Blog Post

Temporary Compliance Staffing

Richard P. Kusserow | March 2022

Chances are your organization is currently dealing with temporary compliance staffing issues. In fact, most health care organizations are struggling with maintaining staff, not only in terms of caregiving services, but also in business operations, including compliance. COVID-19 has obviously been a contributing factor with many employees being reluctant to join new workplaces during the pandemic. There is also evidence across all sectors of the economy that an unusually large number of people retired from their jobs when the full force of the pandemic hit. 

Whatever the causes, continuing operations when short staffed is challenging. For many, the answer may be using consultants on a temporary basis until a permanent solution is found. Benefits of using temporary consultants, include:

  • It prevents gaps that could contribute to potential regulatory or legal issues;
  • It is a cost-effective means to cover work for employees who go out on family, maternity leave, etc.
  • An experienced person, in most cases, can jump in quickly and hold together a position that is usually full-time on a part-time basis;
  • An outside expert might provide fresh eyes, skills, and ideas useful for advancing the compliance program;
  • An outside expert can provide instant impact;
  • For the short-term, almost all of the work can be done remotely, which avoids travel expenses; and
  • Overhead costs, including benefits, are reduced since the outside expert is temporary and only gets paid for the hours worked. 

One of the most critical components of temporary staffing is the selection process. It is critical to find people who are dependable, reliable, and capable of doing the required job. Here are some points to consider:

  • Clearly define the temporary duties, expectations, and responsibilities;
  • Avoid complicating legal issues and ensure the job doesn’t become “permatemp”;
  • Ensure candidates prove they can perform the specific services needed, and verify their experience fits your organization’s needs;
  • Ensure candidates pass a background check and are screened against relevant sanction lists;
  • Determine if there is a reputable firm standing behind the individual being considered;
  • If the individual does not work for a firm, verify that they carry liability insurance;
  • Ensure that any arrangement can be terminated at will with written notice; and
  • Remember to have a HIPAA Business Associate Agreement with the temporary employee or the firm.

For more information about temporary compliance staffing, contact Richard Kusserow at rkusserow@strategicm.com.

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 2,000 health care organizations and entities in developing, implementing and assessing compliance programs.

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