People Processes

Question: Are we were required by law to have a dedicated compliance officer, who cannot be the same individual who handles HR? Answer: No. In general, companies are not required by law to have a dedicated compliance officer. However, some sectors have specific guidelines in place for compliance officers. For example, in the financial sector, compliance officers are subject to regulations and enforcement by the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and the Department of Justice (DOJ). Each agency looks at the compliance officer’s supervision in both legal and compliance matters, and the DOJ also looks at individual accountability in compliance matters. In the healthcare sector, the U.S. Office of Inspector General (OIG) has issued compliance guidelines specific to hospitals. While not mandated by law, the OIG strongly recommends that hospitals develop a compliance program and have a compliance officer available to ensure that hospital standards and