Senior Vice President Chief Compliance Officer

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Senior Vice President Chief Compliance Officer
Duties: Creation and revision of compliance program policies under the direction of the Chief Compliance Officer in accordance with the seven recognized elements of an effective compliance program. Evaluation of periodic risk assessments to identify high risk areas Formulation of annual system level compliance work plan focused on continuous improvement of processes in identified risk areas Provide input, review and approve entity level annual compliance work plans Formulate quarterly entity level dashboards to monitor performance in identified components of the compliance program (which may change from year-to-year). Carry out the Annual Conflicts of Interest Disclosure questionnaire process. Assist the Chief Compliance Officer with quarterly Compliance Council meetings and agenda. Produce reports as requested by the Chief Compliance Officer Oversee entity compliance officer activities, monitor performance in accordance with dashboards, completion of annual work plans and responsiveness to Compliance Oversee and monitor the implementation of the Business Ethics and Compliance Program and the Privacy Program throughout the health care system including policies, education, monitoring processes, performance dashboards, audits, investigations and corrective actions, as warranted. Periodically assess the effectiveness of these programs and related activities. Oversee the Identity Theft Prevention Program (Red Flags Program). Oversee the Anti-Fraud Program. Develop and deploy a multi-faceted educational program that focuses on the elements of the Business Ethics and Compliance Program for new and existing workforce members including certain independent contractors. Develop and deploy education focused on identified business processes to mitigate the risk of noncompliance in areas vulnerable to error or noncompliance such as billing, coding, Stark laws, fraud & abuse laws, false claims or other identified risk areas. Develop and deploy effective communication throughout to maintain high employee awareness of the Business Ethics and Compliance Program including how to raise and address concerns. Develop approaches and programs to encourage managers and employees to report suspected violations of laws, regulations or policies without fear of retaliation. Attend entity level Board Meetings at least once a year to maintain communication and updates for Boards of Trustee in addition to the regular quarterly reports provided by the entity compliance officer. Participate in workgroups and other forums appropriate to facilitate communication and awareness of the Business Ethics and Compliance Program. Establish training programs that: (1) convey Code of Business Ethics Code , the Compliance Program and the Privacy Program (2) periodically refresh employee’s knowledge of the Code and the Programs, and (3) focus on compliance and privacy risks related to specific functional areas and/or specific populations. Operation of the Compliance Hotline. Oversee and carryout independent investigation on matters related to compliance and/or response to reports of possible compliance issues. See that matters are resolved, and corrective action taken as warranted keeping the Chief Compliance Officer informed as appropriate. Coordinate with the Chief Compliance Officer and Legal Services on any review or investigation that is non-routine and/or appears to create risk. See that corrective action is taken in response to substantiated reports of violations or errors. Participate in evaluation of internal controls to see that processes are in place capable of detecting significant instances or patterns of unethical conduct by employees, agents or contractors. Maintain incident tracking system and prepare reports for management and Boards. Serve as a consultant to entity compliance officers with respect to incidents that may arise at the entity level requiring investigation, follow-up and resolution. Periodically assess compliance and privacy risks to which THR is exposed to ensure that the programs are responsive to these risks. Establish and oversee internal reporting processes including the Compliance Hotline to ensure that employees, agents and contractors can report ethics, compliance or privacy concerns in good faith without fear of retaliation. See that compliance or privacy related concerns reported via the Compliance Hotline or through other means are promptly and thoroughly investigated and periodically summarized for the benefit of the System Compliance Council, entity Boards, the Compliance and Audit Committee and senior management. Notify executive management and/or the Boards of Directors (in the instance that executive management is implicated) of compliance issues that may pose significant risk to and/or its subsidiaries. Ensure that any matter requiring external reporting or disclosure, such as to a regulatory or enforcement agency, is coordinated with legal counsel and reported within requirements. Conduct or authorize an independent investigation of any matter which, in the judgment of the Chief Compliance Officer cannot be adequately investigated by a resource. Refer any matter requiring investigation or follow-up to legal services, internal audit, security, human resources, risk management or other department for review and investigation, as appropriate. Serves as internal consultant to appropriate business units including:. Central business office, coding, physician contracting, fraud & abuse laws, Medicare/Medicaid regulatory requirements or other compliance related subject matter. Monitor processes designed to promptly refund overpayments within 60 days of a confirmed overpayment. Coordinate with the Central Business Office and others as needed. Chair the Billing Compliance Committee. Monitor regulatory updates, new laws and stay abreast of healthcare regulatory requirements. Communicate to affected areas. Participate in workgroups and other forums to provide compliance expertise and serve as a subject matter expert as needed to support initiatives. Work with Governmental Activities personnel as needed on emerging legislation, comments to proposed regulations, etc. Facilitate and support the Entity Compliance/Privacy Officers and Committees and other workgroups, as needed. Resource Management and Allocation including:. See that periodic coding compliance reviews are performed, review reports and corrective action plans. Implement compliance monitoring activities in coordination with other areas such as Finance, Central Business Office, Revenue Cycle or other functional areas with high risk areas. Monitor data such as Pepper reports, internal data, OIG reports or other information to assist in identifying areas for further monitoring or audit. Work with Internal Audit function as needed in identified risk areas. Report on a regular basis to the Board Audit and Compliance Committee on the progress of the programs and efforts to reduce vulnerability privacy breaches, fraud, waste and abuse. Evaluate internal control systems to see that the systems are capable of detecting significant instances or patterns of unethical conduct by employees, agents or contractors. Have input into the contracting, hiring, performance evaluation, and exit interview processes to implement procedures designed to properly screen prospective employees and contractors, evaluate existing employees as to compliance efforts, and explore whether exiting employees have ethics or compliance concerns which contributed to the employee’s decision to leave THR. Manage budget, resources and staff. Lead, mentor and develop talent within the compliance staff at both system and entity levels. Responsible for annual compliance department financial budget and staffing plan. Manage services to meet budget. Hire and orient staff, serve as a mentor, coach and hold staff accountable. Perform timely performance evaluations and assist staff reach his or her career goals and potential. Implement effective staff communication vehicles to build successful team and keep staff informed of base camp goals and objectives. Lead compliance staff in meeting key performance indicators. Oversee entity compliance/privacy officers who have direct accountability to the Chief Compliance Officer with respect to their compliance and privacy functions. Establish and communicate expectation of ethical and legal conduct by all employees’ agents and contractors. Manage outside inquiries and/or audits related to compliance or privacy matters including OIG, Department of Justice and/or Medicare and Medicaid audit contractor audit activities. Coordinate with Legal Services as needed in these matters.

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