The Compliance Officer (CO) will serve as the Compliance and Privacy Officer for managed practices and the MSO and will report to the Axia General Counsel. The CO will have direct access to the CEO, CMO, and Axia’s Board and will collaborate with all functional departments, including but not limited to Legal, Risk Management, IT, RCM, HR, Business Development, Innovation Office and Clinical and Business Operations.
The Compliance Officer’s two main responsibilities are (1) to implement and oversee Axia’s Compliance Program, and (2) to oversee Axia’s compliance with all applicable laws, rules, and regulations, including but not limited to healthcare fraud and abuse laws, federal and state privacy laws, OSHA and other laws regulating the business of Axia.
Essential Functions
- Performs a baseline assessment of Axia’s current corporate compliance program documents and makes recommendations for revisions to the Compliance Committee. Serves as Chair of the Compliance and Privacy Committee. Continues to periodically review program documents and disseminates any updates or changes of policy documents to colleagues and agents.
- Serves as Chair of Axia’s Policy and Forms Committee. Organizes and oversees the process for all of Axia’s policies and forms development, approval, and controls and manages publication of policies and forms on Axia’s intranet.
- Manages all compliance reporting channels, including the confidential hotline and secure compliance email reporting mechanism. Oversees all vendor arrangements related to the compliance hotline and serves as the primary point of contact when matters are referred from the external vendor channel.
- Conducts and/or coordinates internal and external compliance audits, ensuring adherence with all areas of the corporate compliance program. Coordinates with RCM on compliance audits, Operations and other functional areas on OSHA/Workplace Safety compliance, and with providers on applicable clinical research regulations. Reviews all areas of possible noncompliance within the organization and supports corrective action.
- Implements and maintains a Privacy Program in compliance with HIPAA, HITECH, and applicable state data privacy laws for the protection of personal information. Monitors and evaluates organizational privacy controls and safeguards, detecting and reducing risks to PHI within acceptable levels and managing business associate agreements.
- Works in tandem with leadership and counsel to support data privacy incident-risk assessment and data breach notification activities. Develops, Implements, and maintains corporate-wide privacy and information-security education and awareness program for delivery to all levels of the enterprise.
- Develops, coordinates/conducts the necessary training programs for all Axia colleagues, including complete education regarding the corporate compliance and privacy programs. Audits, as an element of compliance, the training records that are to be maintained by the organization.
- Reviews or coordinates the review of independent contractor arrangements to ensure all applicable laws and regulations are followed.
- Manages all Business Associate Agreement (BAA) arrangements and serves as the subject matter expert for when such BAAs are required, and negotiates and retains agreements.
- Ensures the screening of employees, agents, and independent contractors, including making inquiries to the cumulative sanction report, and the U.S. Government Accountability Office debarred contractors listing. When a vendor is utilized for screenings, manages and oversees the vendor relationship.
- Ensures that mechanisms are in place for reporting noncompliance issues and managing actual and potential conflicts of interest.
- Performs and/or coordinates all investigations of deficiencies resulting from the reporting system or identified through the periodic assessments/audits and initiates and/or coordinates corrective and preventative action for areas of identified noncompliance.
- Develops and maintains all policies and procedures related to compliance and privacy, including telehealth services. Works with other functional areas to contribute to policy and procedure development and management as they relate to compliance and privacy.
- Maintains compliance plan files, including documentation of the initial baseline audit, periodic compliance audits, training of personnel and agents of the practice, results of screenings of individuals, any reports of suspected or actual noncompliance, all reports of investigations and any corrective action taken after investigations.
- Works with Clinical and Business Operations, Business Development and Innovation Office to support new service offerings and mergers and acquisitions.
- Develops a budget necessary to perform all compliance duties, including items such as training for compliance staff and committee.
- Reports regularly to the owner(s), managing physicians, senior leadership, and Axia’s Board.
Qualities & Skills
- Knowledge in areas such as physician and clinical activities, business administration, medical coding, medical billing, reimbursement, risk management, and the laws and regulations applicable to the medical practice environment.
- Demonstrative good judgment and excellent critical thinking skills.
- Excellent time-management and the ability to prioritize and execute tasks in a high-pressure environment.
- Respectable and approachable with an ability to create necessary culture.
- Demonstrative substantive knowledge of OIG compliance guidance for individual and small group physician practices, clinical laboratories, and third-party billing companies.
- Demonstrative substantive knowledge of key healthcare fraud and abuse laws, including the False Claims Act, Stark Laws, and Anti-kickback Statute and their associate penalties for abuse.
- Demonstrative substantive knowledge of HIPAA privacy rules and OSHA compliance standards. Oversees any matters involving thew Office for Civil Rights for privacy-related matters.
- Ability to perform and handle investigations, including self-disclosure protocols.
- Extensive knowledge and understanding of requirements under Corporate Integrity Agreements (CIAs) and Certificate of Compliance Agreements (CCAs).
- Extensive knowledge and understanding of various other compliance areas such as Human Subject Research Protections and CLIA rules.
- Expertise in OB/GYN operations and telehealth
- Adept analytical skills and proven ability to develop effective solutions to complex business challenges.
- Strong leadership skills and ability to work both independently and as part of a team. Ability to delegate and provide direction.
- Exceptional verbal, interpersonal, and written communications. Ability to present ideas in business and user-friendly language.
- Highly self-motivated, self-directed, and attentive to detail. Team-oriented and collaborative.
- Computer proficiency, including programs such as MS Office, Word, Excel, Outlook, and performing internet research.
Education & Experience
- Master’s degree in business administration, healthcare administration or clinical profession preferred.
- Certifications in Healthcare Compliance preferred.
- Minimum 8-10 years’ recent related compliance experience in healthcare.
- Minimum 5 years’ management or leadership experience.