CPCO Certification Review

Certified Pharmacy Compliance Officer (CPCO) Review

A Review Guide for the Certified Pharmacy Compliance Officer (CPCO) Exam

Block 1: Foundations of Compliance

340B: Section 340B Drug Pricing Program

ACA: Affordable Care Act

AKS: Anti-Kickback Statute

BOP: Board of Pharmacy

CIA: Corporate Integrity Agreement

CLIA: Clinical Laboratory Improvement Amendments

CMS: Centers for Medicare & Medicaid Services

CPCO: Certified Pharmacy Compliance Officer

DEA: Drug Enforcement Administration

DOJ: Department of Justice

DSCSA: Drug Supply Chain Security Act

EHR: Electronic Health Record

FCA: False Claims Act

FDA: Food and Drug Administration

FDCA: Food, Drug, and Cosmetic Act

FWA: Fraud, Waste, and Abuse

HIPAA: Health Insurance Portability and Accountability Act

HHS: Department of Health and Human Services

HRSA: Health Resources and Services Administration

OIG: Office of Inspector General

OSHA: Occupational Safety and Health Administration

PBM: Pharmacy Benefit Manager

PDMA: Prescription Drug Marketing Act

PHI: Protected Health Information

P&P: Policies and Procedures

SOP: Standard Operating Procedure

TJC: The Joint Commission

USP: United States Pharmacopeia

  • This framework, published by the OIG, is the foundation of all healthcare compliance programs.
  • Element 1: Implementing written policies, procedures, and standards of conduct.
  • Element 2: Designating a compliance officer and compliance committee.
  • Element 3: Conducting effective training and education.
  • Element 4: Developing effective lines of communication (including anonymous reporting).
  • Element 5: Conducting internal monitoring and auditing.
  • Element 6: Enforcing standards through well-publicized disciplinary guidelines.
  • Element 7: Responding promptly to detected offenses and undertaking corrective action.
  • A CPCO must be able to describe and provide examples for each of these seven elements.
  • These elements are not optional; they form the basis of how the government assesses a pharmacy's commitment to compliance.
  • The CPCO is responsible for overseeing the development, implementation, and operation of the compliance program.
  • This role requires a direct line of communication to the highest governing body (e.g., the CEO and Board of Directors).
  • Key responsibilities include policy development, training, auditing, and investigating compliance concerns.
  • The CPCO must have the authority and resources to enforce compliance standards across the organization.
  • This individual acts as a central point of contact for compliance questions and concerns from all employees.
  • The role involves staying current on all relevant laws, regulations, and guidance from government agencies.
  • A crucial function is to foster a culture of compliance where ethical conduct is the norm.
  • The CPCO leads the compliance committee, which provides oversight and support for the program.
  • They are responsible for reporting on the status of the compliance program to leadership and the board.
  • The position demands a high level of integrity, objectivity, and the ability to navigate complex situations.
  • Office of Inspector General (OIG): The primary enforcement agency for FWA within HHS.
  • Department of Justice (DOJ): Prosecutes criminal and civil violations of federal healthcare laws.
  • Centers for Medicare & Medicaid Services (CMS): Administers the Medicare and Medicaid programs and sets the rules for participation.
  • Drug Enforcement Administration (DEA): Enforces the Controlled Substances Act.
  • Food and Drug Administration (FDA): Regulates the safety and efficacy of drugs and medical devices.
  • State Boards of Pharmacy (BOP): Regulate the practice of pharmacy at the state level, including licensure and facility standards.
  • Health Resources and Services Administration (HRSA): Administers the 340B Drug Pricing Program.
  • Office for Civil Rights (OCR): Enforces the HIPAA Privacy and Security Rules.
  • The Joint Commission (TJC): An independent accrediting body whose standards are often tied to CMS reimbursement.
  • A CPCO must understand the jurisdiction and primary focus of each of these key agencies.
  • A CIA is a legally binding agreement between a healthcare provider and the OIG as part of a settlement for FWA violations.
  • It requires the provider to implement a strict, government-monitored compliance program for a period of 3-5 years.
  • The terms of a CIA are often based on the OIG's Seven Elements framework.
  • A key requirement is the engagement of an Independent Review Organization (IRO) to conduct audits.
  • CIAs include detailed reporting requirements to the OIG on all compliance activities.
  • Failure to comply with the terms of a CIA can result in significant financial penalties and potential exclusion from federal healthcare programs.
  • Studying existing CIAs provides valuable insight into the OIG's compliance expectations for pharmacies.
  • The CPCO is typically the individual responsible for managing the organization's adherence to a CIA.
  • These agreements are publicly available on the OIG's website.
  • A CIA represents a significant operational and financial burden, highlighting the importance of a proactive compliance program.

