Position: Vice President - Chief Compliance Officer
Organization: John Muir Health (www.johnmuirhealth.com)
Location: Walnut Creek, CA
Position Summary
The Vice President, Chief Compliance Officer (CCO) is the focal point of compliance activities for John Muir Health (JMH). The CCO has oversight of the JMH Compliance Program and its implementation, administers the program in accordance with laws, regulations, and government guidance on effective programs and maintains review of policies and procedures to ensure overall effectiveness. The CCO serves as the designated Privacy Officer under 45 CFR Parts 160-164.
Areas of responsibility include: ensuring compliance with Medicare and Medicaid billing regulations, fraud and abuse laws, policies and procedures for the protection of privacy and confidentiality of protected health information (HIPAA), and other regulatory requirements.
The CCO works with leaders from management and medical staff to promote an awareness, understanding, and culture of positive ethical and moral principles and detection and resolution of instances of conduct that do not conform to applicable federal and state laws. The CCO is also responsible for the ongoing management of patient privacy policies and procedures in order to maintain the confidentiality, integrity and availability of information.
This is a senior corporate staff position reporting to the Senior Vice President and General Counsel, Nancy Olson.
Health System Background
John Muir Health (JMH) is a nonprofit, integrated health delivery system which includes four main entities: John Muir Medical Center-Walnut Creek; John Muir Medical Center-Concord; John Muir Behavioral Health; and John Muir Physician Network, a network of over 800 physicians operating more than 100 practices in the San Francisco East Bay.
John Muir Medical Center-Walnut Creek, named one of “America’s Best Hospitals 2007” by U.S. News & World Report, is a 327-bed acute care facility that is designated as the only trauma center for Contra Costa County and portions of Solano County. Recognized as one of the region’s premier healthcare providers, areas of specialty include high- and low-risk obstetrics, orthopedics, neurosciences, cardiac care, and cancer care.
John Muir Medical Center-Concord, which received the Emergency Department Team of the Year Award-2007 from CEP America, is a 259-bed acute care facility that serves Contra Costa and southern Solano counties. The medical center has long been recognized as a preeminent center for cardiac care, and is also recognized for its Regional Cancer Center. Other areas of service include general medicine and surgery, orthopedics, neurology, and emergency medicine.
Initial Priorities
- Review compliance program controls and procedures across the health system. Assess effectiveness of compliance program and make recommendations for what is needed for JMH.
- Conduct assessment of potential risk and/or vulnerabilities as they relate to compliance and HIPAA issues.
- Review exception reporting under the revised policy related to employee gift acceptance for achievement of both consistency and transparency.
- Develop a Document Retention Policy encompassing both paper and electronic records consistent with federal e-discovery laws.
- Assess and update JMH's compliance education and training programs.
- Encourage participation at all levels (Board, management, employees) regarding compliance policies and regulations.
- Partner with Internal Audit and make future audit recommendations to maintain compliance integrity.
- Work with Internal Audit to review all physician financial relationships and develop a tool for tracking physician relationships mandated by Stark.
Scope of Responsibilities
- Research and maintain awareness of laws and regulations, keeping abreast of current changes that may affect JMH through personal initiative, seminars, training programs, and peer contact.
- Implement JMH-wide programs, policies, and procedures that establish standards for compliance (giving specific guidance to management, individual departments and medical staff as appropriate) and ensures JMH compliance with applicable federal and state laws and regulations. Plan implementation with Senior Vice President, General Counsel.
- Oversee compliance matters relating to the appropriate coding and billing of professional and facility fees and clinical trial billing, as well as, consulting closely with various departments and billing personnel to foster and enhance compliance with all applicable billing requirements. Understand, and perform these duties in recognition of the patient care mission, policies, and procedures of JMH.
- Ensure implementation of appropriate policies and procedures in compliance with federal (Health Insurance Portability and Accountability Act) and state (Confidentiality of Medical Information Act) patient privacy and information security laws and regulations. Implement employee training programs on requirements involving the use and disclosure of patient protected health information.
- Ensure compliance with the Standards of Ethics and Business Conduct, including policies with respect to gifts received by JMH personnel.
- Develop and chair compliance committee(s) for the discussion and resolution of compliance issues, as appropriate.
- Initiate investigation into reports of alleged violations of federal and state law, regulation and/or JMH policies. Review complaints, concerns, or questions relative to compliance issues, and provide consultative leadership and support to employees in all JMH entities as appropriate.
- Directs or participates in monitoring and auditing activities of JMH-wide operations established to assess compliance with standards and procedures implemented through the compliance program. Coordinate auditing and monitoring activities with Internal Audit, including participating in the risk assessment process.
- Provide input to Internal Audit to establish legal compliance controls and measurements for internal processes to ensure that appropriate processes are in place.
- Direct efforts to communicate compliance programs, including preparing written materials and training programs designed specifically to promote understanding of compliance issues, laws and regulations, and the consequences of non-compliance.
- Maintain a system of management reporting that provides JMH with timely and relevant information on all aspects of compliance issues.
- Provide staff support for the JMH Board Compliance Committee regarding contractual relationships with physicians and compliance with federal and state law.
- Present reports to the SVP, General Counsel, and appropriate JMH Board Committee(s) on the status of compliance efforts undertaken, and makes recommendations regarding changes to improve compliance.
Candidate Qualifications
Experience
- Must include experience in health care compliance, health care administration, legal and/or regulatory affairs. Health care legal experience is preferred.
- A minimum of ten years experience, in one or more job functions, resulting in an in-depth and comprehensive understanding of the operations of hospital and health system departments and functions.
- Specific experience with handling medical/legal issues and in implementing programs in compliance with federal and state laws and regulations, and accreditation agency requirements.
- Experience in the management of information .systems to investigate and validate established policies and procedures is required.
- Familiarity with issues relating to professional and facility billing (especially Medicare coding) is essential.
Education
- Bachelor degree required. Masters preferred. Certification in healthcare compliance preferred.
Contact
Please send resume or nominations to:
Kate Kingsley or Barbara Walker
KLKingsley Executive Search
1333 No. California Blvd., Suite 570
Walnut Creek, CA 94596
kate@klkingsley.com
barbara@klkingsley.com
(925) 934-4306 main
(925) 934-4327 fax
