Engaging and Onboarding Interim Compliance Officers

A growing number of health care provider organizations are turning to interim compliance officers to fill temporary vacancies, evaluate the status of their compliance program, and mentor current compliance office staff. It is becoming increasingly common for executive leadership or Boards of Directors to engage a compliance expert that makes improvements or keeps operations running smoothly while the organization searches for a permanent candidate. The question is: how do these organizations gain the best return on the engagement?

Carrie Kusserow, MA, CHC, CHPC, CCEP is the COO for Strategic Management Services, LLC, which provides interim compliance professionals for health care organizations. Ms. Kusserow noted that the OIG compliance guidance for health care providers stresses the importance of a compliance officer reporting directly to the CEO, including interim compliance officers. She advises that once a decision is made to hire an interim compliance officer, the CEO should keep the Board and executive leadership informed throughout the hiring process. This paves the way for the selected candidate and ensures that the Board and executive leadership are invested in the hiring decision. It also permits the interim compliance officer to better plan for the permanent candidate’s arrival and take control of the message that managers and other staff members receive. The preparation and communication regarding the introduction of the interim compliance officer is very important in ensuring successful engagement results.

Al Bassett, JD, has over thirty years of experience as a former Deputy Inspector General and compliance consultant. His experience includes placing qualified experts as interim compliance officers within organizations. This has often involved assisting clients when they made poor decisions about selecting their permanent compliance officer. Mr. Bassett stresses that organizations should take care when deciding upon an individual with the right experience and qualifications. Unfortunately, there are many individuals who have compliance officer experience but may not have served their prior organization’s needs.  In other words, the candidate may be looking for a job because they lost their last one. He therefore suggests that organizations question prospective candidates about their experience and why they are looking for an interim assignment. This line of questioning should include questions as to how the candidates would address known or suspected shortcomings in the compliance program and/or operational compliance gaps. Also, it pays to carefully check references related to their past compliance work to ensure that the person being considered has the expertise and interpersonal skills to work effectively within the organization. Mr. Bassett finds it helpful for an organization to consider the following questions when deciding whether to engage an interim compliance officer:

1. Why is it necessary to bring someone in from outside the organization?
2. How will the interim compliance officer function in the organization?
3. What will the specific objectives be for the engagement?
4. Will the interim compliance officer serve only as a placeholder in an already well-operating program?
5. Will the interim compliance officer be expected to make changes to improve operations?
6. What role will the interim compliance officer have in preparing the organization for the new hire?
7. How do you know that the candidate is truly an expert that can be relied upon?
8. Why are they available for this work?
9. How can their personal history and expertise be verified?
10. What will the interim compliance officer’s exact role be, and what level of authority with that person have?
11. Will the interim compliance officer be able to provide an evaluation report on the state of the program?
12. Does the proposed interim compliance officer carry a multi-million liability insurance policy?

Interim Compliance Officers can be a valuable resource, but health care organizations should consider several  key questions to ensure they select the right candidate with proper expertise and experience. For more on Interim Compliance Officers, visit https://www.compliance.com/services/interim-compliance-officer/ or see Journal of Health Care Compliance at:    https://www.compliance.com/publications/understanding-the-role-of-an-interim-compliance-officer/. 

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.