Kusserow on Compliance: Staffing of interim compliance officers

Serious risks arise when there is a gap in compliance officers. Not having someone managing the day to day compliance program is begging for problems. Filling a gap by having someone designated to manage the program until a permanent replacement is found is a bad idea. They likely will do as little as possible in an area they don’t know or could be expected to recognize and address problems in a timely and professional manner. Currently, on average, it takes a minimum of 3 to 5 months to find and bring on board a permanent replacement; and that is far too long to leave the program without active professional management. One solution to consider is using an expert as an interim compliance officer. Managed correctly, it can provide high-value service that is cost effective. Depending on the size and complexity of an organization, an expert may be able to manage the day-to-day operation and deal with emerging compliance issues at less than full time.

Kash Chopra, JD, MBA, has provided highly experienced and knowledgeable consultants as temporary and interim compliance officers to fill a compliance officer gap. Interim compliance officers can make significant improvements for any compliance program in a relatively short order. She noted among the benefits an interim compliance officer expert can bring to an organization is an objective assessment on the status of the program without being invested in any prior decisions. This added value of providing an independent compliance program effectiveness evaluation is a real bonus and this value by itself should save the cost of the engagement. Incorporating this in the terms of a temporary compliance officer engagement can produce the added benefit of gaining an independent assessment of the status of the program by outside experts that are independent. They can provide a road map action plan for the permanent office to improve program effectiveness. As far as the day-to-day management of the program, interim compliance officers bring the expertise in knowing how to respond to identified problems, as well as educating the Board and executive leadership on changes in the regulatory and enforcement environment. Her final advice on the use of the interim compliance officers is to remember that they are temporary compliance officers serving for a period of time until a permanent replacement can be found. As such, the agreement should set time frames of 60 to 90 days with the option to extend on a month to month basis.

For more information about engaging compliance experts to serve as Interim Compliance Officers, Chopra can be reached at KChopra@strategicm.com or (703) 535-1413.


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 © 2018 Strategic Management Services, LLC. Published with permission.