No healthcare organization can afford the risk of a
Compliance Officer “gap”
Compliance programs may rapidly degenerate without someone being responsible for day-to-day compliance management. Designating an internal employee to fill this “gap” is not a wise idea, as these individuals are likely to take a hands-off approach to an unfamiliar area. Moreover, internal replacements cannot be expected to recognize and address problems in a timely and professional manner, without a strong understanding of compliance. As an alternative, using a compliance expert as an interim compliance officer can be very cost effective. These individuals provide high-value services for day-to-day compliance program management. Depending on the organization’s size and complexity, it can also consider hiring a part-time expert. These experts can bring “fresh eyes” to the compliance program, and are able to carry out their duties objectively, without being invested in any prior organizational decisions. They can also bring their experience from having dealt with similar issues in their previous positions, and in working at the executive level and with the Board of Directors. These interim engagements usually run between three to five months, while the organization finds a permanent replacement.
Suzanne Castaldo, JD explains that she is frequently called upon to provide highly experienced and knowledgeable consultants as interim compliance officers to fill a “gap” created by someone retiring or moving on to another opportunity. Often, the gaps are not with the Chief Compliance Officer position, but with manager level compliance professionals. In some instances, that gap lies with internal auditor and investigator positions. Ms. Castaldo noted that the consultants she provides to clients offer many advantages, including experience dealing with a wide range of compliance issues. These consultants have experience in responding to identified problems and educating the board and executive leadership on the regulatory environment and enforcement changes. Using these experts also provides an independent assessment of the compliance program’s status. Ultimately, this can provide a road map for the permanent compliance office to improve its compliance program effectiveness.
Carrie Kusserow, Chief Operating Officer for Strategic Management Services, made it clear that the temporary compliance officers that she provides to clients have previous experience as compliance officers, in addition to their experience providing advisory compliance services. She believes that engaging temporary compliance officers can be a very cost effective solution to fill the “gap”, as they can also provide an independent compliance program assessment. Ms. Kusserow noted that a standalone engagement for an independent compliance program effectiveness evaluation normally runs between $50,000-$100,000. As such, incorporating this project into the scope of a temporary compliance officer engagement can result in a big bonus for the organization. An independent evaluation can provide both detailed guidance and status updates for the permanent compliance officer replacement, once hired. Such an evaluation can also be extremely valuable for executive leadership and the Board of Directors, as they can gain a better understanding of their compliance program’s true status.
Looking for an Interim Compliance Officer?
The consultants at Strategic Management Services have decades of experience acting as interim and temporary compliance officers and addressing gaps in various compliance programs. For questions about our interim compliance consultants, or any of our other compliance program services, please feel free to contact our experts online, or give us a call at (703) 683-9600.Subscribe to blog