Using Co-Sourcing to Extend Limited Compliance Resources
Health care organizations are seeking the most efficient and effective means to meet the significant challenges of maintaining an effective compliance program in the ever changing regulatory and enforcement environment. As compliance officers seek ways to supplement their limited in-house resources, co-sourcing has been evolving as the preferred method when internal resources are lacking and out-sourcing the program to a Designated Compliance Officer from an expert firm is beyond the organization’s financial means. Co-sourcing involves using expert vendor services to supplement limited internal staff resources to carry out part of their workload. One of the most common co-sourcing methods is to engage a firm with compliance experts on an “on-call” engagement agreement. This would permit using the experts only when and as needed, while maintaining control and direction of the compliance program. The Department of Health and Human Services (HHS) Office of Inspector General (OIG) also recognizes this as a useful solution for an organization that is limited in its compliance expertise and resources.
Co-sourcing Benefits
- Gain immediate access to specialized resources and experts not available internally
- It is less expensive to hire experts for limited services than to hire new full-time staff
- Address the problem of an unexpected loss of staff that creates resource issues
- Bring the benefit of experience with other organizations
- Provide subject matter expertise
- Fill any lack of in-house expertise in selected areas
- Facilitate meeting the ebb and flow of managing all the compliance obligations
- Keep current with the ever changing regulatory and enforcement challenges
- Access needed services, on-demand
- Gain the ability to complete special projects
- Fill a knowledge gap in training, fraud risk assessments, or other compliance-related needs
- Meet obligations across multiple facilities in different jurisdictions
- Develop best practice solutions to problems identified
- Provide benchmarks of current processes against compliance standards
- Implement or improve compliance effectiveness metrics
- Quickly address new regulatory and emerging risks
- Promptly and efficiently meet new leadership demands
- Implement best practice standards and processes
- Provide any sudden need for investigative or forensic expertise
- Evaluate ongoing monitoring of compliance high risk areas
- Assist in development of compliance work plans
- Enable the compliance officer to stay focused on program management and strategic planning
- Increase flexibility in using experts who understand related laws/regulatory requirements
- Gain the capability to perform operational and compliance auditing