Block 2: Fraud, Waste & Abuse (FWA)

  • The FCA is the government's primary civil tool for combating fraud against federal healthcare programs.
  • It imposes liability on any person who knowingly submits a false or fraudulent claim for payment to the government.
  • "Knowingly" includes acting with actual knowledge, deliberate ignorance, or reckless disregard for the truth.
  • Penalties are severe, including treble damages (3x the amount of the fraud) plus per-claim penalties.
  • Common pharmacy-related FCA violations include billing for non-existent prescriptions or billing for brand drugs when generics were dispensed.
  • The FCA includes "qui tam" or whistleblower provisions that allow private citizens to file lawsuits on behalf of the government and share in any recovery.
  • These whistleblower provisions are a major source of FCA cases.
  • Compliance with all billing rules is the best defense against an FCA action.
  • The CPCO must ensure robust auditing and monitoring processes are in place to detect and correct billing errors.
  • Understanding the FCA is critical, as it is the source of the largest financial recoveries for the government.
  • The AKS is a criminal statute that prohibits knowingly and willfully offering, paying, soliciting, or receiving anything of value to induce or reward referrals for items or services payable by a federal healthcare program.
  • "Anything of value" is interpreted broadly and can include cash, gifts, free services, or excessive payments.
  • Unlike the FCA, the AKS is an intent-based statute; a violation requires proof that the kickback was intended to induce referrals.
  • Penalties include fines, imprisonment, and exclusion from federal healthcare programs.
  • Common pharmacy examples include paying physicians for referrals or waiving patient copayments to induce them to fill prescriptions.
  • The OIG has established "safe harbors" that protect certain payment arrangements from prosecution under the AKS.
  • For an arrangement to be protected, it must fit squarely within all requirements of a safe harbor.
  • Examples of safe harbors include space rental, equipment rental, and personal services agreements, all of which must be at fair market value.
  • The CPCO must review all financial arrangements with referral sources to ensure compliance with the AKS.
  • Any remuneration flowing to or from a referral source should be considered a high-risk area.
  • The Stark Law prohibits a physician from making referrals for designated health services (DHS) to an entity with which the physician has a financial relationship, unless an exception applies.
  • Pharmacy services are a designated health service.
  • This is a strict liability statute, meaning no proof of intent to violate the law is required.
  • If a financial relationship exists and no exception applies, the referral is prohibited.
  • The primary remedy is repayment of all claims paid as a result of the prohibited referrals.
  • This law primarily applies to physician-owned pharmacies or pharmacies that have financial relationships with referring physicians.
  • Like the AKS, the Stark Law has a series of detailed exceptions that can protect certain arrangements.
  • Common exceptions include the in-office ancillary services exception and the fair market value compensation exception.
  • The CPCO must work with legal counsel to analyze any financial relationship with a referring physician.
  • The complexity of the Stark Law makes it a significant compliance risk for any affiliated pharmacy.
  • CMS requires all entities that contract with Medicare Part C (Advantage) or Part D (Prescription Drug) plans to provide FWA training.
  • This training must be provided to all employees involved in the administration or delivery of Medicare benefits.
  • Training must occur within 90 days of hiring and annually thereafter.
  • The training curriculum must cover the basics of the FCA, AKS, Stark Law, and other relevant FWA laws.
  • It must also cover the organization's specific policies and procedures for detecting and preventing FWA.
  • CMS provides a standardized FWA training module that can be used to meet this requirement.
  • The pharmacy must maintain records of all employee training, including dates and materials, for at least 10 years.
  • These records are subject to audit by the Medicare plan sponsor or CMS.
  • The CPCO is responsible for ensuring that this training is effectively implemented and documented.
  • This is a fundamental and auditable component of a pharmacy's compliance program.
  • Auditing involves a formal, retrospective review of adherence to policies and procedures.
  • Monitoring involves ongoing, real-time checks to ensure compliance is being maintained.
  • A key area for auditing is claims submission to ensure accuracy and proper documentation.
  • Audits should be conducted on a regular schedule based on a formal risk assessment.
  • Data analytics is a powerful tool for monitoring, allowing for the identification of outliers and unusual patterns.
  • Examples of monitoring include reviewing reports of prescription overrides or early refills.
  • The OIG recommends conducting regular audits of high-risk areas identified in its annual Work Plan.
  • The results of all audits and monitoring activities must be documented and reported to the compliance committee.
  • Any identified deficiencies must lead to a formal corrective action plan (CAP).
  • This is a critical component of the Seven Elements and demonstrates a proactive approach to compliance.

