Blog Post

Differences Between Interim and Designated Compliance Officers

Richard P. Kusserow | November 2022

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They are not the same, and the rules for their use differ

It is common for organizations to ask about filling a compliance officer gap using an expert contractor. The need may arise as result of a temporary gap while seeking a permanent replacement or a decision to permanently outsource the function to a contractor. The use of a contractor as an Interim Compliance Officer (ICO) is quite different from a Designated Compliance Officer (DCO), and the rules governing when each is appropriate make it important to understand the difference.

Interim Compliance Officers are defined as contractor experts temporarily engaged to assume the duties of the Compliance Officer for a limited period to avoid the risk of permitting gaps in the operation of the compliance program for months on end. The use of an ICO has become common, particularly as result of labor disruption arising from the COVID Pandemic. Compliance programs with gaps in staffing may rapidly degenerate. Engaging contractors to temporarily assume duties is more preferable for most organizations than taking the risk of turning to internal, unqualified staff. Properly experienced and knowledgeable professionals can quickly assume duties and provide high-value services for day-to-day compliance program management, often on a part-time basis, while seeking a permanent replacement. Depending on the arrangement, an ICO can be cost-effective in that you pay only for the hours worked and avoid FICA taxes, overhead costs for leave, and benefits. Outside experts provide an independent and objective perspective, free of corporate decisions and actions.

Designated Compliance Officers are defined as individuals to whom an organization outsources the responsibilities of Compliance Officer to develop and manage the day-to-day operation of an organization’s Compliance Program. The HHS OIG sees this as a suitable solution ONLY for smaller health care organizations when hiring a full-time Compliance Officer is not financially justifiable. As such, DCOs normally are part-time contractors. However, the OIG does see larger organizations using this as an option, but they won’t permit using a DCO for organizations under a Corporate Integrity Agreement. Advantages of engaging a qualified DCO include being able to provide the benefits of wide experiences that include awareness of the regulatory environment and what it takes to have an effective program and being able to move quickly to efficiently address any issues that could result in liability.

When selecting either an ICO or DCO contractor, it is advisable to check references, experience in performing similar services in the past, require hefty tort liability insurance, and decide whether to engage a free-standing consultant or one anchored in an established firm.

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About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 2,000 health care organizations and entities in developing, implementing and assessing compliance programs.

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