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Don’t leave a legacy of problems because of your departure 

Compliance professionals are moving from one organization to another, as they continue advancing in their career. However, leaving an organization in a lurch is not a good practice and it may negatively impact one’s reputation. The best practice for Compliance Officers is to provide as much notice as possible to permit the organization to find a replacement. However, even if a Compliance Officer provides such notice, the organization may be left with a serious gap in compliance program management because finding a replacement often takes several months. Consequently, many compliance problems may go unaddressed during that gap. Ultimately, these problems may become part of the previous Compliance Officer’s unwanted legacy. To avoid this, departing Compliance Officers should take steps to ensure that the program’s operation continues uninterrupted, until the organization finds and onboards a permanent replacement. For some organizations, the answer may be promoting someone in the compliance office, however this will not be the right solution for most organizations. Designating someone outside the compliance office, but within the organization, to temporarily manage the program is NOT a good solution for many reasons. Internal replacements will not have the expertise to run the compliance program. Further, that individual may lack commitment to the job and be unwilling to challenge other managers on compliance related issues. The better solution is for organizations to quickly find a compliance expert who will serve as an Interim Compliance Officer. The best solution would be to have the departing Compliance Officer debrief the Interim Compliance Officer. This would permit the program’s management to continue without interruption. Also, who better to ensure that the individual has the knowledge, experience, and good judgment to meet the organization’s specific needs? Factors to consider when choosing an Interim Compliance Officer include the following:

  • Past Compliance Officer experience;
  • Evidence of working at the executive and Board level;
  • Experience with management of staff and projects;
  • Knowledge of the required elements of an effective compliance program;
  • Awareness of applicable laws/regulations (e.g. AKS, Stark Laws, FCA, HIPAA);
  • Experience in the operation and resolution of hotline allegations and complaints;
  • Understanding of how to conduct internal investigations/inquiries;
  • Experience in conducting ongoing auditing/monitoring of high-risk areas; and
  • Ability to develop/deliver compliance education and training programs.

Strategic Management Services places temporary and Interim Compliance Officers.  For more information, come see us at the HCCA conference, booth #420. You can also visit https://compliance.com/services/interim-compliance-officer/ or contact Richard Kusserow at rkusserow@strategicm.com.

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