Associate Compliance Officer

We need to output HTML fragment with sections: headings

for sections like About the role, Responsibilities, Requirements, Qualifications, Skills, Benefits, Pay, Schedule. We must include only sections that have real specific content. The job description includes many responsibilities, but no explicit sections like "About the role", "Requirements", "Qualifications", "Skills", "Benefits", "Pay", "Schedule". We need to infer from content: There's a job summary, essential job functions, etc. We can create sections: About the role (maybe from job summary), Responsibilities (list of essential functions), Requirements/Qualifications (maybe not explicit; there is no explicit qualifications like education, experience). The posting does not list specific qualifications, so we should not create a Requirements section if no real content. Similarly Benefits, Pay, Schedule not mentioned. So we should only include sections for which we have substantive content: About the role (job summary), Responsibilities (essential functions (list). Possibly also "Qualifications" if there is any mention like "Associate Compliance Officer in conjunction with the Compliance Officer" but not explicit. Better to avoid. Thus output:

About the role

The Associate Compliance Officer in conjunction with the Compliance Officer is responsible for the development, implementation, operation, and monitoring of the Compliance Program to ensure regulatory requirements.

Then responsibilities: we need to extract list items from essential job functions. Many bullet-like sentences. We'll create

• each distinct duty. We need to preserve all substantive information, not invent or summarize away detail. Must not omit details. So we need to list each duty as separate
• . The text is long; we need to parse. Let's extract duties from "Essential Job Functions" onward. The text after "Essential Job Functions Alongside the Compliance Officer direct, coordinate, and monitor efforts to ensure operational compliance with (a) applicable federal and state laws and regulations, (b) Centers for Medicare and Medicaid Services (CMS) contract and Part C and Part D Program requirements, (c) Compliance Department and operational policies and procedures as they relate to compliance, and (d) the plan conduct requirements." Then continues: "Alongside the Compliance Officer embody and promote an overall culture of compliance that encourages ethical conduct and a commitment to compliance with the law." Then "Management of Compliance Department alongside the Compliance Officer Oversee and monitor implementation and effectiveness of the Compliance Program, including through supervision of direct employees who assist in Compliance Program efforts. Develop the Compliance Committee. Managing the Compliance Department, including management of the Compliance Program to ensure that compliance goals are met and that resources are used effectively." Then "Compliance Committee Involvement alongside the Compliance Officer Oversee the Compliance Committee, including scheduling meetings, developing appropriate agendas (with a standing FWA agenda item), compiling reports and information as requested by the Compliance Committee, and maintaining meeting minutes. Presenting the findings of any internal or external audit at the first regularly scheduled Compliance Committee meeting after the conclusion of the audit, or sooner, as necessary. Staying abreast of evolving CMS and other compliance program expectations. Making reasonable efforts to stay abreast of current and evolving legal and program standards through review of regulatory and other materials, publications, websites, and guidelines (including Health Plan Management System memoranda) issued by CMS or other relevant government agencies." Then "Internal Reporting Responsibility alongside the Compliance Officer Reporting frequently, as necessary and appropriate, to the CEO, legal counsel and the Compliance Committee on compliance issues and the status of the Compliance Program, unless such reporting would compromise an ongoing investigation or other confidential information. Reporting on a regular basis, at least quarterly, or more frequently as necessary, to the Board of Directors on the implementation and effectiveness of the Compliance Program. Such reports shall contain an update concerning the activities and status of the Compliance Program, including, without limitation (a) the status of compliance training when relevant, (b) issues identified, investigated, and resolved by the Compliance Program, (c) state or federal audits or enforcement activity, (d) a summary of monitoring and auditing activities, and (e) a description of FWA activities. The Associate Compliance Officer will, in conjunction with the Compliance Officer and the Compliance Committee, provide the results of its annual readiness and risk assessment to the Board of Directors." Then "Policies and Procedures/Code of Conduct alongside the Compliance Officer Develop written Compliance Program policies and procedures that meet CMS regulatory and other requirements and are designed to (a) implement an effective Compliance Program; and (b) address existing and new compliance risk areas. Working with senior management as appropriate, to ensure that operational policies and procedures contain effective internal controls designed to prevent and detect significant instances or patterns of illegal, unethical, or improper conduct or FWA. Periodically reviewing, modifying, and amending (or working with others to modify and amend) the Compliance Program, including the Code of Conduct and the Compliance Program policies and procedures, as necessary and presenting the same for Board of Director approval when appropriate." Then "Education and Training alongside the Compliance Officer Create, coordinate, and appropriately document education and training programs relating to the Compliance Program and FWA prevention, detection, and correction programs, and review and updating such education and training programs as necessary, but at least annually. Develop and implement mechanisms for testing the effectiveness of relevant education and training programs as directed by CMS or other oversight bodies. Work with senior management and FDRs, as appropriate, to ensure that these individuals and entities and their staff have the requisite information and knowledge concerning program requirements to carry out their responsibilities in a lawful and ethical manner, including through appropriate specific training." Then "Communication Regarding the Compliance Program alongside the Compliance Officer Appropriately publicizing the existence of the mechanism for reporting suspected instances of non-compliance (e.g., via periodic emails to employees or FDRs, posting the information in prominent common areas, brochures, intranet, and internet). Developing and implementing methods and programs that encourage the asking of compliance related questions and the reporting of suspected fraud, misconduct, and other non-compliance, including through anonymous and confidential good faith reporting of potential non-compliance or FWA through the compliance hotline, without improper retaliation. Develop and implement systems to ensure that member compliance