Kusserow on Compliance: The cost-benefit of engaging interim compliance officers

Carrie Kusserow is COO for Strategic Management, which provides interim compliance officers (ICOs) for health care organizations. She noted that in making the decision about engaging an ICO, close consideration should be given to the return on investment (ROI). In fact, most decisions of this type are made around this time of the year, as organization begin thinking about revitalizing their compliance program in the New Year. The best results from engaging ICOs come from having several different related tasks in a single engagement. First and foremost is managing the program. However, that by itself may not gain the best ROI. She recommends that the ICO engagement include cost avoidance from incidents and event that could give rise to liabilities. Part of this task would be include a “gap analysis” on the status of the program.  Another task should be to help define what is needed in the recruitment of a permanent compliance officer. Also, before the ICO leaves, it is highly advisable to have a full report provided to the executive leadership and board on what was found with regards to the program and anything needed to ensure that it operates in a manner to achieve the desired outcome.  Additionally, the ICO can assist in identifying the education, skills, leadership experience and personality needed in the permanent replacement.

Kashish Parikh-Chopra, J.D., MBA, CHC, CHPC notes that a growing number of health care provider organizations have been turning to her firm to find an Interim Compliance Officer (ICO) to fill temporary vacancies, evaluate status of the compliance program, and mentor current compliance office staff.  Her firm, Strategic Management provides such services with individuals who have all the necessary experience, technical skills, proven leadership and personality to properly fit into the senior management team. Often, executive leadership or the Board decides it is necessary to engage an expert to make improvements or to keep operations running smoothly and addressing issues, while the organization searches for the right permanent candidate. It also provides a fresh set of professional eyes examining and testing the compliance program for any potential deficiencies. By including these evaluations and reporting requirements in the ICO engagement, the organization receives a benefit, which if contracted for separately, would cost twice as much. What this means is that for the cost of a full compliance program evaluation, the ICO would also manage the program for the gap period.


For more on Interim Compliance Officers, Kashish Parikh-Chopra can be reached at kchopra@strategicm.com or via telephone at (703) 535-1413.  Also visit https://compliance.com/services/interim-compliance-officer/ or see Journal of Health Care Compliance at https://compliance.com/publications/understanding-the-role-of-an-interim-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 © 2018 Strategic Management Services, LLC. Published with permission.