VP, Compliance & Privacy Officer
Steward Health Care Network
Steward Health Care Network
* The VP, C&PO, SHCN is a member of the OCCP with general duties and responsibilities related to being the focal point for implementing Steward Health Care Network's Compliance & Privacy Program (Program), including Steward managed Health Plans, MCO and ACO Programs nationally.
* This position reports directly to the Chief Strategy Officer/President of SHCN.
* This position provides regular direct reports to the SHCN Board of Directors and the SHCN managed entity Boards. He or she will not serve as legal counsel to an ACO.
* The VP, C&PO, SHCN needs to be a person of high integrity, and any other duties assigned should not be in conflict with the SHCN's Program goals and objectives. This position will be based in Dallas, TX and will require travel to other assigned Steward locations.
* The VP, C&PO, SHCN is responsible for driving implementation and maintenance of SHCN's Programs. This position will be highly visible and accessible to SHCN and its managed entity leaders in order to implement and maintain the Programs and to provide guidance to leadership and management teams.
* Assists SHCN leadership in understanding compliance with existing and changing laws and regulations to ensure compliance with State and Federal laws, regulations and mandates
* Conduct research on state and federal programs, as needed, and monitor changes to requirements to these programs in order to mitigate risks and achieve compliance
* Establish and assist with implementation of standard policies, procedures, processes and best practices across the Network and managed entity lines of business to promote compliance with applicable laws and contractual obligations
* Drafts annual SHCN Program Work Plans for board approval
* Develops, implements and maintains Program activities that monitor and confirm compliance with legal, regulatory and contractual requirements
* Develops compliance communications
* Assists in the collection of data with management to submit timely and accurate regulatory filings, leads efforts to develop reports, projects, and assessment tools that monitor and confirm compliance
* Establishes and fosters effective working relationships and builds credibility within the Steward System to support a culture of compliance
* Identifies potential risk areas and assists SHCN leadership with developing risk mitigation and/or corrective action plan strategies
* Monitors follow up with management to address / resolve identified compliance concerns (i.e., corrective action plans)
* Acts as a consultative resource on issues concerning compliance and privacy matters, and provides recommendations to enhance policies, procedures and internal controls as needed
* Ensures that information is provided to SHCN leadership to keep them current on the latest compliance program related risks and leading practices
* Works with the OCCP leadership in the development and delivery plan of compliance and privacy training for both employees and network provider partners.
* Prepares written reports, on a quarterly basis or as requested, to keep the CSO/President SHCN informed of compliance program activities and issues on a timely basis
* Provides reports to SHCN leadership on compliance program activities and issues on a regular basis (at least quarterly)
* Ensures all identified issues are logged in the OCCP database (ComplyTrack) accurately and timely
* Leads investigations or supervises investigations of compliance and privacy concerns raised through the Compliance Support Line or other communication mechanisms
* Works with Steward's Office of General Counsel (OGC) as needed to resolve legal compliance issues
* Cooperates with regulators (such as CMS, CMMI, OIG, OCR, etc.) as appropriate, in connection with any privacy or compliance inquiries, audits or investigations
* Reviews conflict of interest disclosure forms for SHCN to identify any concerns that may need to be brought to the attention of the CSO/President of SHCN for follow-up or resolution
* Participates in health care compliance and privacy professional organizations to stay abreast of privacy and corporate compliance developments and leading industry practices
* Attends and/or co-chairs SHCN managed entity Compliance Committee meetings
* Participates in periodic OCCP team meetings in order to ensure effective communication
* As requested, actively participates in Steward committees as an OCCP representative
* Collaborates and works effectively with other OCCP team members to drive "operational excellence" (i.e., standardization, scalability, effectiveness and efficiency) system-wide
* Maintains time and effort reporting records as requested
* Demonstrates respect and regard for the dignity of all patients, families, visitors, and fellow employees to ensure a professional, responsible, and courteous environment
1. Commits to recognize and respect cultural diversity for all customers (internal and external)
2. Communicates effectively with internal and external customers with respect of differences in cultures, values, beliefs and ages, utilizing interpreters when needed
* Performs other duties as assigned
REQUIRED KNOWLEDGE & SKILLS:
* Knowledge of CMS program rules and regulations, including but not limited to, those that apply to ACO's and Medicare Advantage plan sponsors, as well as these CMS programs: bundled payment for care improvement, shared savings, etc
* General knowledge of health plan operations, including Utilization Management, Quality Management, Network, Contracting, etc
* General knowledge of state and federal health care laws as they apply to Qualified Health Plans preferred
* Familiarity with operational, financial, and information technology security regulations
* Strong oral/written communication and presentation skills a must. Excellent grammar and editing abilities
* Strong leadership, organizational, interpersonal and analytical skills and the ability to function effectively in a fast-paced environment
* Ability to prioritize and plan work independently
* Ability to interact with all levels of management
* Effectively work with and coordinate the activities of external consultants and legal counsel
* Ability to anticipate potential issues and proactively respond
* Good judgment and problem solving skills
* Attention to detail a must
* Excellent computer skills (especially MS Word, Excel and PowerPoint)
* Team player
* Ability to maintain confidentiality
* A bachelor's degree required. Higher degree preferred.
* 5 years of experience and knowledge working within a managed care environment
* 3 years of experience working in a regulatory and/or compliance role
* 2 years of experience and understanding of HIPAA and state privacy laws
* Experience in a strategic role, ideally leading and implementing a comprehensive compliance program and supporting business development
* Experience working as a subject matter expert in a matrixed organization, working with various departmental leads and/or stakeholders
* For-profit health care experience a plus
* Certification in Healthcare Compliance (CHC) certification required.
* Certification in Healthcare Privacy Compliance (CHPC) preferred.
* Microsoft Outlook, Word, Excel, Internet Explorer and PowerPoint Skills Required.
* Microsoft Access Skills preferred.
* Ability to effectively navigate electronic health records and hospital billing systems preferred.
?? Ability to research applicable Medicare, Medicaid and other compliance requirements is required.
Other: Travel Requirements:
* The ability to travel nationally
* Must have a valid driver's license, provide own transportation, and be able to travel to Steward locations using a variety of modes of transportation
Job Reference #: 52742