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Differences between the following...please read and post

  • 1.  Differences between the following...please read and post

    Posted 05-23-2020 01:59 PM
    Requested by a colleague...if folks could share their responses to the following:

    I want to ask this community what is the difference among the different titles of "Chief Compliance Officer" vs "Compliance officer" vs "Lead compliance officer", manager etc?

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  • 2.  RE: Differences between the following...please read and post

    Posted 05-23-2020 04:46 PM
    From what I have seen over the last couple of months Frank, as toy move from left to right on your list subtract about $8,000 per year from the salary. 
    Alexander I Slosman, MHA, CHC, CHPC



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  • 3.  RE: Differences between the following...please read and post

    Posted 05-24-2020 09:52 AM
    Edited by Brenda Manning 05-26-2020 07:31 AM

    Good question. Here's my take based on my experience. I disagree with the pay comment. I think the pay is SIGNIFICANTLY more than $8,000 different. I would rate Manager at about 1/3 a Chief Compliance Officer's pay. The fact is titles matter.

    Chief Compliance Officer is someone who oversees an organization's compliance department. This person is a RARE individual who is multifaceted with deep knowledge in general compliance, privacy, audit, coding and billing and is an overall well-rounded person with respect to many skills such as: management, leadership, collaboration and communication.

    Compliance Officer is a step down from Chief Compliance Officer. It typically (not always) indicates the person works for a small organization and is a 1 person Compliance Department, has additional duties besides compliance and does not have the same level of knowledge of a Chief Compliance Officer.

    Lead Compliance Officer. Not familiar with this title so unable to comment.

    Compliance Manager typically indicates someone who has limited responsibility for managing one particular area of compliance versus someone with general compliance expertise. However, I have seen some companies use this title as a low level Compliance Officer type title, meaning someone who is expected to be a one person compliance department with general compliance knowledge reporting up to a Chief Compliance Officer who is at a different corporate location. 



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    Brenda Manning J.D., C.H.C., C.H.P.C.
    Privacy Director
    Interim Privacy Officer
    Carilion Clinic

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.
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  • 4.  RE: Differences between the following...please read and post

    Posted 05-26-2020 08:36 AM
    Honestly, while I don't disagree with Brenda in her interpretation of the position descriptions, I think it depends entirely on the organization.   We only have Directors, Managers, and Coordinators/Analyst in our organization for Compliance, and the pay difference between Directors and Managers is significant but not between the Compliance Director and the other C-Suite positions.   There's only one director, but multiple managers and analysts.   We also loop Compliance and Risk Management together, where I know others have separate departments. 

    If you're looking at job opportunities, I'd pay much more attention to the responsibilities listed than the title itself to make a determination about where that job fits within the organization.  

    Margaret E. Baker, Esq., CHC

    HopeHealth, Inc.
    360 N. Irby Street | Florence, SC 29501
    O: 843.664.3634 |  C: 843.601.0301
    mbaker@hope-health.org | hope-health.org
     
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  • 5.  RE: Differences between the following...please read and post

    Posted 05-27-2020 02:44 PM
    Absolutely Margaret. It's very dependent upon the organization.


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    Brenda Manning J.D., C.H.C., C.H.P.C.
    Privacy Director
    Interim Privacy Officer
    Carilion Clinic

    The views expressed herein are my own and do not represent those of my employer. They are not meant to constitute legal advice or create an attorney-client relationship.
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  • 6.  RE: Differences between the following...please read and post

    Posted 05-25-2020 05:11 PM
    I agree with everything Brenda said, but would add that a one-person compliance office may have no Chief Compliance Officer, but the Compliance Officer is expected to have the same level of knowledge as a CCO, even if they have additional duties.  You will often see a Compliance Officer with also being the Privacy Officer.  Less often you may see that same person being the Security Officer as well, for 3 jobs.  Occasionally, you will see a CO with 4 jobs.

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    Lloyd Hemmert
    Compliance & Ethics Officer
    Hill Country MHDD Centers
    Kerrville,TX
    [lhemmert@hillcountry.org]
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  • 7.  RE: Differences between the following...please read and post

    Posted 05-26-2020 09:32 AM
    I would agree with Margaret. I would pay more attention to the job responsibilites. Based on Brenda's response I would be considered the Chief Compliance Officer at my organization, but my title is Compliance Officer. I am also referred to as the Director of Compliance. We do only have a 2 person department and to some our organization may be small (96 physicians and 22 sites). I also serve as the Privacy Officer (formal title as well) and manage our medical records department. I think it just varies based on the organization.

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    Savannah Knuettel
    Compliance Officer
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
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  • 8.  RE: Differences between the following...please read and post

    Posted 05-26-2020 10:04 AM
    I have to agree with both Margaret and Savannah, and that was pretty much what i was getting at in my original post. What we call you is not nearly as important as the duties you are assigned. 

    When O am asked for my opinion about job titles either for primary position descriptions or ancillary duties (I see compliance assigned in both ways) I do not recommend using the term "Officer" unless the person is a principal of the organization. There is, as far as I know, no legal definition to the designation Officer, I just think it helps avoid confusion. 

    Other than that I have seen junior level dental assistants assigned as privacy officers and highly experienced senior level managers designated as compliance coordinator.  Remember very few people wake up one morning and say "to heck with astronaut, firefighter, or superhero; I want to be a compliance professional when I grow up" Most of us get here because we were by the wrong filing cabinet when the boss said "We need someone to ..." or we were the ones who asked the question "Will the regulations let us do this?"

    Just my 2 cents worth on a Monday morning except on a Tuesday.
    -Alex- 
    Alexander I Slosman, MHA, CHC, CHPC



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  • 9.  RE: Differences between the following...please read and post

    Posted 05-26-2020 12:27 PM

    And to add  a different flavor, there are also folks like me that are the designated Compliance and Privacy Officer without the title in the job description. During my tenure in the health plan arena, when performing compliance program effectiveness audits of delegated entities I got to see HR Directors and UM Directors that were designated as the Compliance Officer and/ or the Privacy Officer.

     

     

     

     

     

    Maria Mojica, CHC, CHPC, CHIAP

    Internal Audit and Compliance Program Manager

    RUHS - Public Health

     

     

     

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