RiskAssessmentGuide PDF
RiskAssessmentGuide PDF
Management Program
Contents
Overview ....................................................................................................................................................... 1
Step 1: Establish the Context ........................................................................................................................ 3
Step 2: Risk Identification ............................................................................................................................ 5
Step 3: Risk Analysis .................................................................................................................................... 8
Steps 4 and 5: Risk Evaluation & Response ............................................................................................... 14
References ................................................................................................................................................... 18
Appendix A - Key ERM Terms and Definitions ........................................................................................ 19
Appendix B - Potential Risk Areas for Higher Education .......................................................................... 23
Appendix C - ERM Program Goals, ERM Guiding Principles, and Institutional Risk Philosophy ........... 26
List of Figures
List of Tables
Enterpriseriskmanagementisastructured,consistent,andcontinuousprocessacrossthewhole
organizationforidentifying,assessing,decidingonresponsesto,andreportingonopportunities
andthreatsthataffecttheachievementofitsobjectives(InstituteofInternalAuditors,2009).
Overview
The risk management processof identifying, analyzing, evaluating, and ultimately responding to and
monitoring riskis at the heart of enterprise risk management (ERM). Extending this process across an
entire organization, looking at both upside and downside risk, and considering risk in the context of
strategy is what differentiates ERM from traditional risk management.
This Guide to Risk Assessment & Response deals with the first steps 1 through 5 of the risk
management process shown in Figure 1: establishing the context, and identifying, analyzing, evaluating,
and responding to risks and opportunities that could affect the institution or a departments ability to
achieve its strategic goals and objectives. The context and the risk assessment steps form the basis for
decision-making about which risks or opportunities are priorities, what the appropriate response should
be, and how resources should be allocated to manage the risk or opportunity in a way that best supports
the organizations strategy. The risk response step involves deciding on and planning for the best way to
treat or modify the risk, and implementing that plan.
Figure1:TheRiskManagementProcess
Any individual at any level of the institution may use this guide to assess and plan responses to risks and
opportunities in their area. For the most part, however, risk assessments at UVM will be conducted
along three primary pathways:
1) As part of UVMs annual ERM process, responsible officials (deans, vice presidents, directors,
or other senior officials designated as responsible for a risk) will be asked to identify and assess
the institutional-level risks and opportunities for which they are responsible.
2) UVM senior management or trustees may choose to conduct a risk assessment of a planned,
institutional, strategic initiative to inform decision-making.
3) Vice presidents, deans, directors, or other senior officials may, at their option, conduct a risk
assessment for their area that considers college-, school-, division-, or department-level risks in
addition to institutional-level issues.
Results of all risk assessments and response plans are collected by ERM staff in the Office of the Vice
President of Finance & Administration (UVMs Chief Risk Officer) and entered in the Universitys risk
database to facilitate monitoring and reporting.
The ERM program staff are a resource for responsible officials and their staff, available to conduct
facilitated risk assessment workshops and other educational/training sessions as well as to review and
offer feedback on completed risk assessments.
Step1:EstablishtheContext
College,School,orDivision Finance_and_Enterprise_Services_Division_of
Department/Unit(ifapplicable):
Date: 5/9/2012
Person(s)completingthisrisk AlTurgeon
UVMStrategicGoals&Objectivesyour Diversity:Buildadiverseandgloballyawareuniversitycommunitysustainedbyaninclusive,supportive,andjustcampusclimate.
Departmentsupportsorrelatesto: AcademicPrograms:Ensurethattheresources,facilities,andsupportprogramsareavailableandpoliciesandproceduresarein
placetoattract,recruit,andretaintheverybestscholarstoUVM.
Scholarship:Continuetomakefocusedinvestmentsininfrastructureandtechnologythatsupportresearch,scholarship,andthe
creativearts.
InstitutionalEfficacy:Asaninstitution,modelthehigheststandardofethicalconduct,accountabilityandbestpractice,public
service,andstrongcommitmenttolifelonglearning.
Strategicgoals/objectivesforyour SeeDFESStrategyMapat:http://www.uvm.edu/~dfes/?Page=strategymap.html&SM=bscmenu.html
College/School/Division/Department
KeyinitiativesforyourCollege,School, SupportStrategicInitiativesProjectproposalsapprovedforimplementation.
