The Director of US Healthcare Compliance is responsible for ensuring regulatory, statutory, and contract compliance of the Company?s Healthcare Operations (Provider and Payor) in the United States and working in concert with the healthcare compliance and information security teams in Jamaica, India, Philippines and Colombia to ensure regulatory, statutory and contractual compliance. More specifically to ensure the Federal and State Healthcare compliances specified by the Department of Health and Human Services (HHS), HIPAA 1996 and Security/Privacy Rules, HITECH Act 2009 and other healthcare related guidelines, Centers for Medicare & Medicaid Services (CMS), Medicaid Guidelines, Compliance requirements specified by the Office of Inspector General (OIG), General Services Administration (GSA), Office of Foreign Assets Control (OFAC), and licensing provisions for TPA and agent under Insurance Codes specified by the respective State?s Department of Insurance. The Director of US Healthcare Compliance oversees the management of the Corporate Compliance Program, functioning as an independent and objective body that reviews and evaluates compliance issues and concerns within the organization. The individual selected for this position will report directly to the EVP, Global General Counsel and will be responsible for reporting incidents of compliance and ethics to the Group CEO and Board of Directors and to ensure all organizational operations, reporting systems and documentation comply with regulatory requirements. The Director of US Healthcare Compliance will not, directly or indirectly, engage or participate in any outside activity that would, or may be perceived to, conflict with the best interests of the Company or his/her duties to the Company.

Duties and Responsibilities: 

1.      Develop, initiate, maintain, and revise policies and procedures for the general operation of the Compliance Program to meet contractual, statutory and regulatory requirements and maintain and update, as necessary and appropriate, the World Class Compliance Program (WCCP) charter document(s).

2.      In collaboration with the Senior Manager for Healthcare Security and Compliance, develop and deliver timely and appropriate compliance trainings for all employees, temporary staff, executives and delegated entities (vendors) at the time of hiring or contracting and annually thereafter. The trainings should emphasize the Company?s commitment to comply with its Code of Conduct; HIPAA Privacy; HIPAA Security; Fraud, Waste and Abuse (FWA); and the WCCP.

3.      Chair and/or participate in various Committees of the organization, including the Quality Committee and Compliance Committees for each of the healthcare operating entities.

4.      Manage, organize and maintain compliance records (includes TPA registrations, Agent Licenses, process review reports, logs, records related to compliance committee meetings and other records as required by law) for a duration specified by applicable regulations and client contracts.

5.      Review and analyze documents submitted by other staff for compliance, provide guidance as needed to ensure the organization?s contractual obligations are met.  Compile and report compliance related data or informational requests as necessary to relevant stakeholders and clients. 

6.      In collaboration with the Senior Manager for Healthcare Security and Compliance, develop, implement and oversee an effective vendor oversight program to ensure each delegated entity (vendor) is meeting the organization?s contractual obligations with its clients, its SLA with the vendor, and other regulatory requirements.

7.      Investigate reported events, incidents, facilitate with internal departments in remediating the compliance FWA issues or incidents.

8.      Coordinate with SPOCs and operational departments and actively participate in client pre-delegation audits, compliance program audits, compliance assessments, quarterly or annual compliance attestations and other ongoing monitoring activities related to compliance and FWA.

9.      Coordinate with Human Resources and Procurement departments to ensure all new hires are screened against the OIG/GSA Exclusion List prior to hire and monthly thereafter. This includes employees, temporary staff, consultants, executives, delegated entities (vendors) and the governing body.

10.  Establish and maintain clear consistent and an effective communication related to compliance and FWA with all levels of staff, including, but not limited to updated compliance posters at all office locations and intranet updates in coordination with Human Resources, Legal, Information Security, and Corporate Communications departments.

11.  Review and revise client contracts related to clients? compliance expectations and Business Associate Agreements (BAA).

12.  Prepare and execute quarterly Compliance Reports for the Board of Directors on the effectiveness of the compliance programs and practices and provide direct reporting of compliance issues or incidents that rise to the level of discretionary or mandatory reporting to the Group CEO or Board of Directors.

13.  Perform other duties as assigned.

QUALIFICATIONS:

Education:

B.A. or B.S. preferably in a healthcare related field or applicable healthcare compliance related experience.  

Graduate degree in a healthcare related discipline is an advantage.

Possessing, actively pursuing or a commitment to pursue HCCA certifications is an advantage.

Knowledge & skills:

1. Comprehensive understanding of Medicare, Medicaid and Commercial Healthcare regulatory system and requirements.
2. General understanding of computing networks and application systems.
3. General understanding of incident investigation related to non-compliance and fraud, waste and abuse (FWA).
4. Develop respectful and collaborative relationships across all lines of the Company and its affiliates. Demonstrate tact and discretion, especially when dealing with confidential and sensitive matters.
5. Excellent verbal and written communication skills, exercise excellent judgment in handling confidential and sensitive matters. Ability to write and edit communications for maximum effectiveness with specific audiences.
6. Patience, calmness and determination as an effective and efficient problem solver to find solutions to complex issues across numerous verticals, in multiple geographies, in an organization with a complicated reporting and operational matrix.

REPORTING RELATIONSHIPS:

Directly reports to the Global General Counsel, with a dotted line reporting relationship to the Sagility Board of Directors, Group CEO, and SVP, Clinical Operations.

EXPERIENCE:

5-7 years healthcare compliance related experience.