In an era of more limited budgets and OMB’s guidance to Agencies to move to fixed-fee implementations, it’s more critical than ever before to understand the underlying legal and regulatory framework up front and to get the business and functional requirements gathering aligned to it from the beginning. Sawyer Consulting partners with traditional system integrators and clients to make this alignment possible.
We begin by working with our team client partner to map Agency program areas to legacy systems. Once we have clear insight into the legacy business, data architecture, and systems architecture, we can turn to analyzing how these components will be required to change under the new regulatory regime.
For this, our expert staff turns to the law. First we identify the client Agency and how it is cited specifically throughout the relevant Act. We identify the components of the law that direct the client Agency to make rules and we inventory these for analysis as they are promulgated. Additionally, we carefully mark ambiguities in the law that we think will be sub-components of specific rulemaking.
We then go back to the Congressional Conference Report (if applicable) to determine the intent of Congress where it is not clear in the law. We also tap our network of former Capitol Hill colleagues and Agency attorneys for Q&A if needed.
Sometimes, our team is added to projects after rulemaking has begun. At corporate, we track the in-flight rulemaking teams, the draft rules, and the final rules of relevant legislation in order to have a full understanding of top-level business requirements as they evolve from the law. This enables us to have relevant expertise at the ready on day one of an engagement.
A new proposed rule is a major milestone for an Agency. And its timely completion is an under- appreciated critical success factor for major IT investments. It is at this point in a project where we can take our first deep dive to construct a draft business architecture and draft list of use cases that will be critical to the successful implementation of a new system.
Sometimes, multiple rulemakings affect the same project. Our team of experts tracks this complexity to inform the evolving business architecture.
Depending on project schedules, the gap between proposed rules and final rules are a good time for our team to turn deeper participation in technical design. Based on our initial work around potential use cases, and a visual RTM that maps back to the rules, we have had great success in helping IT delivery teams meet contracted deadlines by controlling scope and decreasing requirements risk.
Dodd-Frank Thought Leadership/Expertise
In 2010, Title VII of the Dodd-Frank Act amended the Commodities Exchange Act (CEA) to establish a comprehensive new regulatory framework for swaps and security-based swaps. Dodd-Frank expanded the Commodity Futures Trading Commission’s (CFTC) previous role in the regulation of futures and options. The goal of this legislation was to reduce risk, increase transparency, and promote market integrity within the financial system. The CFTC was directed to write rules and implement programs that would achieve these goals.
Sawyer Consulting partnered with Northrop Grumman’s on-the-ground development resources to provide SME’s and business and technical architects to help manage implementation of Dodd-Frank IT programs and projects.
Regulated Institutions Business Web Portal: The Internet Portal Project was chartered by the Commodity Futures Trading Commission to provide a single authenticated entry point for external financial industry participants (dealers, clearinghouses), in order to make communications and data submission for regulated entities more efficient and customer-friendly. The portal provides external participants with customized content and available actions that are relevant to their reporting needs and obligations under the regulations promulgated from the Dodd-Frank Act.
Risk Surveillance Program: The Risk Management Systems Support Project was chartered by the Commodity Futures Trading Commission (CFTC) to support the Division of Clearing and Risk (DCR) and Division of Market Oversight (DMO) in their efforts to monitor, analyze, and reduce systemic risk in the swaps market. It supported this goal by modernizing the IT systems that enable expanded data intake from market participants (dealers, clearinghouses), expanded surveillance and analysis capabilities (industry applications), and improved reporting and data-sharing functions that are required by the regulations promulgated from the Dodd-Frank Act.
Content Management System: The Chairman of the Commodity Futures Trading Commission (CFTC) chartered the public-facing Content Management System. This project entailed the complete teardown of the legacy external content management system and a complete re- architecting and rebuild on a modern platform hosted by an external provider. The team closed the end-to-end timeline for publishing content to the web from the legacy system’s three-hour benchmark down to the new system’s two-minute maximum. The business goal of enabling the syncing of CFTC’s public announcements with that of its sister regulatory Agencies (SEC, Federal Reserve) was accomplished for the Chairman.
