Choose the best qualified compliance consultant to ensure proper return on investment
The OIG and DOJ stress compliance programs are always works in progress that are never completed but must continually evolve and respond to the ever-changing regulatory and business environment. One challenge while managing the day-to-day running of the compliance program is not having the appropriate staffing to address areas warranting attention. Many turn to engaging outside expert consultant assistance to advance the compliance program. With so many choices, it is very important to identify the healthcare consultant best suited for the need. The following are some things to consider in making that decision:
- Cost/Benefit Analysis. Determine up front if it is more cost-effective to hire another employee or engage a consultant to address unmet needs. Take note of recruiting and training costs for new employees, as well as about 30% additional long-term overhead costs (FICA, leave and health benefits, etc.), none of which applies to contractors, as well as avoiding the cost of hiring and training a new employee. For one-off projects, hiring a new employee would not be financially prudent.
- Healthcare Compliance Knowledge, Focus, and Experience. Every business sector has unique issues and standards to consider. Ensure the compliance consultants have a background rooted in healthcare regulatory compliance with experience and knowledge about compliance issues and how other organizations handle similar issues. The greater the experience, the shorter the learning curve and costs of research.
- Specialized Expertise. Define projects that cannot or best not be done by internal staff. For example: (a) developing and implementing compliance programs; (b) evaluating and evidencing compliance program effectiveness; (c) evaluating the accuracy of claims processing; (d) reviewing arrangements with referral sources for compliance with appliable laws; (e) developing and delivering regulatory updates for executive leadership and board; (f) addressing potential conflicts of interest situations; (g) providing temporary staffing for the compliance program; (h) conducting due diligence reviews; (i) developing a more effective compliance risk assessment process.
- Team Background/Credentials. Know the background and review the credentials for what may be needed (e.g., attorneys, CPAs, PhDs, MPHs, Certified Coders, Nurses, MBAs, professional certifications, former regulators, HIM, etc.). This will help understand the depth of the compliance firm’s subject matter expertise.
- Tenure, Stability & Reputation. Determine how long the firm has been engaged in compliance-related services and its reputation. As a rule, the longer the tenure and experience, the more stable and reliable the organization. Also, look at the experience of the assigned consultants.
- Objectivity. Selecting the right consultant with great experience and expertise can result in gaining unbiased and objective advice, absent of emotional attachment to prior decisions.
- Provide Strategic Vision. Look for a compliance consultant with many years of experience working with similar organizations to apply what they have learned in assisting in developing strategies with long-term goals and objectives.
- Compensation. Decide on the manner of payment for the consultant. It can be a fixed fee for tasks, a monthly retainer, or charges at an hourly rate. Decide on exactly what the consultant would be asked to do and how they would charge for the service.
- Check References. Gain feedback from other organizations who used the consulting firms being considered to learn if they performed contracted services in a timely, cost-effective, and efficient manner, as well as the quality of working relationships and communication during the engagement.
- Regulatory Currency. Ensure the consultant keeps current and can provide up-to-date relevant regulatory and legal information.
- Avoid Bait & Switch. Many firms will use their most senior and experienced consultants during the sales process, but those assigned the work are lesser qualified consultants. Learn the identity of those who would provide the service and have them locked into the contract.
- Service Depth and Breadth. Consider the depth and breadth of the consulting firm in terms of the consultant’s ability to draw upon the expertise of others who have other expertise. Know what support resources are available beyond the task work to be engaged.
- Get Acquainted with the Proposed Consultant. A key to success in engaging a consultant is establishing a positive working relationship. This begins with meeting and speaking with the consultants before commencing work.
- Professional Liability Insurance. Ensure that the consultant engaged has multimillion professional liability insurance coverage.
- Right to Terminate. Ensure the right to terminate an agreement by simple written notice to maintain control over work and costs.
For answers to compliance FAQs, see https://www.compliance.com/faqs/
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