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.