The Chief Compliance Officer is responsible for the development, implementation, and oversight of all activities related to the Alliance’s adherence to the laws, regulations and policies that govern its business. The Chief Compliance Officer is responsible for the identification and organization of information and resources related to Compliance requirements and policies; for the communication and training on the importance of Compliance in general; and for the development of policies, procedures and standards related to the Compliance Program. Additionally, the Chief Compliance Officer is responsible for identifying and assessing areas of compliance risk for the Alliance and developing and implementing plans to reduce risk and maintain compliance. The Chief Compliance Officer will report to the Chief Executive Officer and will have access to the Board of Governors.
Principal responsibilities include:
ORGANIZATION (PROGRAM REQUIREMENTS and COMPLIANCE COMMITTEE):
· Update, implement, document, and maintain the Alliance’s Compliance Program, as necessary. The Compliance Program shall be maintained and updated annually to ensure accessibility, compliance with applicable laws and statutes and continuity.
· Develop an annual work plan, in cooperation with the Compliance Committee that will provide for the on-going development and implementation of the Compliance Program.
· Lead efforts to integrate the Compliance Program into the Alliance’s culture and operations.
· Set Compliance Committee agendas and develop reports of Compliance Committee findings and actions on a routine basis and as requested by Alliance senior management.
· Coordinate resources to ensure the ongoing effectiveness of the Compliance Program.
· Present periodic reports and an annual evaluation on the operation of the Compliance Program to the Board of Governors and senior management, including an annual work plan that will include identifying areas of risk.
· Hire and manage Compliance Department staff.
· Manage the Compliance Department’s administrative duties, including supervising support staff, organizing and maintaining compliance files, and preparing necessary reports on activities.
· Represent Alliance as primary contact for Federal, State and regulatory bodies or other relevant parties in issues of compliance. Prepare information, organize materials and staff, and complete or oversee all filings, compliance audits and site visits for and by applicable agencies.
· Coordinate with department directors and managers, legal counsel and the Human Resource Department as necessary and applicable in the execution of the Compliance Program.
POLICIES, PROCEDURES AND STANDARDS:
· In a timely fashion, update and distribute applicable policy and procedures with current compliance information, along with notification and/or training on the effect or implication of such policy or procedure on the Alliance or on a particular department.
· Identify, assess and report on areas of risk for the Alliance and with the appropriate staff of various departments and develop policies and procedures to ensure compliance with federal, state, and local laws.
EDUCATION AND TRAINING:
· Assist internal departments in establishing, maintaining, and updating programs to educate and train managers and other employees regarding applicable state and federal compliance requirements, including HIPAA, and to regularly monitor compliance with those requirements.
· Monitor and identify state and federal regulatory changes that impact the Alliance, and provide education, in conjunction with the senior management team, to employees, agents and contractors in identification and implementation of any required policy or process modifications necessary to comply with all applicable state and federal regulations and contracts.
· Develop, implement, and maintain appropriate training and education for Alliance employees, the Board of Governors, providers and members regarding the Compliance Plan and the Alliance’s commitment to compliance.
EFFECTIVE LINES OF COMMUNICATION:
· In coordination with the Human Resources Department, assist in the development and communication of a confidential process and the open door policy for all employees to seek guidance on compliance questions or concerns and to report suspected violations of the Company Code of Conduct, its policies and procedures, and/or violation of law or regulations.
· Ensure that employees are informed of the Alliance’s non-retaliation policy and in cooperation with the Human Resources Department, ensure the appropriate implementation of the non-retaliation policy.
· Maintain and operate the Alliance’s compliance hotline and other mechanisms to receive reports of alleged compliance violations.
· In coordination with the Human Resources Department, communicate the Compliance Program’s code of conduct, policies, and procedures in a practical manner to all employees through regular training and education programs and other appropriate means.
· Communicate responses/actions to reports of compliance matters to senior managers, as necessary, the Compliance Committee, and the Board of Governors.
· Lead the coordination with HIPAA, privacy, and security risk assessment activities.
· Establish productive working relationships with all Alliance departments and employees to facilitate operation of the Compliance Program including education, training, compliance, auditing and reporting.
· Coordinate with the Human Resource Department to ensure compliance objectives are incorporated into hiring, evaluation, investigation, and discipline practices.
