On May 20th 2025  the Maryland Department of Health posted proposed COMAR 10.63 regulations. If promulgated, the revised regulations in COMAR 10.63.05 require organization have a Corporate Compliance Officer and a Corporate Compliance Program. 

Retrospect Consulting Group, LLC provides consulting service to: 
  • Design Corporate Complaince Officer duties and responsibilities 
  • Train Corporate Complaince Officers
  • Develop Corporate Compliance  Compliance Programs 
  • Conduct forensic audits and investigation. 
  • Provide compliance and documentation training 
  • Train quality assurance staff 

The proposed  COMAR regulations would require the below Corporate Compliance Requirements.
A. An organization shall document and implement a corporate compliance plan covering each program it operates.
B. An organization’s compliance plan shall:
     (1) Meet the standards established by the applicable accreditation organization for its operated program or services; or
     (2) For organizations without an applicable accreditation organization compliance standard, meet the standards outlined in §C of this regulation.
C. Corporate Compliance Standards. A corporate compliance plan shall include the:
     (1) Implementation of policies and procedures covering compliance in key areas of the organization’s provision of behavioral health care services, including, at a minimum:
          (a) Billing;
          (b) Coding;
          (c) Confidentiality;
         (d) Documentation;
         (e) Ethical behavior;
         (f) Preventing illegal service and referral incentives; and
         (g) Contingency planning in case of a loss of key staff or capacity to serve program participants;
(2) Appointment of a corporate compliance officer;
(3)  Implementation of a no-fault reporting system for compliance issues that ensures that whistleblowers are not subject           to punitive actions;
(4)  Documentation of a policy statement indicating a prohibition of conflicts of interest between the organization and                 program participants;
(5)  Implementation of a strategy for risk assessment, auditing, and monitoring which includes:
          (a) A documented annual review of risk areas in the organization;
          (b) Succession and contingency plans for the organization; and
          (c) An audit program with at least four audits a year that is focused on proper documentation, billing, and coding                    practices in high risk areas;
(6)  A process for documentation of the organization’s responses to critical incidents in accordance with Regulation .06 of           this chapter and the development of any necessary corrective actions;
(7)   Investigation of any violations of State or federal law or regulation, or organizational policy; and
(8)   Organization’s procedure in the event of any violation of State or federal law or regulation, or organizational policy                including the:
         (a) Implementation of any necessary corrective action; and
         (b) Submission of any required reports to the Administration or other applicable State, local, or federal authority.