Chief Compliance Officer

Essential Duties And Responsibilities

• Ensures that all departments are following HIPAA, HITRUST and other accreditation standards that apply to Metrocare.
• Makes sure to stay up-to-date with laws and regulations that could affect the organization's policies and procedures.
• Develops, initiates, maintains, and revises policies and procedures for the general operation of the compliance program and its related activities to prevent illegal, unethical, or improper conduct.
• Develops policies and programs that encourage managers and employees to report suspected fraud and other improprieties without fear of retaliation.
• Manages day-to-day operation of the compliance program including direct management of compliance team members, providing routine supervision, training, guidance and performance management feedback.
• Collaborates with Human Resources to develop, review and update Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees.
• Collaborates with other departments to direct compliance issues to appropriate existing channels for investigation and resolution.
• Consults with General Counsel as needed to resolve difficult legal compliance issues.
• Responds to alleged violations of rules, regulations, policies, procedures, and Standards of Conduct by evaluating or recommending the initiation of investigative procedures to the appropriate department.
• Develops and oversees a system for uniform handling of compliance related violations.
• Makes sure to monitor and as necessary, coordinate compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends.
• Identifies potential areas of compliance vulnerability and risk, develops and implements corrective action plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future.
• Provides reports on a regular basis, and as directed or requested, keeps the Corporate Compliance Committee and senior management informed of the operation and progress of compliance efforts.
• Sure to report violations or potential violations to duly authorized enforcement agencies as appropriate or required.
• Manages the compliance hotline.
• Institutes and maintains an effective compliance communication program for the organization, including promoting: (a) use of the compliance hotline; (b) heightened awareness of Standards of Conduct, and (c) understanding of new and existing compliance issues and related policies and procedures.
• Works with the Human Resources Department and others as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees and ongoing training for all employees and managers.
• Makes sure to monitor the performance of the Compliance Program and related activities on a continuing basis, taking appropriate steps to improve its effectiveness.
• Ensure contractors and agents who furnish medical services to the health system are aware of the requirements of the compliance program with respect to coding, coverage, billing, marketing, etc.
• Responds to government investigations and queries as the principal point of contact.
• Develops, implements and monitors corrective actions with all health system departments, providers and sub-providers, agents and, if appropriate, independent contractors.

Privacy Role & Responsibilities

• Oversees all ongoing activities related to the development, implementation, maintenance, and adherence to Metrocare policies and procedures regarding privacy of and access to protected health information (PHI) in compliance to federal and state laws and health system privacy practices.
• Sure to monitor and periodically assess the privacy program to ensure compliance with relevant laws and regulations.
• Develops, implements and maintains the organization’s information privacy policies and procedures in coordination with executive/senior management the Quality Council.
• Serves in a leadership role for the compliance committee's activities.
• Performs information privacy risk assessments and conducts related ongoing compliance monitoring activities in coordination with Metrocare's other compliance and operational assessment functions.
• Works with management, key departments, and committees to ensure the organization has and maintains appropriate privacy and confidentiality consent, authorization forms, and information notices and materials reflecting current organization and legal practices and requirements.
• Ensures compliance with privacy practices and consistent application of sanctions for failure to comply with privacy policies for all individuals in the organization's workforce, extended workforce, and for all business associates, in cooperation with Human Resources, administration, and legal counsel as applicable.
• Initiates, facilitates and promotes activities to foster information privacy awareness within the organization and related entities.
• Reviews all system-related information security plans throughout the organization's network to ensure alignment between security and privacy practices and acts as a liaison to the information systems department.
• Maintains current knowledge of applicable federal and state privacy laws and accreditation standards, and monitors advancements in information privacy technologies to ensure organizational adaptation and compliance.
• Serves as information privacy consultant to the organization for all departments and appropriate entities.
• Cooperates with the governmental auditors, other legal entities, and organization officers in any compliance reviews or investigations.
• Works with administration, legal counsel, and other related parties to represent the organization's information privacy interests with external parties (state or local government bodies) who undertake to adopt or amend privacy legislation, regulation, or standard.
• Coordinates with appropriate Metrocare departments and units to ensure timely development and implementation of corrective action plans in response to monitoring deficiencies and complaints.

Information Security Role & Responsibilities

• Oversee all ongoing activities related to development, implementation, maintenance of, and adherence to Metrocare policies and procedures covering security of and access to protected health information (PHI) in compliance with federal and state laws and health system security practices.
• Sure to ensure the periodic risk assessment and ongoing monitoring and reporting of key elements of the security program.
• Collaborate with the Information Technology Team regarding:
• The development and enforcement of information security policies and procedures, measures and mechanisms to ensure the prevention, detection, containment, and correction of security incidents.
• Ensuring that security standards comply with statutory and regulatory requirements regarding health information.
• Ensuring that security policies are maintained, including administrative security, personnel security, physical safeguards, technical security, and transmission security.
• Assurance that appropriate documentation exists of response of the institution to the addressable portions of the security rule.
• Ensuring that security procedures are maintained, including evaluation of compliance with security measures; contingency plans for emergencies and disaster recovery; security incident response process and protocols; testing of security procedures, measures, and mechanisms, and continuous improvement; and security incident reporting mechanisms and sanction policy.
• Serves as an institutional resource regarding matters of informational security.
• Cooperates with governmental auditors, other legal entities, and organization officers in any compliance reviews or investigations.
• Works with administration, legal counsel, and other related parties to represent the organization's information security interests with external parties (state or local government bodies) who undertake to adopt or amend security legislation, regulation, or standard.
• Coordinates with appropriate Metrocare departments and units to ensure timely development and implementation of corrective action plans in response to monitoring deficiencies and complaints.
• Other duties as assigned.