Posted on Jun 10th, 2025. 

In the complex landscape of healthcare regulation, compliance is not optional—it is a critical component of operating a trustworthy and legally sound organization. However, the Office of Inspector General (OIG) under the U.S. Department of Health and Human Services (HHS) recognizes that not all healthcare entities have the same resources. Small healthcare providers and companies may lack the staff or budget for a full-time Compliance Officer. In response, OIG guidance offers a flexible alternative: the designation of a Compliance Contact Person.

What Is a Compliance Contact Person?

Under OIG’s guidance—particularly as outlined in the OIG Compliance Program Guidance for Individual and Small Group Physician Practices and other industry-specific documents—a Compliance Contact Person (CCP) is an individual designated within a small healthcare entity to oversee the basic functions of a compliance program in lieu of a full-time Compliance Officer. This role is intended to help smaller providers establish and maintain a culture of compliance without the administrative or financial burden associated with larger compliance infrastructures.

Why Allow a Compliance Contact Person?

The rationale is rooted in proportionality and practicality. OIG understands that

• Small practices or companies often have fewer employees and less complex operations.
• Many are operated by owner-practitioners or small management teams.
• Hiring a dedicated Compliance Officer may not be feasible or necessary.

By allowing the use of a CCP, the OIG promotes widespread adoption of compliance programs even in smaller organizations, tailored to their size and capacity.

What Does a Compliance Contact Person Do?

While the CCP does not carry the same authority or responsibilities as a full-fledged Compliance Officer in a large hospital or health system, they are still expected to:

• Serve as a Point of Contact: Be available to staff and leadership to answer questions and discuss concerns related to compliance, including issues such as billing accuracy, HIPAA requirements, and potential fraud or abuse.
• Facilitate Reporting: Ensure that there is a simple and confidential mechanism for employees to report potential compliance concerns or violations.
• Promote Compliance Awareness: Help disseminate basic compliance training and updates relevant to the practice’s activities, such as coding changes, privacy regulations, and fraud prevention practices.
• Coordinate with Leadership: Work directly with ownership or senior management to address any issues raised, escalate concerns when necessary, and support enforcement of internal policies.
• Monitor and Maintain Documentation: Keep track of compliance efforts, policies, and any reports or investigations initiated within the organization.

What a CCP Is Not Required to Do

Importantly, a CCP is not expected to manage or implement a full-scale compliance program akin to those in hospitals or health systems. The CCP typically does not:

• Conduct full internal audits (though they may assist with small reviews or flag areas of concern).
• Draft extensive compliance manuals.
• Oversee complex legal or regulatory analyses.

Instead, they help the organization stay oriented toward compliance and seek external expertise when needed (e.g., legal counsel or compliance consultants).

How to Designate a Compliance Contact Person

According to OIG guidance, small healthcare organizations should:

• Formally designate the CCP in writing and communicate this role to all staff.
• Ensure the individual has basic training in compliance concepts, healthcare fraud, and key regulatory topics (such as HIPAA and the False Claims Act).
• Provide the CCP with access to leadership and support so they can perform their duties effectively.

Often, the CCP may be the office manager, a senior administrator, or even a practitioner-owner—someone who is both accessible and respected within the organization.

Final Thoughts

The OIG’s provision for a Compliance Contact Person is a pragmatic approach that enables small healthcare companies to remain compliant without overextending limited resources. By appointing a CCP, these organizations can demonstrate a good faith effort toward regulatory compliance—a factor that can significantly influence outcomes in the event of an audit or investigation.

The role may be smaller in scope than that of a Compliance Officer, but it serves a vital function: embedding ethical practices and regulatory awareness into the fabric of day-to-day operations.

Michael Staples can assist your company in setting up a compliance program and even contract with you to be your third-party Compliance Contact Person with unparalleled expertise and experience.

Contact him today at [email protected] to help your healthcare business be in compliance and out of harm’s way!