Block 3: Privacy & Security

  • The Privacy Rule establishes national standards to protect individuals' medical records and other personal health information.
  • It applies to health plans, clearinghouses, and healthcare providers that conduct electronic transactions (covered entities).
  • The rule protects all "individually identifiable health information," known as Protected Health Information (PHI).
  • The core principle is the concept of "minimum necessary," meaning a covered entity should only use or disclose the minimum amount of PHI necessary to accomplish the intended purpose.
  • Permitted uses and disclosures of PHI without patient authorization include those for treatment, payment, and healthcare operations (TPO).
  • Patients have specific rights under the Privacy Rule, including the right to access their own PHI and request amendments.
  • A key requirement is providing a Notice of Privacy Practices (NPP) to all patients.
  • The CPCO must ensure robust policies are in place to govern the use and disclosure of PHI.
  • Violations can result in significant civil monetary penalties, especially in cases of willful neglect.
  • Training on the Privacy Rule is mandatory for all workforce members.
  • The Security Rule establishes national standards for protecting electronic Protected Health Information (ePHI).
  • It requires covered entities to implement three types of safeguards: administrative, physical, and technical.
  • Administrative safeguards include policies and procedures like conducting a security risk analysis and implementing a security awareness and training program.
  • Physical safeguards include measures to protect physical access to ePHI, such as facility access controls and workstation security.
  • Technical safeguards include technology-based controls like access control (unique user IDs), encryption, and audit controls.
  • A mandatory requirement of the Security Rule is the completion of a formal Security Risk Analysis (SRA).
  • The SRA is a comprehensive assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI.
  • The CPCO must ensure that an SRA is conducted regularly and that a risk management plan is in place to address identified risks.
  • This rule is designed to be flexible and scalable, allowing entities to choose security measures appropriate for their size and complexity.
  • Failure to conduct a thorough SRA is a common finding in OCR enforcement actions.
  • This rule requires covered entities to provide notification following a breach of unsecured PHI.
  • A "breach" is defined as an impermissible use or disclosure of PHI that compromises its security or privacy.
  • An impermissible use or disclosure is presumed to be a breach unless the covered entity can demonstrate a low probability that the PHI has been compromised.
  • This demonstration is based on a four-factor risk assessment.
  • If a breach occurs, the covered entity must notify affected individuals without unreasonable delay and no later than 60 days.
  • If the breach affects 500 or more individuals, the covered entity must also notify the Secretary of HHS and prominent media outlets.
  • All breaches, regardless of size, must be logged and reported annually to HHS.
  • The CPCO must have a robust incident response plan in place to manage potential breaches.
  • This plan should detail the steps for investigation, risk assessment, and notification.
  • The "wall of shame" on the OCR website publicly lists all breaches affecting 500 or more individuals.
  • A "Business Associate" (BA) is a person or entity that performs functions or activities on behalf of a covered entity that involve the use or disclosure of PHI.
  • Common pharmacy examples include claims processing vendors, software providers, and collection agencies.
  • HIPAA requires covered entities to have a written contract, known as a Business Associate Agreement (BAA), with all BAs.
  • The BAA establishes the permitted uses and disclosures of PHI by the BA.
  • It requires the BA to implement appropriate safeguards to protect the PHI.
  • It also requires the BA to report any security incidents or breaches to the covered entity.
  • Under the HITECH Act, BAs are directly liable for compliance with many parts of the HIPAA rules.
  • The CPCO must maintain an inventory of all BAs and ensure that a current BAA is in place for each.
  • This includes conducting due diligence to ensure the BA has a robust security program.
  • Failure to have a BAA in place is a violation of HIPAA.
  • Patients have the right to access and obtain a copy of their PHI.
  • They have the right to request an amendment to their PHI if they believe it is inaccurate or incomplete.
  • They have the right to an accounting of disclosures of their PHI for purposes other than TPO.
  • They have the right to request restrictions on how their PHI is used and disclosed.
  • They have the right to request confidential communications (e.g., to be contacted at an alternative address).
  • They have the right to file a complaint with the covered entity or with the Secretary of HHS.
  • A key right is the right to restrict disclosures to a health plan for services paid for out-of-pocket in full.
  • The CPCO must ensure that policies and procedures are in place to facilitate the exercise of these patient rights.
  • Workforce members must be trained on how to handle patient requests related to these rights.
  • Timely and appropriate responses to these requests are a key compliance obligation.

