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One of the most significant company trends over the last years has been to outsource functions that are not core service activities. Cutting expenses and acquiring proficiency are the two most widespread motivations for outsourcing. This pattern has long given that reached corporate compliance programs. Many concerns surround this practice in the compliance arena.

Why Outsource Compliance?

The first concern is: why should an organization engage an outdoors expert to help in running the compliance program? The reality is that numerous compliance workplace tasks are regularly contracted out to suppliers to enable the compliance office to focus on the program's core components. Hotlines, sanction screening services, and training programs are frequently outsourced functions.

In some cases, a compliance officer's departure produces the need for assistance up until the company can hire a replacement. In others, an existing compliance program needs assistance to handle added duties, such as compliance management or HIPAA privacy/security officer support.

When Should You Outsource Compliance?

Organizations choose to work with compliance professionals after recognizing weak points or gaps in their operations, such as vacancies in compliance, personal privacy or security officer functions. Sometimes, federal government investigation drives the decision to bring in professionals. Corporate Integrity Agreements mandate that an organization vouches for having a totally operating and reliable compliance program.

Managed Care statutes need maintaining an effective compliance program and notifying CMS when a compliance officer vacancy happens. And under the Affordable Care Act, CMS is needed to develop mandated compliance program requirements. Once these requirements are in result, many will seek expert support to satisfy them.

Where Can You Find Compliance Outsourcing Services?

Where can companies discover needed compliance competence? The simplest starting point is inspecting the internet to discover professional journal posts on the topic. This can offer additional insight and recognize experts on the subject. A search can also determine firms that may supply the required services.

Who Should You Outsource Compliance To?

Who are some specialists that can fill gaps or supplement compliance programs, and have also developed, evaluated, and handled reliable compliance programs? They are people with hands-on experience in multiple scenarios and settings that make them specialists.

The following are examples of professionals with comprehensive compliance program consulting experience, who have worked as compliance officers in several roles:

Cornelia Dorfschmid, PhD, who has more than 20 years of healthcare consulting experience and has worked as designated/interim compliance officer for hospital systems and doctor practices on several occasions.
Steve Forman, CPA, with 12 years as a expert, 10 years as VP for Audit/Compliance at a hospital system, and has actually served as interim/designated compliance officer several times.
Suzanne Castaldo, JD, CHC, a skilled specialist who has served as interim/designated compliance officer numerous times.

How Can You Best Outsource Compliance?

How can organizations use compliance specialists to its best advantage? Using qualified specialists has numerous advantages, but the secret in employing them is to bring an optimum return of advantage for the cost by ensuring included worth. In addition to everyday management, consider including a few of the following:

1. Examine the program to confirm strengths and identify chances for enhancement;
2. Conduct an independent examination of the program for senior management and board;
3. Review the Standard Procedure and other written assistance;
4. Evaluate the quality and effectiveness of compliance training;
5. Assess high-risk locations that necessitate attention;
6. Assess resources needed to successfully run the compliance program;
7. Use experts to identify and construct metrics evidencing compliance program effectiveness;
8. Use specialists to assist in identifying and evaluating candidates for the irreversible compliance officer position; and
9. Provide a "roadway map" for incoming compliance officers to follow.

What Level of Effort Should You Take Into Outsourcing Compliance?

What level of effort do companies need to utilize compliance experts in compliance programs? Even for fairly large organizations, a true compliance professional can hold the program together for a number of months without having to be on-site full-time. Most companies can run compliance programs effectively through using a professional for 50-80 hours monthly for up to 6 months up until having a long-term compliance officer in place becomes important.

Smaller companies and the majority of doctor practices will need experts for just half the time. Due to advances in innovation, not all hours need to be on-site. However, the key is to have the specialist on-call to resolve any emergent issues. Notably, the OIG has accepted that for smaller sized organizations, engaging a certified expert as the Designated Compliance Officer might make more sense. The OIG cites many factors for an organization to think about using an outside expert instead of a W-2 complete time staff member.

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has actually assisted over 3,000 healthcare organizations and entities in establishing, implementing and evaluating compliance programs.