Understanding the Role of an Interim Compliance Officer

Numerous events can trigger the use of an Interim Compliance Officer (ICO).  The trick is finding ICO’s that are properly qualified.

Over the last few years, there has been growth in the use of interim, designated, and outsourced compliance officers. In most cases, these are outside experts brought in to operate or manage an organization’s compliance program. Interim compliance officers (ICOs), as is implied in the name, are temporary compliance officers serving for a period of time while an organization seeks a qualified permanent replacement.

Some ICOs may be designated compliance officers (DCOs). The Department of Health and Human Services (HHS) Office of Inspector General (OIG) has stated compliance program guidance, “For those companies that have limited resources, the compliance function could be outsourced to an expert in compliance.”  For purposes of this article we will focus on ICOs.