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Questions Regarding the Use of Compliance Liaisons
Typical Duties and Responsibilities
Compliance programs must adapt to constant changes in health care regulations, at both the state and federal levels. Not only do health care organizations have to keep track of, and adapt to, these changes, they must also ensure compliance at their affiliated facilities as well. In the traditional compliance program design, the compliance officer reports to the CEO and keeps executive leadership informed on compliance issues, often through an executive or management compliance committee. However, the compliance officer’s span of direct contact is limited and often cannot adequately reach outlying operations or facilities. As a result, there has been a growing trend to establish a compliance liaison program to assist communication from the corporate compliance office to outlying facilities. This line of communication can also relay corporate issues found within the local environment back to the corporate compliance office. Compliance liaisons can help localize compliance risk monitoring and provide useful input to the compliance officer on how to measure compliance program effectiveness at facilities and operations that are removed from corporate headquarters. These liaisons become, in effect, risk and control managers.
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Kashish Parikh-Chopra, MBA, JD, noted that her firm, Strategic Management Services, has extensive experience in evaluating, enhancing, and building a corporate compliance program, and has done so for more than two hundred organizations. Many of those organizations had a compliance framework that spanned multiple facilities and work sites. Ms. Chopra believes that all locations should have some sort of compliance office presence; however, only larger organizations can afford to have full-time compliance officers in every location. The more common practice has been to employ part-time compliance liaisons. These part-time employees can be used to monitor and analyze regulatory developments and help determine which parts of the organization may be affected by new regulatory initiatives. Still, compliance liaisons need to be properly equipped to carry out their duties. Therefore, when developing compliance liaison positions, it is important to ensure that: (a) compliance liaison duties and responsibilities are described in detail; (b) adequate time, resources, and accountability is given to perform their duties; (c) the appropriate level of support from local leadership is given for the work the compliance liaisons do; and (d) compliance liaisons have been trained on meeting their obligations. The role and extent of compliance liaison duties will depend on the size of the organization and diversity of services being provided. Most organizations that establish a compliance liaison program tend to structure the position along the same lines as other staff functions. In this framework, liaisons typically perform compliance functions on a part-time basis and devote most of their attention to their primary duties. Compliance liaisons most often report directly to their functional supervisory chain, with a dotted-line reporting relationship to the compliance office.
Typical Compliance Liaison Duties and Responsibilities
- Assisting in and contributing to the compliance risk assessment process;
- Assisting in the development and distribution of the code of conduct and compliance policies;
- Providing a communication channel to and from the compliance office;
- Assisting in developing and providing employee compliance training;
- Helping to keep track of employee compliance training;
- Serving as a resource to address compliance questions;
- Assisting in conflicts of interest related to gifts and entertainment decisions;
- Receiving allegations of code of conduct violations and other compliance violations;
- Escalating allegations of wrongful behavior to the compliance office;
- Assisting with compliance investigations and tracking them to resolution; and
- Monitoring and reporting on compliance program effectiveness in their area of responsibility.
For more information regarding compliance liaisons and how to improve your compliance program operations, contact Kashish Parikh-Chopra at KChopra@strategicm.com or (703) 535-1413. Or submit an online contact form: https://compliance.com/contact-us/