Chief Ethics, Compliance and Risk Officer

Agilon Health • Remote - IL, IL

1d • Remote

About The Position

Serve as a strategic partner to senior leadership, integrating compliance and ethics considerations into business planning, growth initiatives, and decision-making. Advise on healthcare regulatory matters affecting business operations, market strategy, and strategic initiatives across Medicare Advantage, ACO, and value-based care models. Support complex transactions, new market expansion, and partner relationships by providing proactive compliance guidance that facilitates execution while protecting the organization. Ensure company and partner communications related to Markets, ACO, and Growth achieve business objectives while maintaining regulatory compliance and protecting confidential and proprietary information. Partner with senior management to integrate compliance considerations into business planning and decision-making at the enterprise level.

Develop and implement comprehensive compliance and risk management programs aligned with enterprise strategy. Oversee compliance operations across healthcare, corporate governance, privacy, and other regulatory domains. Design and monitor internal controls and compliance monitoring systems. Lead risk assessment initiatives in partnership with enterprise stakeholders, vendors, and business partners. Ensure alignment between compliance functions and Compliance/Audit Committee requirements. Drive policy development that balances business enablement with regulatory compliance. Build and sustain a compliance culture through training, communication, and stakeholder engagement. Manage regulatory relationships and coordinate responses to regulatory inquiries.

Communicate the importance of the Compliance Program to the executive management team, Board of Directors, and the agilon health enterprise; prepare and distribute the written Code of Conduct; set forth the ethical principles and policies which form the basis of the Compliance Program. Implement education programs addressing compliance and the Code of Conduct; maintain a retaliation-free internal reporting process, including an anonymous reporting system; collaborate with executive management to effectively incorporate the Compliance Program within system operations and programs. Regularly review the Compliance Program and recommend appropriate revisions and modifications, including advising leadership and the Board of Directors of potential compliance risk areas. Ensure that internal controls can prevent and detect significant instances or patterns of illegal, unethical, or improper conduct by employees, agents, affiliated providers, or others working with the organization. Ensure the agilon health Compliance Program effectively detects and prevents violations of law, regulations, and organization policies, including Medicare billing and marketing regulations, fraud and abuse laws, and policies for the protection of privacy and confidentiality of protected health information. Protects protected health information (PHI) in accordance with Health Insurance Portability and Accountability Act (HIPAA) standards.

Lead agilon’s Enterprise Risk Management (ERM) function, establishing the framework, governance structure, risk appetite, and operating cadence in partnership with Internal Audit and senior leadership. Design and implement an enterprise risk identification, assessment, and prioritization process that covers strategic, operational, regulatory, financial, and reputational risk domains. Partner with Internal Audit to align ERM and audit activities, ensuring risks are appropriately covered, escalated, and tracked without duplication of effort. Develop and maintain the enterprise risk register; report on key risk indicators and emerging risks to the CEO, executive team, and Board on a regular cadence. Integrate ERM insights into strategic planning, business development, and operational decision-making across the organization. Champion a culture of proactive risk awareness; build risk management capabilities across business units through training, tools, and embedded support.

Serve as the primary compliance resource for agilon’s ACO programs, including ACO REACH, MSSP, and ACO LEAD, providing guidance on CMS participation requirements, program integrity obligations, and regulatory compliance. Review and advise on ACO participation agreements, CMS data use agreements, and program-related contracting, escalating complex matters to the Chief Legal Officer as appropriate. Monitor CMS and CMMI rulemaking, policy guidance, and program changes affecting agilon’s ACO portfolio; analyze implications and communicate material developments to leadership. Support ACO-related compliance training for physician partners, affiliated providers, and internal teams, ensuring awareness of program integrity requirements and fraud and abuse obligations. Coordinate with the Legal team, Finance, and ACO operations on annual attestation requirements, quality reporting obligations, and regulatory submissions. Track and respond to CMS inquiries, audits, and corrective action requests related to ACO program compliance.

Provide compliance oversight for agilon’s clinical documentation and coding programs, ensuring that risk adjustment coding practices, HCC capture methodologies, and documentation standards comply with CMS requirements, Medicare Advantage regulations, and applicable fraud and abuse laws. Oversee agilon’s coding compliance program, including risk adjustment data validation (RADV) readiness, retrospective and prospective coding review processes, and clinical documentation improvement (CDI) initiatives in partnership with clinical and technology leadership. Serve as the enterprise compliance lead for all CMS audit activity, including any CMS-initiated program audits; coordinate audit response strategies with Legal, Finance, Clinical, and partner-facing teams, and manage corrective action plan development and tracking. Establish and maintain a proactive internal audit framework for coding and clinical compliance, including routine sampling and review of physician partner documentation, encounter data submissions, and diagnosis code accuracy; report findings and remediation status to the Board of Directors on a defined cadence. Partner with agilon’s clinical support and technology teams to monitor encounter data submission quality, identify patterns indicating documentation or coding risk, and implement education and remediation programs for physician partners and clinical staff.

