Chief Compliance Officer

General Responsibilities:
The Chief Compliance Officer ("CCO") provides the Company with advice, representation and leadership on all compliance issues. The CCO also advises and supports the Company's overall business functions to design and ensure compliance with the Company's Code of Conduct, Compliance Program and all applicable United States federal, state and local laws, rules and regulations.
As a member of senior management, the CCO is responsible for collaborating with the Board of Directors, Chief Executive Officer ("CEO") and other executives to establish and maintain appropriate ethical and compliant leadership and set the appropriate "Tone from the Top" for all Company related compliance initiatives. Further, the CCO will reinforce the ability of all employees and contractors to make good faith reports regarding compliance concerns without fear of retaliation. The CCO reports directly to the Company's Board of Directors (its governing body). The CCO is not legal counsel to the Company.
Specific Responsibilities for Oversight by the CCO:
• The CCO may delegate duties and tasks as relevant, but should maintain overall responsibility and oversight.
• Ongoing design and implementation of the Company-wide Compliance Program to ensure compliance with the Code of Conduct, its underlying policies and procedures and all applicable U.S. laws, rules and regulations, including but not limited to applicable FDA regulations, HIPAA, state privacy laws, anti-trust laws, federal anti-kickback statute, stark law and all other applicable federal, state and/or local laws, rules and regulations.
• Ongoing design and implementation of the Company's compliance policies and procedures to adhere to any and all requirements of the Office of the Inspector General's seven elements of an effective compliance program.
• Disseminate information to and educate employees on compliance related issues. (e.g. fraud and abuse laws, stark laws, CMS demonstration models, charitable contributions etc.)
• Responsible for conducting and coordinating internal and external compliance audits that include but are not limited to coding, billing, reimbursement, medical director agreements, deminimus tracking and spend logs, HIPAA guidelines, training and reporting elements of all relevant regulatory compliance manuals.
• Review company agreements, including those involving clinical research, health care professionals, consultants, medical directors, and vendors to ensure compliance with legal requirements.
• Review and coordinate the review of relevant independent contractor arrangements to ensure that all of the applicable laws and regulations have been followed.
• Advise the Board and executives on the compliance risks and terms of various business transactions, arrangements and agreements.
• Maintain knowledge of AKS, Stark, CMS manuals, Medicaid manuals, and Federal Register notices, federal and state legislative changes that may affect the Company.
• Review advertising, marketing, promotional and training materials and programs to ensure compliance with legal requirements.
• The CCO will coordinate and develop policies and programs for reporting noncompliance issues. This will include developing an anonymous reporting system for all persons associated with the practice to utilize when necessary to inform the Compliance Officer of potential noncompliance issues.
• Coordinate corrective and preventative action for areas of noncompliance as identified by audits, quality assurance, peer review programs, other requirements and/or through the reporting system.
• Develop necessary internal and external review processes, compliance metrics, monitoring programs and internal and external auditing processes, including but not limited to those involving health care professionals.
• Perform and/or coordinate with legal counsel all investigations of deficiencies resulting from the reporting system, other reports or identified through the periodic assessments. In coordination with legal counsel perform required self-reporting for actual or probable violations of law, as required.
• Report to the Board of Directors with unfettered access on compliance-related matters to include executive sessions.
Educational Requirements
• Bachelor's degree.
• CHC Credential or obtain credential within 6 to 12 months of hire.
Expertise and Personality:
• Minimum 5-7 years' experience in Compliance.
• Background in Medicare and/or Medicaid reimbursement, AKS, Stark and fraud, waste and abuse laws and/or regulations.
• Ability to supervise and coordinate services of external legal and compliance advisors.
• Proven leader and self-starter.
• Well-organized, detail oriented and a strong team player.