Speeded Commercial Rep Letter process by 92% and enhancing the controls related to an automated workflow and audit trail tool.

1. As Simple as Two Clicks -- Simplification Project Reduces Critical
Compliance Procedure Time By 92%
The Securities and Exchange Commission and Sarbanes-Oxley Act
require market management and finance directors to sign
representation letters and Sox 404 Sub-Certifications each quarter.
These "rep letters" state the company has established effective
internal controls and procedures over financial reporting.
The Chief Executive Officer and Chief Financial Officer rely on those
letters when confirming external validation that the company has
established effective internal controls and procedures over financial
reporting.
At BMS, the requirement has traditionally meant developing and tracking
as many as 100 such “rep letters” involving hundreds of work hours by
dozens of people each quarter. Now that work was reduced by 92% thanks to a simplification process
undertaken by Darshika Patel, BCF lead, Commercial & Medical, and Rob Thibault, communications
consultant, Public Affairs.
“The simplification project Darshika and Rob developed saves a significant amount of time in a process
that is extremely time-critical,” David Levi, executive director, Global Business Controls, says. “The Rep
Letters must be completed during a very busy 3 – 5 day period each quarter, so saving more than two
hours for each letter helps tremendously.”
Cumbersome Process
While time-critical, the existing process for distributing, signing, collecting and assessing the
representation letters was also time intensive and overly complex, requiring multiple touch-points from
each person involved. In addition, the legacy process was paper-based, requiring letters to be customized,
printed and sent to each location for signature, scanned and emailed back to BCF.
Last spring, Patel was inspired by US Medical’s “Think Different, Do Different” theme. She surveyed best
practices in the industry, hosted a few focus groups and discovered, while exact processes differed, they all had
evolved from decentralized paper-based processes to fully electronic ones, thus managing the end-to-end rep
letter process centrally.
“Finance people supporting US Commercial alone produce 13 Rep Letters, each requiring the signature of
business unit and finance representatives,” Patel says, “I knew we could build a digital solution that
simplified work while meeting the needs of everyone involved in the process.”

2. Patel and Thibault mapped and analyzed the existing process, learning that each letter required 31
discrete actions during 16 steps and 140 minutes of time, each quarter.
“That was a real eye-opener,” Thibault says. “Everyone acknowledged that the process was cumbersome
and inefficient, but until we quantified it, no one knew just how inefficient it was.”
After reviewing and testing a variety of options, Patel and Thibault designed an automated process
employing custom SharePoint workflows integrated with email. The process reduced the 16-step, 31-
action process to just four steps, which take just 10 minutes.
For market and finance managers responsible for certification, the process became two clicks; one to
open an email and another to digitally certify the Rep Letter. The workflows also have built-in automated
reminders to issue emails if the certification is not completed by the established deadline.
In addition, the new process also reduces risk by creating an audit trail with a digital stamp of name, date,
time and comments automatically captured for each letter and stored in a discrete database.
The new process was piloted with 19 rep letters in 5 markets: US Commercial, Worldwide
Commercialization, Worldwide Commercial Operations, Medical and R&D/FAMA. The total process time
required for the 19 letters was reduced by 92%, from more than 2,600 minutes to just 190 minutes.
Based on the success of the pilot, plans are underway to expand the process to several international
markets in December and then globally in early 2016.
“There are tremendous opportunities for expanding the process not just to additional markets for Rep
letters, but also in adapting it for other regulatory certification letters,” Patel says.