related issues are appropriately directed to the Compliance Department for consideration and/or investigation. Respond appropriately to compliance with questions and inquiries." Then "FWA Prevention, Detection and Correction Program and Related Matters alongside the Compliance Officer Conduct ongoing FWA risk assessments to direct activities towards high-risk areas. Work with appropriate senior management to institute specific measures to detect, correct and prevent FWA, including through conducting proper internal monitoring, auditing, and oversight of those areas at greatest risk of FWA. Monitor the effectiveness of the FWA program for all subsidiaries, consistent with the program requirements. Oversee the communications with, and reporting to, CMS and its relevant designees, other oversight bodies or law enforcement, as appropriate, regarding compliance issues. Coordinate potential FWA investigations/referrals with the appropriate National Benefit Integrity Medicare Drug Integrity Contractor or other appropriate governmental or other law enforcement entities, particularly where the potential FWA issue identified appears to affect multiple payers." Then "Employment and Disciplinary Matters alongside the Compliance Officer Coordinate with the Human Resources Department and others, as appropriate, to ensure that the OIG and GSA exclusion lists are checked with respect to new hires, employees, officers, directors and FDRs to confirm that such individuals and entities are not on such lists, pursuant to specific policies and procedures. Coordinate with the Human Resources Department with respect to employee performance and disciplinary policies and procedures to ensure cooperation with the Compliance Program elements is rewarded and improper conduct is consistently reported and sanctioned. Coordinate with the Human Resources Department concerning specific disciplinary matters, including recommending, overseeing, and documenting disciplinary action and other remedial measures, where appropriate. Attempt to solicit information concerning potential violations of any applicable requirements from departing employees through a proffered exit interview." Then "Monitoring and Auditing; FDR Oversight alongside the Compliance Officer Lead internal preparation for external audits, e.g., by CMS or its designees. Lead internal and external compliance reviews of plan and FDR operations and practices (and assisting with the same, as necessary and appropriate) to proactively detect potential issues. Work with internal senior management and FDRs (as appropriate) to develop monitoring tools that will allow the plan to determine if sufficient controls are in place to ensure operational compliance. Develop and implement, in conjunction with responsible senior management, mechanisms for ensuring that FDRs, particularly those involved in sales and marketing activities or who perform tasks that may affect member care or access to care, are aware of and follow program requirements." Then "Annual Compliance Audit Workplan alongside the Compliance Officer In consultation with senior managers, identify and assess areas of compliance risk based on monitoring and/or auditing of compliance with program requirements and other factors, as reflected in an Annual Compliance Audit Workplans. Develop and implement an Annual Compliance Audit and Monitoring Work Plan(s) that includes among other things the Compliance Officer conducting and directing (or arranging for) compliance monitoring and auditing activities and specifies audit types and schedules." Then "Investigating and Responding to Identified Potential Non-Compliance or FWA alongside the Compliance Officer Maintain (or oversee) the system for tracking and documenting each report of potential non-compliance or FWA made, which system includes a description of the initial report, the results of the inquiry, the relevant persons and dates, and all corrective and/or disciplinary action taken in response to the inquiry as stipulated by current CMS issue/incident tracking protocols, including conducting beneficiary impact analysis when appropriate. Investigate suspected violations of applicable laws and regulations, and coordinate with or through in-house or outside counsel, as appropriate, on such investigations. The Compliance Officer shall have the flexibility to design and coordinate internal investigations (e.g., responding to reports of problems or suspected violations). Oversee the development and implementation of corrective action plans (including any necessary improvements to policies and practices) and evaluating whether the corrective action plans have addressed the underlying problem. Oversee the response to government communications that assert suspected instances of non-compliance or FWA (such as CMS audit reports, warning letters and deficiency notices). Coordinate with senior management, as necessary, to determine (and help address) any resource or other obstacles to effective implementation of corrective action plans. Coordinate mock audits with senior management or FDRs and actual government audits for federal and state regulators, and/or their contractors." Then "Health Care Privacy and Security Matters alongside the Compliance Officer Work with the Privacy Officer to address the handling of health care privacy and security related issues relating to members and to ensure appropriate reporting to CMS and other appropriate government agencies." Then "Assess Overall Effectiveness of the Compliance Program alongside the Compliance Officer Assess the overall effectiveness of the Compliance Program in an Annual Readiness and Risk Assessment, and taking steps to revise the Compliance Program based on information learned in furtherance of continual process improvement. Orchestrate cooperative efforts between business units to ensure that compliance issues are addressed as efficiently and effectively as possible, with an focus on continuous process improvement." Then "Consult Legal Counsel and Related Matters alongside the Compliance Officer Consult with legal counsel for legal advice and guidance, as appropriate. Periodically review (or assist in reviewing) template contracts between the plan and clinical or administrative FDRs to ensure arrangements comply with relevant laws, regulations and program requirements, as applicable." Then cut off at "Data Submission alon". That seems incomplete; we ignore incomplete. We need to produce list items for each duty. Could be many; but we must preserve all substantive information. We could group similar items but must not lose detail. However we can create list items that each contain a sentence or clause. That's acceptable. We need to avoid duplication: some sentences repeat similar content (e.g., "Management of Compliance Department alongside the Compliance Officer" appears twice). We should keep each distinct duty; but if duplicate, we can keep one. Let's extract distinct duties: 1. Direct, coordinate, and monitor efforts to ensure operational compliance with applicable federal and state laws and regulations. 2. Direct, coordinate, and monitor efforts to ensure operational compliance with Centers for Medicare and Medicaid Services (CMS) contract and Part C and Part D Program requirements. 3. Direct, coordinate,