Hospitals and physician practices are increasingly hiring interim compliance officers (COs) for periods of six to 18 months. Usually they are lawyers or consultants hired to satisfy the sometimes overlapping needs of providers.

Sometimes organizations hire an interim compliance officer when their regular compliance officer has left, and they want the compliance program evaluated from inside over a long period of time to permit a very detailed assessment of the program. “Organizations will hire someone with fresh eyes to come in and manage the compliance program and evaluate where they are and recommend where to go,” says former HHS Inspector General Richard Kusserow, CEO of Strategic Management, a consulting firm in Alexandria, Va.

The board may want someone very experienced to take the reins and keep operations going to buy time while a permanent replacement is chosen and to scrutinize the program, especially if problems are suspected, says James Cottos, a former long-time HHS regional inspector general and chief inspector, who is now senior vice president of Strategic Management and a frequent interim compliance officer.

Sometimes interim compliance officers are needed to ensure an organization complies with the terms of a corporate integrity agreement or after management turnover, adds Cornelia Dorfschmid, Ph.D., an executive vice president of Strategic Management who also works as an interim compliance officer. Or the organization may be in great compliance shape — perhaps the compliance officer has mastered the challenge well and is now ready for something new — but the organization wants to confirm this through objective eyes and make sure the replacement is top-notch.

Also, smaller physician practices may band together to hire an interim compliance officer they can share until they agree on a permanent network-type compliance officer. But Kusserow warns that an interim compliance officer should never become the permanent compliance officer. “It would bias the process,” he says, and undermine the purpose of their mission.

This development is further confirmation that the compliance officer is a permanent, recognized part of the executive world, Dorfschmid says. Organizations do this sort of thing when CEOs and CFOs leave and time is needed to conduct a search for a replacement. “It’s no different from any other interim executive position.”

Cottos, who spent three decades as a federal investigator and executive for HHS and the Department of Treasury OIGs, has been an interim compliance officer for four different hospitals (not at the same time). One gig:Cottos was 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 Cottos as a pair of “fresh eyes” to evaluate the compliance program at the academic medical center, which has 17,000 employees.

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