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Thank you for sharing the Draft (Federal ERM Areas of Practice Guidance – 2021) as risk practitioners seeking a unity of effort approach to risk management across federal and private sector venues. Enterprise Risk Management (ERM) implementation, deployment, and sustainment strategies continue to evolve and need a framework reference, which this guide provides. While reviewing the guide, I believe a section should address traditional risk management versus ERM, including identifying potential gap analysis measures when confronted with existing silo approaches.
Since ERM is promoted as the methodology by which enterprises monitor, analyze, and control risks from across the enterprise while identifying underlying correlations and thus optimizing risk-taking behavior, the guide should further emphasize its “constancy of purpose.” ERM promotes the necessity for a “one picture, one plan” strategy encouraging a dynamic, ongoing process to identify ERM opportunities and emerging risks.
The draft Federal ERM Areas of Practice Guidance – 2021 is very well positioned to promote a “unity of effort” approach associated with existing or multiple approaches and methodologies across the federal workforce associated with risk, including:
• Traditional Risk Management
• Enterprise Risk Management
• Integrated Risk Management
• Agile Risk Tolerance
• Scrum
• ForesightAgain, disparate approaches and philosophies may exist across agencies, confusing the existing culture and behavior across agencies deploying risk management or ERM program, prompting the concern of whether we should acknowledge the above or advocate only for ERM.
Today, ERM provides the best approach and fit across federal activities to ensure continuous improvement and compliance supported by the Evidence Act, OMB Circular No. A-11 (2021), 260.29 through 260.32, OMB Circular A-119: Federal Participation in the Development and Use of Voluntary Consensus Standards and Conformity Assessment Activities and OMB Circular No. A-123.