More Compliance Officers (CO) are engaging in Virtual Compliance Assistance (VCA) as an affordable option to quickly adapt to the industry’s shifting regulatory environment.
Challenged by increasing and changing regulations, more Compliance Officers (CO) are engaging in Virtual Compliance Assistance (VCA) as an affordable option to quickly adapt to the industry’s shifting regulatory environment, while maintaining the daily functions of the compliance program. Compliance departments, like other non-revenue-producing departments, are losing resources as hospitals and physician practices of all sizes face unprecedented financial challenges. Even before the COVID-19 pandemic, compliance departments often faced hurdles in securing adequate resources to execute their compliance work plans and support their organizations’ compliance programs.
Some COs find they are engaged with multiple advisors of virtual compliance services in order to meet varying needs. However, engaging a VCAP provides the greatest advantage, as it fully leverages the institutional knowledge gained as the relationship grows. A VCAP can reassure the CO and the Board that the organization is continuing to assess and mitigate risks, while adapting to a fluid regulatory environment. Further, because a compliance program seldom scales at the same pace as the organization’s growth, a VCAP can bridge gaps and minimize potential vulnerabilities. A VCAP offers a cadre of compliance advisors who can provide bandwidth, as well as a deep bench of experts who can meet nuanced compliance needs.
For example, a VCAP offers both subject matter expertise and experience, derived from working with many different clients on evolving and complex regulations that may require research and evaluation to determine the potential impact on an organization. Consequently, a VCAP can advise as to how a crisis may affect current risk exposure, and how priorities should be assessed and realigned. A VCAP can also assist with routine work plan items, as well as unexpected high-risk items that require additional resources.
A primary advantage of a VCAP is that it can scale its services to meet the specific needs of an organization and its compliance program, regardless of size. A smaller organization may engage a VCAP to support its compliance program in totality because its compliance budget cannot support a full-time position, or partially because the individual serving in the CO role is stretched too thin serving multiple roles. A mid-to-large size organization may engage a VCAP to provide additional bandwidth to complete compliance work plan items. Any size organization can enjoy a strategic advantage by engaging a VCAP to help with specific needs, or to sustain appropriate oversight of the compliance program and support annual compliance initiatives.
VCAPs are financially attractive to COs because they are less expensive than a full-time equivalent (FTE), yet are rich in compliance knowledge. Additionally, VCAPs are agile and can simultaneously support various needs, as well as provide immediate on-call support. VCAPs offer a resource of multiple experts in markets where demand is high. Support can be tailored to meet specific requests, and thus COs reap the maximum benefit of each compliance dollar spent.
Organized in alignment with the Seven Elements of an Effective Compliance Program, VCAPs partner with and support COs by providing services to meet a variety of compliance needs. Such services include:
Depending on the size and compliance needs of an organization, VCA models will vary. The most basic model may be a flat fee per month for an established set of hours, to be used at the CO’s discretion. This model is typically used for more advanced compliance programs that simply need expertise as regulations change or new ones develop.
More advanced models will build upon themselves and may include a variety of the “a la carte” assistance outlined earlier. The advantage of VCA and a VCAP is the flexible budgetary possibilities that offer customizable options maximizing the value of every dollar invested in an organization’s compliance program.
When effectively deployed, a VCAP is not only economically efficient in that it consolidates the role of multiple advisors, it also garners increased executive and shareholder confidence because of the expertise it offers. A VCAP provides sustainability to compliance programs that otherwise might struggle to appropriately support the organization. Working as a trusted and valued member of your team, a VCAP gains the institutional knowledge of the organization and compliance program, resulting in efficiencies and the most value for building and supporting a robust compliance program.
About the Authors
Kristen Lilly Davidson MHA, CCEP-I, CHC, RHIA, CPHQ, is a consulting manager at PYA, who brings more than two decades of diverse experience to the Firm’s Compliance Advisory team, including health system operations, regulatory compliance, human resources, and revenue cycle improvement. She is a published author and co-author, and routinely speaks on regulatory compliance at national meetings.
Lori Foley, CMA, CHC, PHR, SHRM-CP, leads PYA’s Compliance service line and is a member of PYA’s Compensation Valuation Physician Service teams. She combines industry experience in managing multiple hospital-owned practices with over two decades of consulting experience advising physicians, and organizations affiliating with physicians, in the areas of compliance, compensation, strategic planning, operational and financial improvement, MIPS and affiliation structures.