Preparing Internal Staff to Take Over as Compliance Officers
Education, training, credentialling, gaining experience, and tutoring
It has been nearly 30 years since the OIG Compliance Program Guidance helped establish the field of healthcare Compliance Officers. Today, many of those early Compliance Officers are reaching retirement, creating a growing gap and shortages of qualified successors. As these experienced leaders step down, organizations are left with two alternatives: hire externally or promote someone internally, however, there are problems with either approach. Hiring externally can take four to seven months, far too long to leave a compliance program without a dedicated, qualified leader. To bridge the gap, many organizations turn to compliance consulting firms to manage the program until a suitable replacement is found. On the other hand, promoting someone internally can be a genuine problem, unless they have been properly trained and prepared to meet the challenges of the office. In fact, many organizations have suffered regulatory setbacks and reputational harm after placing unprepared individuals in this crucial role. This blog explores how to prepare internal staff to step into the Compliance Officer position confidently and competently.
Education and Training. Becoming a qualified Compliance Officer begins with having a proper educational foundation, preferably a graduate degree. This can be in a variety of fields, such as nursing, public health, legal studies, or healthcare management. Common graduate degrees found among Compliance Officers include JD, MBA, MPH, MSN, or CPA, with a strong orientation toward healthcare. Beyond formal education, specialized compliance training is essential. Programs offered by the Health Care Compliance Association (HCCA), including the Compliance Certification Board (CCB) bootcamps, academies, and workshops, are excellent resources. Many universities also now offer healthcare compliance certificate programs. Professional certifications further demonstrate commitment and capability. Highly regarded options include Certified in Healthcare Compliance (CHC), Certified in Healthcare Privacy Compliance (CHPC), Certified Professional Coder (CPC), Certified Compliance & Ethics Professional (CCEP), among others. Earning multiple certifications is also advisable, as it shows a breadth of knowledge across compliance domains.
Gain Experience. While education and training are foundational, hands-on experience working in a compliance capacity is crucial. Aspiring Compliance Officers should seek roles such as compliance or privacy analyst, medical coder, billing specialist, risk coordinator, HIPAA Privacy, or internal auditor. These positions provide exposure to the practical side of compliance operations. Once engaged in a compliance-related capacity, it is important to try to get cross-trained in other related areas, as is participating in professional development events, such as webinars and conferences. Membership in organizations like HCCA can provide valuable networking and learning opportunities.
Tutoring. Often, the Compliance Officer retires or leaves for a different opportunity before someone internally is fully trained and ready to assume the responsibility of the position. There is elevated risk individually and for the organization for someone to try to assume the role before they are properly prepared. There are numerous horror stories about unprepared Compliance Officers leading organizations into regulatory trouble, financial penalties, and damaged reputation. However, with foresight, this challenge can be turned into an opportunity. A common and effective approach is to engage an external consultant to serve as an Acting Compliance Officer. In addition to maintaining the program’s integrity, the consultant can mentor and develop an internal candidate to assume the role.
I, and others in our firm, have successfully taken this approach on multiple occasions. However, its success depends on the organization viewing the individual positively and being committed to their growth. An added benefit is having an external expert assess both the internal talent and the current state of the compliance program, providing an objective, strategic perspective.
For more about this, feel free to contact me at [email protected].