Division,orDepartment:
CriticalfunctionsforyourCollege,School, ProvideenterprisewideadministrativeservicestoUVMstudents,faculty,andstaff;manageUVM'sresourcesforlongterm
Division,orDepartment: institutionalsustainability.
IntheRiskAssessment&ResponseWorksheet:Tab1Context
1. OpentheworksheetinMicrosoftExcel.Youshouldbeonthe1Contexttab.
2. Savetheworkbookwithauniquenameidentifyingyourunit.
3. FillouttheUnitInformation,choosingyourCollege,School,orDivisionfromthedropdownmenu.
4. NotewhichoftheUniversitysfivestrategicgoalsyourCollege,School,Division,ordepartmentbestsupports.
5. NoteyourCollege,School,Division,ordepartmentsstrategicgoalsorobjectives.
6. NoteanykeyinitiativesyourCollege,School,Division,ordepartmenthasplannedorunderway.
7. NoteyourCollege,School,Division,ordepartmentscriticalfunctionsoractivities.
8. GotothenextTab2Identification.
Steps to Follow
1. Identify all the risks and opportunities you can that might affect your objectives (see Questions
to Spur Thinking & Discussion, above).
2. For each one, give it a short name or title.
3. Write a brief risk statement that describes each risk or opportunity and provides a little more
detail about its sources and causes. Do not include potential impacts or consequences.
a. Aim for a Goldilocks risk statement: not too short, not too long; not too vague, not too
detailed; meaningful but not inflammatory
b. Too vague: IT infrastructure
c. Too specific/inflammatory: IT network and hardware is obsolete, resulting in the
potential for loss of institutional business continuity, loss of irreplaceable data, and
privacy breaches
d. Just right: IT infrastructure not maintained and/or upgraded to necessary standards
6
Step2Risk&OpportunityIdentification
UVMStrategicInitiatives DepartmentGoals,Initiatives,or
RiskorOpportunityName RiskorOpportunityStatement UVMStrategicGoalAffected ResponsibleOfficial
ProjectAreas FunctionsAffected[Optional]
IntheExcelRiskWorksheet:Tab2Identification
1. EnteryourRiskNamesandRiskStatementsincolumnsAandB.
2. ChoosetheUVMstrategicgoalthateachriskoropportunityaffectsfromthedropdownlistincolumnC.
3. ChoosetheUVMStrategicInitiativesProject(SIP)areasthateachriskoropportunityaffectsfromthedropdowninlistincolumnD.
4. IndicateanyotherstrategicgoalsorinitiativesaffectedbyeachriskoropportunityincolumnE.
5. EntertheResponsibleOfficialforeachriskoropportunityincolumnF.
Table1:RiskCategories
Category* Description
Risksoropportunitiesrelatedtoviolationsoffederal,stateorlocallaw,regulation,orUniversity
Compliance&
policy,thatcreatesexposuretofines,penalties,lawsuits,reducedfuturefunding,imposed
Privacy
compliancesettlements,agencyscrutiny,injury,etc.
Risksoropportunitiesrelatedtophysicalassetsorfinancialresources,suchas:tuition
governmentsupport,gifts,researchfunding,endowment,budget,accountingandreporting,
Financial
investments,creditrating,fraud,cashmanagement,insurance,audit,financialexigencyplan,long
termdebt,deferredmaintenance
Risksoropportunitiesrelatedtolegalliability(negligence),injury,damage,orhealthandsafetyof
Hazard,Safety,or
thecampuspopulationortheenvironment,includingimpactscausedbyaccidentalorunintentional
LegalLiability
acts,errorsoromissions,andexternaleventssuchasnaturaldisasters.
Risksoropportunitiesrelatedtoinvestingin,maintaining,andsupportingaqualityworkforce,such
HumanCapital as:recruitment,retention,morale,compensation&benefits,changemanagement,workforce
knowledge,skills,andabilities,unionization,employmentpractices
RisksoropportunitiesrelatedtomanagementofdaytodayUniversityprograms,processes,
Operational
activities,andfacilities,andtheeffective,efficient,andprudentuseoftheUniversitysresources.
