Blog Post

Options For Engaging Short-Term Compliance Staff

Richard P. Kusserow | November 2022

Key Points:

Nation and industry-wide, disruption of labor supply is common, particularly since and during the Pandemic. This extends to Compliance Offices, where frequently, there is a shortfall of available resources to effectively meet all the obligations. This may occur as a result of employee illness, maternity or disability leave, or other sudden departures. In some cases, it may be caused by unexpected or temporary demands in response to incidents or special projects. The challenge is how to get through these periods of overflow without neglecting key responsibilities. Engaging a qualified compliance expert may be the means to gain extra help for a short time to meet demand and enable covering all the bases until someone is engaged internally to provide needed specific skills or experience.

Generally, there are four types of short-time engagements of compliance consultants: (1) engaging for a specific job or task, (2) filling a gap until a new hire can be made, (3) hourly rate for a specified period for support duties, and (4) on-demand consultants with an established hourly rate for assigned short-term tasks. Waiting until an urgent need occurs to find and engage a qualified compliance consultant for a short-term engagement may delay meeting the immediate need. As such, if there is any consideration for using a compliance consultant for any of these services in the foreseeable future, it is advisable to identify potential sources well in advance of the need. This could include (a) interviewing potential parties, (b) determining the range of experience and expertise, (c) on-call availability, and (d) rates charged. Many find establishing a formal or informal “on-call” agreement that establishes availability and rates will ensure prompt support if and when needed. If engaging in a formal agreement, it is advisable to include retaining the right to terminate with a simple written notice.

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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 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.

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