Block 4: Pharmacy Operations & Controlled Substances

  • The Controlled Substances Act (CSA) is the federal law that regulates the manufacture, distribution, and dispensing of controlled substances.
  • The DEA is the agency responsible for enforcing the CSA.
  • Pharmacies must be registered with the DEA to dispense controlled substances.
  • The CSA establishes a "closed system" of distribution to prevent diversion.
  • Key requirements include strict record-keeping for all controlled substance transactions.
  • This includes maintaining biennial inventories and records of receipt and dispensing.
  • Pharmacies have a "corresponding responsibility" to ensure that all controlled substance prescriptions they dispense are issued for a legitimate medical purpose.
  • The CPCO must ensure robust policies are in place to prevent drug diversion.
  • This includes conducting regular audits of controlled substance records and investigating any discrepancies.
  • Violations of the CSA can lead to severe criminal and civil penalties.
  • The DSCSA was enacted to create a national system to trace prescription drugs through the supply chain.
  • The goal is to protect patients from counterfeit, stolen, or contaminated drugs.
  • Pharmacies are required to receive, store, and provide product tracing information.
  • This information is known as the "3Ts": Transaction Information, Transaction History, and Transaction Statement.
  • Pharmacies must only accept prescription drugs from Authorized Trading Partners.
  • They must have systems in place to investigate and quarantine any suspect or illegitimate products.
  • The final phase of the DSCSA requires full, unit-level electronic traceability.
  • The CPCO must ensure that the pharmacy has policies and procedures to comply with all DSCSA requirements.
  • This includes retaining all product tracing information for at least six years.
  • Compliance with the DSCSA is a key component of ensuring a safe and secure drug supply.
  • The United States Pharmacopeia (USP) sets standards for the quality and safety of compounded medications.
  • USP <795> provides standards for non-sterile compounding.
  • USP <797> provides standards for sterile compounding to prevent harm from contamination.
  • USP <800> provides standards for the safe handling of hazardous drugs to protect healthcare personnel.
  • These chapters are often incorporated into state board of pharmacy regulations, making them legally enforceable.
  • Key components include requirements for personnel training, facility design, environmental monitoring, and quality assurance.
  • The CPCO must ensure that the pharmacy's compounding practices are fully compliant with all applicable USP standards.
  • This includes regular audits of compounding facilities and processes.
  • Documentation of training, cleaning, and quality control measures is critical.
  • Non-compliance can lead to significant patient safety risks and regulatory action.
  • The 340B Program requires drug manufacturers to provide outpatient drugs to eligible healthcare organizations (covered entities) at significantly reduced prices.
  • The goal is to allow these safety-net providers to stretch scarce federal resources.
  • The program is administered by the Health Resources and Services Administration (HRSA).
  • Compliance is extremely complex and a major focus of government audits.
  • The two cardinal rules are preventing diversion and preventing duplicate discounts.
  • "Diversion" means providing a 340B drug to an individual who is not an eligible patient of the covered entity.
  • "Duplicate discount" means claiming a 340B discount and a Medicaid rebate on the same drug.
  • Covered entities must maintain auditable records demonstrating compliance with all program requirements.
  • The CPCO of a covered entity must oversee a robust 340B compliance program, including regular independent audits.
  • Non-compliance can result in having to repay manufacturers for all ineligible discounts.
  • Pharmacies are subject to audits from multiple entities, including Pharmacy Benefit Managers (PBMs) and government agencies.
  • PBM audits typically focus on contractual compliance and identifying clerical errors that can lead to financial recoupments.
  • Common PBM audit findings include signature log issues, invalid prescriptions, and incorrect days' supply calculations.
  • Government audits (e.g., from Medicaid or Medicare) are more focused on identifying FWA.
  • A key to surviving audits is maintaining meticulous and organized records.
  • The CPCO should have a formal process for managing audits, from the initial request to the final response.
  • This includes conducting internal mock audits to prepare for external reviews.
  • It is critical to respond to audit requests in a timely and complete manner.
  • The CPCO should review all audit findings to identify trends and implement corrective actions.
  • Proactive compliance is the best defense against punitive audit results.