ImpactsrelatedtoUVM'sabilitytoachieveitsstrategicgoalsandobjectives,includingcompetitive
marketrisks,andrisksrelatedtomission,mission,values,strategicgoals;diversity;academicquality;
Strategic
research;studentexperience;businessmodel;marketpositioning;enrollmentmanagement;ethical
conduct;accreditation
*Note: UVM recognizes that many institutions of higher education use another category: reputational risk. In UVMs view,
however, a significant event in any of the above risk categories has the potential to impact the institutions reputation. UVM
therefore does not classify reputational risks separately, and instead considers reputational impacts in its risk assessment (see
Tables 2 and 3 below).
9
Table2:RiskImpactScale
Impact Short Human Capital Hazard/Safety/Legal Financial Operational Compliance Strategic Reputational
Score Description Liability
1 Minor Affects<5%of Minorinjury Annuallossof<$1 Nodisruptionofcriticaloperationsand Minorauditfindings Slows Limitednegative
employees Minorlegalliabilityexposure millionincurrent services Minorfines progresson publicity
Nocollective Minor,reparable fiscalyear 12daydisruptionofadepartment oneUVM NoeffectonUVM
bargainingimpacts environmentaldamage 5yearcumulative Minorimpactonefficiency,client/student strategic reputation/image
Noimpacton liability/obligation programsandservices,environmental goal
recruitmentor <$10million sustainability,orinfrastructure
retention Noeffectonleadershipeffectiveness
2 Moderate Affects510%of Moderateinjury Annuallossof 3to5daydisruptionofseveral Moderateaudit Slows Local/regionalnegative
employees Selfinsuredworkers $1>$5millionin departmentsoronecriticalservice findings progresson publicity
Collective compensation currentfiscalyear Moderateimpactonefficiency, Moderatefines morethan Minor,shorttermeffect
bargainingrequired injury/exposurepossible 5yearcumulative client/studentprogramsandservices, Shorttermagency oneUVM onUVM
<5%employee Moderatelegalliability liability/obligation environmentalsustainability,or scrutiny strategic reputation/image
turnover exposure $10<50million infrastructure goal
Moderate,reparable Moderateeffectonleadership
environmentaldamage effectiveness
3 Substantial Affects1125%of Substantialinjury Annuallossof 6to10daydisruptionofaCollege, Auditfindings Stops Local/regionalnegative
employees Selfinsuredworkers $5>$10millionin School,orDivisionorseveralcritical requiring progressof publicity
Collective compensation currentfiscalyear services programmatic oneUVM PressureforUVMto
bargainingrequired injury/exposurepossible 5yearcumulative Substantialimpactonefficiency, changes strategic controlthemessage
69%employee Substantiallegalliability liability/obligation client/studentprogramsandservices, Moderateterm goal Moderatedamageto
turnover exposure $50<100million environmentalsustainability,or agencyscrutiny UVMs
Substantialenvironmental infrastructure Enforcementaction reputation/image
damagerequiringmitigation Substantialimpactonleadership likely
effectiveness
4 Serious Affects2650%of Seriousinjury Annuallossof 10to14daydisruptionof2ormore Principalinvestigator Stops Nationalnegative
employees Selfinsuredworkers $10>$25millionin Colleges,Schools,orDivisionsorthreeor debarred progresson publicity
Collective compensation currentfiscalyear morecriticalservices Programfunds morethan Intensepressurefor
bargainingrequired injury/exposure 5yearcumulative Seriousimpactonefficiency, rescinded oneUVM UVMtocontrolthe
1015%employee Seriouslegalliabilityexposure liability/obligation client/studentprogramsandservices, Longtermagency strategic message
turnover Environmentaldamage $100<150million environmentalsustainability,or scrutiny goal Significantdamageto
eligibleforEPANational infrastructure Enforcementaction UVMs
PrioritiesList Seriouseffectonleadershipeffectiveness likely reputation/image
5 Severe Affects5175%of Severeinjuryordeath Annuallossof 14dayto3monthdisruptionof2ormore Imposedsettlement Reverses Nationalnegative
employees Selfinsuredworkers $25>$100million Colleges,Schools,orDivisionsormost orcorporateintegrity progresson publicity
Collective compensation incurrentfiscal criticalservices agreement oneor UVMcannotcontrolthe