Demonstrate rigorous attention to detail and accuracy in work product. Provide excellent client service, including consistently displaying awareness and sensitivity to the needs of internal and/or external clients and proactively ensuring that these needs are met or exceeded. Understand, adhere to, and implement the Company’s policies and procedures. Engage in excellent communication which includes listening attentively and speaking professionally. Demonstrate excellent problem-solving skills and sound independent judgment. Comfortable navigating ambiguity and managing multiple high-priority workstreams simultaneously. Performs special projects and analyses, as well as additional duties as assigned.

Requirements

• Minimum 10+ years of progressive compliance experience, with a minimum of 5 years in a senior compliance leadership role at a healthcare organization.
• Demonstrated experience building and leading enterprise compliance programs at a public company, including Code of Conduct, training, internal controls, and regulatory reporting.
• Deep knowledge of Medicare Advantage, ACO models, value-based care regulatory frameworks, and related compliance domains (fraud and abuse, privacy, billing and marketing regulations).
• Experience managing relationships with and presenting to executive management, boards, and regulatory bodies.
• Strong business acumen and strategic thinking capabilities; ability to translate complex regulatory requirements into clear, actionable business guidance.
• Excellent written and verbal communication skills with high degree of professionalism and discretion.
• Ability to manage multiple priorities independently in a fast-paced, lean-resourced environment.
• Bachelor’s degree required.
• Juris Doctor (J.D.) from an accredited law school with active bar admission in at least one U.S. jurisdiction preferred but not required.
• Working knowledge of federal healthcare regulatory frameworks including AKS, Stark Law, HIPAA, and CMS ACO program rules; familiarity with Medicare value-based care constructs and public company governance requirements.

Nice To Haves

• Advanced degree (J.D., M.B.A., M.H.A.) preferred.
• Professional certifications related to compliance (e.g., CCEP, CHC, CIPP-US).
• Experience with ACO regulatory frameworks (REACH, MSSP, LEAD) and Medicare Advantage star ratings economics.
• Prior experience serving as CCO or Deputy CCO at a publicly traded healthcare company.
• Familiarity with the post-Loper Bright legal environment and its implications for agency deference in healthcare regulation.
• J.D. with active bar admission in at least one U.S. jurisdiction.
• Familiarity with compliance management, matter management, or GRC platforms preferred.

