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Privacy Officer Role

The Compliance Privacy Officer ("CPO") is a unique position, akin to the fraud and abuse Compliance Officer. The shared similarities include, overall, the ability to work within and through disparate departments and processes within the overall organization. In other words, the CPO must take responsibility and accountability for the organization’s privacy program, which involves tracking and coordinating the flow of information from the lowest and most nontechnical echelons of the organization to the highest and most technical echelons of the organization; from the filing clerk to the Chief Information Officer; from the UPS delivery person to the physician owner / medical director. The CPO is responsible, not only to the employer, but to the employees, the patients and their families. In other words, to everyone.

The CPO must assume a leadership role in developing and implementing the privacy compliance program. This includes chairing the Compliance Committee with respect to privacy issues. The CPO must also act as liaison with the organization’s Special Counsel; i.e.; the outside attorney. The CPO must focus on knowing, with Special Counsel’s invaluable assistance, both federal and state privacy laws and regulations. Privacy policies and procedures, request for access and disclosure verification procedures; auditing, monitoring, training, investigating, etc. are some of the key responsibilities for the CPO. Unlike the CPO’s fraud and abuse Compliance Officer counterpart, however, all of the CPO’s efforts are focused on protecting patient information that has been deemed confidential.

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