The Role of the Compliance Officer
Every effective compliance program requires a designated compliance officer who is responsible for developing, operating, and monitoring the compliance program. This individual typically reports directly to the CEO or the governing board to preserve independence and authority.
Core Responsibilities
- Overseeing development and periodic review of policies and procedures
- Coordinating training and education for the workforce
- Operating reporting mechanisms such as a compliance hotline
- Developing a system to solicit and respond to complaints
- Ensuring independent contractors and agents are aware of compliance expectations
- Conducting or coordinating internal investigations
Compliance Committee
The compliance officer usually chairs a compliance committee composed of representatives from key operational areas including HIM, coding, billing, legal, human resources, and clinical departments. This cross-functional structure ensures compliance risks are identified across the organization rather than siloed within a single department.
Where HIM Intersects With Compliance
Health information management directors often serve on the compliance committee because so many compliance risks flow through documentation, coding, and release of information processes. HIM professionals contribute expertise on record retention, coding accuracy, audit trail capabilities, and patient access rights that the compliance officer relies on to assess organizational risk.
Reporting Lines and Independence
A well-structured compliance program keeps the compliance function organizationally separate from the legal department and from operational management that it may need to investigate. This separation is tested on the exam through scenarios asking whether a compliance officer's independence has been compromised by an inappropriate reporting structure.
Common Exam Traps
- Confusing the compliance officer role with the privacy officer role, which HIPAA allows to be combined but does not require
- Assuming the compliance officer must be an attorney, which is not a regulatory requirement
- Overlooking that the compliance committee, not the compliance officer alone, is responsible for program oversight
Authority and Resources
For a compliance program to be effective, the compliance officer needs sufficient authority, staff, and budget to carry out audits, investigations, and training. The exam may test whether an under-resourced program described in a scenario meets the OIG's effectiveness standard.
Key Takeaway
RHIA candidates should understand both the formal authority structure of a compliance program and the practical collaboration between the compliance officer and HIM leadership in identifying and mitigating risk.