Affordable Care Act Thought Leadership/Expertise
In 2010, the Congress passed the Patient Protection and Affordable Care Act (aka Affordable Care Act or ACA). This comprehensive and complex law impacts almost every aspect of private and public healthcare in this country. Its full implementation will be a major effort from doctors, hospital systems, insurance companies, medical device manufacturers, pharmaceutical companies, medical researchers, non-profits, state governments, and federal departments from HHS to IRS.
Sawyer Consulting’s experts have worked with a variety of private industry clients and state governments to provide advice on implementing provisions of the law. It is currently partnering with Northrop Grumman’s on-the-ground IT project teams to provide regulatory analysis, business architecture and technical architecture support to federal departments responsible for implementing the law.
State Medicaid Programs: The Sawyer Consulting team has extensive experience in working with state Medicaid programs to facilitate eligibility expansions, modifications, and reductions, as well as the implementation of Medicaid waiver programs, authorized under section 1115 of the Social Security Act (SSA). The ACA and the subsequent Supreme Court decision create both opportunities and uncertainties for state Medicaid programs and for the stakeholders who work with and rely on them. Sawyer Consulting’s experience can help both private and public clients navigate these changes.
Insurance Exchanges: The movement towards insurance exchanges has been an emerging trend in both the public and private settings. The Sawyer Consulting team has substantial experience working for states in implementing their new insurance exchanges, as required under the ACA. Our consultants also have assisted private sector clients, including large employers and providers, in developing private exchange concepts and platforms for use in the employer sponsored insurance marketplace.
Health Plans and Insurance Issuers: Our team has worked with large employers, new start-up insurance issuers, and large non-profit insurers on a range of issues, from the creation of networks and start-up strategy, to compliance with new ACA standards.
Medical Device Manufacturers: Given the large expansion in coverage brought about by the ACA, as well as greater transparency in the marketplace, medical device, pharmaceutical, and biotech manufacturers are facing a reformed marketplace. Sawyer Consulting has worked to advise clients on new pricing strategies, smarter use of research and development resources, and areas of opportunity in Medicare and Medicaid reimbursement.
Hospital Systems: Sawyer Consulting has substantial experience working with hospital systems and providers across the care continuum. Projects have included compliance with new ACA requirements, identifying strategic and tactical opportunities in the reformed health care delivery system, and developing strategies for movement from fee-for-service to greater risk-bearing reimbursement systems.
Consumer Product Safety Improvement Act (CPSIA) Thought Leadership/Expertise
In 2008, Congress passed CPSIA in response primarily to address major gaps in the nation’s product safety regulatory regime (ex. lead in toys imported from China). Among other things, this reform measure directed the Consumer Product Safety Commission to develop a public and business-facing web portal and to modernize its internal IT investments in support of new business priorities in the program areas.
Sawyer Consulting partnered with Armedia’s on-the-ground technical resources to provide SME’s and business architects to manage implementation of CPSIA-related IT projects.
CPSIA Section 212 Rulemaking:Sawyer Consulting worked with the CPSC to analyze the IT implications of Section 212 of the Consumer Product Safety Improvement Act. In this capacity, we teamed with an executive sponsor to lead the Agency-wide proposed and final rulemaking regarding the practical operation of the Congressionally-mandated Public and Business Web Portal.
IT Planning: Our team worked with an executive sponsor to develop the planning and acquisition artifacts necessary to release the appropriated IT development funds from OMB. Sawyer Consulting’s experienced professionals set up and currently maintain the Capital Planning and Investment Control (CPIC) and the Project Management Office (PMO) support functions at CPSC.
Independent Validation and Verification: Our team provided the Independent Validation and Verification services throughout the 18-month software development life cycle. We worked directly for the CIO to oversee and facilitate the collaboration the various development vendors to ensure that the final product was in compliance with the final regulations.
Medical Device Manufacturers: Given the large expansion in coverage brought about by the ACA, as well as greater transparency in the marketplace, medical device, pharmaceutical, and biotech manufacturers are facing a reformed marketplace. Sawyer Consulting has worked to advise clients on new pricing strategies, smarter use of research and development resources, and areas of opportunity in Medicare and Medicaid reimbursement.
IT Modernization: The CPSC is currently in the second phase of completing the IT goals set out by Congress. The IT modernization continues with guidance from Sawyer Consulting regarding IT strategy, IT vendor selection, and IT acquisition support.