· In conjunction with the Human Resource Department, publicize the consequences of non-compliance by educating employees regarding disciplinary action that may be taken as a result of non-compliance, up to and including termination of employment.
· Formalize and monitor a system to enable employees to report any non-compliance without fear of retribution, ensuring that the reporting system is adequately publicized and that allegations of non-compliance are investigated and responded to promptly.
MONITOR, TRACK AND AUDIT:
· Consistent with the annual compliance work plan, assist departments in compliance identifying, prioritizing, and undertaking monitoring and auditing activities. Lead in the coordination with applicable departments and/or agencies to develop audit procedures and conduct internal and external audits.
· Develop and/or ensure internal controls are capable of preventing and detecting significant instances or patterns of illegal, unethical, or improper conduct.
· Assist department managers in establishing routine audit and reporting procedures in accordance with compliance requirements. In the event of non-compliance, work with applicable department manager to establish a corrective action plan, following up on such plan until compliance is restored.
· Analyze audit reports provided by internal departments and provide analyses of results, risk assessment, and trends.
· Track all issues referred to the Compliance Department, including grievances, up to and including implementation of corrective action.
· Conduct routine review of the OIG’s “List of Excluded Individuals/Entities” to determine if employees, third parties with whom the Alliance does business or any providers have been excluded from federal health care programs.
INVESTIGATION AND CORRECTIVE ACTION:
· Coordinate as appropriate with legal counsel, conducting or authorizing and overseeing investigations of matters requiring investigation under the Compliance Program.
· Develop detailed corrective action plans that clearly identify the corrective action steps required, timeframes, and individuals responsible for corrective action.
· Working with the appropriate department director or manager coordinate implementation of corrective action plans.
· In coordination with senior management and legal counsel, as applicable, communicate with all federal, state, and regulatory bodies on issues of compliance, including but not limited to applicable reporting of compliance audits, fraud or abuse, patient privacy, grievances, and other issues of non-compliance.
ESSENTIAL FUNCTIONS OF THE JOB
· Update, develop, implement, document, and maintain organization-wide compliance program as necessary.
· Update, develop, implement, and maintain organizational policies, procedures, and standards.
· Coordinate and initiate internal audits.
· Compliance education and training of staff.
· Monitor, track, and audit the compliance program, identify risks, and ensure departmental compliance on an ongoing basis.
· Initiate investigations and corrective action plans.
· Constant and close visual work at desk or computer.
· Constant sitting and working at desk.
· Constant data entry using keyboard and/or mouse.
· Frequent use of telephone headset.
· Frequent verbal and written communication with staff and other business associates by telephone, correspondence, or in person.
· Frequent lifting of folders and various other objects weighing between 0 and 30 lbs.
· Frequent walking and standing.
· Occasional driving of automobiles.
EDUCATION OR TRAINING EQUIVALENT TO:
· Bachelor’s degree required.
· Masters degree or JD degree with emphasis in business, health administration, or related field preferred.
MINIMUM YEARS OF ADDITIONAL RELATED EXPERIENCE:
· Seven years experience in Federal and/or State regulatory compliance.
· Three years in compliance and/or risk management roles at the management level in managed health care or insurance industry.
· Ten years health plan management experience.
SPECIAL QUALIFICATIONS (SKILLS, ABILITIES, LICENSE):
· Specialized training in Federal regulatory compliance and/or corporate risk.
· Experience in using managed care concepts within public sector health delivery systems. Excellent oral and written communication skills, with emphasis on effective education, training, and reporting.
· Inquisitive and analytical problem solver with initiative and ability to work independently.
· Excellent interpersonal skills and ability to perform effectively with members of different departments as a team.
· Ability to effectively present and represent the Alliance’s interests externally with regulators.
· Excellent computer analysis and research skills.
· Ability to read, analyze and interpret professional journals, technical procedures, governmental regulations, and legal documents.
· Ability to understand and discuss detail, but also to develop and manage high-level plans and strategies.
· Strong influencing skills and perseverance in investigating.
· Demonstrates high integrity and excellent judgment.
· Proven ability to maintain an effective professional liaison with a Board of Governors.
· Extensive experience with public assistance programs and public agencies. Experience in use of various computer system software as well as Windows, Microsoft Word, Microsoft Excel, Microsoft Outlook and Microsoft PowerPoint.
$225,000 - $337,500/annually