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Compliance offices are overloaded with work from time to time. This happens as a result of responding to some urgent matter, or from having too much on their plates with too little resources to meet all the ever-changing regulatory and enforcement challenges. One way that many compliance offices are meeting the challenge of short-term needs is by having a Master Service Agreement with an expert compliance advisory services firm. The firm provides on-call experts to supplement the compliance office with specific duties or assignments on an as-needed basis.
Suzanne Castaldo, JD, CHC, an expert on the subject, notes that many smaller organizations cannot justify the cost and burdens of supporting the program in-house and therefore outsource it entirely to a Designated Compliance Officer. These experts are most often engaged on a part-time basis. The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recognized the use of Designated Compliance Officers to serve in that capacity for several organizations. The benefits of using outside experts include them bringing the experience of many organizations to the entity. Moreover, the entity only pays when there is a need and the fee terms have already been settled.
Kashish Parikh-Chopra, JD, MBA, CHC, has served as a compliance officer on multiple occasions. Ms. Parikh-Chopra makes the point that in such a rapidly evolving regulatory and enforcement environment, health care organizations cannot afford to let their compliance programs be outdated and ineffective. Having a consulting firm under an on-call agreement to assist, as needed, in developing or managing a compliance program makes a lot of sense. In most cases, these would be limited short-term engagements that can bring a lot of expertise and value at a limited cost.
Jillian Bower Concepcion, MPA, CHC, CHPC, is a highly experienced consultant and has been instrumental in providing supplemental support to compliance officers for years. Ms. Concepcion notes that co-sourcing has evolved as a “middle ground” between in-sourcing and out-sourcing. It offers the advantage of letting the entity’s compliance officer maintain control and direction of the program. Co-sourcing can help bridge the gap without compromising the Compliance Officer’s flexibility to easily re-assume full operation and end co-sourcing at any time, when staffing issues are resolved. Common co-sourcing arrangements include using a consultant as a HIPAA Privacy and/or Security Officer, conducting ongoing monitoring/auditing, performing enterprise risk management/analysis, engaging a Statistical Data Claims Analyst Expert to determine error rates, hotline operations management, compliance investigations/training, reviewing arrangements with referral sources, and managing the sanction screening operations.
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