By Sarah Couture (Principal at Couture Consulting LLC in Indianapolis, IN.)

Originally Posted on: Compliance Cosmos

Over the course of this calendar year, this column has discussed the importance of and strategies for engaging many different groups of people who impact compliance program effectiveness. From the board and internal stakeholders to vendors and your network of compliance contacts, we have provided a host of pragmatic ways to prioritize engagement in our compliance program efforts. In this final column, we will discuss effective working relationships with outside advisers, including consultants and outside counsel.

Those who have been compliance professionals for more than a brief period know there are times and seasons when securing outside expertise and help is necessary. This may be because an objective viewpoint is needed relative to an audit or investigation or to gain a third-party perspective on the compliance program’s effectiveness. It may also be because the internal compliance team does not have the requisite expertise to perform a specific needed task, such as an audit or investigation that requires skills not found in-house. Outside help may also be sought in times of compliance staffing transitions, whether for interim support or to provide additional fractional staffing for a season. There also may be issues that require outside legal advice and navigational support.

In times when outside expertise is required, there are several keys to ensuring the best outcomes and ensuring effective prevention and detection of fraud, waste, and abuse. First, be up-front with expectations and provide clarity and agreement—in writing—on the scope of what is being asked and the approach the outside adviser will be taking. Ensure there is a method to address and manage additional out-of-scope issues should they arise. Develop a communication plan with the outside adviser, including project milestones, meeting cadence, and how to communicate more urgent concerns that surface between regular touchpoints. Make sure the internal team is available to support the outside work and confirm what level of support will be needed. The internal team will need to provide time, discussion and perspectives, data, documents, etc., and the outside experts may need to accomplish the project objectives in a timely manner. Be transparent with the outside team and encourage your internal team and other stakeholders to be transparent as well. Not being forthright or obscuring information can result in not only inefficiency but also invalid findings or recommendations. Finally, communicate in a timely manner if concerns arise, addressing them before they become more complex.

Copyright 2024 Compliance Today, a publication of the Health Care Compliance Association (HCCA)