Compliance Officer Reporting: Written vs. In-Person Presentations

One of the key responsibilities of a compliance officer is providing regular updates (recommended quarterly) to the governing body regarding the effectiveness of the compliance program. But does this report have to be delivered in person, or can it simply be submitted in writing?

The answer: both written and in-person reporting methods are acceptable, as long as there is clear documentation that the compliance officer has directly communicated with the governing body and that there is an opportunity for board members to ask questions.

What Counts as Evidence of Compliance Reporting?

To demonstrate that these reports are taking place, organizations should maintain:

✔ Written Reports submitted to the governing body

✔ Meeting Agendas & Minutes that document compliance updates

✔ Excerpts of Reports highlighting key compliance updates

The governing body should also have an established method for asking the compliance officer questions and clarifying concerns related to compliance matters.

Why In-Person Presentations Are a Best Practice

While written reports are acceptable, best practice suggests that compliance officers deliver reports in person whenever possible. This ensures:

🔹 Direct engagement with governing body members

🔹 Opportunities for discussion and clarification

🔹 Greater transparency and accountability

For those in New York State (NYS), the Office of the Medicaid Inspector General (OMIG) recommends holding an executive session with just the compliance officer and the governing body. This practice mirrors the confidential discussions accountants have with leadership during year-end audits. While this executive session doesn’t have to cover the entire compliance report, it provides a valuable opportunity for private, focused discussion.

What About Small Practices Without a Governing Body?

For small practices and required providers that don’t have a formal governing body, the compliance officer should report directly to:

✅ The owner(s)

✅ The members or partners

✅ The person(s) responsible for senior management oversight

Bottom Line: Prioritize Transparency in Compliance Reporting

Whether in writing or in person, clear and documented compliance reporting is essential to maintaining a strong compliance program. However, in-person reporting provides an extra layer of engagement, accountability, and transparency, ensuring that compliance remains a top priority for the organization.

👉 Need help structuring your compliance reporting process? Our Compliance Membership provides guidance, templates, and best practices to make compliance reporting simple and effective. Reach out today to learn more!