Kusserow’s Corner: Using Vendors to Supplement the Compliance Program

As the job of Compliance Officers has grown in demands and complexity, it has become increasingly common for them to explore whether it makes sense to outsource elements of the compliance program. Outsourcing elements has been a long practice, most notably hotlines, training, and sanction-screening. More recently, many Compliance Officers have been given the responsibility for HIPAA privacy as a secondary duty. This has resulted in reaching out to experts to meet that challenge. The concept of outsourcing the entire program is also a common practice and recognized by the HHS Office of Inspector General (OIG), but should be considered only by smaller organizations when a full-time Compliance Officer does not make financial sense. When this whole area is examined, the scope of using vendors to fill gaps is quite large. In fact, it is the subject of a free hour long webinar on June 17. Supplemental support can be found for all seven of the standard elements of the Compliance Program. The most common areas that are outsourced include:

  • Hotline services
  • Sanction screening tools and services
  • Compliance training (interactive, modular, flat presentations)
  • Policy/compliance program document development
  • Auditing/monitoring tools
  • Compliance program evaluations/assessments
  • Employee compliance effectiveness surveys (compliance culture and knowledge)
  • Investigative support for suspected wrongdoing
  • Internal audit support services
  • HIPAA privacy/security functions

There are a number of challenges in trying to supplement the compliance program with experts and tool vendors. First and foremost is identifying credible vendors and consultants with adequate experience and expertise. Secondly, there is the problem of comparing for best quality and most reasonable cost. As a general rule, in seeking supplemental services, gaining content is more valuable than empty software. If a variety of tools and services are being considered, it is useful to look for vendors or consultants that have multiple tools and services, and whether they are willing to package or bundle multiple ones for discounts.

Whether the organization is large with a compliance office staffed by many people, or very small with only part-time compliance staff, it makes sense to engage in the exploration of what is out there that might make sense to enhance the compliance program in a cost-effective manner.

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2014 Strategic Management Services, LLC. Published with permission.