bargainingrequired injury/exposure year Severeimpactonefficiency, Organizational moreUVM message
1624%employee Severelegalliabilityexposure 5yearcumulative client/studentprogramsandservices, criminalprosecution strategic Severe,longterm
turnover Severeenvironmental liability/obligation environmentalsustainability,or Recordfinancial goals damagetoUVMs
damageeligibleforEPA $150<250million infrastructure judgment reputation/image
NationalPrioritiesList Severeeffectonleadershipeffectiveness
6 Business Affects>75%of Businesscriticalinjuryor Annuallossof UVMshutdown>3months Threatensviabilityof University Negativepublicitycould
Critical employees death >$100millionin Insolvency UVMoritsresearch strategic permanentlyimpair
Collective Criticallegalliabilityexposure currentfiscalyear Leadershipfailureresultsinlongterm mission planfailure UVMs
bargainingrequired Major,irreparable 5yearcumulative damagetotheinstitution Lossofallfederal image/reputation
>25%employee environmentaldamage liability/obligation researchorTitleIV Significantdecreasein
turnover >$250million funds enrollmentorresearch
Insolvency funding
10
Table3:OpportunityImpactScale
Impact Short Strategic Reputational Enrollment Management Financial Operational
Score Description & Student Success
11
Table4:RiskLikelihoodScale
Table5:OpportunityLikelihoodScale
12
Step3Risk&OpportunityAnalysis
RiskorOpportunity InitialRisk Notesre:RationaleforScoringandFactors
RiskCategory Nature ImpactScore LikelihoodScore
Name Score Considered
*Reasonsforchoosingtheimpactandlikelihood
Overall,doesthis
Strategic,Compliance, scores
issuepresent Rateonascaleof1 Rateonascaleof1
Financial,Operational, ImpactScorex *Stakeholderswhocareorwouldbeimpactedby
moreRiskor 6,basedon 3,basedonexisting
Hazard/Safety/Legal Likelihood thisissueandtheirexpectationsforhowitshould
Autofilledfrom Opportunityfor existingcontrols controlsand
Liability,orHuman Score bemanaged
previousworksheet UVM? andconditions conditions
Capital? [Auto *Currentactionsorcontrolsinplacetomanagethis
[Choosefrom [Choosefromdrop [Choosefromdrop
[Choosefromdropdown calculated] riskoropportunity
dropdown downlist] downlist]
menu] *Pastexperiencesoflossorgainrelatedtothisrisk
menu]
oropportunity
EXAMPLELabsafety Hazard,Safety,Legal Risk 4Serious 3High/Probable 12 Couldresultinseriousinjury(impact=4Serious).Risk
EXAMPLE Liability isalreadyoccurring(likelihood=3High/Probable).
IntheExcelRiskWorksheet:Tab3Analysis
1. YourRiskorOpportunityNameshavebeencarriedforwardforyourreferenceincolumnA.
2. ChoosethebestRiskCategoryforthisriskoropportunityfromthedropdownmenuincolumnB.
3. UsethedropdownmenuincolumnCtochoosewhetherthisissueoverallpresentsmoreriskoropportunitytoUVM.
4. Ratetheimpactoftheriskoropportunityonascaleof16usingthedropdownmenuincolumnD.
5. Ratethelikelihoodoftheriskoropportunityonascaleof13usingthedropdownmenuincolumnE.
6. Theinitialrisk/opportunityscorewillbecalculatedforyouincolumnF.
13
14
o Sharing (transfer), opportunity: The share strategy for opportunities seeks a partner
able to manage the opportunity who can maximize the chance of it happening and/or
increase the potential benefits. This will involve sharing any upside in the same way as
risk transfer involves passing penalties.
Risk response (treatment): Process to modify or respond to a risk. Risk response can involve
one or a combination of: acceptance, avoidance, mitigation, or sharing.
o Accept: Form of risk response, an informed decision to tolerate or take on a particular
risk
o Avoid: Form of risk response, an informed decision not to be involved in, or to withdraw
from, an activity, in order not to be exposed to a particular risk.
o Mitigate: Form of risk response involving actions designed to reduce a risk or its
consequences.
o Sharing (transfer), risk: Form of risk response, involving contractual risk transfer to
other parties, including insurance. Risk financing: Form of risk sharing, involving
contingent arrangements for the provision of funds to meet or modify the financial
consequences should they occur
Risk response plan: Plan to implement chosen risk response.
Key Terms
Risk criteria: Terms of reference against which the significance of a risk is evaluated.
