When to stop paying a compliance consultant

This is not an argument against consultants. A good one is worth what they charge for the things that happen once: a first registration, a new registration group, a serious finding you need to answer properly, a decision you have never had to make before.

The question worth asking is different. It is what your retainer is actually paying for between those moments.

What you are probably paying for

Look at the last six months of invoices and put each item in one of two piles.

In the first pile: judgement. Reading a standard against your specific circumstances. Deciding how to respond to a finding. Knowing what a particular auditor will want to see and why.

In the second pile: retrieval and assembly. Chasing which checks have expired. Collecting documents into a pack. Updating a policy date. Reminding you that something is due. Telling you what you already know but cannot easily see.

The first pile is expensive because it is expertise. The second pile is expensive because it is manual, and it is manual because your records live in places that cannot tell you anything on their own.

Most retainers are mostly the second pile.

The tell

There are a few signs that you are paying a professional to be a filing system.

You send documents to your consultant so they can tell you what is missing. Your evidence pack is built by someone outside the business, usually in the weeks before an audit. You find out something expired because they told you. When you ask a question about your own operation, the answer takes days because someone has to go and look.

None of that is the consultant’s fault. They are doing exactly what you engaged them to do. It is just that the work itself should not need doing.

What to keep paying for

Keep the judgement. Specifically:

The first time you do anything. A new registration, a new service type, a new state. Pay for someone who has done it before.

Anything adversarial. A complaint that escalated, a finding with teeth, a decision you might have to defend. Expertise is worth a lot when the downside is your registration.

A second opinion before an audit. Not to build the pack, which should already exist, but to look at it with an auditor’s eyes and tell you what they would ask.

That is real value, and it is periodic. It does not need a monthly retainer.

What to stop paying for

Anything that answers a question your own records should answer. What is current. What expires next. Which version applied in March. Who has completed what training. Whether the evidence pack is complete.

Those are not consulting questions. They are questions about the state of your business, and if you cannot answer them yourself in a few seconds, the problem is the system, not the absence of an adviser.

The honest test

Ask yourself what would break if the retainer stopped tomorrow.

If the answer is “we would lose access to good advice when something unusual happens”, keep them, and put them on a call-when-needed arrangement.

If the answer is “we would not know what was expiring or where anything is”, then the retainer is not buying expertise. It is renting a memory, and a memory is the one thing a system should be giving you for free.