AVP Compliance, Chief Compliance Officer UMass Memorial Medical Center and UMass Memorial Medical Group

UMass Memorial Health•Worcester, MA

About The Position

The AVP Compliance UMass Memorial Health (“UMMH”) and Chief Compliance Officer UMass Memorial Medical Center (“UMMMC”) and UMass Memorial Group (“UMMMG”) (“AVP CCO”), serves as the Compliance Officer for UMMMC and UMMMG and reports to the UMMH Vice President and Chief Compliance Officer (“VP CCO”), with an indirect reporting relationship to the presidents of UMMMC and UMMMG. The AVP CCO will have access to all data and personnel (including senior leadership and members of the Board of Directors) necessary to fulfill the responsibilities outlined below. The Compliance Officer, in conjunction with senior management and the UMMMC Compliance Committee, is responsible for establishing, implementing, and overseeing an effective compliance program fostering ethical business behavior and ensuring compliance with all laws and regulatory requirements applicable to UMMMC.

Requirements

Bachelor’s degree.
Certified in Healthcare Compliance (CHC) within one year of hire
Ten years’ experience in health care organization, plus five years of managerial/supervisory experience including project management.
Ten years in corporate compliance; at least five years of which must be at a management level.
Professional work experience with federal and state agencies in a compliance capacity.
Strong interpersonal skills and leadership ability.
Knowledge of healthcare laws, regulations, and standards.
Extensive experience in report development and policy and procedure development, preferably industry related.
Excellent analytical, written and oral communication skills.
Experience in public speaking and business presentations.
Excellent Excel spreadsheet, Internet, PowerPoint and Word processing skills.

Nice To Haves

Master’s or similar advanced degree in related field (law, healthcare administration, nursing, business administration or accounting/finance).
Understanding of coding and reimbursement systems, risk management and performance improvement helpful.

Responsibilities

Collaborate with the VP CCO, Compliance Office leadership and staff, and UMMMC and UMMMG Senior leadership, to oversee the implementation of an effective compliance program for UMMMC and UMMMG that provides the basis for compliance with laws and regulatory requirements, promotes the organization’s commitment to compliance and a culture of integrity, and incorporates the seven elements of an effective compliance program, including: a. A written code of conduct, policies, and procedures, b. Compliance program leadership and oversight, c. Training and education, d. Effective lines of communication with the compliance office, including a confidential reporting system, e. Enforcing standards, including consequences and incentives, f. Risk assessment, auditing, and monitoring, and g. Responding to detected offenses and developing corrective action initiatives.
Serve as a trusted strategic partner and provide effective leadership, advice and counsel to UMMMC and UMMMG senior leadership to support UMMMC and UMMMG objectives, mission, and strategic objectives in compliance with the law, regulations, ethical business practices, the UMMH Code of Ethics and Business Conduct, and policies.
Oversee an ongoing risk assessment process for UMMMC and UMMMG to identify, prioritize, develop, and modify work plans to address compliance risks.
Oversee and provide guidance to UMMMC and UMMMG leadership to prevent fraud and abuse and other illegal acts, including but not limited to compliance with the Anti-kickback Statute, the Stark Law, and Civil Monetary Penalties.
Work in partnership with other Compliance staff to address risks related to: a. The integrity of billing (under the leadership of the AVP, Revenue Cycle Chief Compliance Officer), b. Privacy (under the leadership of the AVP, Chief Privacy Officer), and c. Monitoring and oversight of conflicts of interest (under the leadership of Compliance Office COI staff),
Oversee and ensure the timely and appropriate response to reports to the Confidential Reporting System or to other communications regarding potential non-compliance.
Assure documentation of investigatory process, findings, summary, recommendations, and action plan/resolution.
Serve as Chair of the UMMMC Executive Management Compliance Committee and support the Committee in its oversight of the UMMMC Compliance program.
Maintain open communication with UMMMC and UMMMG leadership regarding material Compliance matters.
Obtain advice, counsel, and information, and foster cooperative efforts with management and staff as appropriate, including, but not limited to, the Office of the General Counsel, Internal Audit, Risk Management, Revenue Cycle, Information Security and Human Resources.
Maintain a relationship with the Office of the General Counsel, and as needed with outside Compliance counsel, seeking input regarding key risks, significant investigations, and oversight of significant interactions with governmental agencies, including refunds or other self-disclosures.
Participate in UMMH system compliance operations, including, but not limited to the oversight and development of compliance policies, procedures, training, and workplans, contract review, communication and promotion of the Compliance program (including but not limited to the Code of Ethics and Business Conduct, Confidential Reporting System and Compliance policies), and other projects that are implemented for UMMH entities in general. Collaborate with other UMMH entity Compliance Officers.
Manage the Associate Compliance Officer for UMMMC and UMMMG.
Maintain an awareness of, and monitor developments/changes in, laws and regulations affecting the UMMMC and UMMMG Compliance Program. Communicate and advise management regarding these changes and the need for modification of policies or procedures or modification of the compliance plan.
Ensure the visibility of the Compliance Office/Program to UMMMC and UMMMG to provide for effective communication of questions or concerns and collaboration on resolution of compliance issues.
Monitor the performance of the UMMMC and UMMMG Compliance Program and related activities on a continuing basis, taking appropriate steps to improve program effectiveness.
Directs and supervises assigned personnel including performance evaluations, scheduling, orientation, and training. Makes recommendations on employee hires, transfers, promotions, salary changes, discipline, terminations, and similar actions. Resolves grievances and other personnel problems within position responsibilities.
Develops and recommends the budgets for the areas managed. Manages activities to assure financial goals are met.
Coordinates the assignment of tasks and helps resolve technical and operational problems. Evaluates the impact of solutions to ensure goals are achieved.
Provides effective direction, guidance, and leadership over the staff for effective teamwork and motivation and fosters the effective integration of efforts with system-wide initiatives.
Encourages and supports diverse views and approaches, demonstrates Standards of Respect, and contributes to creating and maintaining an environment of professionalism, respect, tolerance, civility and acceptance toward all employees, patients and visitors.
Integrates diversity into departmental objectives, such as hiring, promotions, training, vendor selections, etc.
Participates in performance improvement initiatives and demonstrates the use of quality improvement in daily operations.
Ensures compliance with regulatory agencies such as Joint Commission, DPH, etc. Develops and maintains procedures necessary to meet regulatory requirements.
Ensures that department complies with hospital established policies, quality assurance programs, safety, and infection control policies and procedures.
Ensures adequate equipment and supplies for department.
Develops and maintains established departmental policies, procedures, and objectives.
Ensures compliance to all health and safety regulations and requirements.
Maintains, regular, reliable, and predictable attendance.
Performs similar or related duties as required or directed.