Risk evaluation: Process of comparing the results of risk analysis with risk criteria to determine
whether the risk and/or its magnitude is acceptable. Use of a tool/system to rate and/or prioritize
a series of risks.
15
Figure2:Risk&OpportunityHeatMap
Risk Opportunity
3 High
AREAOFSENIOR 3 High
MANAGEMENTFOCUS:
InstitutionalRisk
Likelihood
Likelihood
2 Medium Portfolio 2 Medium
PreliminaryRisk PreliminaryRisk
1 Low
Inventory
InstitutionalRiskRegister Inventory 1 Low
1 2 3 4 5 6 6 5 4 3 2 1
Minor Moderate Substantial Serious Severe Business Transform Major Serious Substantial Moderate Minor
Critical ative
Impact Impact
16
IntheExcelRiskWorksheet:Tab4Evaluation&Response
1. YourRiskorOpportunityNamesandRiskScoreshavebeencarriedforwardforyourreferenceincolumnsAandB.
2. Thehighestlevelofreviewthateachriskoropportunitywillreceive,basedontheriskscore,isfilledinforyouincolumnC.
3. ChooseyourresponsestrategiesincolumnD(youmaycheckmorethanone).
4. BrieflydescribeyourresponseplanincolumnE.
5. EnteryourresponsecostestimateincolumnF.
6. EnteranyotherresourceneedsincolumnG.
7. EnteryourtargetdateforcompletingyourriskresponseincolumnH.
17
References
Institute of Internal Auditors (2009). IIA Position Paper: The Role of Internal Auditing in Enterprise-
wide Risk Management. Issued January 2009.
ISO 31000. International Standard: Risk management Principles and guidelines. First edition, 2009-
11-15.
ISO Guide 73. Risk management Vocabulary. First edition, 2009.
18
ERM framework: Set of components that provide the foundations and organizational arrangements for
designing, implementing, monitoring, reviewing, and continually improving risk management
throughout the organization at all levels. Ensures that info about risk derived from the risk management
process is adequately reported and used as basis for decision-making and accountability at all relevant
organizational levels.
Risk: Any issue (positive or negative) that may impact an organizations ability to achieve its
objectives; the effect of uncertainty on organizational objectives. Often characterized in reference to
potential events, consequences, and the likelihood thereof.
Context, internal: Internal environment in which the organization seeks to achieve its objectives, which
can include governance, organizational structure, policies, resource and knowledge capabilities,
information systems and flows, decision-making processes, culture, form and extent of contractual
relationships, and relationships with, perceptions, and values of internal stakeholders.
ERM goals (objectives): Goals and objectives that ERM activities are seeking to achieve; what the
ERM program and process should accomplish for the institution
ERM guiding principles (cultural expectations): Description of the risk-aware culture or control
environment; expectations regarding behaviors, communication, information-sharing, reporting, etc.
ERM policy: Statement of the overall intentions and direction of the institution in regard to ERM.
Describes principles, requirements, and restrictions, and establishes standards, rights and responsibilities
that guide individuals in their pursuit of institutional goals and in their relations with the campus
community and apply generally throughout the University and use of its resources.
Responsible official (risk owner): Person or entity with the accountability and authority to manage a
risk
Risk philosophy: Statement of the overall intentions, direction, and attitude of the institution related to
risk; reflected in the ways risks are considered in both strategy development and day-to-day operations.
The organization's approach to assess and eventually pursue, retain, take, or turn away from risk.
19
Avoidance: Form of risk response, an informed decision not to be involved in, or to withdraw from, an
activity, in order not to be exposed to a particular risk.
Enhance: The opportunity equivalent of mitigating a risk is to enhance the opportunity. Mitigation
modifies the degree of exposure by reducing probability and/or impact, whereas enhancing seeks to
increase the probability and/or the impact of the opportunity in order to maximize the benefit to the
project.
Event: Occurrence or change of a particular set of circumstances. Can be one or more occurrences, can
have several causes, and can consist of something not happening.
Exploit: Parallels the avoid response, where the general approach is to eliminate uncertainty. For
opportunities, the exploit strategy seeks to make the opportunity definitely happen (i.e. increase
probability to 100%). Aggressive measures are taken which seek to ensure that the benefits from this
opportunity are realized by the project.