Block 5: Risk Assessment & Management

  • A risk assessment is a systematic process for identifying, analyzing, and prioritizing compliance risks.
  • It is the foundation for building a targeted and effective compliance program.
  • The process involves inventorying all potential compliance risks across the pharmacy's operations.
  • Each risk is then analyzed based on its likelihood of occurring and its potential impact (financial, reputational, clinical).
  • The results are often plotted on a heat map to visually prioritize the highest-risk areas.
  • The OIG's annual Work Plan is a critical resource for identifying potential risk areas.
  • The risk assessment should be a dynamic process, updated at least annually or when new regulations are introduced.
  • The CPCO leads this process in collaboration with operational leaders.
  • The findings of the risk assessment are used to develop the annual compliance audit plan.
  • This proactive approach allows the organization to focus its resources on the most significant threats.
  • The audit plan is a direct output of the compliance risk assessment.
  • It is a formal document that outlines the specific compliance audits to be conducted over the next year.
  • The plan should prioritize the high-risk areas identified in the risk assessment.
  • For each audit, the plan should define the scope, objectives, and methodology.
  • It should also specify the timeline and the individuals or department responsible for the audit.
  • The audit plan should be reviewed and approved by the compliance committee and senior leadership.
  • It is a living document that can be adjusted if new risks emerge during the year.
  • The CPCO is responsible for overseeing the execution of the audit plan.
  • This ensures that the pharmacy's auditing efforts are strategic and risk-based.
  • A well-developed audit plan is a hallmark of a mature compliance program.
  • The compliance program must have a formal process for investigating reports of potential non-compliance.
  • This includes reports made through the compliance hotline or other communication channels.
  • The CPCO is responsible for ensuring that all reports are investigated in a timely and objective manner.
  • The investigation process must be well-documented and conducted under privilege when appropriate.
  • If a violation is substantiated, the organization must take prompt corrective action.
  • This includes addressing the specific issue and implementing systemic changes to prevent recurrence.
  • It also involves enforcing disciplinary standards for the individuals involved.
  • In some cases, a substantiated violation may trigger a legal obligation to self-disclose the issue to a government agency.
  • The CPCO must have a clear policy on when to engage legal counsel during an investigation.
  • A robust investigative process demonstrates a commitment to Element 7 of the compliance program.
  • There are situations where a pharmacy has an affirmative duty to report potential violations to the government.
  • One key example is the "60-Day Rule" under the ACA, which requires providers to report and repay any identified Medicare or Medicaid overpayments within 60 days of identification.
  • The OIG maintains a formal Self-Disclosure Protocol that providers can use to voluntarily report potential FWA violations.
  • Voluntary self-disclosure can significantly reduce the penalties and potential sanctions the organization might otherwise face.
  • The decision to self-disclose is complex and should always be made in consultation with experienced legal counsel.
  • The CPCO is responsible for managing the process of quantifying any overpayments and preparing the disclosure.
  • This process requires a thorough internal investigation to understand the root cause and scope of the issue.
  • A credible compliance program includes a clear policy on when and how to self-disclose.
  • This demonstrates the organization's commitment to transparency and accountability.
  • It is a critical component of responding promptly to detected offenses.

Compliance Risk Heat Map

A visual tool used in risk assessments. It is a matrix that plots identified risks based on their likelihood (e.g., rare to frequent) and impact (e.g., insignificant to catastrophic). This allows for easy identification of the highest priority risks that fall in the "high-likelihood, high-impact" quadrant.

HIPAA Security Risk Analysis (SRA) Tool

The Office of the National Coordinator for Health IT (ONC) provides a downloadable tool to help small and medium-sized providers conduct a security risk analysis as required by the HIPAA Security Rule. It guides the user through assessing threats, vulnerabilities, and existing controls.

OIG Work Plan

Published annually, this is not a tool but a critical resource. The OIG Work Plan outlines the specific areas and topics it intends to review in the coming year. A CPCO uses this document to identify emerging risk areas and proactively incorporate them into their own audit plan.

