Increasing Compliance Officer Retirements Creating Recruitment Problems
Key Points:
- Plan in advance and develop internal staff to fill compliance gaps
- Ten benefits of engaging the right Interim Compliance Officer
- Frequently Asked Questions regarding Interim Compliance Officers
Increasing retirement and an already limited pool of trained healthcare compliance professionals has caused a noticeable shortage of compliance officers at healthcare institutions. Ever increasing regulatory requirements and added responsibilities have contributed to this problem, which has led to burn-out and turnover. Despite the causes for departing compliance officers, there are several solutions. First is to develop and train existing internal staff and move them into responsible compliance positions. Training should include gaining certification in compliance. However, if faced with a vacancy and no internal staff is ready or available to assume a compliance role, consideration should be given to bringing in an experienced professional on a temporary basis, to manage the program, assess its status, and assist in finding a qualified candidate. According to the 2025 “Compliance Benchmark Survey”, hiring a qualified compliance officer can take five to seven months. This is far too long to allow the Compliance Programs to deteriorate and create added risks. In most cases, a well experienced consultant can assume full responsibility as Interim Compliance Officer for the continued development, assessment, and operation of the program. Often, engagement can be cost effective and require less than full-time work. When seeking such a consultant, consideration should be given to healthcare industry-specific experience, regulatory knowledge, certifications (e.g., CCEP, CRCM, CHC, CHPC), strong references, project record, and ability to hit the ground running with minimal onboarding.
The ten most common benefits of using professional compliance consultants include: (1) gaining access to highly experienced professionals with deep knowledge of applicable laws and regulations, (2) acquiring more seasoned and experienced individuals than most who may be seeking the permanent position, (3) ready to start work quickly without lengthy onboarding processes for permanent hire; (4) avoiding the overhead cost of an employee (FICA, leave, insurance, benefits, etc.); (5) paying for only what is needed; (6) easily terminate when no longer needed; (7) obtaining objective feedback on the status of the program, compliance risks, internal controls, and culture unaffected by prior decisions; (8) gaining access to a strong compliance bench of subject matter experts, along with templates, best practices, analytical tools, etc.; (9) providing leadership and boards with highly credible professionals to provide expert advice; and (10) demonstrating independent oversight as called for by the OIG and DOJ guidance and guidelines. In seeking the right consultant, beware of the “freelance” consultant that may have limited experience and record. To meet the needs of your organization, consider the depth of experience and qualification of the firm that employs such individuals. Research reputable consulting firms and review their website and staff. Investigate the range of professional education, credentials, publications, and presentations; ensure that anyone assigned will have multimillion dollar liability insurance; and request a proposal to gain insight into their understanding of needs and the cost of providing those services. Any agreement for temporary services should include the right to terminate the agreement at any time with a simple email notice.
For more information on this topic please contact Richard Kusserow at [email protected].
