Kusserow on Compliance: Co-sourcing benefits to compliance officers

More and more compliance officers seek ways to supplement their limited in-house resources and have found co-sourcing as a means to meet the challenges of the program. For many, the additional responsibility of maintaining a HIPAA privacy officer has forced them to look at various options as the pressures of such new responsibilities often stretch limited internal resources and expertise. Co-sourcing is the solution for many. It represents an alternative option to simply trying to do everything within house staff or completely outsourcing the program to experts. For those considering co-sourcing, it may be worthwhile to examine the benefits of co-sourcing arrangements to determine if it makes sense in light of current resources measured against the obligations and responsibilities of the compliance program. The following is a list of potential benefits of using co-sourcing.

Benefits of co-sourcing compliance arrangements

  • Gain immediate access to specialized resources and experts not available internally
  • Less expensive to hire experts for limited services than hire full new full time staff
  • Addresses the problem of how an unexpected loss of staff could create resource issues
  • Bring the benefit of experience with other organizations
  • Provide subject matter expertise
  • Fill any lack of in-house expertise in selected areas
  • Facilitate meeting the ebb and flow of managing all the compliance obligations
  • Keeping current with the ever changing regulatory and enforcement challenges
  • Accessing needed services, on-demand
  • Can be tasked to complete special projects
  • Fill a knowledge gap in training, fraud risk assessment, or other compliance-related needs
  • Meet obligations across multiple facilities in different jurisdictions
  • Provide needed benchmarking information
  • Develop best practice solutions to problems identified
  • Provide benchmarks of current processes against compliance standards
  • Implement or improve compliance effectiveness metrics
  • Quickly address new regulatory and emerging risks
  • Promptly and efficiently meet new leadership demands
  • Implement best practice standards and processes
  • Perform enterprise risk management (ERM) evaluation and project planning
  • Provide any sudden need for investigative or forensic expertise
  • Evaluate ongoing monitoring of compliance high risk areas
  • Develop and execute compliance work plans using highly-skilled, experienced experts
  • Enable the compliance officer to stay focused on program management and strategic planning
  • Eliminate the need for training and managing of house staff
  • Increased flexibility in using experts who understand related laws/regulatory requirements
  • Provide complete assurance regarding independence and objectivity in work performed
  • Generate compliance program reports to oversight committees
  • Provide compliance program and project management
  • Perform operational and compliance auditing
  • Monitor remediation of identified compliance issues
  • Improved sharing of physical compute resources across virtual workloads
  • Better allocation of compliance office personnel
  • Shorten project development cycle, lower cost, and improve product quality
  • Maintain control and decision-making power with the compliance office

If the decision is made to consider co-sourcing as an option, then other questions should be addressed, such as: (a) what functions or tasks that might be best handled with a co-sourced partner; (b) where to find qualified co-sourced partners; (c) how much will it cost; and (d) how to evaluate whether those considered can do the work at direction of the compliance office in a timely and efficient manner? The best starting point to gain answers to these questions are with others known to have co-sourced work that can provide feedback on their experience; or go online and look for firms that can perform the needed work and find out what they would charge and how they would operate under a co-sourcing agreement. As with all experts services contracted, look for specific experience in performing the needed tasks or function.

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 © 2015 Strategic Management Services, LLC. Published with permission.