Block 6: Calculations & Advanced Topics

Audit Error Rate

A fundamental metric used to quantify the results of a claims audit. It is used to extrapolate a potential overpayment amount across a universe of claims.

Error Rate=(Total Dollars in Error / Total Dollars Audited)×100%

Training Completion Rate

A key metric for the compliance committee and board to demonstrate that Element 3 (Training) of the compliance program is being effectively managed.

Completion Rate=(Employees Completed / Total Eligible Employees)×100%

  • The OIG has the authority to exclude individuals and entities from participating in federal healthcare programs.
  • Pharmacies are prohibited from employing or contracting with any individual or entity that is on the OIG's List of Excluded Individuals and Entities (LEIE).
  • This prohibition applies to all employees, not just those in a clinical role.
  • Submitting claims for items or services provided by an excluded individual can result in significant FCA liability.
  • The CPCO must have a robust process for screening all new and current employees and vendors against the LEIE.
  • This screening must be done upon hiring and on a regular (typically monthly) basis thereafter.
  • The process and results of all exclusion screenings must be documented.
  • In addition to the federal LEIE, many states maintain their own exclusion lists.
  • A comprehensive screening process should check both federal and all applicable state lists.
  • This is a fundamental compliance activity that is often reviewed during government audits.
  • The rise of telehealth and digital health presents new and complex compliance challenges.
  • State laws governing telepharmacy vary significantly and are rapidly evolving.
  • A key issue is pharmacist licensure; the pharmacist must be licensed in the state where the patient is located.
  • Prescribing laws for telehealth encounters must be understood, especially for controlled substances.
  • HIPAA compliance is critical, ensuring that all digital communication platforms are secure.
  • Billing rules for telehealth services must be followed precisely to avoid FCA risk.
  • The CPCO must stay current on the changing regulatory landscape for these technologies.
  • Risk assessments must be updated to include the specific risks associated with digital health services.
  • Policies and procedures must be developed to govern the compliant provision of telepharmacy.
  • This is a major emerging area of focus for compliance professionals.
  • Specialty pharmacies manage high-cost, complex medications for chronic and rare diseases.
  • Many specialty drugs are Limited Distribution Drugs (LDDs), meaning the manufacturer restricts which pharmacies can dispense them.
  • To gain access to LDDs, a pharmacy must typically meet stringent data reporting and clinical management requirements set by the manufacturer.
  • This includes reporting on specific clinical data points and performance metrics.
  • The CPCO must ensure that all data reporting is accurate and that the pharmacy is meeting its contractual obligations.
  • Specialty pharmacies are often subject to accreditation standards from organizations like URAC or ACHC.
  • These standards have their own specific compliance requirements.
  • The high cost of these drugs makes billing accuracy a major compliance risk area.
  • The CPCO must ensure robust processes are in place for benefits investigation and prior authorization.
  • This is a highly regulated and high-risk sector of the pharmacy industry.
  • If it wasn't documented, it wasn't done. This is the cardinal rule of compliance. Meticulous documentation is the best defense in an audit or investigation.
  • Compliance is a journey, not a destination. An effective compliance program is a dynamic, continuous process of assessment, improvement, and adaptation.
  • Culture eats policy for breakfast. A stack of well-written policies is useless without a strong, ethical culture that starts at the top and permeates the entire organization.
  • Be a partner, not a police officer. The most effective compliance officers are seen as trusted advisors and partners who help the business achieve its goals in a compliant manner, not as internal police who only say "no."
  • Know what you don't know. Compliance is vast and complex. A great CPCO knows when to seek expertise from legal counsel, consultants, or other specialists.
  • Trust, but verify. Assume good intentions, but always verify compliance through robust auditing and monitoring. A proactive approach is essential.
  • Prevention is cheaper than the cure. The cost of a proactive compliance program is a fraction of the cost of a government investigation, settlement, and CIA.
  • Communication is key. The ability to clearly and effectively communicate compliance risks and requirements to all levels of the organization is a critical skill.
  • Stay informed. The regulatory landscape is constantly changing. A commitment to lifelong learning and staying current is mandatory for success in this role.
  • Always act with integrity. The compliance officer must be the ethical compass for the organization, demonstrating unwavering integrity in every action and decision.
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