Responsibilities

• Serve as a strategic partner to senior leadership, integrating compliance and ethics considerations into business planning, growth initiatives, and decision-making.
• Advise on healthcare regulatory matters affecting business operations, market strategy, and strategic initiatives across Medicare Advantage, ACO, and value-based care models.
• Support complex transactions, new market expansion, and partner relationships by providing proactive compliance guidance that facilitates execution while protecting the organization.
• Ensure company and partner communications related to Markets, ACO, and Growth achieve business objectives while maintaining regulatory compliance and protecting confidential and proprietary information.
• Partner with senior management to integrate compliance considerations into business planning and decision-making at the enterprise level.
• Develop and implement comprehensive compliance and risk management programs aligned with enterprise strategy.
• Oversee compliance operations across healthcare, corporate governance, privacy, and other regulatory domains.
• Design and monitor internal controls and compliance monitoring systems.
• Lead risk assessment initiatives in partnership with enterprise stakeholders, vendors, and business partners.
• Ensure alignment between compliance functions and Compliance/Audit Committee requirements.
• Drive policy development that balances business enablement with regulatory compliance.
• Build and sustain a compliance culture through training, communication, and stakeholder engagement.
• Manage regulatory relationships and coordinate responses to regulatory inquiries.
• Communicate the importance of the Compliance Program to the executive management team, Board of Directors, and the agilon health enterprise; prepare and distribute the written Code of Conduct; set forth the ethical principles and policies which form the basis of the Compliance Program.
• Implement education programs addressing compliance and the Code of Conduct; maintain a retaliation-free internal reporting process, including an anonymous reporting system; collaborate with executive management to effectively incorporate the Compliance Program within system operations and programs.
• Regularly review the Compliance Program and recommend appropriate revisions and modifications, including advising leadership and the Board of Directors of potential compliance risk areas.
• Ensure that internal controls can prevent and detect significant instances or patterns of illegal, unethical, or improper conduct by employees, agents, affiliated providers, or others working with the organization.
• Ensure the agilon health Compliance Program effectively detects and prevents violations of law, regulations, and organization policies, including Medicare billing and marketing regulations, fraud and abuse laws, and policies for the protection of privacy and confidentiality of protected health information.
• Protects protected health information (PHI) in accordance with Health Insurance Portability and Accountability Act (HIPAA) standards.
• Lead agilon’s Enterprise Risk Management (ERM) function, establishing the framework, governance structure, risk appetite, and operating cadence in partnership with Internal Audit and senior leadership.
• Design and implement an enterprise risk identification, assessment, and prioritization process that covers strategic, operational, regulatory, financial, and reputational risk domains.
• Partner with Internal Audit to align ERM and audit activities, ensuring risks are appropriately covered, escalated, and tracked without duplication of effort.
• Develop and maintain the enterprise risk register; report on key risk indicators and emerging risks to the CEO, executive team, and Board on a regular cadence.
• Integrate ERM insights into strategic planning, business development, and operational decision-making across the organization.
• Champion a culture of proactive risk awareness; build risk management capabilities across business units through training, tools, and embedded support.
• Serve as the primary compliance resource for agilon’s ACO programs, including ACO REACH, MSSP, and ACO LEAD, providing guidance on CMS participation requirements, program integrity obligations, and regulatory compliance.
• Review and advise on ACO participation agreements, CMS data use agreements, and program-related contracting, escalating complex matters to the Chief Legal Officer as appropriate.
• Monitor CMS and CMMI rulemaking, policy guidance, and program changes affecting agilon’s ACO portfolio; analyze implications and communicate material developments to leadership.
• Support ACO-related compliance training for physician partners, affiliated providers, and internal teams, ensuring awareness of program integrity requirements and fraud and abuse obligations.
• Coordinate with the Legal team, Finance, and ACO operations on annual attestation requirements, quality reporting obligations, and regulatory submissions.
• Track and respond to CMS inquiries, audits, and corrective action requests related to ACO program compliance.
• Provide compliance oversight for agilon’s clinical documentation and coding programs, ensuring that risk adjustment coding practices, HCC capture methodologies, and documentation standards comply with CMS requirements, Medicare Advantage regulations, and applicable fraud and abuse laws.
• Oversee agilon’s coding compliance program, including risk adjustment data validation (RADV) readiness, retrospective and prospective coding review processes, and clinical documentation improvement (CDI) initiatives in partnership with clinical and technology leadership.
• Serve as the enterprise compliance lead for all CMS audit activity, including any CMS-initiated program audits; coordinate audit response strategies with Legal, Finance, Clinical, and partner-facing teams, and manage corrective action plan development and tracking.
• Establish and maintain a proactive internal audit framework for coding and clinical compliance, including routine sampling and review of physician partner documentation, encounter data submissions, and diagnosis code accuracy; report findings and remediation status to the Board of Directors on a defined cadence.
• Partner with agilon’s clinical support and technology teams to monitor encounter data submission quality, identify patterns indicating documentation or coding risk, and implement education and remediation programs for physician partners and clinical staff.
• Demonstrate rigorous attention to detail and accuracy in work product.
• Provide excellent client service, including consistently displaying awareness and sensitivity to the needs of internal and/or external clients and proactively ensuring that these needs are met or exceeded.
• Understand, adhere to, and implement the Company’s policies and procedures.
• Engage in excellent communication which includes listening attentively and speaking professionally.
• Demonstrate excellent problem-solving skills and sound independent judgment.
• Comfortable navigating ambiguity and managing multiple high-priority workstreams simultaneously.
• Performs special projects and analyses, as well as additional duties as assigned.

Benefits

• Salary range shown is a guideline. Individual compensation packages can vary based on factors unique to each candidate, such as skill set, experience, and qualifications.
• The passion to change the way healthcare is delivered permeates everyone and everything at agilon health. Working together we can use our expertise to make a difference in the lives of patients and physicians alike. We can bring the joy back to practicing medicine for physicians and improve the care experience for patients across the country.
• We value your privacy and trust as much and are committed to protecting your personal information and respecting your choices. We use technology and best practices to ensure that your data is secure and compliant with applicable laws and regulations. We also provide you with clear and transparent information about how we collect, use, and share your data, and how you can access, update, or delete it. We strive to develop leaders and build future talent pools to help us meet the needs of our customers.

What This Job Offers

• Job Type: Full-time
• Career Level: Senior