The Compliance Officer and General Counsel plays a crucial role in fulfilling the commitment of Community Medical Centers, Inc. (CMC) to provide the best quality of care possible as well as the continuous assessment and improvement of the quality of care and the services. This position has the principal authority and responsibility for the development, implementation, oversight and evaluation of a dynamic integrated risk management program and compliance program across all CMC clinical and business units. This position reports to the Chief Executive Officer and will advise the CEO on legal strategies to enhance the work of the community health center.  

SPECIFIC DUTIES:

• Serves as health center counsel advising the CEO on legal strategy and coordinates work with external attorneys.
• Coordinates with CEO or his/her delegate on composition and delivery of responses to state regulatory agency complaints and inquiries.
• Drafts and reviews contracts related the health center’s business relationships.
• Oversees the development, management and annual review of CMC’s policies and procedures, in collaboration with policy owners and executive reviewers.
• Develop a risk and compliance strategy including objectives, identification of key risks, and controls that are aligned with policies, procedures and operating principles.
• Develop and implement a corporate infrastructure that facilitates early identification of new risks, incident identification, communication, issues management and internal and external reporting.
• Responsible for insurance management and liaison with our insurance broker to provide information for insurance policy renewals to insure appropriate coverage for organizational risks.
• Develops and coordinates in collaboration with the Chief Medical Officer the clinical risk management processes to ensure a culture of safety, timely capture of events, reporting to insurance and federal agencies and initiation of risk analysis for all events.
• Develops and coordinates with the Director of Human Resources the management of the Workers’ Compensation Insurance coverage to include Workplace Safety Risk Controls and Claims Management.
• Work closely with the Director of Quality Improvement on matters related Quality Improvement and Assurance including review of relevant Incident Variance Reports and periodic reports to the Quality Improvement Committee.
• Oversee and monitor the development and implementation of the Corporate Compliance Plan, Manual and Work Plan
• Establish methods such as conducting periodic audits, developing effective lines of communication on compliance issues, and preparing written practice standards and procedures to improve the health center 's efficiency and quality of services and to reduce health center 's vulnerability to fraud and abuse as outlined by the Office of the Inspector General.
• Establish and Chair the Corporate Compliance and Risk Management Committee
• Periodically revise the Compliance Plan, by recommending such revisions to the Corporate Compliance and Risk Management Committee, in light of changes in the needs of health center or changes in the law and/or in the standards and procedures of government and private payer health plans
• Advise the Security Officer on matters related to HIPAA regulations and required controls including periodic Risk Assessments

Advise the Privacy Officer on matters related to HIPAA regulations and required controls, including Medical Records Release of Information.

• Ensure that independent contractors, consultants and volunteers who furnish medical services to health center are aware of the requirements of the Corporate Compliance Plan
• In conjunction with the Director of Human Resources, insure that the HHS OIG's List of Excluded Individuals and Entities, and the General Services Administration's (GSA's) List of Parties Debarred from Federal Programs have been checked with respect to all employees, medical staff and independent contractors
• Monitor the Compliance Hotline; Investigate and resolve any reported issues.
• Independently investigating and acting on any report or allegation of unethical or improper conduct or business practices, reporting on the results of such investigations to the Corporate Compliance and Risk Management Committee, and implementing and monitoring appropriate corrective action and/or subsequent compliance
• Reporting on a regular basis to the Board of Directors and CEO on the progress of the Compliance Plan's implementation and on the methods adopted to improve the health center’s efficiency and quality of services and to reduce its vulnerability to fraud and abuse.
• Responsible for the management and processing of FTCA claims and serves as the claims point of contact any such claims
• Continuing the momentum of the Corporate Compliance Plan and the accomplishment of its objectives after its implementation.
• Participates on the Quality Improvement Committee, the Retirement Committee, and the Leadership Group.
• Other duties as assigned

PERFORMANCE REQUIREMENTS:

Knowledge, Skills and Abilities

• Highly effective collaboration skills, written and verbal communications skills.
• Computer competent and able to present key information in a succinct and clear manner.
• Ability to facilitate conflict resolution, competent in identification of risk situations and resolution.
• Ability to communicate well with families, patients, staff and physicians based on age, cultural beliefs and educational level.
• Attention to detail, meticulous development and maintenance of regulatory paperwork.
• Speaks with confidence and command.
• Knowledge of organizational policies, procedures and systems
• Ability to interact with internal personnel and external agencies requiring reasonable tact, discretion, and self-expression.
• Ability to maintain open dialogue with supervisors and management staff
• Ability to work independently, use good judgment, maintain excellent communication skills and self-initiative
• Ability to read, understand, and follow oral and written instructions
• Ability to establish and maintain effective working relationships with employees and the public

TYPICAL PHYSICAL DEMANDS:

• Must be able to lift up to 40 pounds and push up to 100 pounds (on wheels)
• Must be able to hear on the phone and those who are served in person, and speak clearly in order to communicate information to staff
• Must have vision with or without lenses that is adequate to read memos, a computer screen, personnel forms and other documents
• Must have high manual dexterity
• Must be able to reach above the shoulder level to work, must be able to bend, squat and sit, stand, stoop, crouch, reach, kneel, twist/turn, fingering and feeling

TYPICAL WORKING CONDITIONS

Work is performed in an office environment within a clinic setting.  Involves frequent contact with staff and the public.  Work may be stressful at times.  Contact may involve dealing with upset people.