Kusserow on Compliance: Extending limited compliance resources

Co-Sourcing and On-Call Experts

Health care organization seek the most efficient and effective means to meet the great challenges of maintaining an effective compliance program in the ever-changing regulatory and enforcement environment. As compliance officers seek ways to supplement their limited in-house resources, Co-Sourcing has been evolving as preferred method when internal resourcing is lacking and out-sourcing the program to expert firms to provide a Designated Compliance Officer. Co-Sourcing involves using vendor expert services to supplement limited staff resources to carry out part of their workload. One of the most common Co-Sourcing methods is to engage firm with compliance experts on a “on-call” engagement agreement. This would permit using the experts only when and as needed, while maintaining control and direction of the program. This approach is also recognized by the OIG as a useful solution where an organization is limited in its compliance expertise and resources.


Co-Sourcing Benefits

  • Gains immediate access to specialized resources and experts not available internally
  • Less expensive to hire experts for limited services, than to hire full new full-time staff
  • Addresses the problem of an unexpected loss of staff and resulting resource issues
  • Brings the benefit of experience with other organizations
  • Provides subject matter expertise
  • Fills any lack of in-house expertise in selected areas
  • Facilitates meeting the ebb and flow of managing all the compliance obligations
  • Keeps organizations current with ever-changing regulatory and enforcement challenges
  • Accesses needed services, on-demand
  • Can be tasked to complete special projects
  • Fills a knowledge gap in training, fraud risk assessment, or other compliance-related needs
  • Meets obligations across multiple facilities in different jurisdictions
  • Develops best practice solutions to problems identified
  • Provides benchmarks of current processes against compliance standards
  • Implements or improves compliance effectiveness metrics
  • Quickly address new regulatory and emerging risks
  • Promptly and efficiently meets new leadership demands
  • Implements best practice standards and processes
  • Provides any sudden need for investigative or forensic expertise
  • Evaluates ongoing monitoring of compliance high risk areas
  • Assists in development of compliance work plans
  • Enables compliance officers to stay focused on program management and strategic planning
  • Increases flexibility in using experts who understand related laws/regulatory requirements
  • Performs operational and compliance auditing

For more information on how Co-Sourcing arrangements can work, contact Kashish Parikh-Chopra, JD 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 © 2019 Strategic Management Services, LLC. Published with permission.