Job Description

Management/ Professional


Corporate Compliance

Req Number:

Job Details:

The VP, C&PO, SHCN is a member of the OCCP with general duties and responsibilities related to being the focal point for implementing Steward Health Care Network's Compliance & Privacy Program (Program), including Steward managed Health Plans, MCO and ACO Programs nationally.

This position reports directly to the System Chief Compliance Officer and indirectly to the President of SHCN.

This position provides regular direct reports to the SHCN Board of Directors and the SHCN managed entity Boards. He or she will not serve as legal counsel to an ACO.

The VP, C&PO, SHCN needs to be a person of high integrity, and any other duties assigned should not be in conflict with the SHCN's Program goals and objectives. This position will be based in Dallas , TX and will require travel to other assigned Steward locations.

The VP, C&PO, SHCN is responsible for driving implementation and maintenance of SHCN's Programs. This position will be highly visible and accessible to SHCN and its managed entity leaders in order to implement and maintain the Programs and to provide guidance to leadership and management teams.

· Assists SHCN leadership in understanding compliance with existing and changing laws and regulations to ensure compliance with State and Federal laws, regulations and mandates

· Conduct research on state and federal programs, as needed, and monitor changes to requirements to these programs in order to mitigate risks and achieve compliance

· Establish and assist with implementation of standard policies, procedures, processes and best practices across the Network and managed entity lines of business to promote compliance with applicable laws and contractual obligations

· Drafts annual SHCN Program Work Plans for board approval

· Develops, implements and maintains Program activities that monitor and confirm compliance with legal, regulatory and contractual requirements

· Develops compliance communications

· Assists in the collection of data with management to submit timely and accurate regulatory filings, leads efforts to develop reports, projects, and assessment tools that monitor and confirm compliance

· Establishes and fosters effective working relationships and builds credibility within the Steward System to support a culture of compliance

· Identifies potential risk areas and assists SHCN leadership with developing risk mitigation and/or corrective action plan strategies

· Monitors follow up with management to address / resolve identified compliance concerns (i.e., corrective action plans)

· Acts as a consultative resource on issues concerning compliance and privacy matters, and provides recommendations to enhance policies, procedures and internal controls as needed

· Ensures that information is provided to SHCN leadership to keep them current on the latest compliance program related risks and leading practices

· Works with the OCCP leadership in the development and delivery plan of compliance and privacy training for both employees and network provider partners.

· Prepares written reports, on a quarterly basis or as requested, to keep the CCO informed of compliance program activities and issues on a timely basis

· Provides reports to SHCN leadership on compliance program activities and issues on a regular basis (at least quarterly)

· Ensures all identified issues are logged in the OCCP database (ComplyTrack) accurately and timely

· Leads investigations or supervises investigations of compliance and privacy concerns raised through the Compliance Support Line or other communication mechanisms

· Works with Steward's Office of General Counsel (OGC) as needed to resolve legal compliance issues

· Cooperates with regulators (such as CMS, CMMI, OIG, OCR, etc.) as appropriate, in connection with any privacy or compliance inquiries, audits or investigations

· Reviews conflict of interest disclosure forms for SHCN to identify any concerns that may need to be brought to the attention of the CCO and President of SHCN for follow-up or resolution

· Participates in health care compliance and privacy professional organizations to stay abreast of privacy and corporate compliance developments and leading industry practices

· Attends and/or co-chairs SHCN managed entity Compliance Committee meetings

· Participates in periodic OCCP team meetings in order to ensure effective communication

· As requested, actively participates in Steward committees as an OCCP representative

· Collaborates and works effectively with other OCCP team members to drive "operational excellence" (i.e., standardization, scalability, effectiveness and efficiency) system-wide

· Maintains time and effort reporting records as requested

· Demonstrates respect and regard for the dignity of all patients, families, visitors, and fellow employees to ensure a professional, responsible, and courteous environment

1. Commits to recognize and respect cultural diversity for all customers (internal and external)

2. Communicates effectively with internal and external customers with respect of differences in cultures, values, beliefs and ages, utilizing interpreters when needed

Performs other duties as assigned

Application Instructions

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