CJ Wolf
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Reporting structure really matters in compliance. That’s why almost every CIA you read will mention reporting structure, specifically, that a compliance officer shouldn’t report to the general council or CFO. Compliance officers shouldn’t have a compliance/CFO role or a compliance/general council role. The compliance officer shouldn’t hold any position or report to any position where there could be a conflict of interest.
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Transcript:
Hi everyone, I’m CJ Wolf, Healthicity’s Senior Compliance Executive, and today I wanted to talk about seven tips that every Compliance Officer should know. Tip number one reporting structure really matters. What I mean by that is, in just about every corporate integrity that you read, and even in some of these OIG’s guidance documents it talks about the compliance officer should not be subordinate to the general council or the CFO, or they should also not be in that role. Part of the reason being that there can be some conflicts there, and there needs to be some real independence when it comes to a compliance program. So that reporting structure is really important if you’re considering a job as a compliance officer, or if you’re in a job and you’re wanting to make your program stronger, you should really discuss with your board or your senior management how you as a compliance officer are going to report up in the organization, so to speak. So, in addition to not reporting to general council or the CFO, you should also have a regular reporting structure to the governing board, and most organizations will do this in a way that the compliance officer can have executive sessions with the board outside of the presence of senior management.
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