Compliance Officer and Compliance Committee: Your First 100 Days

By Jan Elezian, Director at SunHawk Consulting, LLC in Denver, CO, and Gerry Roy, Vice-President, Chief Compliance and Privacy Officer at Phoenix Children’s Hospital in Phoenix, AZ.

In today’s highly regulated healthcare market, a chief compliance officer (CCO) seldom has time to rest. This is clearly the case with a seasoned CCO who has been in place for some time, but even more so for one who is new to an organization. The first few months can be overwhelming—as if someone dumped a puzzle with missing pieces on your desk. This is true whether you are joining an existing compliance program or creating a new one. This article will provide a framework to help you prioritize the first 100 days in your new role. 

Step 1: Sorting your pieces with an onboarding road map

Within the construction industry, there is well-known principle: Measure twice and cut once. The same principle can be applied here as it relates to your onboarding as the CCO. Regardless of the state of the compliance program, your very first step should be one of assessment and planning, not action. Take time to create a road map for methodically analyzing the organization and developing and executing a new program. To help capture fleeting thoughts as they pour in, consider focusing on another five primary areas:

  • Orienting to the organization 

  • Orienting to the compliance program 

  • Conducting an initial risk assessment

  • Developing resources and tools

  • Introducing yourself to the organization 

Consider these areas the five. . . click for Full Article.

1 “Compliance Guidance,” U.S. Department of Health & Human Services Office of Inspector General (OIG), accessed January 8, 2020, 2 OIG Supplemental Compliance Program Guidance for Hospitals, 70 Fed. Reg. 4858 (January 31, 2005) ,

3 HCCA-OIG Compliance Effectiveness Roundtable, Measuring Compliance Program Effectiveness: A Resource Guide, March 27, 2017, 4 Department of Justice, Criminal Division, Evaluation of Corporate Compliance Programs (Updated April 2019),

Copyright 2020 Compliance Today Magazine, a publication of the Health Care Compliance Association (HCCA)

Ramping Up Virtual Project Management / Team Facilitation in Response to COVID-19? SunHawk Can Help

Our skilled leaders and professionals at SunHawk are experts at managing complex and time sensitive projects in a virtual on-line world.  In these disruptive times, we can jump in to help your organization with regulatory and compliance management needs including:

· Organizing a short-term crisis management/response team,

· Facilitating or assume leadership of a new compliance initiative, or

· Provide leadership to an established team or add additional expertise.

Do you have work that needs to be done? Do you not have the immediate bandwidth or resources to see such projects to fruition given other priorities? We can help, please reach out to Jim Rough or James Rose for assistance:

SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs and budgets come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management and employees, special committees, bankruptcy trustees and receivers, and government agencies.