As published in the Journal of Health Care Law and Policy 

In the strange way that thoughts connect and evolve, an experience I had on October 11, 2019 as a panelist for the University of Maryland Carey Law’s In-House Counsel Roundtable¹ just came back to mind as I read an online post from one of those accounting firms that sounds like people really wanting to be lawyers who are trapped in the license of accountants. Everyone is giving advice on what to do during and after our experience with COVID-19, and you have already heard from me on this point.² However, this particular measure of information is meant to address a disturbing trend highlighted in both my panel experience and in the accounting firm post, which is the misunderstanding of the separate roles of the compliance officer and counsel, and—of more immediate concern—the unhelpful (and in some cases dangerous) broadening of the role of the compliance officer into an all-laws inspector general for the healthcare enterprise. 

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Barry S. Herrin, JD, FAHIMA, FACHE, is the founder of Herrin Health Law, P.C., in Atlanta, Ga. Herrin offers more than 30 years of experience practicing law in the areas of healthcare and hospital law and policy, privacy law and health information management, among other healthcare-specific practice areas. He is a Fellow of the American College of Healthcare Executives and a Fellow of the American Health Information Management Association. He also holds a Certificate in Cyber Security from the Georgia Institute of Technology. Reach him at 404-459-2526 or


Barry S. Herrin, What Your Compliance Office Is – And Is Not, 24 J. Health Care L. & Pol’y 139 (2021). Available at:

¹ Further details and information regarding this event can be found at: Hot Topics for In-House Counsel at Health Care Institutions, UNIV. OF MD. FRANCIS KING CAREY SCH. L., (Oct. 11, 2019),

² Barry Herrin, Teleworking Due to COVID-19? Protect PHI From Security Threats, Starting with this Policy, HERRIN HEALTH L., (last visited Feb. 3, 2021).