Ignore: Just as the acceptance strategy takes no active measures to deal with a residual risk,
opportunities can be ignored, adopting a reactive approach without taking explicit actions.
Impact (consequences): Outcome of an event affecting objectives, either positively or negatively. Can
be certain or uncertain; can be expressed qualitatively or quantitatively. An event can lead to a range of
consequences, and initial consequences can escalate through knock-on effects.
Likelihood: The chance that something will happen whether defined, measured, or determined
objectively or subjectively, qualitatively or quantitatively, and described using general terms or
mathematically
Mitigation: Form of risk response involving actions designed to reduce a risk or its consequences.
Risk analysis: Process to comprehend the nature of risk and to determine the level of a risk; provides
the basis for risk evaluation and decisions about risk response.
Risk control: Any process, policy, device, practice, or other action that modifies risk
Risk criteria: Terms of reference against which the significance of a risk is evaluated.
20
Risk evaluation: Process of comparing the results of risk analysis with risk criteria to determine
whether the risk and/or its magnitude is acceptable or tolerable. Use of a tool/system to rate and/or
prioritize a series of risks.
Risk financing: Form of risk response, involving contingent arrangements for the provision of funds to
meet or modify the financial consequences should they occur
Risk inventory, preliminary: Preliminary list of potential risks identified for further assessment and
analysis.
Risk portfolio (profile): A composite view of highest-level institutional risk exposures for presentation
by management and discussion with the Board; provides information regarding relationships,
concentrations, and/or overlaps of risk as they relate to strategic objectives. Description of any set of
risks.
Risk register (log, repository): Record of information about identified risks; the complete list of all
risks identified in the ERM process
Risk response (treatment): Process to modify or respond to a risk. Risk response can involve one or a
combination of: avoidance, acceptance, mitigation, or transfer.
Risk statement (description): Structured statement of risk usually containing four elements: sources,
events, causes, and impacts/consequences.
Sharing (transfer), opportunity: The transfer response allocates ownership to a third party best able
to deal with the threat. Similarly, a share strategy for opportunities seeks a partner able to manage the
opportunity, who can maximize the chance of it happening and/or increase the potential benefits. This
will involve sharing any upside in the same way as risk transfer involves passing penalties.
Sharing (transfer), risk: Form of risk response, involving contractual risk transfer to other parties,
including insurance.
Source (of risk): Element or circumstance which alone or in combination has the intrinsic potential to
give risk to risk. Can be tangible or intangible.
21
Monitoring: Continual checking, supervising, critically observing, or determining the status in order to
identify change from the performance level required or expected. Can be applied to a ERM framework,
ERM process, risk, or control.
Reporting: Form of communication intended to inform particular internal and external stakeholders by
providing information regarding the current state of risk and its management.
22
23
24
25
3. Increase capacity to identify and seize opportunities by facilitating greater transparency and
openness regarding risk.
26
c. Integrate risk ownership and management activities at all levels of the institution.
d. Where possible, use and strengthen existing management processes, reporting and
approval channels, and organizational structures.
e. Establish and maintain an institutional risk register that allows for the tracking and
reporting of risk trends and of risk response plans.
f. Review the effectiveness of risk management practices regularly.
1. All individuals, regardless of their role at the University, are empowered and expected to
report early on to senior management any perceived risks or opportunities and any near
misses or failures of existing control measures, without fear of retribution.
2. Risk management is integral to the management and future direction of the University
and is a shared responsibility at all levels of the University.
3. Ownership and management of risk will be retained within the University function,
department, or unit that creates the risk or is best capable of responding to it.
4. The Universitys risk philosophy will guide strategic and operational decisions at all
levels.
The University acknowledges that risk, in one form or another, is present in virtually all its
endeavors, and that successful risk-taking will often be necessary to achieve its aims.
We therefore do not seek to eliminate all risk; rather, we seek to be risk-aware but not risk-
averse, and to effectively manage the uncertainty inherent in our environment.
27
To this end, we seek to identify, understand, assess, and respond to the risks and opportunities
we face, taking into account their impact on UVMs people, standing, reputation, financial
position, and performance. We further seek to pursue prudent risks or opportunities that we
believe will generate sufficient and sustainable performance and value, avoid intolerable risks,
manage residual risk within defined levels, and be prepared to respond to risks or appropriate
opportunities when necessary.
28