Search Results for: interim

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.

Connect with Richard Kusserow on Google+ or LinkedIn.

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

Kusserow on Compliance: The relationship between an Interim Compliance Officer and the CEO

Getting the right start is the best way to have a good return on investment

Catie Heindel, J.D., a highly experienced compliance consultant who has served as an Interim Compliance Officer, notes it is increasingly common for healthb care organizations to seek a temporary compliance officer to cover a gap. Though the rationale behind hiring an interim compliance officer is different for every organization, the ultimate goal is usually the same—to provide high quality and efficient compliance program leadership that will reduce exposure to unwanted risks and problems. Preparation and communication with staff to introduce the person selected to act in an interim capacity is very important to having a successful result from the engagement.

Ensuring a successful hiring decision really needs the personal involvement of the CEO. The OIG compliance guidance stresses that the compliance officer should report directly to the CEO. This sentiment also applies to Interim Compliance Officers; and the best return on investment for having someone move in and successfully temporarily fill a compliance officer gap is for the CEO to establish a direct reporting relationship. It is also helpful for everyone involved if the CEO personally provides a detailed background briefing on the organization that includes:

  • management structure;
  • mission/vision;
  • why the person was engaged;
  • expectations for the engagement; and
  • their role in the organization.

Upon arrival, the CEO should ensure there is a proper “on-boarding” process that includes personally introducing the interim compliance professional to the executive leadership, key program managers, legal counsel, HRM, and Board members. This interaction, from the outset, sets the right tone and will help to ensure that the interim is in lockstep with the CEO.  Furthermore, this empowerment exercise will permit the interim to move more quickly in gathering the reins of the compliance program and guard against having anything fall “beneath the cracks”.  It will also help the interim compliance professional to “hit the ground” running immediately and begin productive work.

For more information regarding engaging and preparing Interim Compliance Officers, Catie Heindel can be contacted at www.cheindel@strategicm.com, or via phone at (847) 707-9830.

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.

Connect with Richard Kusserow on Google+ or LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

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

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.

Connect with Richard Kusserow on Google+ or LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

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

Kusserow on Compliance: Temporary staffing and interim compliance officers

When individuals from a compliance office, including compliance officers, retire, move to new organizations, or are replaced for any reason, it can leave a gap in the day to day management of the compliance efforts that can create a serious risk. This underscores the importance of not only finding a suitable replacement quickly, however, that process can be time consuming. As such, it is not surprising that many organizations turn to engaging temporary expert assistance, including acting the use of Interim Compliance Officers (ICOs). This decision is often made with the realization that having a gap in the program over a period of months, or designating someone internally to do the work can be dangerous. Smaller organizations are not likely to have anyone sufficiently qualified to carry out all the duties. It is also risky to have someone making decisions, or failing to make decisions, that may create liabilities. The worst decision is selecting someone to take on the role of compliance officer as a temporary set of secondary duties to his or her current job. This will always lead the individual to continue giving priority to their regular job and do as little as possible in compliance.

Temporary staffing has the advantage of quickly filling immediate needs, including addressing any pending issues or problems. Properly experienced professionals can hit the ground quickly and be effective, not just be a placeholder. This approach will permit the organization to continue its search for the permanent replacement.  Using a properly qualified outside expert presents a lot of advantages. The expert can bring the experience of having served in other organizations and dealing with many of the same issues already addressed by prior jobs.  Important also is that they have not been invested in any prior decisions, nor have they been aligned with any parties in the organization. Most importantly, the expert brings “fresh eyes” to the program. An outside expert can provide an objective assessment on the state of the compliance program, offer suggestions, and give guidance for improvements.

Finding the right ICO with a lot experience and technical skills can make significant improvements for any compliance program in a relatively short order.  In fact, it may be the most economical means to have an independent evaluation of a compliance program. However, care needs to be taken when deciding on an expert. It is important that someone is not hired who is a “cast off” from another organization. As such, it is important that references be checked carefully to be assured of someone who is competent and reliable. It is important to design the engagement to bring maximum return of benefit for the cost. Therefore, in the case of an ICO, consideration should be given to the added scope of work. Organizations should expect to have the outside expert:

  • provide an independent assessment of the status of the compliance program;
  • make an assessment of high-risk areas that warrant attention;
  • be able to efficiently and effectively address compliance risk issues that may arise;
  • offer suggestions to build a firmer foundation for the compliance program;
  • review the existing Code, compliance policies, and other guidance;
  • evaluate the quality and effectiveness of compliance training;
  • develop a “road map” for the incoming compliance officer to follow;
  • assist in identifying and evaluating candidates for the permanent position;
  • assess resources needed to effectively operate the compliance program;
  • identify or build metrics that evidence compliance program effectiveness; and
  • develop comprehensive briefings for management and board on the state of the program.

Finally, for even fairly large organizations, a true compliance expert can hold things together for several months without having to be full time on site. Most organizations can keep their compliance program operating with many of the added benefits noted above, using an expert for 50 to 80 hours per month. After all, the ICO is holding the compliance program together, not building it.

 

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.

Connect with Richard Kusserow on Google+ or LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

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