VP, Chief Compliance Officer

The Vice President & Chief Compliance Officer provides strategic and independent leadership for Boston Medical Center Health Systems compliance and privacy programs across Boston Medical Center hospitals Health Plan and Physician Organizations. The position designs implements evaluates and continuously improves an effective enterprise compliance program that identifies prevents detects investigates and remediates potential violations of law regulation policy and ethical standards. Reporting to the Senior Vice President General Counsel the Vice President & Chief Compliance Officer leads the Health Systems compliance and privacy staff and has direct and unrestricted access to the Chief Executive Officer senior leadership and the Audit and Compliance Committee of the Board regarding significant compliance matters.

ESSENTIAL RESPONSIBILITIES / DUTIES:

Establishes leads and continuously improves the Health Systems enterprise compliance and privacy program to prevent detect and address conduct inconsistent with applicable laws regulations contractual requirements ethical standards and Health System policies. Maintains the independence authority visibility and resources necessary to administer an effective compliance program working directly with senior leadership and the Audit and Compliance Committee of the Board. Chairs the Hospital Compliance Oversight Committee; participates in WellSense Health Plan Boston University Medical Group and other compliance or governance committees; and provides regular reports to the Boards of Trustees Audit and Compliance Committee General Counsel and senior leadership regarding compliance priorities significant matters emerging risks and corrective actions. (20% of time)

Leads the enterprise compliance risk assessment and annual compliance work-planning process to identify and prioritize regulatory billing privacy operational financial and business-conduct risks. Oversees risk-based monitoring auditing data analysis and testing activities; develops key compliance indicators; evaluates trends audit findings training completion reporting activity and corrective-action status; and uses results to assess program effectiveness and implement continuous improvements. (20% of time)

Directs the intake triage investigation escalation documentation and resolution of reported compliance and privacy concerns in coordination with Legal Human Resources Internal Audit Information Security and other functions as appropriate. Maintains confidential reporting channels promotes good-faith reporting without fear of retaliation evaluates substantiated concerns for root causes and ensures timely and sustainable corrective-action plans are implemented and monitored. Advises senior management regarding appropriate remediation and disciplinary action for confirmed violations or failures to report or address known concerns. (15% of time)

Provides enterprise oversight of healthcare regulatory compliance and privacy activities including billing coding clinical documentation reimbursement medical necessity cost reporting government program requirements and arrangements involving referral sources. Supports compliance with applicable federal and state healthcare laws including the False Claims Act Anti-Kickback Statute Stark Law Civil Monetary Penalties Law exclusion requirements and other fraud-and-abuse provisions. Oversee compliance with HIPAA Privacy Security and Breach Notification requirements and 42 CFR Part 2 and participates in the assessment investigation mitigation notification and remediation of potential privacy and information-security incidents. (15% of time)

Develops and oversees enterprise compliance and privacy education communication and policy-management programs to ensure employees leaders clinicians contractors and other workforce members understand applicable standards policies reporting expectations and individual responsibilities. Maintains and regularly updates the Code of Conduct compliance and privacy policies training materials and related communications. Promotes a culture of integrity accountability transparency ethical decision-making and non-retaliation through visible leadership and ongoing engagement with clinical and operational teams. (10% of time)

Oversees compliance due diligence and monitoring related to third parties transactions and business arrangements including vendors contractors delegated entities providers business partners and other external parties. Ensures effective processes are maintained for required exclusion debarment licensure and sanction screening. Advises on compliance considerations associated with acquisitions affiliations joint ventures clinical arrangements value-based care initiatives new programs and other significant business activities. (10% of time)

Coordinates the Health Systems response to compliance-related government and payer inquiries audits subpoenas investigations and information requests in partnership with Legal Counsel and other appropriate leaders. Evaluates potential overpayments reportable events and disclosure obligations and oversees timely remediation repayment reporting or self-disclosure when required. Ensures the Health System cooperates with government and payer reviews and maintains appropriate documentation escalation and follow-through. (5% of time)

Leads develops and retains a high-performing compliance and privacy team by establishing clear priorities accountability performance expectations and resource allocation. Partners with Legal Finance Internal Audit Human Resources Quality Patient Safety Information Security clinical leadership and operational leaders to integrate compliance and privacy considerations into organizational decisions and daily operations. Maintains current knowledge of federal and state laws regulations enforcement priorities and industry standards and translates changes into timely organizational action. Adheres to and models BMCs behavioral attributes: responsibility empathy service excellence problem solving and continuous improvement efficiency cultural competency and teamwork. (5% of time)

REQUIRED EDUCATION AND EXPERIENCE:

Bachelors degree in business healthcare administration law public health or a related field and at least twelve (12) years of progressively responsible healthcare compliance privacy legal regulatory audit or related experience including experience leading a compliance program in a complex healthcare organization. Or equivalent combination of education and experience.

PREFERRED EDUCATION AND EXPERIENCE

Graduate degree in law business administration healthcare administration public health or a related discipline preferred. Experience leading compliance within an integrated health system that includes hospitals physician organizations health plans accountable care arrangements or value-based care entities is preferred.

CERTIFICATIONS LICENSES REGISTRATIONS PREFERRED

Certification in Healthcare Compliance or CHC; Certified in Healthcare Privacy Compliance or CHPC; Certified Compliance and Ethics Professional or CCEP; or another relevant compliance privacy audit or legal credential preferred.

KNOWLEDGE SKILLS & ABILITIES (KSAs)

• Knowledge of federal and state healthcare compliance requirements including fraud-and-abuse billing coding reimbursement privacy and government program regulations.
• Working knowledge of pharmacy regulations and 340B compliance requirements.
• Ability to design implement and evaluate an enterprise compliance and privacy program using recognized regulatory guidance and program-effectiveness measures.
• Ability to conduct compliance risk assessments and translate identified risks into prioritized monitoring auditing education and corrective-action plans.
• Ability to direct sensitive investigations assess evidence document findings identify root causes and oversee sustainable corrective actions.
• Ability to interpret complex laws regulations enforcement guidance payer requirements and contractual obligations and translate them into operational requirements.
• Ability to develop and present compliance reports trends key indicators and significant findings to executive leaders governance committees and Boards of Trustees.
• Ability to manage confidential reporting channels non-retaliation processes regulatory inquiries repayment obligations and government or payer disclosures.
• Ability to lead a multidisciplinary compliance and privacy team and coordinate work across legal clinical operational financial audit information-security and human-resources functions.

Compensation Range: $321400 - $370000

This range offers an estimate based on the minimum job qualifications. However our approach to determining base pay is comprehensive and a broad range of factors is considered when making an offer. This includes education experience skills and certifications/licensures as they directly relate to position requirements; as well as business/organizational needs internal equity and addition BMCHS offers generous total compensation that includes but is not limited to benefits (medical dental vision pharmacy) discretionary annual bonuses and merit increases Flexible Spending Accounts 403(b) savings matches paid time off career advancement opportunities and resources to support employee and family well-being.

NOTE: This range is based on Boston-area data and is subject to modification based on geographic location.

Equal Opportunity Employer/Disabled/Veterans

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