Blog Post

Smaller Organizations Have Option to Outsource Their Compliance Program

Richard P. Kusserow | September 2022

Register for a complimentary CEU credited webinar “Building Blocks for Effective Compliance Programs (,” November 10, 2022, at 2 PM Eastern.

Key Points:

Many smaller health care organizations have learned that relying on an employee with limited experience and expertise to serve as compliance officer can be difficult and risky. There is also the common practice of adding duties to the Compliance Officer’s responsibilities, running the added risk of overextending their workload. Yet, one out of three respondents to the 2022 Healthcare Compliance Benchmark Survey, conducted by SAI360 and Strategic Management Services, indicated that this is occurring in their organization. The risk is having a compliance officer who lacks the time, knowledge, and skills to operate an effective compliance program. This, in turn, increases the exposure of liabilities, including painful encounters with regulatory and legal enforcement authorities.

For smaller healthcare organizations, there is the option of engaging an outside expert to be the Designated Compliance Officer (DCO) who would be responsible for developing and managing the Compliance Program. Effectively, this would be outsourcing the entire responsibility. Such a person, by being experienced and independent, can move quickly to build and manage an effective program. This approach has been officially recognized as an alternative by the Department of Health and Human Services Office of Inspector General (OIG) in their Compliance Program Guidance where they state, “for those that have limited resources, the compliance function could be outsourced to an expert in compliance.” As such, an outside expert would be a part-time but permanent alternative to a W-2 employee compliance officer. The Centers for Medicare and Medicaid Services also recognizes the advantage of outsourcing the compliance programs. 

There are many advantages for this option, including: 

  1. Little or no compliance learning curve for immediate management of the program;
  2. Bringing experience from other engagements;
  3. Ensuring immediate coverage for operation of the program;
  4. Can be cost efficient as it is part-time;
  5. Ability to provide an accurate assessment of what is needed for the program;
  6. Ability to efficiently address compliance issues;
  7. Reporting and acting upon problems and taking needed corrective action measures;
  8. Evidencing to outside authorities organization’s commitment to compliance;
  9. Ability to terminate with a simple written notification;
  10. No overhead costs such as FICA, insurance, health and leave benefits, retirement, etc.

For more on this topic, contact Richard Kusserow at [email protected].

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Register for a complimentary CEU credited webinar “Building Blocks for Effective Compliance Programs (,” November 10, 2022, at 2 PM Eastern.

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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