Jim Cottos answered this question. He is SVP at Strategic Management (jcottos@strategicm.com) having provided compliance advisory service for the past ten year. Previously served as Regional Inspector General and Chief Inspector for the DHHS OIG and as Assistant IG for Investigations at the Department of Treasury.
We are finding that more and more organizations are engaging experienced professionals and subject matter experts as Interim Compliance Officers (ICO). The normal period for such arrangements is between six to eighteen months. I have been an ICO at a number of organizations ranging from a small stand alone hospital to being the interim chief compliance officer for Baylor Health Care System in Dallas, while it took its time finding just the right person to replace the former compliance chief. Baylor also wanted me as a pair of “fresh eyes” to evaluate the compliance program at the academic medical center, which has 17,000 employees. In some cases, I was hired to be the ICO in order to build or rebuild a compliance program before having a permanent replacement take over. In other cases where I was engaged to be the ICO, it was to either build or rebuild the stature of the compliance officer before selecting a permanent one. The real questions to be asked are:
- When and under what circumstance is it advisable to take this course of action?
- What are the advantages of using an ICO?
- How do you select an ICO?
Hiring an ICO can have several benefits. First, the program is not left unattended and continues in full operation, leaving more time to find the right permanent compliance officer. Secondly, an ICO will be able to provide an independent assessment of the state of the program. Third, the ICO can assist in defining the specific qualifications for selection of the new permanent compliance officer. This latter point leads to the fact that the organization may wish to use the ICO to vet and assess candidates for the job. This may help avoid hiring someone who on paper looks great but is seeking a new job because they are not doing well in their current position. There are a lot of failed compliance officers looking for new jobs.
My suggestion to any organization considering hiring an ICO would be to take care to find someone with the right experience and expertise. You don’t want to bring a stranger into the work environment who is an amateur that could create confusion, stir up problems with the workforce or management, let along creating a potential liability. It is best to find a firm that has a lot of experience doing this kind of work, and who uses only qualified compliance experts.
Thank you for sharing the information with us
ICO most definitely sounds like someone who’d bring in a fresh new perspective to a company. It always helps to have different viewpoints of the same, helps growth not just vertically, but in relevant angles that matter.
This needs to reach a wider audience! Thank you