect. Now, it’s clear that a hospital stay must include two midnights in order for associated services to be classified as inpatient. This rule change has tremendous financial and operational implications and should be addressed immediately. Hospitals that continue to ignore the problem are at significant risk of facing more and more Medicare denials. Here are five steps hospitals can consider taking to help address this risk:

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