Kusserow on Compliance: Can small organizations use a part-time expert to run their compliance program?

The answer is yes, engaging a part-time expert as the designated compliance officer is an option for smaller organizations. It is widely recognized that keeping up with the vast range of compliance responsibilities can be a serious problem for a smaller organization. Smaller organizations generally cannot afford a full-time compliance officer and having someone performing that service as a secondary duty does not work, as primary duties will almost always takes precedence. The HHS Office of Inspector General (OIG) recognized this idea and stated that “for those companies that have limited resources, the compliance function could be outsourced to an expert in compliance.” The agency also noted that an outsourced party can provide services on a part-time basis.

Using experts with a proven record can potentially lower fixed costs, reduce staff loads, and avoid having to use someone for the job who is less qualified. It also reduces costs of recruiting, supporting full-time compliance staff and benefits. Using a part-time outside expert can accomplish more than assigning the responsibilities to a lesser experienced full-time employee. In many circumstances, it may only require 40 to 100 hours per month. Compare this with the cost of hiring a full-time employee. The reported base salary for this type of position is around $106,000 per year for small companies according to Thomson Reuters. The Health Care Compliance Association’s Healthcare Compliance Staff Survey cited the average at around $125,000, plus benefit cost.

Best Practice Tip

Compare the cost of hiring a full-time compliance officer against that of using a part-time expert acting as the designated compliance officer.

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 © 2016 Strategic Management Services, LLC. Published with permission.