Responsibilities handled by Compliance Officers have grown in demands and complexity. More recently, many Compliance Officers have been given the responsibility of HIPAA privacy as a secondary duty. As a result, it has become increasingly common for Compliance Officers to explore outsourcing elements of the compliance program. Outsourcing elements has been a long practice, most notably with outsourcing the compliance hotline, computer-based training programs and sanction screening. The concept of outsourcing the entire program is also a common practice and recognized by the U.S. Department of Health and Human Services Office of Inspector General. But outsourcing the entire program should only be considered by smaller organizations when a full-time Compliance Officer does not make financial sense.
When this whole area is examined, the scope of using vendors to fill gaps is quite large. Supplemental support can be found for all seven of the standard elements of the Compliance Program. The most common areas that are outsourced include:
- Hotline services
- Sanction screening tools and services
- Compliance training (interactive, modular, flat presentations)
- Policy/compliance program document development
- Auditing/monitoring tools
- Compliance program evaluations/assessments
- Employee compliance effectiveness surveys (compliance culture and knowledge)
- Investigative support for suspected wrongdoing
- Internal audit support services
- HIPAA privacy/security functions
There are a number of challenges in trying to supplement the compliance program with experts and tool vendors. First and foremost is to identify credible vendors with adequate experience and expertise. Seek vendors with experience in the healthcare industry. For example, look for compliance hotline vendors that are knowledgeable and well versed on incidents or areas that employees may report. Their background will enhance the debriefing and engage the employee calling to report.
Second, there is the problem of comparing best quality and most reasonable cost. As a general rule, when evaluating a vendor, gaining content is more valuable than empty software. For example, when evaluating compliance training vendors, it is better to work with a vendor that provides the training program as well as the online platform to deliver the training.
Third, if you are considering outsourcing several compliance program elements, it is useful to consider vendors that can offer multiple tools and services. Not only does it reduce the number of vendors you need to work with but also many times vendors offer packages and discounts.
Whether your organization is large with a compliance office staffed by several full-time employees or small with only part-time staff, it makes sense to explore outsourcing. Engaging with experienced vendors, such as compliance hotline vendors and compliance training vendors, can enhance the elements of your compliance program and also prove to be a cost-effective.