Purpose

This charter establishes the role, authority, and responsibilities of the ABAS Compliance Officer. It ensures that ABAS maintains a dedicated compliance function with the independence and resources necessary to promote lawful, ethical operations across the organization.

Scope

This policy applies to the individual appointed as Compliance Officer and to all ABAS leadership and employees who interact with or are subject to the compliance program. It defines the Compliance Officer's authority, reporting structure, and core duties.

Definitions

Policy Statement

5.1 Appointment and Authority

The Compliance Officer is appointed by the Executive Director of ABAS. The CO holds senior management standing and has the authority to access all areas of the organization, personnel, and records necessary to carry out compliance duties. The CO may not be terminated or have their responsibilities materially reduced without the knowledge and input of the Compliance Committee.

5.2 Reporting Structure

The CO reports directly to the Executive Director. The CO also provides regular reports to the Compliance Committee. This dual reporting line ensures the CO has both operational access and independent oversight. The CO will submit written compliance reports to the Compliance Committee and Executive Director at least quarterly.

5.3 Core Responsibilities

The Compliance Officer is responsible for the following:

1. Develop, implement, and manage the ABAS compliance program, including all related policies and procedures.
2. Stay current with changes to federal, state, and local laws and regulations that affect ABAS operations, and update policies accordingly.
3. Oversee compliance training for all employees, including onboarding training, annual refreshers, and role-specific modules.
4. Maintain confidential channels for employees to report compliance concerns or potential violations without fear of retaliation.
5. Coordinate internal audits and monitoring activities as outlined in the annual compliance work plan.
6. Lead or oversee investigations into reported compliance concerns, and coordinate corrective actions for confirmed violations.
7. Provide regular updates on compliance risks, program effectiveness, and open items to the Compliance Committee and Executive Director.
8. Monitor disciplinary actions across the organization to verify they are applied fairly and consistently (see POL-001 relationship to Rec 20).
9. Serve as Chair of the Compliance Committee.

5.4 Independence

The CO must be able to carry out compliance responsibilities without interference from other business functions. No employee or manager may direct the CO to ignore, conceal, or delay action on a compliance matter. If a compliance concern involves the Executive Director, the CO will report directly to the Compliance Committee.

5.5 Continuing Education

ABAS will support the Compliance Officer in pursuing continuing education and professional development in healthcare compliance. This may include attendance at compliance conferences, completion of relevant coursework, and pursuit of certification through organizations such as the Health Care Compliance Association (HCCA).

Procedures

Responsibilities

Steps

1. The Executive Director appoints the Compliance Officer and communicates the appointment to all employees.
2. The CO develops or updates the annual compliance work plan within 30 days of appointment (or annually thereafter).
3. The CO submits quarterly written reports to the Compliance Committee and Executive Director covering compliance activities, open investigations, training status, and risk areas.
4. The CO reviews and updates this charter annually, or sooner if regulatory changes require it.

Training Requirements

The Compliance Officer must complete initial compliance training within 60 days of appointment. The CO is expected to pursue at least 8 hours of continuing education annually in healthcare compliance topics. ABAS will budget for registration fees, travel, and materials associated with this training.

Reporting and Enforcement

Any concerns about the Compliance Officer's performance or conduct should be directed to the Executive Director. If the concern involves the Executive Director, it should be directed to the Compliance Committee. Failure to fulfill the responsibilities outlined in this charter may result in reassignment of the CO role or other corrective action as determined by the Executive Director and Compliance Committee.