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Managing compliance program responsibilities is a daunting challenge and having a full time compliance officer for smaller organizations may be cost prohibitive. It is virtually impossible for an effective compliance program to be managed as a secondary duty, as anyone who has attempted this can agree. For organizations with limited resources it is becoming increasingly common to outsource compliance duties to a designated compliance officer (DCO). Using experts with a proven record can lower fixed costs, reduces staff load, and avoid having to use someone who is less qualified. It also reduces recruiting costs and avoids supporting full-time compliance staff with benefits. The Department of Health and Human Services (HHS) Office of Inspector General (OIG) has long-recognized that smaller health care organizations may reasonably decide to outsource compliance duties and activities; OIG stated that “For those companies that have limited resources, the compliance function could be outsourced to an expert in compliance.” An expert engaged on a part-time basis can often accomplish more than a lesser experienced full-time employee. For many, it may only require 40-100 hours per month, with most of the work being provided remotely. However, DCOs must make themselves immediately available in the event of compliance risk events. The cost of using a part-time expert must be compared with hiring a full-time compliance officer. Compliance experts know what it takes to operate an effective program and require no on-the-job training. They can bring tested best practices as a result of their experience, and, in general, have greater credibility with management than someone internal to the organization. It is very important that the DCO is properly qualified and truly is an expert with multiple levels of experience, not just as a compliance officer for an organization that may or may not have been a model program. Organizations should consider experts from an established firm with liability insurance coverage rather than a “free-lance” consultant.
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