Wednesday, May 20, 2009

Can the Same Firm Provide CMMI Consulting & SCAMPI A Services?

I have been hearing that the SEI has stringent rules stating that the consulting firm cannot perform a SCAMPI A appraisal as it results in conflict of interest and the appraisal may lose it's objectivity. Couold you please throw light on this issue and give me the correct information? It would be great if you can refer to any documents listing these rules e.g. SEI audit policies.

Yes, the same COMPANY and same LEAD APPRAISER can provide both CMMI consulting and SCAMPI A appraisal services to the same client. However, the Lead Appraiser and SEI Partner must notify the SEI if there is a Conflict of Interest. The situation to avoid is the Lead Appraiser appraising his or her own work in a SCAMPI A appraisal. The Code of Professional Conduct (CoPC) spells out the policy and the steps that must be taken if there is an indentified Conflict of Interest.

The primary issue concerns the type of consulting provided by the Lead Appraiser. If the consulting consists of writing processes and process assets for the client, then there is a clear Conflict of Interest. But if the consulting consists of training on different ways to implement a Process Area, reviewing documents and identifying strengths and weaknesses, reviewing evidence for inclusion in the PIIDs, etc. then there is no Conflict of Interest.

So most Lead Appraisers will try their best to remain ethical and either just provide the hands-on consulting and have another Lead Appraiser lead the SCAMPI A appraisal OR lead the SCAMPI A appraisal and help the organization get prepared for the appraisal.


Anonymous said...

Hello I will like to ask you about if I am currently the legal representative and BPOC of my organizacion which in turn is also CMMI Institute Partner but I have no been involved in any consulting activity at all. Could I will be in a potential conflict of interest? How I could mitigate this? It is possible to have an observation (since I am a SLA candidate) having a mitigate procedure to follow?

Henry Schneider said...

Conflicts of Interest, potential or actual, will not prevent you from leading an appraisal. You have to be aware of them and document them as risks to the appraisal with appropriate mitigation and/or contingency plans. Since you have not provided any consulting to the OU you will be appraising there is no direct Conflict of Interest. But here is the issue, your consulting company has provided consulting services to the company you will be appraising. If during the appraisal you discover a weakness in the OU’s implementation that was a direct result of your consulting company’s advice, then that makes your company look bad. So now you are torn between protecting your company’s reputation vs. accurately identifying a weakness. This issue would become very serious if the weakness caused the failure of one or more goals. The result would mean that the company being appraised could become very angry about the consulting provided by your company and could also result in a law suit. So you would have to aware of these possible consequences and take appropriate mitigation steps to protect yourself and your company, set the appraisal sponsor’s expectations, and handle the issue.

Also, having one or more consultants from your company on the appraisal team is another potential Conflict of Interest. The issue here is that the consultants would be appraising their own advice to the company and may not be objective in their job as an Appraisal Team Member (ATM). One mitigation strategy is to use other consultants from your company as ATMs instead. What also needs to be considered is the type of consulting provided. If it is advice and recommendations on how to address implementation issues, then the potential conflict is not so serious. The OU is then responsible for deciding how to resolve the issues. But if the consultants provided hands-on consulting by writing processes, procedures, templates, etc., then the potential conflict is very serious.

Since this will be your observation appraisal, I would recommend that you try to avoid or eliminate as many potential Conflicts of Interest as possible. The more issues or risks you have with the appraisal will increase the complexity of your observation, providing the observer more things to criticize. The best path forward is to make the appraisal as simple as possible so the CMMI Institute observer can focus on how you conduct the SCAMPI A appraisal.