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.

Connect with Richard Kusserow on Google+ or LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

Copyright © 2019 Strategic Management Services, LLC. Published with permission.

Kusserow on Compliance: Extending and economizing compliance programs—tools, services and tips

Compliance officers are confronted with a host of ever increasing external regulatory and internal demands with most having inadequate resources to meet all the challenges.  Furthermore, it is becoming increasingly common to add responsibility for HIPAA Privacy to the portfolio of compliance officers’ duties. All of this results in ongoing efforts to find ways to extend capabilities, while being sensitive to limited available resources. There are finite options available. Of course, the preference is to handle all this with internal staff. However, unfortunately for most compliance officers, limitations on increased office staffing limits this option. In some cases, organizations turn to Out-Sourcing their compliance program. This is most often done as a measure to temporarily fill gaps with an Interim Compliance Officer (ICO) when an incumbent leaves, or smaller organizations contracting the function out to an individual or firm to assume responsibility by providing a Designated Compliance Officer (DCO). Co-Sourcing is a third option and “middle ground” between hiring new staff (In-Sourcing) and Out-Sourcing and may prove to be the best strategy available for compliance officers to take huge pressures away, if implemented correctly. It involves using limited vendor services and tools to address key elements in the compliance program.

Co-Sourcing Compliance Services/Tools

The key factor that separates Out-Sourcing from Co-Sourcing is the maintaining control and direction under the compliance officer. It involves using a third-party on an ongoing basis to supplement limited staff resources by carrying part of the workload. It can help bridge the gap without compromising the ability to easily return to a structure where the compliance officer reassumes full operation when staffing issues are resolved. This approach is also recognized by the OIG as a useful solution to where an organization is limited in-house compliance expertise and resources. Compliance Officers are increasingly employing this as a means as a practical solution when confronted with a staffing shortage and offers the advantage of using limited, rather than full time services. It also may permit gaining access to a range of specialist without having them full time on payroll.

Common Types of Co-Sourcing Tools/Services

Co-Sourcing Expert Services

There are a number of advantages of engaging outside experts for limited scope of work, especially to address staff shortage or obtaining technical skills that do not exist in-house. Careful use of vendors to supplement the Compliance Office can not only gain access to experts not available in-house, but can save time, money, and effort; while maintaining flexibility to end an arrangement at anytime, when no longer needed. The following are common examples of Co-Sourced services:

Co-Sourcing Tips

  1. Clearly define duties, tasks, responsibilities, and methodology for vendor to follow.
  2. Ensure the agreement is flexible to expand or contract levels of service as needed.
  3. Look for providers that have industry specific expertise.
  4. Check experience and seek references of the firm.
  5. Ensure individuals provided have the needed skills, experience, and expertise.
  6. Bigger is not always better, as smaller niche firms are more likely to provide better, less expensive services.
  7. If planning to Co-Source for multiple tools and services, consider seeking discounts for a “bundling” arrangement.

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 © 2017 Strategic Management Services, LLC. Published with permission.