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The Strategic Management Services and SAI Global Ninth Annual Healthcare Compliance Benchmark Survey found that most Compliance Officers were stressed about meeting all of their obligations. One third of respondents indicated that the Compliance Office was a one-person operation. The combination of increasing responsibilities during a time of heightened government agency enforcement is likely stretching resources for most Compliance Offices. It is common to be looking for alternative ways to meet these resource challenges, especially among smaller organizations.

Kashish Parikh-Chopra, JD, MBA, CHC, CHPC, has assisted organizations in meeting resource challenges, and she reminds smaller organizations that they have the option of engaging a part-time expert as a Designated Compliance Officer. The OIG recognizes that keeping up with the wide range of compliance responsibilities can be a serious problem and may create a situation where an organization cannot afford a full-time Compliance Officer. Performing compliance responsibilities as a secondary duty does not work because part-time employees are not likely to have the capacity to do justice to the Compliance Program. In addition, the individual’s primary job duties will almost always take precedence, leaving the Compliance Program incomplete and ineffective. The OIG recognizes that, “For those companies that have limited resources, the compliance function could be outsourced to an expert in compliance.” The OIG also notes that an outsourced party can provide services on a part-time basis. Using experts with a proven record can potentially lower fixed costs, reduce staff loads, and avoid appointing someone who is less qualified for the role. It also reduces costs of recruiting, supporting full-time compliance staff, and benefits. As a rule, using a part-time outside expert can accomplish more than using a lesser experienced full-time employee. For many, it may only require 40-100 hours per month. Ms. Parikh-Chopra advises organizations to compare the cost of hiring a Compliance Officer against that of a part-time expert acting as a Designated Compliance Officer.

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For more information on this subject, Kashish Parikh-Chopra can be reached at kchopra@strategicm.com or via telephone at (703) 535-1413.

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