A question facing every compliance and ethics program (compliance program) is how to best structure the program to achieve optimal effectiveness (i.e., how to structure it to prevent and detect fraud, waste, and abuse, which is the objective) most effectively. For multisite organizations, one structure option involves the use of compliance liaisons. Compliance liaisons are generally not employees of the compliance program but are individuals with an operational role—sometimes in a higher-risk department or off-site location—that function as a liaison between the compliance program and operations stakeholders throughout the organization. Compliance liaisons can help bridge a gap over which many compliance programs struggle: practical engagement with and impact on operations departments and personnel. Compliance liaisons—while not employees of the compliance program—have a formal or informal "dotted line" to the compliance program to help the compliance program function more effectively and have an influence on operations staff and teams "in the field." Implementing a compliance liaison model effectively can increase engagement with individual departments and/or off-site facilities. Some may feel very removed from the compliance program because of their physical distance from or lack of engagement with the compliance program.
While some types of organizations have chosen a compliance liaison model to promote compliance program effectiveness for skilled nursing facility (SNF) operators with five or more facilities, this is now a requirement of participation under Phase Three.
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